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Electronically Filed

Sep 30 2021 04:37 p.m.

Elizabeth A. Brown

Clerk of Supreme Court

 

IN THE SUPREME COURT OF THE STATE OF NEVADA

 

Supreme Court No. 82559

District Court Case No. 09OC005791B

 

REZA ZANDIAN, A/K/A GOLAMREZA ZANDIANJAZI, A/K/A GHOLAM REZA ZANDIAN, A/K/A REZA JAZI, A/K/A J. REZA JAZI, A/K/A G. REZA JAZI, A/K/A GHONOREZA ZANDIAN JAZI, AN INDIVIDUAL,

     Appellant,

 

vs.

 

JED MARGOLIN, AN INDIVIDUAL,

    Respondent.

 

 

RESPONDENT’S REPLY IN SUPPORT OF MOTION TO TAKE JUDICIAL NOTICE

 

 

Appellant does not oppose Respondent’s Motion to Take Judicial Notice and therefore Respondent’s unopposed Motion should be granted. See Appellant’s Response, p. 4.

 

While Appellant does not oppose Respondent’s Motion, Appellant takes another opportunity to reargue his Opening Brief and advance his meritless NRS 17.150(4) arguments that were never raised in the District Court and should not be

 

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considered on appeal. Despite the irrelevant hyperbole contained in Appellant’s Response, the fact remains that Appellant’s allegations that Respondent never recorded his Affidavit of Judgment anywhere are false. Furthermore, Appellant’s admission that the recordings of the Affidavit of Judgment that are the subject of Respondent’s Motion to Take Judicial Notice are not in the record below only supports Respondent’s argument that this Court should not consider Appellant’s NRS 17.150(4) argument that was never raised in the district court and only raised for the first time on appeal.

 

 

DATED this 30th day of September, 2021.

 

BROWNSTEIN HYATT FARBER SCHRECK, LLP

 

By: /s/ Matthew D. Francis

 

Matthew D. Francis

Nevada Bar No. 6978

Arthur A. Zorio

Nevada Bar No. 6547

5520 Kietzke Lane, Suite 110

Reno, NV 89511

Telephone: 775.324.4100

Facsimile: 775.333.8171

Email: mfrancis@bhfs.com

azorio@bhfs.com

Attorneys for Respondent JED MARGOLIN

 

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CERTIFICATE OF SERVICE

 

Pursuant to NRAP 25(b), I certify that I am an employee of Brownstein Hyatt Farber Schreck, LLP, and on this 30th day of September, 2021, I served the document entitled RESPONDENT’S REPLY IN SUPPORT OF MOTION TO TAKE JUDICIAL NOTICE on the parties listed below in the manner described below:

 

Mark Forsberg, Esq.

Rick Oshinski, Esq.

Oshinski & Forsberg, Ltd.

504 E. Musser Street, Suite 202

Carson City, NV 89701

rick@oshinskiforsberg.com

mark@oshinskiforsberg.com

 

 

[  ]   VIA U.S. MAIL: by placing a true copy thereof enclosed in a sealed envelope with first class postage thereon fully prepaid, in the United States mail at Reno, Nevada as addressed to the foregoing party.

 

[  ]  VIA COURIER: by delivering a copy of the document to Federal Express for first priority delivery to the foregoing party in Paris, France.

 

 

[x]  VIA ELECTRONIC SERVICE: by electronically filing the document with the Clerk of the Court using the ECF system which served the foregoing parties electronically:

 

/s/ Jeff Tillison

 

Employee of Brownstein Hyatt Farber Schreck, LLP

 

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