MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 10) u 12| 13] 14] 15] 16] 17 I3| 19 20} a 22| 23 2al 2s) 26) 27] 28| FILED Electronically GR25-00275 2025-06-23 09:45:27 AM Alicia. Lerud JENNIFER M. McMENOMY, Esq. Clerk ofthe Court Nevada State Bar No. 14239 SSS MARSHALL LYON, Esq, Nevada State Bar No. 16425 MeMENOMY LAW, PLLC 100 Vine Street Reno, Nevada 89503 Telephone: (775) 525-850 Email: [email protected] Attorneys for Petitioner IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA IN AND FOR THE COUNTY OF WASHOE COUNTY IN THE MATTER OF THE GUARDIANSHIP FOR THE PERSON AND ESTATE OF Case No, JOAN RAE MACK Dept. No. Proposed Protected Person )R_ APPOINTMENT OF. INCLUDING REQUEST FOR TEMPORARY GUARDIANSHIP COMES NOW, JORY MACK (hereinafter “Petitioner”), by and through his attorneys] McMenomy Law, PLLC, and hereby petitions this Honorable Court for Guardianship over JOAN| RAE MACK (“Joan”), the proposed protected person. In accordance with Chapter 159 of the Nevadal Revised Statutes, Petitioner respectfully represents to this Honorable Court as follows: 1, PRELIMINARY INFORMATION A. Circumstances: Joan is presently an eighty-eight (88) year old woman. Her date of birth is March 29, 1937. Joan currently resides at 5690 Ambrose Drive, Reno, Nevada 89519 and) has a mailing address of the same. Joan has been a resident of the State of Nevada since prior to] 1958.MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 Upon information and belief, Joan suffers from early onset dementia, is wheelchair bound, and has advanced diabetes. Joan is currently under the care of her son Landon Mack (“Landon”) and her granddaughter-| in-law Samantha Mack (“Samantha”) who reside with her at her home located at 5690 Ambrose} Drive, Reno, Nevada 89519. (hereinafter “5690 Ambrose Drive”) Joan currently docs not receive o has ever received Medicaid Joan’s son and Jory’s father, Darren Mack (“Darren”) shot the Honorable Charles Weller and| then murdered his wife Charla Mack in 2006.' Darren is currently incarcerated at Lovelock] Correctional Center. Approximately eleven (11) years ago, Darren, while incarcerated became| religious. Samantha and Jory joined Darren’s religion about eight (8) years ago, when Samantha| expressed a desire to become more religious, and had wanted to reconcile Darren and Jory's relationship. Landon joined Darren's religion about two (2) years ago. ‘As time went on, Darren began exercising control over Jory, Samantha, and Landon through| various hours-long daily phone calls with them from Lovelock Correctional Center in which he| conducted sermons and told the family members that he was a “prophet.” Among other things, Darren| told the family that the family members must obey everything Darren told them because it eame| directly “from God.” Darren’s control over the family members included dictating sleep schedules, exercise regimes, prayer time, and mealtimes. Throughout last year, Jory became disturbed by the level of control Darren had over himself} Landon and Samantha. Jory initially dissociated himself from the “religion.” However, when Jory] began moving away from the religious aspects of his life, Darren directed Samantha to cut ties with] ' This court is requested to take judicial notice of these facts pursuant to NRS 47.150(2) and as| supplied in Mack v. Estate of Mack, 125 P.3d 80, 91, 206 P.3d 98, 106 (2009).MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 her husband Jory because he has “demons.” Jory was subsequently ostracized completely away from| the rest of his family including his wife, Samantha, his uncle, his father, his child and Joan. Jory has| now received primary physical and sole legal custody over his and Samantha’s daughter. At this time, Joan lived with Landon at 5690 Ambrose Drive. Jory and Samantha lived at al ‘separate residence with their small daughter. Jory disassociated himself from the family in or around) August 2024 and was cut off by Darren, Samantha and Landon. Samantha, along with their daughter, moved in with Landon and Joan at 5690 Ambrose Drive and withheld Jory’s daughter from him. Thereafter, Samantha and Landon became the primary caretakers for Joan. Upon information and belief, around January 2025, Joan began joining the “religious” phone| sessions with Darren promising Joan that she would receive “community.” Joan and Jory had| previously had a good relationship and would communicate frequently. In a January 16, 2025 email, Landon told Jory that he must only communicate with Joan via email and that Landon would readl them to Joan. Landon stated to Jory, “[Joan] understands and agrees she can not (sic) keep company with you until you repent and come back to God.” See January 16, 2025 email attached hereto Exhi 1 For a time after joining the “religion,” Jory and Joan communicated secretly through a paid| caretaker of Joan's named Michelle Carrow (“Michelle”). During this time, Joan communicated to Jory that she was extremely unhappy in the home and did not like the restrictions and requirements placed upon her by Darren and Landon. Joan also stated that she loved Jory and wanted to see him] but could not because she was not allowed to see him. Michelle became increasingly disturbed by the restrictions Darren directed Joan to be put under. Specifically, Joan’s daily schedule called forMCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 1 2 u 12] 13] 14 15| 16 7 18 19 20) 2 n 231 24] 2s] 26) 27] 28| sleep deprivation.? Joan's daily schedule, upon information and belief, provided to Michelle Landon and Samantha is as follows: 11:45 PM 12:00AM 1:00AM. 2:10AM 3:00AM-6:00AM 6:00AM 6:30AM-8:00AM 8:00AM-8:40AM 9:00AM-12:00PM. 12:00PM 1:00PM-3:00PM 3:00PM-5:15PM_ 5:30PM 6:15PM. 6:45PM. 7:00PM, 7:30PM-11:4SPM ‘See Exhibit 2. * See a copy of Joan’s purported daily schedule attached hereto as Exhibit 2. Wake up for midnight prayer Midnight Prayer (1 hour) Meditation (1 hour) Workout Sleep Wake up, go potty, brush teeth Bible Study (1.5 hours) Shower Options: journaling, bible study, prayer, meditation, walking, running| errands, helping around the house Midday Prayer (at least 15 minutes) Bible Study (2 hours) Options: journaling, bible study, prayer, meditation, walking, running Errands, helping around the house Dinner (when not fasting) Bible Study (30 minutes) Get ready for bed, brush teeth, go potty Evening Prayer (at least 15 minutes) SleepMCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 16| 1 18| 19) 20} 21 23 24] 25 26 2 28 tis worth noting here that, according to this schedule, Joan gets a total of seven (7) hours and| fifteen (15) minutes of sleep broken into two (2) allocations per day. It is also worth highlighting} that this schedule includes dinner when she is not “fasting.” Apparently, Joan is also on a strict fasting schedule wherein she is required to refrain from eating or drinking for two (2) twenty-four] (24) hour periods per week. This “schedule” is particularly concerning given Joan’s advanced age and diabetes diagnosis. Allegedly, Joan is on the “body for life” program which Darren has stated) “God commands her to do.” According to Michelle, in addition to the above grueling schedule for Joan, Landon and| ‘Samantha refuse to allow Joan to seek any medical treatment. Additionally, Landon and Samantha| will not allow Joan to take any medication. Michelle became so troubled by the situation at 56 Ambrose Drive that she quit her caretaking position because she was frightened that Landon and) ‘Samantha would kill Joan by failing to properly care for her or seek medical intervention for her. As| an unfortunate side effect of Michelle's resignation, Jory lost all communication with Joan. In evaluating the foregoing circumstances, APRN Ryan Bristol opined that given Joan's} history of dementia, type 2 diabetes mellitus and suicidal ideation, that she is in a “medically unsafe"| environment and that such living conditions “raise significant concem for elder abuse and neglect.”| See attached hereto, a June 11, 2025 letter from Ryan Bristol APRN Nevada License Number 842491 is attached hereto as Exhibit 3 Upon information and belief, in or around February 2025, Landon and Samantha arranged fe Joan to meet with an estate planning attorney to revise her estate planning documents. Previously, Jory was named as the successor trustee of Joan’s personal trust. It is currently unclear whether Jory still remains as the Trustee of Joan's Trust. Until March 2025, Joan’s lifelong friend, Melvin Laub (“Mel”) visited regularly with Joan] On Joan’s birthday, March 29, 2025, Mel offered to take Joan out to lunch for her birthday. Landon|MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 10 u 13) 14 15 16 7 18 19] 20] 2 22| 23 24] 25 26 27] 28] refused to allow Mel to take Joan out ro lunch because restaurants are “poison” to Joan, At that time, Mel noticed a visible shift in Joan's normally cheerful and upbeat demeanor. Joan was now sullen} and withdrawn. Shortly after this incident, Mel was no longer permitted to speak to Joan on the phone} or visit with her at her home In addition, many of Joan's friends are also concemed about her wellbeing. According to some of Joan's friends, she has been visibly upset and morose. According to these friends, Joanl stated that she would never have agreed to joining Darren’s “religion” if she would have known! everything that was involved with it. Recorded phone calls between Darren, Landon and Joan have become increasingly disturbing} with Darren telling Joan things like if she does not fast for two (2) days a week, she will end up “in al Nazi prison camp with your feet nailed to the floor being raped every day.” Darren is aware that this behavior is not normal and states on a phone call that he is aware that both him and Landon could get into legal trouble for forcing Joan into their practices. In or around early May 2025, on a recorded phone call with Darren and Landon, Joan stated} that she wanted to commit suicide. Darren, in response to Joan’s comment stated “Good, hopefully| something breaks soon.” Washoe County Sheriff's Office completed a welfare check on Joan at 5690 Ambrose Drive| and said that the call was “bizarre”, but that Joan told them she did not want to leave. Nevada State Adult Protective Services (“APS”) has been contacted in addition to local authorities. Despite the fact that Joan has told these investigative agencies she does not want to leave 5690 Ambrose Drive, there is still valid and real concer for her wellbeing, I, NEED FOR GUARDIANSHIP A. Immediate Need for Temporary Guardianship. NRS 159.0523 permits a court to appoint a temporary guardian if a proposed protected person is “unable to respond to a substantialMCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 uw 12 1B 15 16| v7 18 19] 20) ai 22 23] 2a 25] 26| 21 28| and immediate risk of physical harm or to a need for immediate medical attention.” Here, Joan is| unable to respond to substantial and immediate risk of physical harm. As outlined above, Joan has| been living for the past six (6) months, at least, in an environment that is extremely restrictive to the| point of abuse. At present, Joan has limitations that prohibit her from walking, showering and caring} for herself and she is unable to engage in activities of daily living without assistance from another person. Joan is currently being deprived of basic necessities like food, water, and sleep. Based on} her conversations with Darren and Landon, Joan is also at high risk of harming herself due to het current circumstances and Darren's continued control over her. Joan is unable to respond to the immediate risk of physical harm because she is being mentall and physically dominated and controlled by Darren, Landon and Samantha. Itis common, and Darren] has acknowledged, that depriving a person of basic necessities is a form of mind control. Once again Joan is 88 years old. She has limited mobility, diabetic and is suffering from dementia, The combination of control and Joan’s physical ailments lead her to be unable to respond to the immediate physical harm in which she finds herself. Moreover, Joan is facing substantial and immediate risk of financial harm because Landon] and Samantha live exclusively on Joan’s financial resources and are using said resources fo expensive trips to various locales. Additionally, Jory was the successor trustee of Joan’s trust andl has now allegedly been removed from that role. Joan is unable to respond to this immediate tisk o harm to her finances and for the same reasons she is unable to respond to the immediate risk of harm| relating to her person. B. Need for Permanent Guardianship. It is possible that once Joan is removed from the| toxic environment in which she currently finds herself and is provided with ample food, water andl sleep as well as medical attention, that she will no longer need a guardianship however, Joan is 88| ‘years old, susceptible to suggestion because of her dementia and diabetes and may need a continued|MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8880 u 2 13 14 15 16 7 18) 19 20) 21 22] 23] 2a 25| 26| 21] 28) guardian to ensure that Darren, Landon, and Samantha cannot coerce her back into their “religious, practices.” C. Alternatives. Jory is open to looking into less restrictive alternatives to guardianship} for Joan once she has been removed from her current situation, However, due to the fact that Joan is} currently being completely isolated and abused there are no less restrictive alternatives that have been} explored. Jory is willing to take Joan into his home and care for her with a caregiver, and Michelle} Carrow is willing to work with Joan. D. Requested Powers. Jory is requesting full powers to make decisions for Joan with] respect to her health care, finances, and assets. Specifically, Jory requests the ability to remove both| Landon and Samantha from 5690 Ambrose Drive, ascertain the amount of money spent on Joan’s accounts and trust sources, pay for Joan’s care, etc. Jory also requests the ability to access Joan’s healthcare records, arrange for and attend healthcare appointments with Joan and ensure that Joan is} getting adequate healthcare. E. Voting Rights. Joan should be permitted to keep her right to vote. F, Firearms/Guns, Due to her current suicidal ideations, Joan currently does not have the| capacity to possess a firearm and said right should be suspended. G. Driving. Due to her current physical limitations, Joan is currently not able to drive and| should not hold a driver’s license, H. Lawsuit. The guardianship is not currently being sought to initiate a lawsuit. 1. Abuse/Neglect: The guardianship is being requested because of abuse, neglect, exploitation, and isolation. J. Documents. It is currently unknown what the current documentation has been| executed. K. Assets, Joan’s estate is valued at more than $10,000.00MCMENOMY LAW, PLLC 100 Vine Strect Reno, NV 89503 Phone: (775) 525-8850 28 26| 27 28| IL. PETITIONER Petitioner's full legal name is JORY DAINE MACK, DOB: August 9, 1988 and is current! thirty-six (36) years old. Petitioner is Joan’s grandson and currently resides at 14350 Ghost Rider Drive, Reno, Nevada 89511 with a mailing address of the same. Petitioner is a resident of the State} of Nevada. Petitioners want to be the guardian over Joan. Petitioner is competent and capable of acting as guardian of Joan and consents to act in this capacity. Petitioner has not been convicted of a crime of moral turpitude, a crime involving domestic violence or a crime involving abuse, neglect, exploitation, isolation or abandonment of a child, his spouse, his parent or any other adult. Petitioner has never been convicted of a felony. Petitioner has never been suspended for misconduct or disbarred from the practice of law, the practice of accounting| or any other profession which involves the management or sale of money, investments, securities 0 real property and requires licensure in Nevada or any other state. Petitioner has not filed for bankruptcy within the last seven (7) years. Petitioner is not a party to any pending criminal or civil litigation aside from divorce and custody proceedings fron Samantha. Petitioner is not currently being paid to act as a guardian for any protected person. Petitione has attempted to contact the below relatives via text message, phone or email to inform them of these| proceedings, Petitioner understands that if he is appointed as the temporary guardian: © The Court will set a hearing within 10 days to decide whether to extend the temporary guardianship, Petitioner will have to attempt in good faith to notify the adult’s relatives and any other required person of the temporary guardianship and the hearing to extend the temporary| guardianship, If he does not, the court can terminate the guardianship.g = z a : 3 g a = g i & $ 8 2 Reno, Phone: (775) $25-8850 10 u 12) 13) 14 15 16 7 18 19 20} 21 22 23 24] 25 26] 27] 28) ® The court can extend the temporary guardianship only if there is clear and convincin evidence that the adult still needs a temporary guardian. If extended, the guardianship can] usually can only be extended for two (2) 60-day periods. IV. RELATIVES OF PROTECTED PERSON ‘The following are the relatives of the Protected Person: ‘Name Relationship to | Age ‘Address Protected Person Darren Mack ‘Son Adult | Lovelock Correctional Center #1014861 1200 Prison Road Lovelock, Nevada 89419 Landon Mack ‘Son’ ‘Adult | 5690 Ambrose Drive Reno, Nevada 89519 Tory Mack Grandson ‘Adult | 14350 Ghost Rider Drive Reno, Nevada 89511 Elise Mack Granddaughter [Adult [3313 Ridge Road Durham, North Carolina 27705 | Erika Mack Granddaughter | Adult [2711 McGee Avenue | Apartment B Berkeley, California 94703 Petitioner notified, via text message, both Elise Mack and Brika Mack of the proceedings via text message on June 13, 2025. Petitioner did not notify Darren Mack or Landon Mack about the temporary guardianshi because Joan would be at immediate risk of physical, emotional, and/or financial harm if notice was provided before the court determines whether to appoint the temporary guardian. WHEREFORE, Petitioner requests this guardianship be granted, that the relief requested be| granted as stated herein, and for other such relief as the Court may deem just and proper. AFFIRMATI ‘The undersigned affirms this document submitted for filing does not contain the Social Securit number of any person. 10MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503 Phone: (775) 525-8850 10 ul 12 13 14 15 16 17 18 19 20} 21 22 23 2a 25) 26| 27] 2s DATED this 20" day of June, 2025 u McMENOMY LAW, PLLC By: lifer NicMenomy, Esq. 10 Vine Street Reno, Nevada 895034 DDocusign Envelope 0) 4970A675.9¢47-427E TAZ AICS ISZBFFS MCMENOMY LAW, PLLC 100 Vine Street Reno, NV 89503, Phone: (775) 525-8850 10] 12] 13] 14] 15] 16 17 183] 19] 20] au 22| 2B 24] 28 26| 27] 28| VERIFICATION 1, JORY MACK, declare that I am the Petitioner in the foregoing action; that I have read the foregoing Petition For Appointment of Guardian and know the contents thereof; that the same is true} of my knowledge except as to those matters therein state upon information and belief and as to those} matters, | believe them to be true. | declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct. Dated: 6/17/2025 — GL JORY MACK 12FILED Electronically GR25-00275 2025-06-23 09:45:27 AM ‘Alicia L. Lerud Clerk of the Court ‘Transaction # 11079431 : csulezic EXHIBIT 1Jenny McMenomy. From: Jory Mack Sent: Wednesday, May 21, 2025 5:13 AM To: Jenny MeMenomy Subject: Fwd: Joan Isolation email to me - Forwarded message From: Landon Mack Date: Thu, Jan 16, 2025 at 8:12AM ‘Subject: Re: Joan To: Jory Mack Dear Jory, | will try to keep this short. | just wanted to take a small amount of time to point out in all your email responses you made no references to the three requests that | made before and when you talked to your grandmother and you took zero responsibility and or accountability for any of her upset you caused. Instead you made everything about you you you. But itis all mute now. Your grandmother has been called. She is holding the Commandments. She is holding Sabbath by convicating and studying the Bible with us, she is praying three times a day, she is getting up at midnight to pray, she is holding New Moons and all other Holy Days. She agreed and ordered the closing of the business on the Sabbath. She understands and agrees she can not keep company with you until you repent and come back to God. Ifyou like to communicate with her please do it by email. You can email her at this address and | can read them to her, or if you are not comfortable having me read your communications | can get you her PJL. ‘email and one of her caretakers or possibly Sue can read them. Love your Uncle Lanny (On Wed, Jan 15, 2025 at 10:06 AM Jory Mack wrote: Hey Lanny! Can I call Joan at some point today? JoryFILED Electronical GR25-002 2025-06-23 09:45:27 AM ‘Alicia L. Lerud Clerk of the Court ‘Transaction # 11079431 : csulezic EXHIBIT 2Joan's Schedule 11:45 PM Wake up for midnight prayer 12 AM Midnight prayer (1 hour) 1AM Meditation (1 hour) 2:10 AM Workout ———> > oo Tues. Cardio 3. AM-6 AM Sleep Thurs. Caratio 6 AM Wake up, go potty, brush teeth 6:30 AM - 8 AM Bible Study (1.5 hours) 8 AM - 8:40 AM Shower 9 AM - 12 PM options: journaling, Bible study, prayer, meditation, walking, r i helping around the houseFILED Electronically ‘GR25-00275 2025-06-23 09:45:27 AM ‘Alicia L, Lerud Clerk of the Court Transaction # 11073431 : csulezic EXHIBIT 306/11/2025 To Whom it May Concern, | am writing in my capacty as a licensed medical professional to express serious concer after reviewing information regarding an 88-yesr-old female with a known history of dementia, type 2 diabetes relitus, and reported suicidal ideation. Based on the details provided, the patiant has been subjected to several conditions that are medically unsafe and raise significant concer for elder abuse and neglect. These include: ‘+ Disrupted Sleep Schedule: Dementia patients require a consistent and calming daily routine. ‘Chronic sleep deprivation or erratic steep patterns can lead to increased confusion, impaired judgment, emotional instabiity, and a heightened state of suggestibilty.In a cognitively impaired ‘and fragile individual, lack of sleep reduces the brain's abilty to process information critically or defend against manipulative behavior. This can leave the patient more vuinerable to influence, coercion, or persuasion, especially from individuals in positions of perceived authorty or trust ‘= Seclusion from Friends and Support Systems: Isolation from familiar individuals—especially in. Patients with cognitive impalrment—can exacerbate anxiety, depression, and contribute to rapid cognitive deci. ‘= Fasting Without Food or Water for 24 Hours: For an elderly diabetic patient, this is medically dangerous and unacceptable. Extended fasting can result in hypoglycemia, dehydration, kidney injury, confusion, and even loss of consciousness. ‘© Suicidal Ideation: The presence of suicidal thoughts in a patient with dementia and chronic illness isan urgent mental health concem and should trigger immediate intervention and support—not further destabilization ‘Taken together, these circumstances strongly suggest patterns consistent with elder abuse or neglect. ‘The patient appears to be in an environment that is falling to meet even the most basic medical and. ‘psychological standards of care required for her complex health needs. {tis my professional opinion that this situation warrants immediate reevaluation of the patient's {guardianship and living environment. A transition of care to a responsible party who can provide ‘appropriate oversight, consistent medical care, and emotional support should be seriously considered Please contact me should you require additional information or professional insight. Sincerely, Ryan Bristol APRN Nv 842491