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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
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
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.
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
[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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