Case No.: A-22-852032-C
Dept.: 8
Filed: May 2, 2022
District Court
Clark County, Nevada
ANDREA COLLIER, Plaintiff, v. PENNIE MOSSETT-PUHEK, individually; ANTHEM HIGHLANDS COMMUNITY ASSOCIATION, a Nevada Non-Profit Corporation; CARMEN EASSA, an individual; K.G.D.O.HOLDING COMPANY, LLC d/b/a TERRA WEST MANAGEMENT SERVICE
FIRST CAUSE OF ACTION
(For Violation of Nevada Law and Nevada Statutes Against All Defendants)
SECOND CAUSE OF ACTION
(Breach of Contract/Governing Documents/ Breach of Real Covenant/Chapter 116 Against Anthem)
THIRD CLAIM FOR RELIEF
(Breach of Covenant of Good Faith and Fair Dealing (In Tort And Contract) - Against
Defendants)
FOURTH CLAIM FOR RELIEF
(Breach of Fiduciary Duty - Against Defendants)
FIFTH CLAIM FOR RELIEF
(Conspiracy - Against Defendants)
SIXTH CLAIM FOR RELIEF
(Negligence/ Negligent Supervision Against Defendants)
SEVENTH CLAIM FOR RELIEF
(Declaratory Relief Against All Defendants)
EIGHTH CLAIM FOR RELIEF
(Slander of Title Against All Defendants)
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“I love getting these” Puhek regarding email from Plaintiffs lawyer, email dated 4/12/21, Ex 28, pg 877
“I love when they get attorneys involved. Makes me happy because they don't know shit about NRS 116” Puhek about Plaintiffs lawyer, email on 4/12/21, Ex 28, pg 876
“I can't send these things to Ted (HOA lawyer) because it literally makes me happy to put them in their place.” Puhek email on 4/12/21, Ex 28, pg 876
“I will drag this out and make her spend a crap load of money if she wants to play this game.” Puhek about Plaintiffs use of a lawyer, email on 4/15/21, Exhibit 28, pg 874