Green Tree Servicing LLC v. Elkhorn Community Association et al

Filing 25

ORDER Granting 24 Stipulation to File First Amended Complaint for Quiet Title. Signed by Magistrate Judge Cam Ferenbach on 7/1/2015. (Copies have been distributed pursuant to the NEF - DC)

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COLT B. DODRILL, ESQ.
Nevada Bar No. 9000
WOLFE & WYMAN LLP
980 Kelly Johnson Drive, Ste 140
Las Vegas, NV 89119
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Plaintiff
GREEN TREE SERVICING LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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GREEN TREE SERVICING LLC,

CASE NO. 2:15-cv-00477-APG-VCF

Plaintiff,

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v.
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ELKHORN COMMUNITY ASSOCIATION; S.
AYRES, TRUSTEE OF THE 8117 GUAVA
NECTAR TRUST; DOES 1 through 10, inclusive;
ROES Business Entities 1 through 10, inclusive;
and all others who claim interest in the subject
property located at 8117 Guava Nectar Ave., Las
Vegas, NV 89131,

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Defendants.
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S. AYRES, TRUSTEE OF THE 8117 GUAVA
NECTAR TRUST,

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Counterclaimant,
v.
GREEN TREE SERVICING, LLC, DOES 1
through X, inclusive,
Counterdefendant.
S. AYRES, TRUSTEE OF THE 8117 GUAVA
NECTAR TRUST,

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Third-Party Plaintiff,
v.
LAURENCE WILLIAMS; JENNIFER
WILLIAMS; DOES 1 through X, inclusive,

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Third-Party Defendants.
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2034867.1

STIPULATION AND ORDER TO FILE
FIRST AMENDED COMPLAINT FOR
QUIET TITLE

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STIPULATION

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It is hereby stipulated and agreed by and between GREEN TREE SERVICING LLC,

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ELKHORN COMMUNITY ASSOCIATION, and S AYRES, TRUSTEE OF THE 8117 GUAVA

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NECTAR TRUST (collectively as the “Parties”), by and through their respective counsels of record,

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that GREEN TREE SERVICING LLC may file the First Amended Complaint attached to this

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Stipulation as Exhibit “1.”
The Parties are stipulating in the interest of judicial economy and this Stipulation shall not be

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construed to prejudice any claims or defenses asserted by the Parties in this action.
IT IS SO STIPULATED.

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DATED this 1st day of July, 2015.

DATED this 1st day of July, 2015.

By:/s/ Colt B. Dodrill
.
Colt B. Dodrill, Esq.
Nevada Bar No. 9000
Yanxiong Li, Esq.
Nevada Bar No. 12807
WOLFE WYMAN, LLP
980 Kelly Johnson Drive, Suite 140
Las Vegas, NV 89119
Attorneys for Plaintiff,
GREEN TREE SERVICING, LLC

By:/s/ Edward D. Boyack
.
Edward D. Boyack, Esq.
Nevada Bar No. 5229
BOYACK & TAYLOR
401 n. Buffalo Drive, Suite 202
Las Vegas, NV 89145
Attorneys for Defendant,
ELKHORN COMMUNITY ASSOCIATION

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DATED this 1st day of July, 2015.
By:/s/ Aaron R. Dean
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Aaron R. Dean, Esq.
Nevada Bar No. 9541
THE DEAN LEGAL GROUP, LTD.
725 S. 8th Street, Suite B
Las Vegas, NV 89101
Attorneys for Defendant,
S. AYRES, TRUSTEE OF THE 8117
GUAVA NECTAR TRUST

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2034867.1

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ORDER
Based upon the stipulation of the parties, it is hereby Ordered that Plaintiff GREEN TREE

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SERVICING LLC be allowed to file its First Amended Complaint in this matter.
IT IS SO ORDERED.

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____________________________________

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UNITED STATES MAGISTRATE JUDGE

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Dated: July 1, 2015

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Pursuant to Local Rule 15-1(b),
IT IS FURTHER ORDERED that Plaintiff must file and serve the First Amended
Complaint on or before July 8, 2015.

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2034867.1

Case 2:15-cv-00477-APG-VCF Document 24-1 Filed 07/01/15 Page 1 of 13

EXHIBIT “1”

EXHIBIT “1”

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COLT B. DODRILL, ESQ.
Nevada Bar No. 9000
WOLFE & WYMAN LLP
980 Kelly Johnson Drive, Ste 140
Las Vegas, NV 89119
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Plaintiff
GREEN TREE SERVICING LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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GREEN TREE SERVICING LLC,

CASE NO.: 2:15-cv-00477-APG-VCF

Plaintiff,

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v.

FIRST AMENDED COMPLAINT FOR
QUIET TITLE

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ELKHORN COMMUNITY ASSOCIATION; S.
AYRES, TRUSTEE OF THE 8117 GUAVA
NECTAR TRUST; DOES 1 through 10, inclusive;
ROES Business Entities 1 through 10, inclusive;
and all others who claim interest in the subject
property located at 8117 Guava Nectar Ave., Las
Vegas, NV 89131

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Defendants.
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GREEN TREE SERVICING, LLC (“Green Tree”), by and through its counsel of record,

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Wolfe & Wyman LLP, hereby complains against Defendants as follows:
STATEMENT OF JURISDICTION

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1.

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because this claim challenges the constitutionality of Nevada’s HOA foreclosure statutes.
2.

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This Court has original subject matter jurisdiction pursuant to 28 U.S.C. § 1331

This Court also has original subject matter jurisdiction pursuant to 28 U.S.C. § 1332

because there is complete diversity between the parties and the amount in controversy exceeds
$75,000.00.
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2008855.1

3.

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This matter involves certain real estate located at 8117 Guava Nectar Ave., Las

Vegas, NV 89131 (“Subject Property”) and falls under the jurisdiction of this Court.

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PARTIES

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4.

Green Tree is a limited liability company organized under the laws of Delaware.

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5.

Upon information and belief, Defendant, S. AYRES, TRUSTEE OF THE 8117

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GUAVA NECTAR TRUST (“GNT”) is a resident and Citizen of the State of Nevada.
6.

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Defendant, ELKHORN COMMUNITY ASSOCIATION is a Nevada non-profit

corporation with its principal place of business in Nevada.
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Green Tree is unaware of the true names and capacities, whether corporate,

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individual, associate, or otherwise of the other Defendants, and therefore sues those Defendants by

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fictitious names DOE or ROE BUSINESS ENTITY. When Green Tree ascertains the identities and

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exact nature of such fictitious Defendants, it will seek leave of this Court to amend this Complaint to

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assert the true names thereupon.

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FACTUAL ALLEGATIONS
8.

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This action centers around the parties’ rights in that certain real property commonly

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described as 8117 Guava Nectar Ave., Las Vegas, NV 89131; APN 125-16-317-040 (the “Subject

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Property”). The Subject Property is legally described as follows:
LOT EIGHTY-TWO (82) IN BLOCK THREE (3) OF ELKHORN SPRINGS PARCEL 2UNIT 2, AS SHOWN BY MAP THEREOF ON FILE IN BOOK 80 OF PLATS, PAGE 36,
IN THE OFFICE OF THE COUNTY RECORDER OF CLARK COUNTY, NEVADA.

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falls within the Covenants, Conditions, and Restrictions of the Elkhorn Community Association.
Green Tree’s Interest in the Property

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10.

Green Tree is informed and believes and thereon alleges that at all times relevant to

this action, Laurence and Jennifer Williams were title owner of record of the Subject Property.

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Green Tree is informed and believes and thereon alleges that the Subject Property

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In 1998, the Subject Property was conveyed to Laurence and Jennifer Williams. A

Grant, Bargain, Sale Deed evidencing the conveyance was recorded 1 on or about April 30, 1998 as

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Unless stated otherwise, all recorded documents referred to herein were recorded in the
official records of the Clark County Recorder.
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Book and Instrument 980430.02290. A true and correct copy of the Grant, Bargain, Sale Deed is

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attached as Exhibit 1.
12.

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Green Tree is informed and believes and thereon alleges that on or about January 26,

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2005, Laurence and Jennifer Williams entered into a mortgage loan transaction (“Subject Loan”) in

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which they borrowed $205,000.00 from Countrywide Home Loans, Inc. (“Countrywide”), evidenced

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by a Note and secured by the Subject Deed of Trust encumbering the Subject Property recorded in

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the official records of the Clark County Recorder on January 31, 2005 as Instrument Number

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20050131-0004157. A true and correct copy of the Subject Deed of Trust is attached as Exhibit 2.
13.

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On or about June 14, 2005 Laurence and Jennifer Williams obtained a second

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position line of credit loan in the amount of $62,300.00, secured by a second position Deed of Trust

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recorded in the official records of the Clark County Recorder on June 14, 2005 as Instrument

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Number 20050614-0001679. A true and correct copy of the Subject Deed of Trust is attached hereto

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as Exhibit 3.
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On or about June 06, 2012, an Assignment of Deed of Trust was recorded as Book

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and Instrument Number 201206060000232 whereby Mortgage Electronic Registration Systems, Inc.,

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as nominee, assigned the Subject Deed of Trust to Bank of America, N.A., Successor by Merger to

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BAC Home Loans Servicing, LP FKA Countrywide Home Loans Servicing, LP. A true and correct

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copy of the Corporation Assignment of Deed of Trust is attached as Exhibit 4.
15.

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On or about June 27, 2013, an Assignment of Deed of Trust was recorded as Book

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and Instrument Number 201306270002461 whereby Bank of America, N.A. assigned the Subject

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Deed of Trust to Green Tree Servicing LLC. A true and correct copy of the Assignment of Deed of

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Trust is attached as Exhibit 5.
16.

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Green Tree is the current beneficiary of the Subject Deed of Trust and servicer of the

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Subject Loan.

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The HOA Foreclosure and GNT’s Alleged Acquisition of the Property
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The Property is subject to a Declaration of Covenants, Conditions & Restrictions of

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the HOA (the “CC&Rs”). The CC&Rs were recorded on or about March 22, 1995, as Book and

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Instrument Number 950322.00346. A true and correct copy of the CC&Rs is attached as Exhibit 6.
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2008855.1

18.

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On or about July 08, 2010, a Notice of Delinquent Assessment Lien was recorded as

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Book and Instrument Number 2010070800017295 on behalf of the HOA by its foreclosure agent. A

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true and correct copy of the Lien for Delinquent Assessment is attached as Exhibit 7.
19.

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The Notice of Delinquent Assessment Lien referred to in the above paragraph recites

the “Amount due as of 7/6/2010 $754.45.”
20.

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On or about August 20, 2010, a Notice of Default and Election to Sell Under Notice

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of Delinquent Assessment Lien was recorded as Book and Instrument Number 201008200001205 on

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behalf of the HOA by its foreclosure agent. A true and correct copy of the Notice of Default and

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Election to Sell Pursuant to the Lien for Delinquent Assessments is attached as Exhibit 8.
21.

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On or about January 17, 2013, a Notice of Sale was recorded as Book and Instrument

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Number 201301170000883 on behalf of the HOA by its foreclosure agent. A true and correct copy

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of the Notice of Sale is attached as Exhibit 9.
22.

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The Notice of Sale identified in the above paragraph recites that the property would

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be sold for “the amount of $4,063.75 as of 1/16/2013, which includes the total amount of the unpaid

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balance and reasonably estimated costs, expenses and advances at the time of the initial publication

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of this notice.”
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claimed lien were for alleged late fees, interest, fines/violations, or collection fees/costs.
24.

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None of the aforementioned notices identified above identified what portion of the

None of the aforementioned notices identified above specified what portion of the

lien, if any, that the HOA claimed constituted a “super-priority” lien.
25.

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None of the aforementioned notices identified above specified whether the HOA was

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foreclosing on the “super-priority” portion of its lien, if any, or under the non-super-priority portion

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of the lien.

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26.

None of the aforementioned notices identified above provide any notice of a right to

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On or about June 19, 2013, a Trustee’s Deed Upon Sale was recorded as Book and

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cure.

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Instrument Number 201306190000830 stating that GNT had prevailed at an HOA lien foreclosure

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sale conducted on March 29, 2013. The deed indicates a sale price of $5,164.00. A true and correct
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copy of the Trustee’s Deed Upon Sale is attached as Exhibit 10.

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Upon information and belief, the sales price at the HOA Sale was $5,164.00.

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29.

Green Tree is informed and believes that it or its predecessors in interest attempted to

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cure the HOA lien prior to the HOA sale.
30.

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Green Tree is informed and believes that the HOA and/or its agent refused to provide

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Green Tree and/or its predecessors information sufficient to allow it to cure the HOA lien prior to

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sale.
31.

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refused the tender of payment from Green Tree and/or predecessors to cure the HOA superpriority
lien prior to the HOA sale.
32.

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superpriority amount such that Green Tree’s Deed of Trust was not extinguished by the HOA sale.
Alternatively, Green Tree is informed and believes that because the HOA and/or its agent refused
Green Tree’s tender of the HOA superpriority lien prior to the HOA sale, that the HOA sale
proceeded in bad faith and/or in a commercially unreasonable manner and is invalid and should be
set aside here.
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35.

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The HOA Sale violated Green Tree’s rights to due process because it, its agents, loan

servicers, and/or predecessors in interest were not given proper, adequate notice and the opportunity
to cure the deficiency or default in the payment of the HOA’s assessments.
36.

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Upon information and belief, the HOA assessment lien and foreclosure notices

included improper fees and costs in the amount demanded.

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Upon information and belief, the HOA and its foreclosure agents did not comply with

all mailing and noticing requirements stated in N.R.S. 116.31162 through N.R.S. 116.31168.

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Green Tree is informed and believes that, to the extent Green Tree and/or

predecessors cured the HOA superpriority lien prior to sale, the HOA sale proceeded under the non-

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Alternatively, Green Tree is informed and believes that the HOA and/or its agent

The HOA Sale was an invalid sale and could not have extinguished Green Tree’s

secured interest because of defects in the notices given, if any, to Green Tree, its agents, loan
servicers, and/or predecessors in interest.
37.

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Without providing Green Tree or its agents, loan servicers, or predecessors in interest
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2008855.1

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with notice of the correct super-priority amount and a reasonable opportunity to satisfy that amount,

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including its failure to identify the super-priority amount and its failure to adequately describe the

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deficiency in payment as required by Nevada law, the HOA’s foreclosure sale is commercially

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unreasonable and deprives Green Tree, its agents, loan servicers, and/or predecessors in interest of

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their right to due process.
38.

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Extinguishment of Green Tree’s Deed of Trust would deprive it of its right to due

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process because the HOA included amounts in its super-priority lien, such as fines, late fees, interest,

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dues, and costs of collection that are not allowed to be included in its super-priority lien, if any,

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under Nevada law.

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39.

Extinguishment of Green Tree’s Deed of Trust would deprive it of its right to due

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process because the HOA’s foreclosure trustee and/or the HOA failed to describe the deficiency in

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payment as required by Nevada law and failed to give Green Tree, its agents, loan servicers, and/or

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predecessors in interest, any reasonable opportunity to satisfy the super-priority lien, if any.
40.

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The HOA assessment lien and foreclosure notices included costs of collection and

fees that are not permissible under N.R.S. 116.3102 et seq.

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41.

The HOA Sale did not comply with N.R.S. 116.3102 et seq.

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42.

Upon information and belief, at the time of the HOA Sale, the amount owing on the

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Subject Loan was approximately $204,000.00.
43.

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Property exceeded $100,000.00.
44.

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The HOA Sale was invalid because it was conducted in a commercially unreasonable

manner.
47.

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The sale price at the HOA Sale is not commercially reasonable when compared to

the debt owed to Green Tree on the Subject Loan and the fair market value of the Property.

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The amount paid by GNT at the HOA Sale, upon information and belief, was

approximately $5,164.00.

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Upon information and belief, at the time of the HOA Sale, the fair market value of the

The HOA Sale by which GNT took its interest was commercially unreasonable if it

extinguished Green Tree’s Deed of Trust.
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48.

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The sales price to GNT, when compared to the outstanding balance of Green Tree’s

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Note and Deed of Trust and the fair market value of the Property, demonstrates that the HOA Sale

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was not commercially reasonable or conducted in good faith.
49.

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The HOA Sale is commercially unreasonable because the HOA’s foreclosure trustee

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and/or the HOA failed to describe the deficiency in payment as required by Nevada law and failed to

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give Green Tree, its agents, loan servicers, and/or predecessors in interest any reasonable

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opportunity to satisfy the super-priority lien.
50.

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The HOA Sale was an invalid sale and could not have extinguished Green Tree’s

secured interest because it was not a commercially reasonable sale.
51.

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Because the CC&Rs contained a Mortgagee Protection Clause, and because Green

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Tree, its agents, loan servicers, and/or predecessors in interest were not given proper notice that the

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HOA intended to foreclose on the super-priority portion of the dues owing, Green Tree was not on

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notice that it had to attend the HOA Sale to protect its security interest.
52.

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Because the CC&Rs contained a Mortgagee Protection Clause, and because proper

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notice that the HOA intended to foreclose on the super-priority portion of the dues owing was not

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given, prospective bidders did not appear for the HOA Sale, making the HOA Sale commercially

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unreasonable.
53.

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GNT and the HOA knew that Green Tree would rely on the Mortgagee Protection

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Clause contained in the recorded CC&Rs, and knew that Green Tree, its agents, loan servicers, or

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predecessors in interest would not know that the HOA was foreclosing on super-priority amounts

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because of the failure of the HOA and the HOA’s foreclosure trustees’ failure to provide such notice.

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Green Tree’s absence from the HOA Sale allowed GNT to appear at the HOA Sale and purchase the

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Property for a fraction of market value, making the HOA Sale commercially unreasonable.
54.

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GNT and the HOA knew that prospective bidders would be less likely to attend the

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HOA Sale because the public at large believed that Green Tree was protected under the Mortgagee

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Protection Clause in the CC&Rs of public record, and that the public at large did not receive notice,

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constructive or actual, that the HOA was foreclosing on a super-priority portion of its lien because

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the HOA and the HOA’s foreclosure trustees improperly failed to provide such notice. The general
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public’s belief therefore was that a buyer at the HOA Sale would take title to the Property subject to

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Green Tree’s Deed of Trust. This general belief resulted in the absence of prospective bidders at the

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HOA Sale, which allowed GNT to appear at the HOA Sale and purchase the Property for a fraction

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of market value, making the HOA Sale commercially unreasonable.
55.

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The circumstances of the HOA Sale of the Property breached the HOA’s, HOA’s

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foreclosure trustee’ and the other Defendants’ obligation of good faith under N.R.S. 116.1113 and

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their duty to act in a commercially reasonable manner.

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56.

Green Tree is informed and believes that GNT is a professional property purchaser.

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57.

The circumstances of the HOA Sale of the Property and GNT’s status as a

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professional property purchaser prevent GNT from being deemed a bona fide purchaser for value.

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FIRST CAUSE OF ACTION

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(Quiet Title versus GNT)
58.

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Green Tree incorporates by reference the allegations of all previous paragraphs, as if

fully set forth herein.
59.

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Pursuant to 28 U.S.C. § 2201 and N.R.S. 40.010, this Court has the power and

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authority to declare Green Tree’s rights and interests in the Property and to resolve the parties’

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adverse claims in the Property.
60.

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N.R.S. 116.3116(2)(b).
61.

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Green Tree’s Deed of Trust is a first secured interest on the Property as intended by

As the current beneficiary under the Subject Deed of Trust securing the Subject Loan,

Green Tree retained its first position status in the chain of title for the Property after the HOA Sale.
62.

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GNT claims an interest in the Property through a Trustee’s Deed Upon Sale recorded

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in the Clark County Recorder’s Office as Book and Instrument Number 201306190000830 which is

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adverse to Green Tree’s interest.
63.

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reasons set forth above in the Factual Allegations.
64.

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The HOA Sale could not have extinguished Green Tree’s secured interest for the

Based on the adverse claims being asserted by the parties, the parties are entitled to a

judicial determination regarding the rights and interests of the respective parties to the case.
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65.

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Green Tree is entitled to a determination from this Court, pursuant to 28 U.S.C.

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§ 2201 and N.R.S. 40.010, that Green Tree is the beneficiary of a first position Deed of Trust which

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still encumbers the Property.
66.

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Green Tree is entitled to a determination from this Court, pursuant to 28 U.S.C.

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§ 2201 and N.R.S. 40.010, that Green Tree’s secured interest by virtue of its Deed of Trust is

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superior to the interest, if any, acquired by GNT through the Trustee’s Deed Upon Sale.
67.

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It has been necessary for Green Tree to retain counsel in order to file this lawsuit, as a

result, Green Tree is entitled to its costs and a reasonable attorneys’ fee.

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SECOND CAUSE OF ACTION

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(Declaratory Relief versus all Defendants)
68.

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fully set forth herein.
69.

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70.

The Subject Deed of Trust is a first secured interest on the Property whose priority is

protected by N.R.S. 116.3116(2)(b).
71.

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Pursuant to 28 U.S.C. § 2201, this Court has the power and authority to declare Green

Tree’s rights and interests in the Property and to resolve the parties’ adverse claims in the Property.

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Green Tree incorporates by reference the allegations of all previous paragraphs, as if

As the current beneficiary under the Deed of Trust, Green Tree’s interest in the

Property retained its first position status in the chain of title after the HOA Sale.
72.

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GNT claims an interest in the Property through a Trustee’s Deed Upon Sale recorded

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in the Clark County Recorder’s Office as Book and Instrument Number 201306190000830 which is

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adverse to Green Tree’s interest.
73.

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Green Tree is entitled to a judicial determination regarding the rights and interests of

the respective parties to the case.
74.

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Green Tree is entitled to a determination from this Court, pursuant to 28 U.S.C.

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§ 2201, that its secured interest by virtue of its Deed of Trust is superior to the interest, if any,

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acquired by GNT through the Trustee’s Deed Upon Sale, or held or claimed by any other party.
75.

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Green Tree is entitled to a declaration that the HOA Sale conducted by the HOA did

not affect or extinguish Green Tree’s rights, status, legal relations and interest in the Property.
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76.

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HOA Sale was not a valid sale and conveyed no legitimate interest to GNT.
77.

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In the alternative, Green Tree is entitled to a determination from this Court that the

Green Tree has been required to retain counsel to prosecute this action and is entitled

to recover reasonable attorney’s fees to prosecute this action.

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THIRD CAUSE OF ACTION

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(Unconstitutional Statute versus all Defendants)
78.

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fully set forth herein.
79.

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Green Tree incorporates by reference the allegations of all previous paragraphs, as if

This Court has the duty and jurisdiction to declare unconstitutional any law that

violates a protected right.
80.

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Nevada’s HOA foreclosure statutes violate the Due Process Clauses of the Nevada

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and United States Constitutions because the opt-in notice provisions do not mandate that reasonable

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and affirmative steps be taken to give actual notice to lenders and other holders of recorded security

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interests prior to a deprivation of their property rights.
81.

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Because the Statutes do not require the foreclosing party to take reasonable steps to

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ensure that actual notice is provided to interested parties who are reasonably ascertainable (unless

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the interested party first requests notice) they do not comport with long standing principles of

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constitutional due process.
82.

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As a direct and proximate result of the above, Nevada’s HOA foreclosure statutes are

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facially unconstitutional in violation of the Due Process Clauses of both the United States and

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Nevada Constitutions and should be stricken.
83.

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Green Tree is entitled to a determination from this Court that because the HOA Sale

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proceeded under an unconstitutional statute, it was not a valid sale, conveyed no legitimate interest

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to GNT, and did not extinguish Green Tree’s Deed of Trust.
84.

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Green Tree has been required to retain counsel to prosecute this action and is entitled

to recover reasonable attorney’s fees to prosecute this action.

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PRAYER FOR RELIEF
Wherefore, Plaintiff Green Tree Servicing, LLC prays for relief as follows:

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1.

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unconstitutional;

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2.

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3.

4.

For a declaration and determination that Green Tree’s interest is secured against the

Subject Property, and that Green Tree’s first Deed of Trust was not extinguished by the HOA Sale;
5.

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For a judgment quieting title and declaring that Green Tree’s Deed of Trust continues

to encumber the Property;

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For a declaration and determination that the HOA Sale was invalid and conveyed no

legitimate interest to GNT;

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For a judgment determining that Nevada’s HOA foreclosure statutes are stricken as

For a declaration and determination that Green Tree’s interest is superior to the

interest of GNT and all other parties;
6.

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For a preliminary injunction that GNT, its successors, assigns, and agents are

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prohibited from conducting any sale, transfer or encumbrance of the Property that is claimed to be

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superior to Green Tree’s Deed of Trust or not subject to that Deed of Trust;
7.

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For a preliminary injunction that GNT be required to pay all taxes, insurance and

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homeowner’s association dues and segregate and deposit with the Court or a Court-approved trust

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account over which GNT has no control during the pendency of this action;
8.

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If it is determined that Green Tree’s Deed of Trust has been extinguished by the HOA

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Sale, for special damages in the amount equal to the fair market value of the Property or the unpaid

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balance of the Subject Loan, plus interest, at the time of the HOA Sale, whichever is greater;

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9.

For general and special damages;

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10.

For costs incurred herein, including post-judgment costs;

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11.

For attorney’s fees; and

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For any and all further relief deemed appropriate by this Court.

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DATED: June _____, 2015

WOLFE & WYMAN LLP

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By: /s/ Colt B. Dodrill
COLT B. DODRILL, ESQ.
Nevada Bar No. 9000
980 Kelly Johnson Drive, Ste. 140
Las Vegas, NV 89119

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Attorneys for Plaintiff,
GREEN TREE SERVICING LLC

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