Electronically Filed
`10/22/2021 7:13 PM
`Steven D. Grierson
`CLERK OF THE COURT
`
`Electronically Filed
`Oct 22 2021 07:17 p.m.
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`Docket 83635 Document 2021-30620
`Case Number: A-18-777196-C
`
`
`10/22/2021 7:13 PM
`Steven D. Grierson
`CLERK OF THE COURT
`
`Electronically Filed
`Oct 22 2021 07:17 p.m.
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`Docket 83635 Document 2021-30620
`Case Number: A-18-777196-C
`
`
`
`respondent(if the name of respondent’s counsel is unknown, indicate as much andprovide the name
`
`and address of respondent’s trial counsel: RELIENT TITLE USA, LLC,and are represented by JAY
`
`KENYON,ESQ., of the law firm of YAN KENYON, 7881 W. Charleston Blvd., Suite 165, Las
`
`Vegas, Nevada 89117, Telephone: (702) 888-0000 and J. DANIEL WEIDNER,ESQ., pro hacvice,
`
`KOLEYJESSEN,P.C., L.L.O., 1125 South 103Street, Ste. 800, Omaha, NE 68124, (402)390-9500—
`
`Appellant’s counsel believes the sameattorneyswill represent respondent on appeal.
`
`5. Indicate whether any attorney identified above in response to questions 3 or4 is not
`
`licensed to practice law in Nevadaand,if so, whetherthedistrict court grantedthat attorney permission
`
`to appear under SCR 42 (attach a copyof anydistrict court order granting such permission): As noted,
`
`J. DANIEL WEIDNER,ESQ., pro hac vice, KOLEY JESSEN,P.C., L.L.O., 1125 South 103 Street,
`
`Ste. 800, Omaha, NE 68124, (402)390-9500. (See attached)
`
`6.
`
`Indicate whether appellant was represented by appointedorretained counsel in the
`
`district court: Represented by retained counsel.
`
`7.
`
`Indicate whether appellantis represented by appointedor retained counsel on appeal:
`
`Represented by retained counsel
`
`8. Indicate whether appellant was granted leave to proceed in forma pauperis and the date
`
`of entry ofthe district court order granting appellant permission: Appellantdid not request to proceed
`
`in forma pauperis andthereforethere is no order.
`
`9,
`
`Indicate the date the proceeding commencedindistrict court: The Complaint was
`
`filed on July5, 2018.
`
`10.
`
`Provide a brief description of the nature of the Action andresult in the district court,
`
`including the type ofjudgment or order being appealed andtherelief granted bythedistrict court:
`
`Respondent, Reliant Title, who shared office space with Defendant, Horizon,failed to protect the
`
`
`
`no contractual duty owed. Co-Defendant, Horizon and Berkshire settled and stipulated to judgement.
`
`Motion to Dismiss Minutesfiled January 10, 2019; Order for Motion for Leave to Amend Complaint
`
`entered February 14, 2020; Order for Motion to Dismiss Second Amended Complaintentered May 1,
`
`2020; Order for Motion for Reconsideration entered June 19, 2020.
`
`11.
`
`Indicate whetherthe case waspreviously the subject of an appealto ororiginal writ
`
`proceeding in the Supreme Court and,ifso, the caption and Supreme Court docket numberofthe prior
`
`proceeding: There was no prior appealfiled in Supreme Court.
`
`12.
`
`Indicate whetherthis appeal involves child custodyorvisitation: This case does not
`
`involve child custody orvisitation.
`
`13.
`
` I£this is a civil case, indicate whether this involvesthe possibility of settlement:
`
`Settlement is worth pursuing.
`
`Dated this 22day of October, 2021.
`
`/s/ Leo P. Flangas
`FLANGASCIVIL LAW FIRM,LTD.
`LEO P. FLANGAS, ESQ
`Nevada Bar No. 5637
`600 S. 3"Street
`Las Vegas, NV 89101
`Phone: (702) 384-1990
`E-mail: leo@flangaslawfirm.com
`Attorneys for Petitioners
`
`
`
`CERTIFICATE OF ELECTRONIC SERVICE
`
`[hereby certify thaton this 22
`
`day of October 2021, service ofthe foregoing document
`
`was made uponeachofthe following personsvia the Odyssey E-Filing System pursuant to NRCP
`
`5(b)(2)(D) and EDCR8.05:
`
`jay@yan-kenyon.com
`Jay Kenyon
`kelsey@yan-kenyon.com
`Kelsey Priest
`daniel.weidner@koleyjessen.com
`Daniel Weidner
`dan.weidner@koleyjessen.com
`J. Daniel Weidner
`tina@yan-kenyon.com
`Tina Yan
`brent@mynevadalawoffice.com
`Brent Ellison
`Leventhalandassociates@gmail.com
`Todd Leventhal
`erick.ferran@hitzkelaw.com
`Erick Ferran
`Melissa Isabel Sandoval=melissa@mynevadalawoffice.com
`Linda D'Agostino
`lindad@bhhsnv.com
`Elizabeth Ocampo
`elizabetho@bhhsnv.com
`Darren J. Welsh, Esq.
`darrenw@bhhsnv.com
`Christian Balducci
`cbalducci@maclaw.com
`
`/s/ Natasha Smith
`An employee of FLANGAS LAW FIRM,LTD.
`
`22
`
`
`
`||}ORDR
`
`ay Kenyon, NV Bar No. 2367
`Yan Kenyon
`7881 W. Charleston Blvd. Suite 165
`Las Vegas, NV 89117
`41} Phone: 702.888.0000
`Fax: 702.888.0011
`ja
`an-kenyon.com
`
`Electronically Filed
`12/13/2018 1:03 PM
`Steven D. Grierson
`CLERK OF THE COU
`
`( hc. A.
`
`
`
`. Daniel Weidner, admittedpro hac vice
`71|(Bar No. 23738 NE)
`KoleyJessen, P.C., L.L.O.
`1125 South 103rd Street, Suite 800
`9||Omaha, NE 68124
`(402) 390-9500
`10)|(402) 390-9005 (facsimile)
`1 Dan.weidner@koleyjessen.com
`
`12||Attorneysfor Defendant RELIANT TITLE USA, LLC
`
`DISTRICT COURT
`
`CLARK COUNTY, NEVADA
`
`YVES GHIAI-CHAMLOU,
`
`Plaintiff,
`
`
`
`18]1}vs. Case No.: A-18-777196-C
`
`Dept. No.: 22
`
`RELIANT TITLE USA, LLC,
`20|| VERONICA MARTINEX, HORIZON
`40
`REALTY GROUP, LLO, DOES| through|ORDER ADMITTING,PRACTICE
`211! XXX,inclusive, and ROE BUSINESS
`ENTITIES | though X,inclusive,
` Defendants.
`;
`“Nts
`«ol
`Wei
`|
`J. Daniel Weidner, Esq. havingfiled his Motion to Associate Counsel under
`saucieston Bd.||Nevada Supreme Court Rule 42, together with a Verified Application for Association of
`
`Counsel, a Certificate of Good Standingfor the states of Nebraska and Iowa,and the
`
`
`
`State Bar of Nevada Statement; said application having been noticed, no objections having
`
`been made, and the Court being fully apprised in the premises, and good cause appearing,
`garsuank 40 Eck 2-20Ce)
`IT HER HEREBY ORDERED,thatsaid application is hereby grantedandJ.
`
`Daniel Weidner, Esq.is hereby admitted to practice in the aboveentitled Courtfor the
`
`purposes of the aboveentitled matter only.
`
`th
`Dated this_ /O“fay of
`
`Submitted by:
`
`é
`
`
`Counselfor Defendant Reliant Title USA, LLC
`
`6 7 8 9
`
`10
`
`IL
`
`12
`
`13
`
`14
`
`15
`
`16
`
`{7
`
`18
`
`19
`
`20
`
`21
`
`22
`
`2B
`
`U7 Yan *
`Kenyon
`25
`
`26
`
`27
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
