Foundational Record
Hung v. Chen
All facts below are judicially confirmed in the Decree of Divorce entered August 25, 2025, by Judge Mari D. Parladé, Eighth Judicial District Court, Family Division, Department A, Clark County, Nevada. 93 Findings of Fact. Clear and convincing evidence standard.
Portfolio Gross Value
$1,967,864
Five community real properties
Net Community Equity
$1,460,932
After mortgages
Monthly Ongoing Harm
$7,400
$3,400 mortgages + $4,000+ withheld rent
Offshore Transfer
$189,000
JPI violation — June/July 2024
Marriage Duration
11 Years
Feb 6, 2014 — Aug 25, 2025
Next Court Date
Jul 27, 2026
8:45 AM — Dept. A
👤 The Parties
| Party | Name | Role | Status | Details |
|---|---|---|---|---|
| Plaintiff | Dr. Chun Kar Hung, M.D. | Prevailing Party | Prevailed at Trial | Age 83, VA physician, Missouri. Independent contractor. ~$16,000/month net income. Hearing and visual impairments. Credible on all material issues per court. |
| Defendant | Sherry Xue Ling Chen (a/k/a Sherry Filos) |
Appellant | Appeal Pending | Age 61, unemployed 11+ years. Mandarin interpreter required at trial. Testimony found "inconsistent, vague, evasive and lacking in credibility" on virtually every issue. Resides at 80 Newton Ridge Way. |
🏠 Five Community Properties — All Currently in Xue Ling Chen Living Trust
| Address | Value | Mortgage | Net Equity | Dr. Hung's 50% | Status |
|---|---|---|---|---|---|
| 80 Newton Ridge Way, LV 89183 | $628,164 | ($333,453) | $294,711 | $147,356 | Chen Residence |
| 5675 Leaning Oak Ave, LV 89118 | $367,500 | ($173,479) | $194,021 | $97,011 | Rental |
| 5125 W. Reno Ave #1055, LV 89118 | $290,500 | $0 | $290,500 | $145,250 | Unencumbered |
| 4838 Ranch Estates Ct, LV 89139 | $367,300 | $0 | $367,300 | $183,650 | Unencumbered |
| 5125 W. Reno Ave #1104, LV 89118 | $314,400 | $0 | $314,400 | $157,200 | Unencumbered |
| TOTALS | $1,967,864 | ($506,932) | $1,460,932 | $730,466 |
Approved Allocation Plan (March 6, 2026): Chen receives Newton Ridge, Leaning Oak, Reno #1055. Dr. Hung receives Ranch Estates + Reno #1104. Equalization payment of $48,766 waived by Dr. Hung.
⚖ Critical Judicial Findings — Decree of Divorce
| Finding # | Subject | Finding |
|---|---|---|
| FF 6 | Dr. Hung's Credibility | "Detailed, clear, concise testimony that was forthcoming and credible." Court credits all material testimony. |
| FF 9 | Chen's Credibility | Testimony "inconsistent, vague, evasive and lacking in credibility." Court finds against Chen on virtually every issue. |
| FF 14 | Legal Separation Purpose | Parties "entered a legal separation to shield their property from being recovered by potentially meritorious plaintiffs." Mutual malpractice protection strategy. |
| FF 26 | Property Titling | "In effort to further shield their newly purchased property from potential litigation, the married couple's properties were all titled in Ms. Chen's name." |
| FF 35 | Funding Source | "Nearly all the money used for the couple's five real estate investments originated from Dr. Hung's income." |
| FF 46 | Transfers Not Gifts | Transfers to Chen were "not charity nor gifts" but "financial entanglements of a Husband and Wife." |
| FF 65 | Perjury Predicate | Saving $800K on $168K income was "mathematically impossible." Court explicitly uses this term. |
| FF 70–73 | $189K Transfer | Chen transferred $189,000 offshore. Two explanations given — both found "not plausible." Funds originated from Dr. Hung per FF 71. |
| FF 74–75 | Trust Transfer | "Unilaterally transferred all the couple's properties into her own living trust." Dr. Hung "shocked." Transfer "was what led Dr. Hung to immediately file for divorce." |
| FF 78 | Extortion Finding | "Kill herself" threat found to be "a manipulative ploy to extort more money from her faithful, loyal, hard-working husband." Not jest. |
| COL | NRS 123.230(6) | Court finds Chen violated NRS 123.230(6) by "conveying the parties' community real estate portfolio into her separate trust." Judicial finding of unlawful conduct. |
| COL | JPI Violation | Chen "willfully and knowingly violated Section 1 of the Court's Joint Preliminary Injunction" via $189K offshore transfer. Uses exact criminal mens rea language. |
📅 Case Timeline
February 6, 2014
Marriage
Dr. Hung and Sherry Chen marry.
February 5, 2016
California Legal Separation
Filed in LA County (BD628403). Purpose: asset protection from malpractice. Both parties lived together as married couple throughout. Neither party aware property would legally separate by operation of CA law.
2018 — 2020
Five Properties Purchased
$800,000+ in cash/down payments from Dr. Hung's income. All titled in Chen's name to further shield from potential litigation. Total purchase over three years.
July 28, 2021
Transmutation Agreement
Both parties signed agreement seeking to vacate the 2016 Legal Separation and return all property to community status. California court rejected filing for unknown reasons, but court found agreement binding as private contract under NRS 123.070.
January 2024
⚠ Trust Transfer — The Central Act
Chen unilaterally transferred all five community properties into the Xue Ling Chen Living Trust — naming herself sole creator, trustee, and beneficiary. Dr. Hung had zero knowledge. Trust attorney prepared documents. False Declarations of Value filed with Clark County Recorder certifying $0 value and sole ownership.
March 2024
Discovery & Divorce Filing
Dr. Hung discovers trust transfer accidentally during tax preparation. Files Complaint for Divorce April 18, 2024. JPI entered same day. Six lis pendens filed April 23-24, 2024.
June — July 2024
⚠ $189,000 Offshore Transfer — JPI Violation
Chen transfers $189,000 to Chinese bank account in violation of the JPI. Court finds "willful and knowing" violation. Two explanations given — stock losses and scammer — both found implausible. Money unrecovered.
May 2, 9, 2025
Two-Day Evidentiary Trial
Before Judge Parladé. Dr. Hung credible on all issues. Chen's testimony found lacking in credibility throughout. Chen required Mandarin interpreter.
August 25, 2025
Decree of Divorce Entered
93 Findings of Fact. 50/50 property division ordered. Attorney fees awarded against Chen. No alimony to either party. Court retains jurisdiction.
March 31, 2026
Gersten Files Documents Without Being Counsel of Record
Docket #67 never served on Dr. Hung. No substitution of counsel, no court order, no consent from Lin & Page.
April 8, 2026
Chen Files NV Supreme Court Opening Brief — Gersten Notice of Appearance
Chen's 100+ page brief violates NRAP 32's 30-page limit. Gersten also files Notice of Appearance — cannot retroactively authorize March 31 filings.
May 7, 2026
⚠ Dr. Hung Files Motion to Strike Gersten's Unauthorized March 31 Filings
Motion to Strike filed at trial court — Gersten appeared without authorization. Affects Docket #67 validity.
May 9, 2026
Dr. Hung's Respondent's Answering Brief Due at NV Supreme Court
22 pages pro se. 4 independent grounds: functional separation, rule of situs, transmutation, community property presumption.
September 3, 2025
⚠ Leavitt Error #1
Leavitt advises Dr. Hung that implementation requires Chen's voluntary signature first before NRCP 70 can be invoked. Incorrect. Causes months of delay.
September 12, 2025
Chen Files Appeal — No Bond Posted
NV Supreme Court Case No. 91296. No supersedeas bond. No stay. Decree remains fully enforceable.
September 22, 2025
Brunzell Memorandum Filed (Timely)
Leavitt timely files attorney fees memorandum. Chen objects October 3. Fees ruling still pending.
November 12, 2025
⚠ Chen Threatens Foreclosure
WeChat message: "我从现在开始不付房贷了，等银行把房子收走" — "I will not pay the mortgage from now on, waiting for the bank to take the house." Dr. Hung begins covering mortgages out of pocket.
December 2, 2025
⚠ Leavitt Error #2
Leavitt advises appeal "divested" trial court of jurisdiction. Wrong under NRAP 8(a)(1). No bond = no stay. Causes additional months of inaction.
December 19, 2025
Chen's Lawyers Both Withdraw Simultaneously
Michael Lin and Fred Page file simultaneous withdrawal notices — one day after Dr. Hung emailed them requesting allocation. False claim "matter reached final determination."
March 9, 2026
NV Supreme Court Denies Summary Affirmance
Appeal will proceed on merits. Chen's opening brief due April 8, 2026 (100+ pages — NRAP 32 violation — 30 page limit). Motion to Strike required.
March 13, 2026
Pro Se Enforcement Motion Filed
Dr. Hung files comprehensive enforcement motion. Clerk's nonconforming notice issued March 16. Corrected exhibits filed March 25. Hearing set July 27, 2026.
March 31, 2026
⚠ Chen Files Opposition + Countermotion for Stay
Chen opposes enforcement motion and countermoves to stay all trial court proceedings pending appeal. This is the same wrong argument Leavitt told Dr. Hung was already in effect.
March 31, 2026
Gersten Files Without Authority
Joseph Gersten files documents in trial court WITHOUT being counsel of record. No substitution filed, docket silent on any change of counsel. Docket #67 never served on Dr. Hung.
April 8, 2026
Supreme Court Appeal Opens
Chen files 100+ page opening brief in NV Supreme Court (Case 91296). Gersten files Notice of Appearance — too late to authorize March 31 trial court filings.
May 7, 2026
Motion to Strike — Gersten's Filings
Dr. Hung files Motion to Strike Gersten's unauthorized March 31 filings and Reply in Support. Seeks to void all Gersten trial-level filings.
May 9, 2026
Answering Brief Due — NV Supreme Court
Dr. Hung's Respondent's Answering Brief due. 22 pages pro se with 4 independent grounds for affirmance: functional separation, rule of situs, transmutation, community property presumption.
July 27, 2026
Enforcement Hearing — Judge Parladé
8:45 AM, Dept. A. All relief pending before this hearing.
Strategic Overview
Actions Against Chen
All offensive and defensive actions organized by status. Chen's primary strategy is delay through appeal while retaining control of all five properties and blocking property division implementation.
⚖ NV Supreme Court Appeal — Case 91296
| Event | Status | Date/Details |
|---|---|---|
| Chen's Opening Brief | Filed | April 8, 2026 — 100+ pages |
| Karl's Answering Brief | Drafted | Filing May 9 — 22 pages pro se, 4 independent grounds |
| Motion to Strike (Trial Court) | Filed | May 7, 2026 — Gersten unauthorized appearance |
| Chen's Reply Brief | Next | Expected — TBD, due 30 days after answering brief |
| Oral Argument | TBD | Date to be scheduled |
4 key appellate arguments: (1) Functional separation of assets, (2) Rule of situs controls Nevada property, (3) Transmutation of separate funds, (4) Community property presumption under Nevada law.
⚔ Offensive Actions — Completed
Done
Divorce Trial Won — August 25, 2025
93 findings of fact. 50/50 property division ordered. Chen found not credible on every material issue. Attorney fees awarded against Chen. No alimony to either party.
Done
Motion for Summary Affirmance — NV Supreme Court
Filed November 4, 2025. Denied March 9, 2026 — appeal proceeds on merits. Established Dr. Hung is actively defending.
Done
Enforcement Motion Filed — March 13, 2026
Comprehensive pro se motion: appointment as administrator, NRCP 70 relief, allocation plan approval, third-party communications authority, property access order. Hearing July 27, 2026.
Done
AcclaimWeb Deed Search — Initiated
January 2024 trust transfer deed Instrument 202401290001132 identified. Four remaining deeds being pulled. Trust attorney identification pending.
⚔ Offensive Actions — Urgent / Immediate
Drafted
File Answering Brief at NV Supreme Court — Case 91296
22 pages. Ready to file May 9, 2026. Pro se filing with 4 independent appellate grounds: functional separation, rule of situs, transmutation, community property presumption.
✓ READY — Filing deadline May 9, 2026
Urgent
Retain Nevada Appellate Counsel
Dr. Hung is currently pro se at the NV Supreme Court. Chen has Gersten (Gersten Law Firm). Court has flagged Dr. Hung's pro se filings for compliance issues. Brief prepared and ready for filing May 9 regardless of counsel status.
⚠ DEADLINE: This week
Urgent
Pull All Five Trust Transfer Deeds — Clark County Recorder
AcclaimWeb: recorderecomm.clarkcountynv.gov/AcclaimWeb. Find all five January 2024 transfer instrument numbers. Order certified copies at $4/deed. Review for: marital status language, Dr. Hung's signature presence, preparer identification, notary identification. This unlocks the trust attorney claim.
⚠ DEADLINE: This week
Soon
DA Criminal Referral — False Declaration of Value
File with Clark County DA Economic Crimes Unit. Five signed false Declarations of Value certifying Chen's sole ownership of community property under penalty of perjury. NRS 197.170. Can be filed by family member as third party. Does not require attorney. Attach Decree pages FF 74, 75, COL NRS 123.230(6) finding.
⚠ DEADLINE: Within 2 weeks of receiving certified deeds
Soon
FinCEN Tipline Referral — $189,000 Offshore Transfer
File at fincen.gov/financial-institution/fincen-tipline. Report $189K transfer to Chinese bank account during pendency of JPI. Include Decree FF 70-73 and JPI violation finding. Triggers FinCEN investigation with subpoena power reaching Chinese banks via MLAT.
Can be filed now — no deeds required
Soon
First Periodic Status Report — Trial Court
March 13 proposed order requires reports every 30 days. Even though the order is not yet signed, proactively filing a status report demonstrates good faith and builds the contemporaneous record for July 27.
⚔ Offensive Actions — Medium Term
Planned
Civil Complaint Against Trust Attorney
Full complaint framework drafted. Five causes of action: professional negligence, aiding and abetting, civil conspiracy, negligent misrepresentation, unjust enrichment. Potential damages: entire divorce litigation cost. Requires retaining Nevada civil litigation counsel and confirming trust attorney identity from deeds.
Planned
OCC / CFPB Bank Complaint
File against East West Bank / Bank of America for processing $189K offshore wire from account Dr. Hung funded with paychecks without dual authorization. Regulatory complaint triggers investigation independent of civil discovery. Confirm wire source account from Exhibit 6 first.
Planned
IRS Criminal Investigation Referral — FBAR
Chen testified to tens of thousands of dollars in Chinese accounts (FF 55). US persons with foreign accounts exceeding $10K must file FBAR annually. Willful failure: up to $250K fine and 5 years imprisonment per count. Plus potential tax evasion on unreported rental income.
Planned
NRS 41.1395 Elder Financial Exploitation Suit
Standalone civil action. Dr. Hung is 83 (vulnerable person under the statute). Double damages + mandatory attorney fees. Predicate: trust transfer, $189K offshore theft, ongoing extortion pattern, "kill herself" threat found to be manipulative extortion by the court. Must be separate civil complaint.
Planned
APS Referral — Adult Protective Services
Financial exploitation of an elder (age 83) is within APS jurisdiction. The documented facts — unilateral $2M property transfer, $189K offshore theft, foreclosure threats, extortion — constitute elder financial abuse reportable to Nevada APS.
Planned
Crime-Fraud Exception Motion — Trust Attorney File
File in enforcement proceeding before Judge Parladé (she retained jurisdiction). Predicate: NRS 123.230(6) judicial finding. Compels in camera review and production of trust attorney's complete file including all communications with Chen. Will reveal what Chen told the attorney about Dr. Hung's interest.
🛡 Defensive Actions — Defeating Chen's Stay Countermotion
Chen filed a Countermotion to Stay District-Court Proceedings Pending Appeal on March 31, 2026. This is the single most important defensive action before July 27. The legal argument for defeating it is airtight.
Primary Argument
NRAP 8(a)(1) — No Bond, No Stay
The filing of a notice of appeal does not automatically stay enforcement of a judgment in Nevada. A stay pending appeal requires a separate application AND the posting of a supersedeas bond. Chen posted no bond. She sought no stay order. The Decree has been fully enforceable since August 25, 2025. This is not a close question — it is black letter appellate procedure.
Secondary Argument
Express Retention of Jurisdiction in the Decree
The Decree itself states: "IT IS HEREBY ORDERED, ADJUDGED and DECREED that the Court retains jurisdiction over the parties and the subject matter hereof." Chen's own attorney prepared a position that directly contradicts the Decree's plain text. The trial court never lost jurisdiction because the Decree expressly preserved it.
Tertiary Argument
Ongoing Waste — Equity Requires Enforcement
$7,400/month in ongoing harm to the community estate. Chen threatened foreclosure in writing. Chen has been withholding Dr. Hung's rental income since the Decree. The equities overwhelmingly favor enforcement regardless of the appeal. Even if there were a colorable stay argument (there is not), the trial court has discretion to enforce to prevent ongoing waste.
Note
Chen Is Making Leavitt's Mistake in Court
The exact argument Chen's attorneys are now advancing in court is the same wrong argument Leavitt gave Dr. Hung in his December 2 email — that the appeal automatically divested the trial court of jurisdiction. Leavitt counseled his own client into his adversary's legal theory. This strengthens the Leavitt malpractice claim.
🛡 Defensive Actions — Protecting the Properties
Active
Continue Mortgage Payments to Prevent Foreclosure
Dr. Hung is paying approximately $3,400/month on mortgages for Newton Ridge and Leaning Oak to prevent foreclosure. This must continue until the properties are formally conveyed pursuant to the allocation plan. Document every payment for reimbursement or offset claims.
Soon
Post-Decree Property Protection Instruments
Lis pendens expired upon entry of the Decree. Five properties remain in Chen's exclusive control and trust. Consider whether post-decree notice instruments should be recorded against the five properties to protect against further unilateral transfers pending the July 27 hearing and implementation.
Planned
Demand Rental Income Accounting
Chen has been collecting rental income from the community properties since the Decree. That income is community property subject to equal division. Demand complete accounting of all rent collected since August 25, 2025 as part of the enforcement proceeding. Offset against any obligations Dr. Hung owes.
⚠ Appellate Vulnerabilities — What Chen Will Argue
The Nevada Supreme Court will hear Chen's appeal on the merits. These are the arguments Gersten will make and what appellate counsel must be prepared to defend.
Primary Vulnerability
Transmutation Agreement Retroactive Effect
The Decree's core property classification ruling rests on the 2021 Transmutation Agreement operating retroactively to February 2016. Chen will argue: (1) California rejected the Agreement — Nevada must give it full faith and credit. (2) The Agreement's retroactivity was inferred, not expressed. (3) California Family Code §772 created vested statutory property rights that cannot be undone retroactively by a private agreement. This is the strongest appellate argument and requires careful defense.
Secondary Vulnerability
Gift Presumption on Two Deeds
Dr. Hung executed Grant, Bargain, Sale Deeds for Newton Ridge and Unit 1055. Nevada creates a gift presumption from spouse-to-spouse conveyances (Kerley v. Kerley). The court credited Dr. Hung's testimony to overcome this presumption — but credibility findings are reviewed deferentially. Chen will argue the signed deeds are objective evidence that should outweigh testimony about subjective intent.
Tertiary Vulnerability
Full Faith and Credit vs. Private Contract
The Decree simultaneously honors the California Legal Separation under full faith and credit AND holds that the Transmutation Agreement as a private contract supersedes it. Chen will argue this is internally inconsistent — you cannot honor a judgment under full faith and credit and then allow the parties to privately nullify its property classification effects retroactively.
Civil Malpractice Action
Hung v. Leavitt
Brandon K. Leavitt, Esq., Leavitt Family Law Group. Dr. Hung's trial counsel and post-decree counsel. Two documented erroneous advisories in writing. One probable failure to serve JPI on financial institutions. Causation unusually clean — written advice, documented reliance, subsequent court filings proving advice was wrong.
Claim 1 — Confirmed
Erroneous Deed Requirement Advice — September 3, 2025
Six days after the Decree, Dr. Hung asked Leavitt to begin property division implementation. Leavitt responded that implementation required, as a mandatory first step, obtaining Chen's voluntary signature on deeds — and only then could NRCP 70 or contempt be invoked. This is incorrect. NRCP 70 does not require a prior voluntary signature attempt as a predicate. The Decree's property division was immediately enforceable. Chen's cooperation was what enforcement mechanisms exist to compel, not a prerequisite to them. Dr. Hung stood down based on this advice. No motion was filed. No NRCP 70 application was made. Three months of inaction resulted.
Evidence: Exhibit 4 — September 3, 2025 Leavitt email
Claim 2 — Confirmed
Erroneous Appeal Divestiture Advice — December 2, 2025
Leavitt emailed Dr. Hung advising that the pending appeal "divested" the Divorce Court of jurisdiction and no enforcement could proceed until the Court of Appeals returned jurisdiction. This is wrong under NRAP 8(a)(1). No supersedeas bond was posted. No stay was sought. No stay was granted. The Decree expressly retained jurisdiction. Leavitt's advice was irreconcilable with the plain text of the document he drafted. Dr. Hung stood down for an additional three months based on this advice. Ironically, the exact same wrong argument is now being made by Chen's attorneys as their affirmative countermotion — meaning Leavitt counseled his own client into his adversary's legal theory.
Evidence: Exhibit 8 — December 2, 2025 Leavitt email
Claim 3 — Probable (Requires Confirmation)
Failure to Serve JPI on Financial Institutions — April 2024
The docket shows Leavitt filed six lis pendens against the five properties within five days of the JPI — correctly protecting real property during litigation. However, no certificate of service appears in the docket showing the JPI was served on any financial institution. The JPI was emailed only to Leavitt's firm per the docket entry. Two months later — June-July 2024 — Chen transferred $189,000 offshore in violation of the JPI. A bank with actual notice of the JPI that processed that wire would be liable for the full $189,000. Without notice, the bank processed it freely. The corresponding step to lis pendens for liquid assets is serving the JPI on banks. Leavitt did one, apparently not the other. Damages: $94,500 (Dr. Hung's 50% of dissipated community funds) or potentially the full $189,000.
How to confirm: Request Leavitt's complete file under NV RPC 1.16(d). Check for any letter to East West Bank or Bank of America enclosing the JPI.
Claim 4 — Arguable
Failure to Protect Properties During Post-Decree Implementation Gap
Lis pendens protection expired upon entry of the Decree on August 25, 2025. The five properties remained titled entirely in Chen's name within a trust she solely controls. Chen had already demonstrated willingness to make unilateral transfers (January 2024) and threatened foreclosure (November 2025). A competent post-decree attorney should have immediately filed post-decree protective instruments, pursued NRCP 70 authorization, or sought a post-decree injunction to protect the properties during the implementation gap. Leavitt took none of these steps — instead giving two erroneous advisories that caused Dr. Hung to stand down entirely.
Damages: Included in delay damages — $7,400/month for 6.5 months
$ Itemized Damages — Leavitt Malpractice
| # | Item | Amount | Confidence | Notes |
|---|---|---|---|---|
| 1 | Out-of-pocket mortgage payments (6.5 months × $3,400) | $22,100 | High | Documented — Bank of America records, Exhibit 6 |
| 2 | Withheld rental income (6.5 months × $4,000+) | $26,000+ | Medium | Floor estimate — needs precise verification from rental records |
| 3 | Time value of $730,466 inaccessible equity (6.5 months @ 6%) | $23,740 | Medium | Market dependent — compare Aug 2025 vs Mar 2026 LV real estate values |
| 4 | Disgorgement of post-decree fees (Sept–Dec 2025) | TBD | Pending | Request Leavitt billing records under NV RPC 1.16(d) |
| 5 | Cost of appellate counsel now required | $15K–$40K | Estimate | Attributable to Leavitt's abandonment of appellate representation |
| 6 | Failure to serve JPI — dissipated community funds | $94,500 | Probable | Dr. Hung's 50% of $189K offshore transfer. Requires JPI service confirmation. |
Conservative Total (Before TBD Items)
Excluding disgorgement, appellate counsel, emotional distress
$181,340 — $206,340
📋 Key Evidence Checklist
| Item | Status | Action Required |
|---|---|---|
| Exhibit 4 — Leavitt email, September 3, 2025 (deed requirement error) | In Hand | None — attach to malpractice complaint |
| Exhibit 8 — Leavitt email, December 2, 2025 (jurisdiction error) | In Hand | None — attach to malpractice complaint |
| Exhibit 6 — Bank of America records (mortgage payment pattern) | In Hand | Confirm whether $189K wire came from joint account |
| JPI service records — was bank ever served? | Not Confirmed | Pull certificate of service from docket entry [3] — check if any bank listed |
| Leavitt billing records (Sept–Dec 2025) | Not Obtained | Request under NV RPC 1.16(d) immediately |
| Lis pendens confirmation — filed April 23-24, 2024 | Confirmed | Docket entries [5]-[10] — Leavitt did file these correctly |
| Brunzell memorandum — September 22, 2025 | Confirmed Filed | Docket entry [43] — Leavitt filed timely. Claim 3 of original letter correctly excluded. |
→ Next Steps — Leavitt Claim
Now
Send Malpractice Solicitation Letter to Nevada Malpractice Attorneys
Letter fully drafted incorporating all three confirmed/probable claims. Remove Robert Clapp references. Send to 3-5 Nevada legal malpractice attorneys. The causation is unusually clean — written advice, documented reliance, subsequent court filings proving advice was wrong.
Now
Confirm JPI Bank Service — Pull Docket Entry [3]
The JPI was emailed to Leavitt's firm per the docket. Check whether Leavitt sent a corresponding letter to any financial institution. Also request Leavitt's file under NV RPC 1.16(d). If no bank service letter exists, Claim 3 ($94,500) is confirmed.
Soon
Request Leavitt's Billing Records
Dr. Hung is entitled to his complete client file under NV RPC 1.16(d). Request specifically: all billing records for September through December 2025 (the post-decree period during which the two erroneous advisories were given and no enforcement action was taken).
Civil Action — Identity TBD
Hung v. [Trust Attorney]
The attorney who prepared the January 2024 trust transfer instruments transferring five community properties into the Xue Ling Chen Living Trust. Identity to be confirmed from deed preparer block on certified copies currently being pulled from Clark County Recorder. Potentially the largest single recovery in this entire case — damages measured by the entire divorce litigation cost because the trust transfer caused the divorce.
🚩 The Three Red Flags — Why the Attorney Had a Duty to Investigate
Red Flag One — Chain of Title
"Married Woman" Language + Dr. Hung's Name as Prior Grantor
Before preparing any real property transfer, a competent Nevada attorney must review the existing chain of title. That review would have revealed: (1) The existing deed for 80 Newton Ridge Way described Chen as "a married woman, as her sole and separate property" — standard Nevada deed language appearing in the public record. (2) For 5125 W. Reno Ave Unit 1055, Dr. Hung's name appears as prior grantor — he signed a deed conveying his interest to Chen. His name "Chun Kar Hung" is in the recorded chain of title. Any attorney seeing a man's name on a prior deed has an immediate obligation to ask who he is and whether he retains any current interest. The answer — Chen's husband and the person who funded all five properties — was one question away.
Red Flag Two — The Income Impossibility
$800,000 in Real Estate Purchased by an Unemployed Person
Five residential properties purchased over three years for $800,000+ in cash and down payments. Chen was unemployed throughout. She had no income source capable of funding these purchases. The court called this "mathematically impossible." A competent attorney preparing trust transfer documents had an obligation to ask where the money came from. The answer — Dr. Hung's medical income — establishes community property character regardless of whose name is on the deed. An attorney who accepted a client's claim of self-funded purchases without documentation when the math is impossible has failed below the standard of care.
Red Flag Three — The Asset Protection Purpose
Properties Titled for Malpractice Protection — Judicially Confirmed
The court found — at clear and convincing evidence standard — that the properties were titled in Chen's name specifically to protect their mutual assets from malpractice litigation against Dr. Hung's medical practice (FF 26, COL p.33). If Chen disclosed this to the attorney — even partially — the attorney knew the properties represented a mutual marital arrangement, not Chen's separate estate. Converting that arrangement into a sole-beneficiary trust without Dr. Hung's consent was not estate planning. It was conversion of a mutual asset into one spouse's separate property at the other's expense.
⚖ Five Causes of Action
First Cause — Strongest / Survives Regardless of What Attorney Knew
Professional Negligence — Duty to Non-Client
Standard of care for a Nevada real property attorney handling a $2M trust transfer for a married client in a community property state: (1) Review existing title — required. (2) Upon seeing "married woman" — investigate community property implications. (3) Ask about marital status and spousal consent. (4) Obtain Dr. Hung's signature, documented separate property proof, or refuse to proceed. (5) Ensure Declaration of Value forms accurately reflect ownership. The attorney failed every step. This claim does not require proving what the attorney knew subjectively — only what a competent attorney should have done. The "married woman" language and Dr. Hung's name on the prior deed eliminate any good faith defense based on client representations.
Damages: Full divorce litigation cost from inception — because the trust transfer caused the divorce.
Second Cause — Strong Once File Is Produced
Aiding and Abetting Breach of Fiduciary Duty
Chen owed Dr. Hung fiduciary duties as a spouse under NRS 123.230. The unilateral trust transfer breached those duties — confirmed by the court's NRS 123.230(6) finding. The attorney who prepared the instruments that effectuated the breach provided substantial assistance to it. The trust structure itself — a married person's revocable trust naming only themselves as sole beneficiary in a community property state — is anomalous and should have prompted investigation. Punitive damages available if actual knowledge of the breach's purpose is established through the attorney's file.
Damages: Same as negligence + potential punitive damages.
Third Cause — Requires Attorney File to Confirm
Civil Conspiracy — Fraudulent Conveyance (NRS 112.180)
If Chen told the attorney about Dr. Hung's community interest or the asset protection purpose, and the attorney proceeded anyway, the attorney knowingly participated in a fraudulent conveyance. The badges of fraud are all present: transfer to insider ($0 consideration), complete concealment, transfer of substantially all assets, transferor retained control. The crime-fraud exception motion compels production of the attorney's file — the file will confirm or eliminate this theory. Once confirmed, this is the highest-value claim with punitive damages available.
Damages: Full $1,460,932 community equity + punitive damages.
Fourth Cause
Negligent Misrepresentation — Declaration of Value Forms
The attorney prepared five Declaration of Value forms certifying Chen's sole ownership of community property under penalty of perjury. That information was false. Dr. Hung owned a 50% community interest in each property. The attorney prepared the forms without reasonable grounds for believing they were accurate given the red flags in the existing title. Dr. Hung was within the class of persons the Declaration of Value certification was intended to protect.
Damages: All resulting losses from the false certifications.
Fifth Cause
Unjust Enrichment — Disgorgement of Professional Fees
The attorney received professional fees from Chen for services that harmed Dr. Hung by facilitating the unlawful transfer of his community property interest. Those fees were earned through work that caused Dr. Hung's harm. It would be inequitable to allow the attorney to retain them.
Damages: Disgorgement of fees paid for the trust transfer work.
⚠ Parallel Criminal Referral — False Declaration of Value
Independent of the civil action. Targets Chen's conduct primarily; trust attorney potentially as aider and abettor in preparing the forms.
NRS 197.170 — Criminal Offense
Five Signed False Government Declarations Under Penalty of Perjury
Each of the five trust transfer deeds was accompanied by a Declaration of Value form — required by NRS 375.060 — signed by Chen certifying she was the sole owner of the properties and that the living trust exemption applied. The court found the properties were community property at the clear and convincing evidence standard. Chen owned only 50%. Her certifications of sole ownership were false. Five declarations. Five potential counts. Referral to Clark County DA Economic Crimes Unit. Can be filed by family member as third party — no attorney required, no Dr. Hung authorization required.
Clark County DA — Economic Crimes Unit
200 Lewis Avenue, Las Vegas, NV 89155
Phone: (702) 671-2500
Also file with: Nevada Dept. of Taxation — (775) 684-2000
1550 College Parkway, Suite 115, Carson City, NV 89706
200 Lewis Avenue, Las Vegas, NV 89155
Phone: (702) 671-2500
Also file with: Nevada Dept. of Taxation — (775) 684-2000
1550 College Parkway, Suite 115, Carson City, NV 89706
🔍 Investigation Checklist — Trust Attorney
| Step | Action | Status | What It Reveals |
|---|---|---|---|
| 1 | Pull all 5 trust transfer deeds from AcclaimWeb | In Progress | Marital status language, preparer ID, Dr. Hung's signature presence |
| 2 | Review grantor description on each transfer deed | Pending Deeds | Married/unmarried/omitted — determines strength of good faith defense |
| 3 | Check for Dr. Hung's signature on any transfer deed | Pending Deeds | If present and he didn't sign = forgery (NRS 205.090 felony) |
| 4 | Identify preparer from deed preparer block | Pending Deeds | Trust attorney identity — enables NV Bar search and complaint |
| 5 | Confirm attorney's NV Bar license at nvbar.org | Pending ID | Active license at time of transfer — professional standards apply |
| 6 | Check for Declaration of Value forms with each deed | Pending Deeds | Chen's signed perjury certifications — core of criminal referral |
| 7 | File crime-fraud exception motion in enforcement proceeding | Planned | Compels production of attorney's complete file — confirms conspiracy or limits to negligence |
| 8 | Retain Nevada civil litigation counsel | Planned | File civil complaint — full framework already drafted |
Complete Roster
Parties, Counsel & Agencies
Every person and institution involved in or relevant to this matter — with biographies, contact information, and their specific role in the case.
THE PLAINTIFF
CH
Chun Kar Hung, M.D.
Plaintiff / Prevailing Party / Appellant Respondent
Credible — All Issues
Dr. Hung is an 83-year-old physician employed as an independent contractor at a Veterans Affairs Medical Center in Missouri. He works a two-week-on / two-week-off schedule, flying between Las Vegas and Missouri. Despite his age he remains professionally active and productive, earning approximately $16,000 per month in disposable income. The court found he has hearing and visual impairments that required accommodation throughout trial — yet notwithstanding these challenges, Judge Parladé found his testimony "detailed, clear, concise... forthcoming and credible" on every material issue in the case.
Dr. Hung married Sherry Chen in 2014. He placed all five properties in her name during the marriage as a deliberate mutual strategy to protect their shared estate from potential malpractice claims against his medical practice — a fact judicially confirmed at the clear and convincing evidence standard. When he discovered in March 2024 that Chen had unilaterally transferred all five properties into a trust naming only herself, he was shocked and immediately filed for divorce. The trust transfer caused the divorce — not any pre-existing marital breakdown.
He prevailed at trial on every material issue. He has since been proceeding pro se in the NV Supreme Court appeal and filed his own enforcement motion on March 13, 2026 after months of inaction by prior counsel.
Dr. Hung married Sherry Chen in 2014. He placed all five properties in her name during the marriage as a deliberate mutual strategy to protect their shared estate from potential malpractice claims against his medical practice — a fact judicially confirmed at the clear and convincing evidence standard. When he discovered in March 2024 that Chen had unilaterally transferred all five properties into a trust naming only herself, he was shocked and immediately filed for divorce. The trust transfer caused the divorce — not any pre-existing marital breakdown.
He prevailed at trial on every material issue. He has since been proceeding pro se in the NV Supreme Court appeal and filed his own enforcement motion on March 13, 2026 after months of inaction by prior counsel.
Contact:
8445 Las Vegas Blvd South, Unit 1010, Las Vegas, NV 89123
Phone: (973) 495-0035
Email: drkarlhung@yahoo.com
8445 Las Vegas Blvd South, Unit 1010, Las Vegas, NV 89123
Phone: (973) 495-0035
Email: drkarlhung@yahoo.com
Role in Ongoing Proceedings: Plaintiff and enforcement movant in trial court (D-24-687267-D). Respondent in NV Supreme Court appeal (Case No. 91296). Potential plaintiff in Leavitt malpractice action and trust attorney civil suit. Primary victim in DA criminal referral and FinCEN/IRS regulatory filings.
THE DEFENDANT
SC
Sherry Xue Ling Chen
Defendant / Appellant (also known as Sherry Filos)
Not Credible — Court Finding
Sherry Xue Ling Chen, age 61, is Dr. Hung's former spouse. She has been unemployed for over 11 years despite having significant work experience — trained chef (two-year degree), certified card dealer, professional poker player, and former gift shop owner. The court found she voluntarily retired at age 50. She is in good physical health and the court determined she has every capability to return to work.
Chen required a Mandarin court interpreter throughout the trial proceedings. Her testimony was found "inconsistent, vague, evasive and lacking in credibility" on virtually every issue the court addressed. The court found she made "mathematically impossible" financial claims, gave two mutually contradictory and implausible explanations for the $189,000 offshore transfer, threatened to "kill herself" as a manipulative financial extortion tactic (the court so found), and concealed multiple foreign bank accounts from discovery.
In January 2024 she unilaterally transferred all five community properties into the Xue Ling Chen Living Trust — naming herself as sole creator, trustee, and beneficiary — without Dr. Hung's knowledge or consent. The court found this violated NRS 123.230(6) and was the proximate cause of the divorce filing. She has appealed the Decree and is represented by Joseph Gersten at the NV Supreme Court level and by Michael Lin and Jericho Remitio in the trial court enforcement proceeding.
Chen required a Mandarin court interpreter throughout the trial proceedings. Her testimony was found "inconsistent, vague, evasive and lacking in credibility" on virtually every issue the court addressed. The court found she made "mathematically impossible" financial claims, gave two mutually contradictory and implausible explanations for the $189,000 offshore transfer, threatened to "kill herself" as a manipulative financial extortion tactic (the court so found), and concealed multiple foreign bank accounts from discovery.
In January 2024 she unilaterally transferred all five community properties into the Xue Ling Chen Living Trust — naming herself as sole creator, trustee, and beneficiary — without Dr. Hung's knowledge or consent. The court found this violated NRS 123.230(6) and was the proximate cause of the divorce filing. She has appealed the Decree and is represented by Joseph Gersten at the NV Supreme Court level and by Michael Lin and Jericho Remitio in the trial court enforcement proceeding.
Last Known Address:
80 Newton Ridge Way, Las Vegas, NV 89183
Email: sherryflos990@gmail.com / sherryfilos@hotmail.com
Son (Devon Filos): devonfilos@gmail.com / devonfilos1234@hotmail.com
80 Newton Ridge Way, Las Vegas, NV 89183
Email: sherryflos990@gmail.com / sherryfilos@hotmail.com
Son (Devon Filos): devonfilos@gmail.com / devonfilos1234@hotmail.com
Ongoing Actions Against Chen: Defendant in enforcement proceeding (July 27, 2026 hearing). Appellant in NV Supreme Court. Subject of DA criminal referral (false Declarations of Value). Subject of FinCEN referral ($189K offshore transfer). Subject of potential IRS FBAR investigation. Subject of potential NRS 41.1395 elder exploitation civil action.
THE JUDICIARY
MP
Hon. Mari D. Parladé
District Judge — Family Division, Dept. A
Presiding — Both Matters
Judge Parladé is the district court judge who presided over the two-day evidentiary trial and entered the 48-page Decree of Divorce on August 25, 2025. She authored all 93 findings of fact and the comprehensive conclusions of law. She retains jurisdiction over the parties and subject matter and is scheduled to preside over the July 27, 2026 enforcement hearing. Her findings were thorough, well-supported, and strongly favor Dr. Hung on every material issue.
Eighth Judicial District Court
Family Division, Department A
200 Lewis Avenue, Las Vegas, NV 89155
Phone: (702) 671-3120
Case: D-24-687267-D
Family Division, Department A
200 Lewis Avenue, Las Vegas, NV 89155
Phone: (702) 671-3120
Case: D-24-687267-D
NS
Nevada Supreme Court
Appellate Court — Case No. 91296
Appeal Pending
The Nevada Supreme Court is hearing Chen's appeal (Case No. 91296). The court denied summary affirmance on March 9, 2026, meaning the appeal proceeds on the merits. Chen's opening brief (100+ pages, violating NRAP 32's 30-page limit) was filed approximately April 8, 2026. The Motion to Strike must be filed immediately by retained appellate counsel.
Nevada Supreme Court
201 S. Carson Street, Carson City, NV 89701
Phone: (775) 684-1600
201 S. Carson Street, Carson City, NV 89701
Phone: (775) 684-1600
CHEN'S LEGAL TEAM
JG
Joseph Z. Gersten, Esq.
Chen's Appellate Counsel — NV Supreme Court
Active Adversary
Motion to Strike Pending
Gersten filed documents on March 31, 2026 WITHOUT being counsel of record — no substitution, no court order, no consent from Lin & Page. Dr. Hung's Motion to Strike (May 7, 2026) seeks to invalidate these unauthorized filings. His April 8 Notice of Appearance cannot retroactively authorize March 31 filings. He entered the case as Chen's appellate counsel on November 14, 2025 and filed the opening brief in the NV Supreme Court appeal — reportedly exceeding 100 pages in violation of NRAP 32's 30-page limit.
The Gersten Law Firm PLLC
Nevada appellate counsel for Sherry Xue Ling Chen
NV Supreme Court Case No. 91296
Nevada appellate counsel for Sherry Xue Ling Chen
NV Supreme Court Case No. 91296
ML
Michael M. Lin, Esq.
Chen's Trial Court Counsel (Re-Retained)
Lin was Chen's trial attorney and withdrew December 19, 2025 — one day after Dr. Hung emailed requesting allocation discussions. He has since been re-retained and appears as active counsel in the trial court enforcement proceeding. His simultaneous withdrawal with Fred Page immediately after Dr. Hung's allocation email is noted as suspicious timing. He falsely claimed the matter had "reached final determination" when filing his withdrawal.
Lin Law Group
NV Bar No. 10392
ML@LINLAWGROUP.COM
NV Bar No. 10392
ML@LINLAWGROUP.COM
FP
Fred Page, Esq.
Chen's Former Trial Counsel (Withdrew)
Page represented Chen at trial and withdrew simultaneously with Lin on December 19, 2025 — the day after Dr. Hung's allocation email — falsely claiming "final determination." He appeared at trial and cross-examined Dr. Hung. His PACER search attempting to disprove Dr. Hung's malpractice history was found by the court to be incomplete.
Page Law Firm
NV Bar No. 6080
fpage@pagelawoffices.com
NV Bar No. 6080
fpage@pagelawoffices.com
JR
Jericho L. Remitio, Esq.
Chen's Co-Counsel — Trial Court (New)
Remitio appears as active co-counsel for Chen in the trial court enforcement proceeding alongside Michael Lin. He is listed in the docket as of the current proceedings. He appears to have been newly retained for the enforcement phase.
Active in Case No. D-24-687267-D
Enforcement phase counsel for Chen
Enforcement phase counsel for Chen
DR. HUNG'S PRIOR COUNSEL — POTENTIAL MALPRACTICE DEFENDANTS
BL
Brandon K. Leavitt, Esq.
Dr. Hung's Trial Counsel — Malpractice Exposure
Potential Defendant
Leavitt represented Dr. Hung throughout the trial proceedings and is responsible for the two documented erroneous post-decree advisories that caused approximately 6.5 months of implementation delay. He timely filed the Brunzell attorney fees memorandum (September 22, 2025) and correctly filed six lis pendens against the five properties in April 2024. However he apparently failed to serve the JPI on any financial institution — the corresponding protection for liquid assets that he correctly applied to real property. He was removed from the NV Supreme Court appellate case in October 2025 when Dr. Hung filed to proceed pro se, leaving Dr. Hung without appellate counsel in a complex appeal.
Leavitt Family Law Group
efiling@leavittfamilylaw.com
brandon@leavittfamilylaw.com
NOTE: Do not contact Leavitt directly — any contact should be through malpractice counsel once retained
efiling@leavittfamilylaw.com
brandon@leavittfamilylaw.com
NOTE: Do not contact Leavitt directly — any contact should be through malpractice counsel once retained
Malpractice Claims: (1) Erroneous deed requirement advice — Sept 3, 2025. (2) Erroneous appeal divestiture advice — Dec 2, 2025. (3) Probable failure to serve JPI on banks — April 2024. (4) Failure to protect properties during post-decree implementation gap. Estimated damages: $181,340–$206,340 before disgorgement and TBD items.
TRUST-DRAFTING ATTORNEY — IDENTITY PENDING
??
[Identity TBD — Pending Deed Review]
Attorney Who Prepared January 2024 Trust Transfer Documents
Identity Pending Recorder Search
This attorney prepared the legal instruments that transferred all five community properties into the Xue Ling Chen Living Trust in January 2024 — naming Chen as sole creator, trustee, and beneficiary. The trust transfer was the precipitating act of this entire litigation. The attorney's identity will be confirmed from the "Prepared By" block on the certified deed copies currently being pulled from the Clark County Recorder (AcclaimWeb).
Before preparing these instruments a competent Nevada real property attorney was required to review the existing chain of title — which included at minimum: (1) "married woman" language in existing recorded deeds; (2) Dr. Hung's name as prior grantor on the Unit 1055 deed; (3) an acquisition pattern showing $800,000 in purchases by an unemployed person with no documented income source. Any one of these three red flags triggered a mandatory duty to investigate the community property character of the properties before proceeding. All three were simultaneously present.
Before preparing these instruments a competent Nevada real property attorney was required to review the existing chain of title — which included at minimum: (1) "married woman" language in existing recorded deeds; (2) Dr. Hung's name as prior grantor on the Unit 1055 deed; (3) an acquisition pattern showing $800,000 in purchases by an unemployed person with no documented income source. Any one of these three red flags triggered a mandatory duty to investigate the community property character of the properties before proceeding. All three were simultaneously present.
How to Identify:
1. Complete AcclaimWeb search for all 5 January 2024 trust transfer deeds
2. Order certified copies — "Prepared By" block on each deed names the attorney/firm
3. Confirm NV Bar license:
4. Check for prior disciplinary history on NV Bar search
1. Complete AcclaimWeb search for all 5 January 2024 trust transfer deeds
2. Order certified copies — "Prepared By" block on each deed names the attorney/firm
3. Confirm NV Bar license:
4. Check for prior disciplinary history on NV Bar search
Potential Claims: Professional negligence (duty to non-client), aiding and abetting breach of fiduciary duty, civil conspiracy (fraudulent conveyance), negligent misrepresentation (Declaration of Value forms), unjust enrichment. Potential NV State Bar complaint. Potentially largest damages in entire case — measured by full divorce litigation cost from inception.
POTENTIAL RETAINED COUNSEL
PK
Patrick W. Kang, Esq.
Founding Partner — Ace Law Group
Potential Malpractice Counsel
Patrick W. Kang is the founding partner of Ace Law Group, a Las Vegas civil litigation firm. Ace Law Group handles complex civil matters including professional malpractice, business litigation, and personal injury. As a Las Vegas-based firm with trial experience in Clark County courts, Kang and his team are positioned to evaluate both the Leavitt malpractice claim and the trust attorney civil action. The firm's familiarity with Clark County Family Court and the Eighth Judicial District is directly relevant given that the underlying case and all enforcement proceedings are before Judge Parladé in that court.
Ace Law Group
6480 W. Spring Mountain Rd., Suite 1
Las Vegas, NV 89146
Phone: (702) 333-4223
Website:
6480 W. Spring Mountain Rd., Suite 1
Las Vegas, NV 89146
Phone: (702) 333-4223
Website:
Potential Role: Civil malpractice counsel for Leavitt claim ($181K–$206K+ damages) and/or trust attorney civil complaint (full divorce litigation cost). Also evaluate NRS 41.1395 elder exploitation claim (double damages + mandatory fees) and bank liability civil action ($189K).
SB
Steven M. Burris, Esq.
Founder — Burris & Thomas, LLC
Potential Malpractice Counsel
Steven M. Burris is the founder of Burris & Thomas, LLC, a Las Vegas litigation firm focusing on serious civil claims including legal malpractice, personal injury, and complex civil litigation. Burris brings trial experience in Nevada courts and a track record in high-stakes civil matters. For a legal malpractice case with the clean causation profile of the Leavitt claim — written erroneous advice, documented reliance, subsequent court filings proving the advice was wrong — Burris & Thomas represents a strong candidate for contingency fee evaluation.
Potential Role: Legal malpractice counsel against Leavitt. Two documented erroneous advisories in writing. Causation unusually clean. Damages floor $181K–$206K before TBD items. Strong contingency fee candidate given documented liability and calculable damages.
GOVERNMENT AGENCIES
DA
Clark County District Attorney — Economic Crimes Unit
Criminal Referral Target — False Declaration of Value
Referral Needed
The Clark County District Attorney's Economic Crimes Unit handles real property fraud and financial crimes. This is the primary agency for the criminal referral regarding Chen's five false Declarations of Value filed under penalty of perjury with the Clark County Recorder in January 2024. The referral can be filed by any person with knowledge of the alleged conduct — including a family member as third party — without requiring Dr. Hung's formal authorization or the involvement of an attorney. The Decree's findings provide a fully adjudicated factual predicate for the referral.
200 Lewis Avenue, Las Vegas, NV 89155
Phone: (702) 671-2500
Statutes to cite: NRS 197.170, NRS 205.377, NRS 375.060, NRS 123.230(6)
Key attachments: Decree pages (FF 74, 75, COL NRS 123.230(6) finding) + all 5 certified deeds with Declaration of Value forms
Phone: (702) 671-2500
Statutes to cite: NRS 197.170, NRS 205.377, NRS 375.060, NRS 123.230(6)
Key attachments: Decree pages (FF 74, 75, COL NRS 123.230(6) finding) + all 5 certified deeds with Declaration of Value forms
FC
FinCEN — Financial Crimes Enforcement Network
Regulatory Referral — $189K Offshore Transfer
FinCEN is the U.S. Treasury bureau responsible for anti-money laundering enforcement. A tipline referral triggers investigation with subpoena power reaching Chinese financial institutions through MLAT. Report the $189K transfer, the two implausible contradictory explanations found by the court, Chen's failure to disclose foreign accounts, and potential FBAR violations. Can be filed now without waiting for deed copies.
U.S. Department of the Treasury
P.O. Box 39, Vienna, VA 22183
OC
Office of the Comptroller of the Currency (OCC)
Bank Regulator — AML Complaint
The OCC is the primary federal regulator for nationally chartered banks. A complaint about East West Bank's failure to flag the $189K international wire as suspicious — from an account whose holder had no documented income, to a Chinese bank, during a pending divorce — triggers an AML compliance examination. File after confirming the bank processed the wire.
P.O. Box 53570, Houston, TX 77052
Phone: (800) 613-6743
IR
IRS Criminal Investigation Division
Tax & FBAR Violations
IRS CI investigates tax evasion and FBAR violations. Chen testified to having tens of thousands of dollars in Chinese accounts (Decree FF 55). Any US person with foreign accounts exceeding $10K must file FBAR annually. Willful failure: civil penalty up to $100K or 50% of account balance, plus potential criminal charges. Additionally, rental income Chen withheld from community properties may be unreported income.
IRS Criminal Investigation
Las Vegas Field Office: (702) 868-5005
Form 3949-A for referral
AP
Nevada Adult Protective Services
Elder Financial Exploitation Referral
Nevada APS has jurisdiction over financial exploitation of elders (age 60+). Dr. Hung is 83 with documented physical impairments. The documented conduct — unilateral $2M property transfer, $189K offshore theft, foreclosure threats, the "kill herself" extortion threat — constitutes elder financial abuse within APS's purview. An APS referral triggers an independent protective investigation and can support the NRS 41.1395 civil claim.
Nevada Division of Aging & Disability Services
Phone: (702) 486-6930 (Clark County)
24-Hour Hotline: (888) 729-0571
LV
LVMPD — Las Vegas Metro Police
Criminal Report — If Forgery Found
LVMPD is relevant if review of the trust transfer deeds reveals that Dr. Hung's signature was forged on any of the January 2024 transfer instruments. Forgery (NRS 205.090) is a Category D felony. If the deeds are void because they lack Dr. Hung's required signature and he did not sign them, a forgery report to LVMPD triggers a criminal investigation independent of the civil proceedings.
Las Vegas Metropolitan Police Department
400 S. Martin Luther King Blvd., Las Vegas, NV 89106
Non-Emergency: (702) 828-3111
400 S. Martin Luther King Blvd., Las Vegas, NV 89106
Non-Emergency: (702) 828-3111
CR
Clark County Recorder
Public Records — Critical Document Source
The Clark County Recorder maintains all recorded real property documents in Clark County. The five January 2024 trust transfer deeds are public records in the Recorder's office. These documents will reveal the trust attorney's identity, Chen's marital status as described in the transfer instruments, whether Dr. Hung's signature appears, the notary's identity, and the Declaration of Value forms certifying false sole ownership.
500 S. Grand Central Pkwy, Las Vegas, NV 89155
Phone: (702) 455-4336
Certified copies: $4/document + $1/page
Phone: (702) 455-4336
Certified copies: $4/document + $1/page
NB
Nevada State Bar — Office of Bar Counsel
Attorney Disciplinary Authority
The Nevada State Bar has disciplinary authority over all Nevada-licensed attorneys. Bar complaints can be filed by any person — including third parties — who have knowledge of attorney misconduct. Two potential bar complaints are relevant to this case: (1) Against Leavitt for the two documented erroneous advisories that caused Dr. Hung to forgo available legal remedies for months. (2) Against the trust-drafting attorney (once identified) for the standard of care violations in preparing the January 2024 trust transfer instruments. Bar complaints do not produce monetary recovery for Dr. Hung but create a parallel disciplinary record and may generate investigative findings that inform the civil actions.
3100 W. Charleston Blvd., Suite 100, Las Vegas, NV 89102
Phone: (702) 382-2200
Phone: (702) 382-2200
NT
Nevada Department of Taxation
RPTT Exemption Fraud — Parallel Referral
The Nevada Department of Taxation administers the Real Property Transfer Tax (RPTT). Chen claimed the living trust exemption on five property transfers — certifying sole ownership of community property under penalty of perjury — to avoid approximately $7,675 in RPTT. False claims for Nevada tax exemptions are reportable to the Department of Taxation which has independent investigation and enforcement authority. File simultaneously with the DA criminal referral using the same exhibit package.
1550 College Parkway, Suite 115, Carson City, NV 89706
Phone: (775) 684-2000
Las Vegas Office: 555 E. Washington Ave., Suite 1300
Phone: (702) 486-2300
Phone: (775) 684-2000
Las Vegas Office: 555 E. Washington Ave., Suite 1300
Phone: (702) 486-2300
Asset Analysis
Financial Overview
Complete financial picture — income, harm, assets, allocation plan, cash flow, and exposure.
Monthly Income (Dr. Hung)
~$16,000
VA physician contractor
Monthly Harm (Ongoing)
$7,400
Active harm — ongoing
Portfolio Net Equity
$1,460,932
After all mortgages
Dr. Hung's 50% Share
$730,466
50/50 community division
Offshore Transfer
$189,000
Unrecovered
Equalization Payment
$48,766
Waived
🏠 Approved Allocation Plan (March 6, 2026)
| Party | Property | Gross Value | Mortgage | Net Value |
|---|---|---|---|---|
| CHEN | Newton Ridge | $628,164 | ($333,453) | $294,711 |
| Leaning Oak | $367,500 | ($173,479) | $194,021 | |
| Reno #1055 | $290,500 | $0 | $290,500 | |
| CHEN SUBTOTAL | $1,286,164 | ($506,932) | $779,232 | |
| HUNG | Ranch Estates | $367,300 | $0 | $367,300 |
| Reno #1104 | $314,400 | $0 | $314,400 | |
| HUNG SUBTOTAL | $681,700 | $0 | $681,700 | |
💵 Monthly Cash Flow — Dr. Hung
| Item | Amount |
|---|---|
| Income: VA physician contractor | ~$16,000 |
| Hardship: Newton Ridge mortgage | ($2,400) |
| Hardship: Leaning Oak mortgage | ($1,000) |
| Hardship: Rent withheld by Chen | ($4,000+) |
| Net After Harm | ~$8,600 |
Note: $7,400/month ongoing harm = $88,800/year in direct damages
📜 Father's Holographic Will
Handwritten will executed May 8, 2026. Valid under NRS 133.090. Assets pass directly to Dr. Hung outside the marital estate. This will controls distribution of Dr. Hung's separate property inherited from his father.
⚠️ Financial Exposure & Risks
| Risk Item | Amount | Status |
|---|---|---|
| Unrecovered offshore funds | $189,000 | Unrecovered |
| Legal fees — appeal | $20,000–$40,000 est. | Pending |
| Ongoing monthly harm | $7,400/month | Active |
| Chen's sanctions exposure | TBD | Motion to Strike pending |
| Attorney fee recovery | Determined by court | Awarded — amount TBD |
| Total hard exposure estimate | ~$300,000–$318,000 |
📋 Tax Implications
| Issue | Detail |
|---|---|
| Property transfer | Tax-free under IRC §1041 |
| Rental income | Chen reports all rental income despite community property |
| Mortgage interest | Dr. Hung pays but cannot deduct — Chen holds title |
| Inheritance | Separate property under CA and NV law |
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