    In opposition, Dr. Idnani argued that the sanctions aspect of the one-

action rule applied only to borrowers, not guarantors. Because Earl waived

his right to any equitable defenses in the Personal Guaranty, argued

Dr. Idnani, Nevada law permitted her to pursue the Guarantor Action

against Earl separately and independently from her nonjudicial foreclosure

action; therefore, neither the Guarantor Action against Earl nor her

incomplete nonjudicial foreclosure sale was an "action" which violated

Nevada's one-action rule and triggered the sanctions aspect of the rule

resulting in loss of her lien. Further, argued Dr. Idnani, the Nevada state


                                   failure to interpose, before the entry of a final judgment, the
      provisions of NRS 40.430 as an affirmative defense in such a proceeding
      waives the defense in that proceeding. Such a failure does not affect the
      validity of the final judgment, but entry of the final judgment releases and
      discharges the mortgage or other lien.

                                           9
rule as a "security first" rule. "Under the one-action rule, a