1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`
`
`
`
`LEO P. FLANGAS, ESQ.
`Nevada Bar No.: 5637
`FLANGAS CIVIL LAW FIRM, LTD.
`600 South Third Street
`Las Vegas, Nevada 89101
`Telephone:
`(702) 384-1990
`Facsimile:
`(702) 384-1009
`Email: leo@flangaslawfrim.com
`Attorney for Plaintiff
`
`Electronically Filed
`10/7/2021 11:20 PM
`Steven D. Grierson
`CLERK OF THE COURT
`
`Electronically Filed
`Oct 15 2021 04:21 p.m.
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`DISTRICT COURT
`CLARK COUNTY, NEVADA
`
`Case No.: A-18-777196-C
`Dept. No.: XXII
`
`
`
`
`Plaintiff,
`
`YVES GHIAI-CHAMLOU,
`
`
`vs.
`
`RELIENT TITLE USA, LLC; HORIZON
`REALITY GROUP, LLC; BERKSHIRE
`HATHWAY HOMESERVICES NEVADA;
`DOES I through XXX, inclusive, and ROE
`BUSINESS ENTITIES
`I
`through X,
`inclusive,
`
`Defendant.
`
`
`
`
`NOTICE OF APPEAL
`
`NOTICE IS HEREBY GIVEN THAT YVES GHIAI-CHAMLOU, the PLAINTIFF above
`
`named, hereby appeal to the Supreme Court of Nevada from the minute and written orders which
`
`cumulatively dismissed RELIENT TITLE USA, LLC from this action, to wit:
`
`1. Motion to Dismiss Minutes filed January 10, 2019;
`
`2. Order for Motion for Leave to Amend Complaint entered February 14, 2020;
`
`3. Order for Motion to Dismiss Second Amended Complaint entered May 1, 2020;
`
`4. Order for Motion for Reconsideration entered June 19, 2020.
`
`
`
`
`
`
`Page 1 of 3
`
`Docket 83635 Document 2021-29738
`Case Number: A-18-777196-C
`
`

`

`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`
`
`
`This matter became ripe for Appeal upon Notice of Entry of the September 10, 2021,
`
`Stipulated Judgment Against Horizon Realty Group, LLC resolving all remaining claims of all
`
`parties
`
`Dated this 5th day of October 2021.
`
`
`_/s/ Ian Christopherson____
`IAN CHRISTOPHERSON, ESQ.
`Nevada Bar No. 3701
`600 S. Third Street
`Las Vegas, Nevada 89101
`Iclaw44@gmail.com
`Attorney for Defendant
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 2 of 3
`
`
`
`
`
`
`
`
`
`

`

`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to NRCP 5(b), I hereby certify that on this 7th day of September, 2021, service
`
`of the forgoing document was made by depositing a true and correct copy of the same service
`
`was made U.S. Mail and by submission to the electronic filing service for the Clark County
`
`Nevada Eighth Judicial Court upon all the parties registered to the District Court Electronic
`
`Filing Program.
`
`_/s/ Ian Christopherson____
`IAN CHRISTOPHERSON, ESQ.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Page 3 of 3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`Location: Department 22
`Judicial Officer: Johnson, Susan
`Filed on: 07/05/2018
`A777196
`Cross-Reference Case
`Number:
`
`§§§§§
`
`CASE INFORMATION
`
`Case Type: Negligence - Other Negligence
`Case
`Status: 01/28/2021 Dismissed
`
`Yves Ghiai-Chamlou, Plaintiff(s)
`vs.
`Reliant Title USA LLC, Defendant(s)
`
`Statistical Closures
`01/28/2021 Stipulated Dismissal
`08/13/2018 Voluntary Dismissal
`
`DATE
`
`CASE ASSIGNMENT
`
`Current Case Assignment
`Case Number
`Court
`Date Assigned
`Judicial Officer
`
`A-18-777196-C
`Department 22
`07/05/2018
`Johnson, Susan
`
`PARTY INFORMATION
`
`Plaintiff
`
`Ghiai-Chamlou, Yves
`
`Defendant
`
`Americana LLC
`Removed: 02/03/2021
`Dismissed
`
`Horizon Realty Group LLC
`
`JP Morgan Chase Bank N A
`Removed: 08/13/2018
`Dismissed
`JP Morgan Chase Holdings LLC
`Removed: 08/13/2018
`Dismissed
`Martinez, Veronica
`Removed: 08/14/2018
`Inactive
`Reliant Title USA LLC
`
`DATE
`
`07/05/2018
`
`07/05/2018
`
`EVENTS & ORDERS OF THE COURT
`
`EVENTS
`Complaint
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[1] Complaint and Jury Demand
`
`Initial Appearance Fee Disclosure
`[2] Initial Appearance Fee Disclosure
`
`Lead Attorneys
`Flangas, Leonidas P, ESQ
`Retained
`702-384-1990(W)
`Welsh, Darren J.
`Retained
`702-733-9310(W)
`Ferran, Erick M.
`Retained
`702-476-9668(W)
`
`Kenyon, Jay A.
`Retained
`702-888-0000(W)
`
`INDEX
`
`PAGE 1 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`Summons Electronically Issued - Service Pending
`Party: Plaintiff Ghiai-Chamlou, Yves
`[3] Summons- Civil
`
`Notice of Voluntary Dismissal
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[4] Notice of Voluntary Dismissal & Order
`
`Amended Complaint
`[5] Amended Complaint and Jury Demand
`
`Summons Electronically Issued - Service Pending
`[6] Summons-Civil
`
`Errata
`[7]
`
`Affidavit of Service
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`Party Served: Defendant Reliant Title USA LLC
`[8] Affidavit of Service - Reliant Title USA LLC
`
`Affidavit of Service
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`Party Served: Defendant Horizon Realty Group LLC
`[9] Affidavit of Service - Horizon Realty Group LLC
`
`Notice of Intent to Take Default
`Party: Plaintiff Ghiai-Chamlou, Yves
`[10] Three Day Notice of Intent to Take Default
`
`Notice of Intent to Take Default
`[11] Three Day Notice of Intent to Take Default
`
`Answer
`Filed By: Defendant Reliant Title USA LLC
`[12] Defendant Reliant Title Usa, Llc s Answer To Amended Complaint
`
`Initial Appearance Fee Disclosure
`Filed By: Defendant Reliant Title USA LLC
`[13] Initial Appearance Fee Disclosure
`
`Motion to Dismiss
`Filed By: Defendant Horizon Realty Group LLC
`[15] Defendant's Motion To Dismiss, Or, In The Alternative, For A More Definite Statement
`
`Initial Appearance Fee Disclosure
`Filed By: Defendant Horizon Realty Group LLC
`[14] Initial Appearance Fee Disclosure
`
`07/11/2018
`
`08/13/2018
`
`08/14/2018
`
`08/14/2018
`
`08/14/2018
`
`08/22/2018
`
`09/05/2018
`
`09/11/2018
`
`09/24/2018
`
`09/25/2018
`
`09/25/2018
`
`09/28/2018
`
`10/01/2018
`
`10/02/2018
`
`Notice of Change of Hearing
`[16] Notice of Change of Hearing
`
`PAGE 2 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`Request for Exemption From Arbitration
`[17] Request for Exemption from Arbitration
`
`Commissioners Decision on Request for Exemption - Granted
`[18] COMMISSIONER'S DECISION ON REQUEST FOR EXEMPTION - GRANTED
`
`Opposition to Motion to Dismiss
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[19] Plaintiff's Opposition To Defendant Horizon Realty Group's Motion To Dismiss, Or, In
`The Alternative For A More Definite Statement And Request For Leave To Amend And For A
`Continuance Pursuant To Nrcp 56(F)
`
`Motion to Associate Counsel
`Filed By: Defendant Reliant Title USA LLC
`[20] Defendant Title USA, LLC's Motion to Associate Counsel
`
`Certificate of Service
`Filed by: Defendant Reliant Title USA LLC
`[21] Certificate of Service
`
`Notice of Hearing
`Filed By: Defendant Horizon Realty Group LLC
`[22] Defendant's Re-Notice of Hearing For Motion To Dismiss, Or, In The Alaternative, For A
`More Definite Statement
`
`Order Admitting to Practice
`Filed By: Defendant Reliant Title USA LLC
`[23] Order Admitting to Practice
`
`Notice of Entry of Order
`Filed By: Defendant Reliant Title USA LLC
`[24] Notice of Entry of Order Admitting to Practice
`
`Certificate of Service
`Filed by: Defendant Reliant Title USA LLC
`[25] Certificate of Service
`
`Joint Case Conference Report
`[26] Joint Case Conference Report
`
`Answer
`Filed By: Defendant Horizon Realty Group LLC
`[27] Defendant's Answer To Plaintif's Amended Complaint
`
`Order Scheduling Status Check
`[28] Order Scheduling Mandatory Rule 16 Conference
`
`Motion for Leave to File
`Party: Plaintiff Ghiai-Chamlou, Yves
`[29] Motion for Leave to Amend Complaint & Voluntary Dismiss Without Prejudice Veronica
`Martinez Only
`
`10/03/2018
`
`10/16/2018
`
`10/22/2018
`
`11/14/2018
`
`11/19/2018
`
`11/26/2018
`
`12/13/2018
`
`01/09/2019
`
`01/09/2019
`
`03/05/2019
`
`03/05/2019
`
`03/11/2019
`
`04/01/2019
`
`04/03/2019
`
`Clerk's Notice of Hearing
`
`PAGE 3 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`[30] Notice of Hearing
`
`Scheduling and Trial Order
`[31]
`
`Opposition to Motion
`Filed By: Defendant Reliant Title USA LLC
`[32] Defendant Reliant Title USA, LLC's Brief In Opposition To Plaintiff s Motion For Leave
`To Amend
`
`Notice of Association of Counsel
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[33] Notice of Association of Counsel
`
`Motion for Leave to File
`[34] Plaintiff's Motion for Leave to Amend Complaint to Add Additional Parties
`
`Motion to Extend Discovery
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[35] Motion to Extend Discovery Deadline Dates
`
`Supplement
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[36] Supplement to Plaintiff's Motion for Leave to Amend to Add Additional Parties
`
`Notice of Non Opposition
`Filed By: Defendant Reliant Title USA LLC
`[37] Defendant Reliant Title Usa, LLC's Notice of Non-Opposition to Plaintiff's Motion for
`Leave to Amend Complaint
`
`Amended Certificate of Service
`Party: Defendant Reliant Title USA LLC
`[38] Corrected Certificate Of Of Service
`
`Notice
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[39] Notice of Hearing on Plaintiff's Motion for Leave to Amend Complaint to Add Additional
`Parties
`
`Clerk's Notice of Hearing
`[40] Notice of Hearing
`
`Order Granting Motion
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[41] Order Granting Plaintiff s Motion for Leave to File an Amended Complaint
`
`Notice of Entry of Order
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[42] Notice of Entry of Order
`
`Second Amended Complaint
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[43] Second Amended Complaint
`
`04/03/2019
`
`04/10/2019
`
`05/01/2019
`
`12/05/2019
`
`12/05/2019
`
`12/13/2019
`
`12/16/2019
`
`12/16/2019
`
`01/13/2020
`
`01/14/2020
`
`02/13/2020
`
`02/14/2020
`
`02/21/2020
`
`PAGE 4 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`Summons Electronically Issued - Service Pending
`Party: Plaintiff Ghiai-Chamlou, Yves
`[44] Summons - Civil
`
`Summons Electronically Issued - Service Pending
`[45] Summons - Civil
`
`Summons Electronically Issued - Service Pending
`Party: Plaintiff Ghiai-Chamlou, Yves
`[46] Summons - Civil
`
`Motion to Dismiss
`Filed By: Defendant Reliant Title USA LLC
`[47] Reliant Title Usa, LLC's Motion To Dismiss And Memorandum Of Points And Authorities
`
`Clerk's Notice of Hearing
`[48] Clerk's Notice of Hearing
`
`Initial Appearance Fee Disclosure
`Filed By: Defendant Americana LLC
`[49] Defendant Americana LLC dba Berkshire Hathaway HomeServices Nevada Properties'
`Initial Appearance Fee Disclosure
`
`Motion for More Definite Statement
`Filed By: Defendant Americana LLC
`[50] Defendant Americana LLC dba Berkshire Hathaway HomeServices Nevada Properties'
`Motion For More Definite Statement
`
`Clerk's Notice of Hearing
`[51] Notice of Hearing
`
`Opposition to Motion to Dismiss
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[52] Plaintiff's Opposition to Defendant's Motion to Dismiss Complaint
`
`Notice of Appearance
`Party: Plaintiff Ghiai-Chamlou, Yves
`[53] Notice of Appearance of Counsel
`
`Reply in Support
`Filed By: Defendant Reliant Title USA LLC
`[54] Defendant Reliant Title USA, LLC's Reply Brief In Support Of Its Motion To Dismiss
`
`Substitution of Attorney
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[55] SUBSTITUTION OF ATTORNEY
`
`Stipulation and Order
`[56] Stipulation and Order to Continue Hearing
`
`Stipulation and Order
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[57] (Duplicate) STIPULATION AND ORDER TO CONTINUE HEARING
`
`02/21/2020
`
`02/21/2020
`
`02/21/2020
`
`03/20/2020
`
`03/20/2020
`
`04/02/2020
`
`04/02/2020
`
`04/03/2020
`
`04/10/2020
`
`04/13/2020
`
`04/14/2020
`
`04/15/2020
`
`04/20/2020
`
`04/20/2020
`
`PAGE 5 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`Order Granting Motion
`Filed By: Defendant Reliant Title USA LLC
`[58] Order Granting Defendant Reliant Title USA, LLC's Motion to Dismissal Plaintiff's
`Second Amended Complaint with Prejudice
`
`Order Granting Motion
`Filed By: Defendant Reliant Title USA LLC
`[59] (DUPLICATE FILING SAME DATE) Order Granting Defendant Reliant Title USA,
`LLC's Motion To Dismiss Plaintiff s Second Amended Complaint With Prejudice
`
`Notice of Entry of Order
`Filed By: Defendant Reliant Title USA LLC
`[60] Notice of Entry of Order
`
`Opposition and Countermotion
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[61] Plaintiff's Opposition to Defendant Americana LLC dba Berkshire Hathaway
`Homeservices Nevada Properties Motion for More Definite Statement and Motion for Leave to
`Amend the Complaint
`
`Motion to Reconsider
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[62] Plaintiff's Motion for Reconsideration of Order Granting Defendant Reliant Title USA,
`LLC's Motion to Dismiss Plaintiff's Second Amended Complaint with Prejudice and/or Motion
`for NRCP Rule 59 or 60 Relief from Order
`
`Clerk's Notice of Hearing
`[63] Notice of Hearing
`
`Order Granting Motion
`Filed By: Defendant Americana LLC
`[64] Order Granting Defendant Americana, LLC's Motion for More Definite Statement
`
`Notice of Entry
`Filed By: Defendant Americana LLC
`[65] BHHSNV - Notice of Entry of Order executed
`
`Opposition to Motion
`Filed By: Defendant Reliant Title USA LLC
`[66] Reliant Title USA, LLC's Opposition to Plaintiff's Motion For Reconsideration of Order
`Granting Defendant Reliant Title USA, LLC's Motion to Dismiss Plaintiff's Second Amended
`Complaint With Prejudice and/or Motion For NRCP Rule 59 or 60 Relief From Order
`
`Affidavit
`Filed By: Defendant Reliant Title USA LLC
`[67] Affidavit of J. Daniel Weidner
`
`Affidavit
`Filed By: Defendant Reliant Title USA LLC
`[68] Affidavit of Shannon Persoma
`
`Third Amended Complaint
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[69] Third Amended Complaint and Request for Jury Trial
`
`05/01/2020
`
`05/01/2020
`
`05/01/2020
`
`05/04/2020
`
`05/11/2020
`
`05/12/2020
`
`05/21/2020
`
`05/22/2020
`
`05/26/2020
`
`05/26/2020
`
`05/26/2020
`
`05/27/2020
`
`PAGE 6 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`Reply to Opposition
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[70] Response to opposition to Plaintiff's Motion for Reconsideration
`
`Stipulation and Order
`Filed by: Defendant Reliant Title USA LLC
`[71] Stipulation and Order on Defendant Reliant Title USA, LLC's Deadline to Respond to the
`Third Amended Complaint
`
`Notice of Entry of Stipulation and Order
`Filed By: Defendant Reliant Title USA LLC
`[72] Notice of Entry of Stipulation and Order
`
`Motion to Dismiss
`Filed By: Defendant Americana LLC
`[73] Defendant Americana LLC's Motion to Dismiss as to Plaintiff's Third Amended
`Complaint
`
`Clerk's Notice of Hearing
`[74] Notice of Hearing
`
`Order Denying Motion
`Filed By: Defendant Reliant Title USA LLC
`[75] Order Denying Plaintiff's Motion for Reconsideration
`
`Notice of Entry of Order
`Filed By: Defendant Reliant Title USA LLC
`[76] Notice of Entry of Order
`
`Opposition to Motion
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[77] PLAINTIFF S OPPOSITION TO DEFENDANT AMERICANA LLC S MOTION TO
`DISMISS AS TO PLAINTIFF S THIRD AMENDED COMPLAINT AND MOTION FOR
`LEAVE TO AMEND
`
`Stipulation and Order
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[78] Stipulation and Order to Extend Briefing Schedule
`
`Reply
`Filed by: Defendant Americana LLC
`[79] Defendant Americana LLC's Reply Brief and Opposition to Motion For Leave to Amend
`
`Order
`Filed By: Defendant Americana LLC
`[80] Order Granting in Part, Denying in Part Defendant Americana, LLC's Motion to Dismiss
`
`Notice of Entry of Order
`Filed By: Defendant Americana LLC
`[81] Notice of Entry of Order
`
`Amended Order Setting Jury Trial
`[82] First Amended Order Setting Civil Jury Trial
`
`06/04/2020
`
`06/09/2020
`
`06/09/2020
`
`06/10/2020
`
`06/11/2020
`
`06/19/2020
`
`06/19/2020
`
`06/29/2020
`
`06/29/2020
`
`07/10/2020
`
`08/17/2020
`
`08/17/2020
`
`08/26/2020
`
`PAGE 7 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`01/27/2021
`
`01/28/2021
`
`02/03/2021
`
`02/17/2021
`
`09/10/2021
`
`09/10/2021
`
`10/07/2021
`
`08/13/2018
`
`05/01/2020
`
`08/17/2020
`
`02/03/2021
`
`02/17/2021
`
`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`Fourth Amended Complaint
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[83] FOURTH AMENDED COMPLAINT AND REQUEST FOR JURY TRIAL
`
`Order to Statistically Close Case
`[84] Civil Order to Statistically Close Case - Stipulated Dismissal
`
`Stipulation and Order for Dismissal With Prejudice
`Filed By: Defendant Americana LLC
`[85] Stipulation and Order for Dismissal with Prejudice as to Defendant Americana, LLC
`d/b/a Berkshire Hathaway Homeservices Nevada Properties
`
`Stipulation and Order
`Filed by: Plaintiff Ghiai-Chamlou, Yves
`[86] Stipulated Judgment Against Horizon Realty Group, LLC
`
`Notice of Entry
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[87] Notice of Entry of Order
`
`Notice of Entry
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[88] Notice of Entry of Order
`
`Notice of Appeal
`Filed By: Plaintiff Ghiai-Chamlou, Yves
`[89] Notice of Appeal
`DISPOSITIONS
`Order of Dismissal Without Prejudice (Judicial Officer: Johnson, Susan)
`Debtors: Reliant Title USA LLC (Defendant), JP Morgan Chase Holdings LLC (Defendant), JP
`Morgan Chase Bank N A (Defendant)
`Creditors: Yves Ghiai-Chamlou (Plaintiff)
`Judgment: 08/13/2018, Docketed: 08/13/2018
`Comment: 8/17/18 Case Reopened
`
`Order of Dismissal With Prejudice (Judicial Officer: Johnson, Susan)
`Debtors: Yves Ghiai-Chamlou (Plaintiff)
`Creditors: Reliant Title USA LLC (Defendant)
`Judgment: 05/01/2020, Docketed: 05/04/2020
`
`Order of Dismissal (Judicial Officer: Johnson, Susan)
`Debtors: Yves Ghiai-Chamlou (Plaintiff)
`Creditors: Americana LLC (Defendant)
`Judgment: 08/17/2020, Docketed: 08/18/2020
`Comment: In Part/ Causes of Action
`
`Order of Dismissal With Prejudice (Judicial Officer: Johnson, Susan)
`Debtors: Americana LLC (Defendant)
`Creditors: Yves Ghiai-Chamlou (Plaintiff)
`Judgment: 02/03/2021, Docketed: 02/04/2021
`
`Judgment Plus Legal Interest (Judicial Officer: Johnson, Susan)
`Debtors: Horizon Realty Group LLC (Defendant)
`Creditors: Yves Ghiai-Chamlou (Plaintiff)
`Judgment: 02/17/2021, Docketed: 02/18/2021
`Total Judgment: 160,000.00
`
`PAGE 8 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`11/19/2018
`
`11/27/2018
`
`11/27/2018
`
`12/04/2018
`
`01/08/2019
`
`01/10/2019
`
`HEARINGS
`Minute Order (3:00 AM) (Judicial Officer: Johnson, Susan)
`Minute Order - No Hearing Held;
`Journal Entry Details:
`Pursuant to EDCR 2.20(g), the moving party shall deliver Courtesy Copies of all papers
`related to their Motion at least 5 judicial days before the hearing. This includes the Opposition
`if opposing counsel fails to deliver their own courtesy copies. Furthermore, EDCR 7.20(d)
`requires that all exhibits attached to the pleadings or papers must be clearly divided by a tab.
`As all courtesy copies have not been received and/or properly tabbed, the following hearing(s)
`have been VACATED: Tuesday November 27, 2018: Motion to Dismiss Should the parties
`wish to proceed, the Hearing will need to be Re-Noticed. All courtesy copies must be properly
`tabbed and delivered to chambers 5 judicial days before the hearing. CLERK'S NOTE: The
`above minute order has been distributed to counsel by the Judicial Executive Assistant, via
`electronic service, facsimile and/or mail. kc//11-19-18;
`
`CANCELED Motion to Dismiss (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated
`Defendant's Motion to Dismiss or in the Alternative for More Definite Statement
`
`CANCELED Motion to Dismiss (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated - On in Error
`Defendant's Motion to Dismiss or in the Alternative for More Definite Statement
`
`Minute Order (3:00 AM) (Judicial Officer: Johnson, Susan)
`Minute Order - No Hearing Held;
`Journal Entry Details:
`Having examined Defendant Reliant Title USA, LLC s Motion to Associate Counsel filed
`November 14, 2018, noted the motion was served upon the parties, no Opposition was filed
`thereto, and there is good cause therefore, COURT ORDERS Defendant Reliant Title USA,
`LLC s Motion to Associate Counsel filed November 14, 2018 is GRANTED pursuant to EDCR
`2.20(e). The matter scheduled to be heard Tuesday, January 8, 2019 at 8:30 a.m. is VACATED
`pursuant to EDCR 2.23. Counsel is to prepare and submit a proposed Order to the Court
`within ten (10) days of this Minute Order or no later than Friday, December 14, 2018
`pursuant to EDCR 7.21. CLERK'S NOTE: The above minute order has been distributed to
`counsel by the Judicial Executive Assistant, via electronic service, facsimile and/or mail.
`kc//12-04-18 ;
`
`CANCELED Motion to Associate Counsel (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated
`Defendant Reliant Title USA LLC's Motion to Associate Counsel
`
`Motion to Dismiss (9:00 AM) (Judicial Officer: Johnson, Susan)
`Events: 11/26/2018 Notice of Hearing
`Defendant's Re-Notice of Hearing for Motion to Dismiss or in the Alternative for a More
`Definite Statement
`Granted in Part;
`Journal Entry Details:
`Arguments made by counsel regarding Horizon Realty Group's involvement in this action.
`COURT ORDERED, Motion GRANTED IN PART as to the fraud claim; Dismissal is
`WITHOUT PREJUDICE. Motion is, DENIED IN PART as to the first and third causes of
`action.;
`
`04/03/2019
`
`Mandatory Rule 16 Conference (8:30 AM) (Judicial Officer: Johnson, Susan)
`Matter Heard;
`Journal Entry Details:
`
`Mr. Leventhal stated they filed a Motion for Leave to Amend Complaint so they can add
`additional parties. Counsel anticipate 7-10 days for trial. COURT ORDERED, trial date SET.
`COURT FURTHER ORDERED, discovery cutoff is March 5, 2020; adding parties, amended
`pleadings, and initial expert disclosures DUE December 5, 2019, rebuttal expert disclosures
`
`PAGE 9 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`05/01/2019
`
`05/07/2019
`
`01/30/2020
`
`02/18/2020
`
`03/18/2020
`
`04/21/2020
`
`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`DUE January 3, 2020; dispositive motions TO BE FILED BY April 3, 2020. Scheduling Order
`will issue. 6/17/20 8:30 AM PRETRIAL/CALENDAR CALL 6/29/20 8:30 P.M. JURY TRIAL ;
`
`Minute Order (3:00 AM) (Judicial Officer: Johnson, Susan)
`Minute Order - No Hearing Held;
`Journal Entry Details:
`Pursuant to EDCR 2.20(g), the moving party shall deliver Courtesy Copies of all papers
`related to their Motion at least five (5) judicial days before the hearing. This includes the
`Opposition if opposing counsel fails to deliver their own courtesy copies. Furthermore, EDCR
`7.20(d) requires that all exhibits attached to the pleadings or papers must be clearly divided
`by a tab. As all courtesy copies have not been received and/or properly tabbed, the following
`hearing(s) have been VACATED: Tuesday May 7, 2019: Motion for Leave to Amend
`Complaint & Voluntary Dismiss without Prejudice Veronica Martinez Only Should the parties
`wish to proceed, the Hearing will need to be Re-Noticed. All courtesy copies must be properly
`tabbed and delivered to Chambers five (5) judicial days before the hearing. CLERK'S NOTE:
`This Minute Order was electronically served by JEA, to all parties registered for Odyssey File
`& Serve. (5/01/19 sb);
`
`CANCELED Motion for Leave (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated - per Judge
`Motion for Leave to Amend Complaint & Voluntary Dismiss Without Prejudice Veronica
`Martinez Only
`
`Minute Order (3:00 AM) (Judicial Officer: Johnson, Susan)
`Minute Order - No Hearing Held;
`Journal Entry Details:
`Having examined Plaintiff's Motion for Leave to Amend Complaint filed December 5, 2019,
`noted the motion was electronically served upon the parties, no Opposition has been filed
`thereto, and there is good cause therefore, COURT ORDERS Plaintiff's Motion for Leave to
`Amend Complaint filed December 5, 2019 is GRANTED pursuant to NRCP 15(a) and EDCR
`2.20(e). Plaintiff has leave to file the proposed complaint attached as Exhibit 1 to the
`Supplement to the Motion for Leave to Amend Complaint filed December 13, 2019. Matter
`scheduled to be heard February 18, 2020 at 8:30 a.m. is VACATED pursuant to EDCR 2.23.
`Counsel is to prepare and submit a proposed Order within fourteen (14) days of this Minute
`Order or no later than February 13, 2020 pursuant to EDCR 7.21. CLERK'S NOTE: The
`above minute order has been distributed to counsel by the Judicial Executive Assistant, via
`electronic service, facsimile and/or mail. jmc 1/30/2020;
`
`CANCELED Motion for Leave (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated - Previously Decided
`Plaintiff's Motion for Leave to Amend Complaint to Add Additional Parties
`
`Status Check: Trial Readiness (8:30 AM) (Judicial Officer: Johnson, Susan)
`Matter Heard;
`Journal Entry Details:
`Telephonic appearances by counsel excluding Mr. Ferran. Court advised counsel of their
`place on the trial stack. Mr. Ellison stated that he was granted leave to amend the trial and
`that he served the new party. Colloquy regarding extending discovery. Court advised parties
`that once the new party is involved they can submit a stipulation to extend the discovery. Mr.
`Weidner stated that parties would get together and do a revised discovery plan. Mr. Ferran
`stated that his client's business owner passed away and left no assets. Court directed counsel
`to appear for the Calendar Call and if a stipulation is submitted to the Court, the dates would
`be moved accordingly. ;
`
`Motion to Dismiss (8:30 AM) (Judicial Officer: Johnson, Susan)
`Reliant Title USA, LLC's Motion to Dismiss and Memorandum of Points and Authorities
`Granted With Prejudice;
`Journal Entry Details:
`Counsel appearing remotely via Bluejeans. Argument by counsel. COURT ORDERED,
`MOTION GRANTED WITH PREJUDICE and directed Mr. Kenyon and Mr. Weidner to
`prepare the order forwarding it to Mr. Christopherson to approve as to form and content.
`CLERK'S NOTE: Minute order corrected to reflect Motion granted WITH prejudice. jmc
`
`PAGE 10 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`05/11/2020
`
`05/26/2020
`
`05/26/2020
`
`06/11/2020
`
`06/17/2020
`
`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`5/4/20;
`
`Minute Order (3:00 AM) (Judicial Officer: Johnson, Susan)
`Minute Order - No Hearing Held;
`Journal Entry Details:
`Having examined Defendant Americana LLC's Motion for More Definite Statement filed April
`2, 2020, as well as the Opposition thereto filed May 4, 2020, and found good cause therefore,
`COURT ORDERS Defendant Americana LLC's Motion for More Definite Statement filed April
`2, 2020 is GRANTED. Plaintiff may amend his Second Amended Complaint to include the
`correct name of Defendant Americana LLC, and to include the address of the property in
`question as shown within the Exhibit attached to his Opposition and Counter-Motion filed May
`4, 2020. Counsel is to prepare and submit a proposed Order to the Court within fourteen (14)
`days of this Minute Order or no later than Tuesday, May 26, 2020 pursuant to EDCR 7.21.
`The hearing scheduled to hear this matter, Tuesday, May 26, 2020 at 8:30 a.m. is VACATED.
`CLERK'S NOTE: This Minute Order was electronically served by Courtroom Clerk, Jill
`Chambers, to all registered parties for Odyssey File & Serve. jmc 5/11/20;
`
`CANCELED Motion for More Definite Statement (8:30 AM) (Judicial Officer: Johnson,
`Susan)
`Vacated - Previously Decided
`Defendant Americana LLC dba Berkshire Hathaway HomeServices Nevada Properties'
`Motion For More Definite Statement
`05/05/2020
`Continued to 05/26/2020 - Stipulation and Order - Ghiai-Chamlou, Yves;
`Americana LLC
`
`CANCELED Opposition and Countermotion (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated - Previously Decided
`Plaintiff's Opposition to Defendant Americana LLC dba Berkshire Hathaway Homeservices
`Nevada Properties Motion for More Definite Statement and Motion for Leave to Amend the
`Compla
`
`Motion For Reconsideration (9:00 AM) (Judicial Officer: Johnson, Susan)
`Plaintiff's Motion for Reconsideration of Order Granting Defendant Reliant Title USA, LLC's
`Motion to Dismiss Plaintiff's Second Amended Complaint with Prejudice and/or Motion for
`NRCP Rule 59 or 60 Relief from Order
`Denied;
`Journal Entry Details:
`Counsel appearing remotely via Bluejeans. Argument by counsel. Court advised counsel that a
`review of the Second Amended Complaint and the previous motions was done by the Court and
`found that the decision previously made was correct. COURT ORDERED, MOTION DENIED
`and directed Mr. Kenyon or Mr. Weidner to prepare the order and circulate to counsel to
`approve as to form and content. ;
`
`Pretrial/Calendar Call (8:30 AM) (Judicial Officer: Johnson, Susan)
`MINUTES
`Matter Heard;
`Journal Entry Details:
`Counsel appearing remotely via Bluejeans. Court advised counsel that the current trial setting
`would need to be moved to September. Mr. Christopherson stated that Mr. Welsh would be
`filing a Motion to Dismiss, adding a new defendant and parties would need additional time for
`discovery. COURT ORDERED, TRIAL RESET and advised that it would review the new
`discovery plan. 8/26/20 8:30 AM PRETRIAL/CALENDAR CALL 9/8/20 1:00 PM JURY
`TRIAL;
`SCHEDULED HEARINGS
`Pretrial/Calendar Call (08/26/2020 at 8:30 AM) (Judicial Officer: Johnson, Susan)
`CANCELED Jury Trial (09/08/2020 at 1:00 PM) (Judicial Officer: Johnson, Susan)
`Vacated
`
`06/29/2020
`
`CANCELED Jury Trial (8:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated
`
`PAGE 11 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`07/14/2020
`
`08/26/2020
`
`Motion to Dismiss (8:30 AM) (Judicial Officer: Johnson, Susan)
`Defendant Americana LLC's Motion to Dismiss as to Plaintiff's Third Amended Complaint
`Granted in Part;
`Journal Entry Details:
`Counsel appearing telephonically. Argument by counsel. Court reviewed the causes of action
`listed in the third Amended Complaint. COURT ORDERED, MOTION GRANTED IN PART,
`DENIED IN PART adding that the Amended Complaint cannot include the 3rd, 5th, 7th, 8th or
`9th causes of action. COURT FURTHER GRANTED Deft's Motion with respect to the Second
`Amended Complaint and will allow the amendment to only have the one cause of action
`against Berkshire Hathaway resulting in a Third Amended Complaint. Mr. Welsh to prepare
`the order.;
`
`Pretrial/Calendar Call (8:30 AM) (Judicial Officer: Johnson, Susan)
`MINUTES
`Matter Heard;
`Journal Entry Details:
`Counsel appearing remotely via Bluejeans. Mr. Kenyon stated that his client was dismissed out
`of the action and was only present to observe. Court advised that Jury Trials were not yet
`being heard and the trial would need to be reset. Mr. Christopherson stated that parties were
`working on a resolution. COURT ORDERED, JURY TRIAL CONTINUED and clarified there
`would be no further discovery allowed. 12/23/20 8:30 AM PRETRIAL/CALENDAR CALL
`1/4/21 8:30 AM JURY TRIAL;
`SCHEDULED HEARINGS
`Pretrial/Calendar Call (12/23/2020 at 8:30 AM) (Judicial Officer: Johnson, Susan)
`CANCELED Jury Trial - FIRM (02/03/2021 at 9:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated
`
`09/08/2020
`
`CANCELED Jury Trial (1:00 PM) (Judicial Officer: Johnson, Susan)
`Vacated
`
`12/23/2020
`
`Pretrial/Calendar Call (8:30 AM) (Judicial Officer: Johnson, Susan)
`Matter Heard;
`Journal Entry Details:
`Court noted this was #1 on the stack, but given the Governor's pause, trial could not proceed
`until March 15. Mr. Christopherson advised the case was resolved with all of the Defendants
`and they had to file an amended complaint to finalize client security funds. Upon Court's
`inquiry, Mr. Christopherson advised the amended complaint was necessary to make claim on
`the security funds. Court directed Mr. Christopherson to complete that as soon as possible.
`Counsel anticipated 2 days to try. COURT ORDERED, jury trial RESCHEDULED and SET
`on a firm setting. 02/03/2021 - 9:30 AM - JURY TRIAL (FIRM);
`
`02/03/2021
`
`DATE
`
`CANCELED Jury Trial - FIRM (9:30 AM) (Judicial Officer: Johnson, Susan)
`Vacated
`
`FINANCIAL INFORMATION
`
`Defendant Americana LLC
`Total Charges
`Total Payments and Credits
`Balance Due as of 10/11/2021
`
`Defendant Horizon Realty Group LLC
`Total Charges
`Total Payments and Credits
`Balance Due as of 10/11/2021
`
`Defendant Reliant Title USA LLC
`Total Charges
`Total Payments and Credits
`Balance Due as of 10/11/2021
`
`223.00
`223.00
`0.00
`
`223.00
`223.00
`0.00
`
`223.00
`223.00
`0.00
`
`PAGE 12 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`EIGHTH JUDICIAL DISTRICT COURT
`CASE SUMMARY
`CASE NO. A-18-777196-C
`
`Plaintiff Ghiai-Chamlou, Yves
`Total Charges
`Total Payments and Credits
`Balance Due as of 10/11/2021
`
`294.00
`294.00
`0.00
`
`PAGE 13 OF 13
`
`Printed on 10/11/2021 at 10:12 AM
`
`

`

`A-18-777196-C
`
`Department 22
`
`Case Number: A-18-777196-C
`
`

`

`Electronically Filed
`2/13/2020 7:36 PM
`Steven D. Grierson
`CLERK OF THE COURT
`
`Case Number: A-18-777196-C
`
`

`

`2) The matter scheduled to be heard Tuesday, February 18, 2020 at 8:30 a.m. is VACATE
`
`pursuant to EDCR2.23.
`
`Ath
`
`DATEDthis_!
`
`“day of February, 2020.
`
` A-\WG~ TTT A