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Zach Coughlin <zadlcoughlin@hotmaiLcom>
Wednesday, December 12, 20U 2:35 PM
leslie, Jim; Bosler, Jeremy; Dogan, Biray; Goodnight. Joseph W; Fortier, Chris; Tuttle,
Steve; Kandaras, Mary; Young. Zach;;;;;;;;;;;;;;;;
The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17,
2012 to Coughlin in rcr2012-065630
12 1 U declaration of zach coughlin 0204.pdf; 2 6 12 email from Fortier regarding
Dogan 065630.pdf; 10 1112 email flNmisueof911 case 065630 fortler etal.htm;
transparent nevada Veronica lopez Marcia lopez 26405 2217600696 065630 0204.pdf;
112 12 rpd police report 12 cr 00696 sifre leedy look nash young kandaras bradshaw
0204 065630 redacted ocrd.pdf; BedcetLRI20110404 0204 065630.pdf; Beckett and
Tanner examples special treatement for prosecutor and tanner petty theft involve s16K
0204 Bar_CounsetReport..June_2011.pdf; 1122 12 26405 Motion for Continuance
because Hill on vacation Hazlett Declaration 0204 065630.pdf; 12 6 12 not authorized
by Clifton Custodian of Records WCPD 065630.pdf; 12 6 12 subpoenas 065630 Thew
Sifre Schaur lopez Foreshee ECOMM.pdt, coughlin nsct docket search as of 121 12
0204 065630.pdf; 8 20 11 unredaeted dispatch logs 063341 back from tiff.jpg.pdt, 9 1 12
063341 Order For Competency Evaluation 0204 065630 12420.pdf; 12 19 11 063341
GOODNIGHT'S REQUEST FOR DISCOVERY 0204 06S630.pdf; nset docket 54844
coughlin v dist ct joshi 01168 0204 26405 61901.pdt, 11 2112 065630 fax cover page
post it clifton 112812 don't file this in stays w case file however 1 of 69 pages.pdf; U 6
12 26405 Notice of Deficiency of Record on Appeal and Filing of Judicial Discipline
Commission Complaint 0204 - Copy.pdf; 12 6 U stamped 065630 emergency Motion
for Mistrial and Continuance Given state's failure timely provide discovery exculpatory-
Copy.pdf; 12 4 12 Affidavit of Service ruc Bailiff John Reyes lacks a lack number, lacks a
notary 065630 063341 067980 has no Order attached to it or incorporated by
reference. pdf; paes 1 to 11 from first fax judicial discipline commission complaints 0204
gardner elliot howard nash holmes sferrazza clifton final-2-2.pdf; Paul-D-Elcano-
Jr--l010555-a stanford 0204 elliot echeverrla.pdf;01955 docket coughlin elliot gardner
elcano.pdf; cr12-0316 coughlin judge steven elliot 0204 docket ccwashoe.pdf;
crl1-2064 docket coughlin v city of reno Judge elliot city attorney roberts 0204.pdf; paul
alcano suing rutherform chiropractice and dr ross and nicholS 0204 60317.pdf; 2312
22116608380204 roberts Gmail- courtesy copy of audio of trail exhibit 1 to
Supplement to Opposition to Motion to Dismiss.pdf; 1110 12063341 nrs 114.345
sbupoena on Duralde Rosa Alaksa and others rrr certified 1045 skau 0204.pdf; 11 26 12
S big recent ema"s 60302 60317 Garin WLS Gardner 0204 6033161383 063341 etc. pdf;
54844 COUGHI.lN VS. DIST. CT. and linda Gardner 0204 0435 26405.pdf
The Trial yesterday in RCR2012-065630 featured extended discussions regarding
the failure of the WCPO, Dogan, and Leslie, to tum over discovery propounded by
bOA Young in the fonn of cd's featuring 911 calls OOA Young provided to the
WCPD on 8113/12 and 8/17/12 ... And the heavy hitters were there, too (Elliot
Sattler) ..... despite numerous written requests from Coughlin that the WCPD do so,
f. \\i-A II
12/18/2012 10:19 7753375732
PAGE 13/39
and mUltiple trips to the WCPD personally by Coughlin to pick such materials up,
and despite more flip flopping on their story by Leslie and Dogan regarding
whether they ever gave Coughlin some package of materals responsive to
Coughlin's request for his "file" ... But, Jim Leslie is stuck with the 7/27/12 date he
mentions in his email, then he is stuck with what his recent email wherein he
purports to have therein digitally transmitted Coughlin his "file", which obviously
does not include the cd's of 911 calls (the one's DDA Young took up an enormous
amount of court time playing, over and over (well, Young only played over and
over the particular calls he felt were strongest for his case and most prejudicial,
claiming some "cutting room foor mishap" for the reoccurence of certain calls,
arguing that such a "happy accident" justified playing them again and again, at ever
increasing volumes, etc., etc.). Apparently, I am here to subsidize Young's baby
making, just like I was with Ms. Gorman, as a continuance of prejudicial length of
afforded to the State where none was forthcoming to Coughlin, despite Leslie and
Dogan's obstuctionist tantrums, ones of a quality that WOUld. J remember wh my
life featured happy moments like the birth of twins ... but that was before our
eviathan legal system wrecke s 0] on my existenge. What sir hall be m
compensation? Do you mind i I put my arm around,commlfd
Ti is a fonnal gievance against Dogan, Leslie, Bosler, Young ... etc.
If Svengnliliann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases. and gag order
them, he better be sure not to screw up the cases requiring a mistrial by failing to provide the client te cd's of
911 calls DDA Young gave the wcpd on 8/13 and 8/17112 in rc rv2011-065630, and clearly, any packet from
7/27/12 wouldn't have them (not to even get into the flip flopping contradictory account by Leslie and Dogan
as to who gave Coughlin the packet, or who didn't or blah blah bla) ... and certainly Leslie email below only
contained a 57 page pdLway to close to the 12111112 trial date, and containing materals Coughlin had never
been given bcfore .... so much easier. Jimmy Sleazy to email the client a "digital transmittal" proving what you
gave and when" .... but, no. that would make it so had to fdge the accounts of what was contained therein. or
who handed what to whom. or who failed to pick up this or that. or Dogan's slippery nonsense:
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 + 0
Mr. Coughlin:
Attached ac the discovery materials i te above-referenced case that you had requested and we had made a
. Mditional copy of for you i response to your request. Please note that te July 27, 2012. cover letter was for
you pick up and you never picked it up. Note also that the July 27, 2012. packet encloses a copy of te April
17. 20 I 2. hand delivery transmittal of the very same documents which you received.
12/18/2012 10:19 7753375732
PAGE 14/39
Since we have been removed from the 911 cae, we are closing our fle. The attached materials were sitting at
our front desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of
our file.
No respone to this transmittal is required from you.
James B. Leslie, Esq."
So, while Dogan states on 7/27/12 in 65630 "Your Honor, I have never even spoken
with Judge Dorothy Nash Holmes" ... he coyly fails to indicate whether he spoke
with anyone with the RMC, Marilyn Tognoni, included, or why his 2/28/12 fax to
Coughlin was so insistent that it was "Lae's Crossing's Bill Davis, Ph.D." who
must conduct the "Competency Evaluation", or how it was Judge Clifton's 2/27/12
Order for Competency Evaluation could have possibly known and included Judge
Elliott as the "randomly assigned judge" to that Competency Case in CR120376
(Judge Elliott on Committee to Aid Abused Women's Board, (CAAW) .. .Judge
Elliott prsiding over Coughlin's wrongfl termination lawsuit against WCDA's
Office ECR Partner, Washoe Legal Services, its Executive Director Paul Elcano,
and CAA W, in CVII-01955 ... Judge Elliott fails to disclose conflict or recuse
himself, Judge Elliott manages to "randomly" be assigned Coughlin's two criminal
appeals from RC convictions (the Wal-Mart "candy bar" petty larceny leading to
a 6 months, so far, temporary suspension of Coughlin's law license in 11 cr 22176
in the RMC, then cr11-2064 in the appeal Judge Elliott caned based upon a civil
statute requiring a down payment for the preparation of transcripts and Elliott's
contention that he need not address the merits of Coughlin's appeal given the lack of
a written transcript (Coughlin paid for the audio cd, and its not even clear that the
RMC is a court of record anyways, and the RMC distributes to defendants
instructions sheets and enforces "house rules" regarding the preparation of
transcripts that require one utilizing the services of RMe "official transcriptionist
Pam Longoni (whom hung up on Coughlin twice, and refsed to prepare the
transcript in 11 cr 22176/cr11-2064, failed to retur emails/faxes, etc.)" and where
the RMC refused to even give Coughlin the audio recording for some time, insisting
Coughlin could merely have it made available to Longoni.. .. Oh, Coughlin didn't get
12/18/2012 10:19 7753375732
PAGE 15/39
no continuance from Judge Howard in that 11 cr 22176 (even where he was
wrongfully evicted in Rev2011-001708 (now on appeal in 60331 and 61383) on
1111111, then wrongfully arrested on 11113112 in 11 cr 26405 (now feature in
61901, 62104, 54844, 60302, 60317, etc .. ) and incarcerated between 11/13/12 and
11/15/12, no continuance for the 11/30/12 Trial in 11 cr 22176, despite an
agreement in writing with City Attorey Pamela Roberts (whom put on perjured
testimony by three witnesses where she possess a video and other evidence
conclusively proving that Coughlin did provide his driver's license to RSIC Officer
Crawford ... and where Robert's prosecuted based on an arrest for a misdemeanor by
tribal officers where NRS 178.1255 bars such an arrest, and where Wal-Mart's
Thomas Frontino and Roberts herself admit no citizen's aest was effectuated .... so,
about that RPC 3.8 violation ... ). Then there is the appeal in cr12-1262 that Judge
Elliott, again, was "randomly" assigned from the conviction by RC Judge
William Gardner in 11 cr 26405 based upon the criminal trespass complaint signed
by Richard G. Hill, Esq. (opposing counsel in the summary eviction from
Coughlin's former home law ofce in rjc rev2011-001708, presided over by Judge
Sferrazza, though Hill and his associate Casey D. Baker, Esq. fax, on October 17th,
2011 to Judge Clifon (who was not Chief Judge at the time, or anything) an
Emergency Ex Parte Motion for Inspection of Coughlin's Law Ofice, and where in
his October 19th, 2011 Order in that matter 001708, Judge Clifton ruled as "moot"
Coughlin' 11117112 Motion to Set Aside the 11/13/12 Order following Summary
Eviction Proceeding by Judge Sferrazza setting the matter for "Trial" on 10/25/12,
on the condition that Coughlin deposit a rent escrow of $2,275 with the RJe
(though Judge Sferrazza admitted later on the record on 11/7/12 that the RJC Judges
had a meeting wherein they all had to agree that Coughlin was absolutely correct
that the RJC was violating Nevada law in having an unpublished "house rule"
corollary to JCRL V 44 requiring such rent escrow deposits in landlord tenants
matter here JCRCP 83 had not been followed in that the RC had not published and
had approved by the N. S. Ct. any such deviation from the statutory remedies set
forh in NRS 40 and lISA. Judge Elliott managed to torpedo that appeal of the
criminal trespass conviction stemming from the criminal complaint and custodial
arrest at Coughlin's former home law office by co-signing RMC Judicial Assistant
Usa Wagner's and the RC's nonsense about not having received Coughlin's
Notice of Appeal timely under NRS 189.010. The proof of delivery fax
confirmation indicates otherwise, Lisa. And regardless. the conveniently timed
arrest of Coughlin on 6/28/12, and the tolling nature of Coughlin's 6/26/12 Motion
for New Trial in that matter, and the kited, dated 7/10112 jailhouse Notice of Appeal
by Coughlin, and the curiously failure to grant Coughlin tier time in the interim
12/18/2012 10:19 7753375732
PAGE 15/39
while Judge Gardner manageed to push through his 7/11112 Order Denying
Coughlin's Motion for New Trial, is all the more reason to apply consteration to
Judge Elliott's work on the appeal on CRI2-01262.. Then there is Judge Linda
Gardner being Judge Peter Breen, MD's law clerk, and Breen kicking Coughlin out
of the Mental Health Court based upon Sharon Dollarhid, Rene Biondo, and Breen
ru'd the MHC's own breach of contact (if they provide program materials,
acceptance, and a contract that list cerain medications as disallowed, how is it the
can claim non-compliance or "failure to abide" by the rules for taking a medication
not listed therein? Don't ask WCPD Joe Goodnight or Jetnifer Rains ... they know
what side their bread is buttered on .... MHI2-0032 ... so DDA Young tries to jam
through a trial in 063341 on May 7th, 2012, despite the mandatory stay in NRS
178.405 and the then still pending Order for Competency Evaluation in rjc 2012-
065630 fom the clandestine status conference Dogan and Young never quite seem
to refute happening on 21271l2 ... 0h, and Judge Clifton, then DA Dorothy Nash
Holmes, and Judge Linda Gardner were all co-workers once upon a time, working
closely with then Sparks City Attorey/prosecutor Steven Elliott, whom worked for
the law firm of the father of the Panel Chair for Coughlin's 11/14/12 SBN v.
Coughlin formal Disciplinay Hearing in NGI2-0204, 0434, 0435 (the last two
being grievances against Coughlin filed, in pat, by RC Judge William Gardner,
prior to Gardner failing to recuse himself from the criminal tespass case against
Coughlin before him in 11 CR 26405 ... even where Judge Gardner's sister Judge
Linda Gardner's April 2009 Order sanctioning Coughlin was cited by WLS's Elcano
as the sole basis for firing Coughlin. and where Coughlin filed a Mandamus Petition
in 54844 challenging those sanctions, and where ng12-0435 was one of three
grievances fonning the 8/23/12 SCR 105 Complaint against Coughlin
(strangely .. .the Wal-Mar "candy bar" petty larceny conviction and the formal
hearing for the "sole purose" of determining Coughlin's punishment for such
required by SCR 111 (8) and the Court's 617112 Order got particularly short shrift in
the 8/23/12 triple grievance numbered SCR 105 Complaint by Bar Counsel Pat
"Patty Ice" King, a/ka Pat Salieri, whom wants no part of explaining his statements
to Coughlin during the 3/26112 appearance at the SBN by Coughlin, for the sole
purpose of taking King up on his offer to let Coughlin review the materials
submitted along with the grievances (therein King claimed to have received
grievances against Coughlin from three different Judges .... though, by 3/26/12. it
couldn't have been Beesley, as Coughlin only filed the exhibits detailing Judge
Nash Holmes and the WCSO and WCDA impermissibly confiscating Coughlin's
smart phone without a warrant or court order and well after the end of the period to
do a search incident to arrest (the arrest was 2/27/12 for some pastiche of summary
12/18/2012 10:19 7753375732
plenar civil criminal contempts statuts that Judge Nash Holmes whipped
PAGE 17/39
up .. .though she avoid NRS 22.030 and definitely there wasn't no affidavit signin' by
01' RMC Marshal Harley for alleged conduct in a restroom or restroom stall, which
assuredly was not "under the watchful eye of the court" or "in the immediate
presence" of the court .... so much easier for Bar Counsel to feed Judge Nash Holmes
the "clear and convicing evidence" standad from Schaefer required to prove an
ethical violation, have here copy and paste some RC's into a second bite at the
apple and more than 10 days later (civil statute, NRS 22.010, NRCP and JCRCP 59
allow sua sponte amending within 10 days. no 12 days ... 2/27/12 to 3/12/12 .... void
Order of 3/12112 by Judge Nash Holmes, so, sorry Patty Ice, nice try, no SCR
111(5) "an Order or conviction is conclusive proof of guilt and I don't recognize
Claibore as binding authority because it maes my job harder .... " .. ..
Thank You Jim for continuing to prevaicate in writing, your recent email combined
with some, uh, other materials that have been culled, will surely be helpful in
exposing you for the fraud that you are. And Biray Dogan too ... Oh, by the way,
that 11/7/12 fax confirmation page or proof of faxing? How is that coming along,
because I need to see it from you. My records show absolutely no receipt of any
fax of that sort, not on that day, not on any day ... which means the ball is in your
court to show how Dogan's representations to Judge Sferazza on 11/19/12 in court
were not displaying a lack of candor to the tribunal and How Leslie Tibbals'
certificate on service therein is not faud.
Oh, attached is Goodnight's 12 19 11 Request for Discovery, which includes:
through his attorey of record, Joseph W. Goodnight, Deputy Public Defender, and
hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295,
inclUsive. 1. Inspect and receive copies or photograph any written or recorded
statements or confessions made by the Defendant or any witness, or copies thereof,
within the possession, custody or contol of the State, the existence of which is
known or by the exercise of due diligence may become known to the prosecutor,
NRS 174.235(1)(a). This request includes any video and audio recordings,
including those presered on 10cket recording devices, 9-1-1 emergency calls, and
ay dispatch logs, written or recorded, generated in connection with this case."
12/18/2012 10:19 7753375732
PAGE 18/39
Jim, then there is you chiming in, in your role as "standby counsel", attempting to
aid the Court and DDA Young in coercing from me my Fifth Amendment rights at
the 9:06 am mark on the transcript from 11120/12 ("Your Honor, I'll remind the
Court that I am here to jump in in my role as standby counsel anytime the Court's
feels he is dragging his feet. . . . He is wasting County assets ! " . . . very Atticus Finch,
So, then there is Jim's 10/3/12 subpoena to EcommlKelley Wood . . . ad given he was
counsel of record until 10/22/12, yet completely failed to tum over anything
(responsive or not) in relation to that subpoena, and the fact that the entire
Suppression Motion tured on "what information the RPD received from dispatch",
nr the fat that the aldio of the "raQio traffic" between the RPD and Dispatch on
that mght or at least the porIons ot it 1 have been able to extract trom the powers
that be) reveal, one, no report of a possible fight was received by RPD (they were
on the scene by the time the 11 :27: 1 1 pm text was sent to the displays in their
vehicles, and the one audible "radio traffic" recording contains no mention of
anything beyond "check for possible larceny of a cell phone that just occurred,
suspect still on the scene, also reports of a loud verbal disturbance . . . ", Then there is
Jim and Goodnight completely whifing on the detaining argument, in addition to
the whole "assuming we win on the pat down, mae sure to oppose the notation that
there was sufcient probable cause for an arest and search incident thereto . . . . ", not
to mention that it was Coughlin (whose filings Jim managed to cheerlly announce
"The Public Defender's Ofice is not joining in on those fugitive documents . . . ",
despite the 2/21/12 Filings by Goodnight that do just that.. . . ) that pointed out the
whole NRS 171.360 basis for throwing out the search (which Jim managed to not
cite to or quote from in his closing argument as the Suppression Heaing . . . where
Jim did manage to ask Cory Goble questions on cross that were designed to do
nothing more than establish a citizen's arrest suficient to rebut the NRS 171.360
basis for throwing out the a est and fruits culled therefrom .. , ).
Oh. then there is youX' ofice blacking out the numbers of the callers on the dispatch
logs and refusing to tum over even a redacted version of the alleged victim's call
records for the time in question, thereby completely obstructing the defendant's
ability to impeach the various lies testified to by all the witnesses. And "Coach"
DDA Young can tell you all about his 40 minutes coaching sessions visible through
the plexiglass in the Justice Court lobby with Zarate, Goble, Lichty, and Templeton,
and their constant parroting (along with RPD Duralde) of "prosecutor buzzwords"
("will fully withheld", "report from dispatch of a possible fight", "my training and
12/18/2012 10:19 7753375732
PAGE 19/39
experience", "detained", "I don't remember who made the call", "I can't remember
which one of my friends it was who was with me", etc. , etc.) Also, the WCPD
practice of blacking out locations and addresses sure makes it difficult to establish
inconsistencies between testimony and the reportslWitness Statements or otherwise
utilize them for impeachment purposes . .
So, now today, we get this Jim Leslie email with all it's revisionist history . . . which
only contradicts the position Leslie and Dogan have taken that Coughlin already
picked up this 7127/1 2 packet (at first Dogan claimed to have personally handed it
to Coughlin, then changed his story 2 minutes later and said he saw Leslie
personally hand it to Coughlin . . . . and Dogan asserts to the Court at the 1 1/27/1 2
Hearing in rcr201 2-065630 that he has never spoken with Judge Dorothy Nash
Holmes (see materials regarding clandestine status conference of 2/27/1 2 and
subsequent fallout with Judge Nash Holmes of 2/27/12 a couple hours after Dogan
secured his 2/27/12 1 : 31 pm Order for Competeny Evaluation in 065630 from
Judge Clifton).
Te SBN v. Coughlin Complaint of 812311 2 specifically mentions the arrest of
1/14/12 that theis 065630 case is based on, in addition to the 063341 iPhone arest,
and RC Judicial Secretar Lori Townsend sent Coughlin's 2/21112 in 065630 to the
SBN, and offered to send Coughlin's 2115/12 filing in 063341 to the SBN . . . and
Judge Nash Holme's 3/1 2/12 Order in 1 1 T 26800 mentions Coughlin quoting
"rock lyrics" in a filing as a basis for her transmogrifying a " simple trafc citation"
to a "formal disciplinary heaing on an ethics violation" wherein she quotes the
Schaefer standard for an ethical violation that Ba Counsel had fed her earlier in the
day . . . and that window between the 1 :00 pm noticed start time of the traffic citation
trial in 1 1 t 26800 and the 3: 30 pm eventual start time includes the 1 : 25 pm
courthouse sanctuary doctine violating service upon Coughlin (by RMC Marshal
Joel Harley, on behalf of WCSO Deputy Machen, hired by Richard G. Hill, Esq., at
whose office Coughlin was retaliated against by RPD Sargent Tarter with the three
traffic citations shortly after Coughlin reported to Tarter the admissions regarding
bribery by Richard G. Hill, Esq. by RPD Officer Chris Carter, Jr . . . . and Marshal
Haley was serving the Order to Show Cause for the 3/23/1 2 Hearing in te appeal
of the summary eviction from Coughlin's former law ofice (where RPD Carer
made the trespass arrest now detailed in N. S. Ct. case 61901 ), on behalf of Deputy
Machen, in the conference room within the Courtroom B of the RMC, despite
Coughlin, an efler, having already been sered it). However, the only filing by
Coughlin that could be said to quote "rock lyrics" is the 2/21/12 fiUng in Dogan's
12/18/2012 10:19 7753375732
PAGE 20/39
case 065630 (the one where Dogan had appeared as attorey of record then failed to
show up for a hearing on 2/ 1 3/ 1 2, then retaliated against Coughlin for Coughlin's
2/21112 filing in 065630 by moving for a Competency Evaluation and basically
doing absolutely nothing on the case for the next 9 months besides raping fom
Coughlin his medical privacy rights along with Judge Steven Elliot and DDA Zach
Young at the 4/1 9/1 2 hearing in CR1 2-0376 (one of 3 criminal appeals Judge ElJ iot
was "randomly" assigned in which Coughlin is a pay . . . to go along with the
wrongful termination suit by Coughlin that Judge Elliot presided over in CVI l
01 955 wherein Coughlin sued CM Wand WLS, despite Judge Elliot sitting on
eA W's Board, and where Judge Elliot, the Panel Chair at Coughlin's formal
disciplinary hearing of 1 1114/ 1 2, and Washoe Legal Service's Paul Elcano all went
to Stanford together, and where Judge Elliot worked for Panel Chair John
Echeverria's father's law firm, Echeverria and Osbore). Then there is Linda
Gardner being Judge Breen's law clerk, and Judge Breen removing Coughlin from
Mental Health Court in MH1 2-0032, where the MHC's Rene Biondo and Sharon
Dollarhide lied about what medications were listed as accepted or not in the
materials provided by Goodnight and or the MHC along with the contract entered
into with Coughlin, whom was accepted into the MHC. Then there is WCPD Joe
Goodnight and Jennifer Rains refusal to file anything directed towads enforcing the
MHC's contract with Coughlin, wherein they bot demonstrated they know what
side their bread is buttered on and indicated " there just isn't a basis for seeking
reconsideration of Judge Breen's Order", Judge Peter Breen, MD.
Funny how Dogan did not state to Judge Clifton that he never spoke with anyone
else at the Reno Municipal Court about Coughlin . . . . including Marilyn
Tognoni . . . but, rather Dogan just indicated he never spoke with Judge Nash
Holmes, in his best innocent little boy voice that he cops when he isn't busy tittering
away with Jim Leslie i n the spectator area during the 1 1 119 and 1 1 /20 Trial in
063341 (where he failed to apprise Judge Sferrazza of the fraud attendant to his
earlier attestations regarding proof of service (by fax no less) of his 1 1/7/12 Motion
to Quash Coughlin's Subpoena . . . .
Also, its a bit strange how Dogan and the WCPD redact or black out the names of
the RPD Officers and Dispatch Operators beginning on page 16 of the .6 page fle
Jim Leslie finally emailed me today titled "Coughlin Discovery 91 1 Case", which,
as is their wont, he and Dogan have continued to change their stories about whether
they had or had not provided to me already until the last possible minute before
trial, whereupon, with a Trial date of December 1 1 t, 201 2 in rcr201 2-065630, Jim
12/18/2012 10:19 7753375732
PAGE 21/39
Leslie finally emails me a 56 page pdf purporting it to be my "file". One wonders
where any audio recordings, dispatch recordings, 9 1 1 call recordings or other media
are any why Leslie and Dogan did not provide them. Coughlin appeared at the
WCPD's Ofice today and asked for the hard copy of his file, yet was told by front
desk receptionist "Paula" (of course, no last name provided) that she "spoke with an
associate" and they told her that Jim Leslie had already provided Coughlin his file
and that he, therefore, would not be given the hard copy. "Paula" eventually
seemed to have to admit that the misleading use of the term "associate" actually did
not connote her having spoken with an attorey about the matter ... but rather Linda
Gray, whom has been curiously silent as to the apparent misconduct attendat to her
admitting that she did not mail out any written notice to Coughlin of the August 6th,
201 2 "combo-hearing" in rcr201 2-067980 Or rcr201 2-065630 (Leslie glossed over
at fact by sending Coughlin a note about how he "saved the day" with his
"advocacy" . . . skipping past the part about how the client, Coughlin, was not noticed
on the hearing in any matter, much less in writing . . . . Leslie later refused to indicate
with any specificity whatsoever how he "knew" Coughlin had been noticed on the
8/6/1 2 hearing in writing . . . and RJC Judges are only too willing to "believe" Jim
Leslie, Esq. when he explains away vaguely such things .. .
Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have
continued in your way (similar to how you approached the rcr201 1 -063341 case
where Joe Goodnight, Esq. was counsel of record until you had him removed on
7/1 6/12, the moring of Trial. . . afer Mr. Goodnight and I have completed a video
conference final trial preparation at 4:30 pm on Friday, July 1 3th, 201 2 while 1 was
in custody (pursuat to an arrest on July 3rd, 201 2, ordered by RD Sargent Kim
Bradshaw, she of the 1/12112 custodial jaywalking arrest along with RPD Sargent
Paul Sifre) . . . . Things fall through the cracks, Mr. Leslie, when you place a gag order
on the associates you claim to supervise, then stubborly, petulantly, and
retaliatorily refuse to work the cases you have snatched back fom your
associates . . . . Similarly, WCPD Fortier's email to me of Febrary 6th, 201 2 may have
contributed to Mr. Dogan's confsion in failing to attend te Hearing on Feburary
1 3th, 2012, which begat my filing of Febrary 21 st, 2012, which begat Mr. Dogan's
procuring the February 27th, 201 2 Order for Competency Evaluation, which begat
the 5 day summary incarceration for summary/plenary/criminal/civil/transmogrified
disciplinary hearing on an ethics violation/what is jUrisdiction? Order by RMC
Judge Nash Holmes on 2/27/1 2 at 4:40 pm . . . which begat NG1 20434, and probably
0435 (the SBN v. Coughlin SCR 105 Complaint of 8/23/1 2).
12/18/2012 10:19 7753375732 PAGE 22/39
However, Mr. Dogan, you are not off the hook just because Jim Leslie places a gag
order on you. Mr. Leslie sent this email today with a 56 page pdf fle purporting to
be my "file". I, as now a former client, have rights to "my file". I have requested
my file in writing from your ofce on numerous occasions, and given your removal
as counsel of record on 1 1122/1 2 (amazingly Mr. Dogan probably managed to say
200 words on a case that he had been counsel of record on for nearly a year, and
had not managed to file a single document in that case, RCR2012-065630, and had
managed to get upset that a client would take issue with his missing the 2/1 3/1 2
Hearing, even though WCPD Fortier's 2/6/1 2 email makes clear, the matter was
assigned to Mr. Dogan at that point, and he had already sat down and discussed the
case with Coughlin for over one hour on or about February 8th, 201 2, where
Coughlin went to check in with Mary Watson, whom was then represented by
WCPD Branzell, who dragged Watson over to te Sparks Justice Cour Bailiff and
demanded they breathalyze her client. They did, she was taken into custody.
So, after sitting down with Dogan for at least an hour and discussing various things,
some including matters related to the case he was then attorey of record on
RCR201 2-065630, the February 1 3th, 201 2 court date (Dogan and Coughlin have
conflicting views as to what was agreed upon and the applications of NRS
NR 178.388 provides that the defendant must be present at arrainment, ta, and sentencing and provides tat the
defndant may waive his appearance when cerai conditions are met.
Its kind of odd how Judge Clifon (whose attached bio indicates he has deep and
longstanding ties to the domestic violence industry infrastructure) knew
instantaneous to signing the Order for Competency Evaluation of 2/2711 2 at 1 : 31
pm that the matter would be randomly assigned to District Court Judge Steven
Elliot (also a lifelong prosecutor with deep and longstanding ties to the domestic
violence industrial complex, and a member of the Committee to Aid Abused
Women's (CAA W, one of the named defendants in the wrongful termination
lawsuit Coughlin brought and over which Judge Steven Elliot presided in CV1 1 -
01 955, where he failed to point out his per se conflict of interest to plaintiff
Coughlin at any time, and where he ultimately pulled out just about every wrinle
in the insufciency of service and or process and or service of process (a movie
showing a non party over 1 8 years of age serving a senior paralegal at Washoe
Legal Serices, whose Executive Director Paul Elcano went to Stanford with Judge
Elliot and the Panel Chair of Coughlin's 1 1/14/12 Formal Disciplinary Hearing
12/18/2012 10:19 7753375732
PAGE 23/39
before the State Bar of Nevada. John Echeverria in the late 1 960s . . . and Judge Elliot
worked at John Echeverria's father's law firm, Echeverria and Osbore Board of
Directors. in addition to being a former ass
In CV1 1 -01 955. Coughlin sued his former employer Washoe Legal Services. whose
Executive Director Paul Eleano went to Stanford in the late 1 960s with Judge
Steven Elliot and John Echeverria, the Panel Chair of Coughlin's 1 1/14/1 2 Formal
Disciplinary Hearing before the State Ba of Nevada . . and Judge Elliot worked at
John Echeverria's father'S law fir, Echeveria and Osbore, and Judge Elliot
served on the Board for CAA W, and was a prosecutor as the Sparks City Attorey,
Also. Mr. Leslie, while the 56 page pdf you finally sent me (gosh. was it that hard
to click "attach". load a 2 mb pdf fle and hit "send" on an email to me? No
debatin', no arguing about whether Leslie and Dogan left te package at the desk.
whether Dogan already gave it to Coughlin. or whether Dogan then changed his
story and said Leslie gave it to Coughlin, whether Coughlin already picked it up, no
claims by Jessica the Receptionist of anyone kickin' furiture . . . nothing like that,
just a digitally verifiable means of ascertaining what you tansmitted and
when . . . was that so hard? Heck, Jim, you could probably just email those ECOMM
recordings too . . . and if attachment size is an issue, sign up for a
(the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive
functionality, and up to 100 mb attachments via plan email, and over 25 free gb of
storage on the Skydrive, etc., etc. : .), But its Leslie fnally sent the 56 page "client's
fle" on or about 1 21711 2, yet he failed to include the insipid Motion of 1 1 126/1 2 by
DDA Young (wherein, just afer Judge Clifton finishes telling Coughlin at the
1 1127/1 2 Hearing that Coughlin is not allowed to even think about the other two
rc shotgunnin' stle splatter paint prosecutions by DDA Young, as "they are just
not relevant to this proceeding" . . . and anytime Coughlin would point out specific
basis for underaking a recusal or conflict analysis vis a vis either Judge Clifton, te
rc, DDA Young, the WCPD, or the WCDA, Judge Clifon would say "your're
losing me . . . your're losing me . . . " as if Coughlin was speaking in tongues all the
sudden . . .
So, while Coughlin is reportedly not even allowed to email DDA Young about
cases not even before Judge Clifton, or something like that . . . DDA Young is able to
get an unnoticed, ex pare, emergency Motion to Prho
12/18/2012 10:19
Zach Coughlin
1471 E. 9th SI.
Reno, NY 8951 2
Tel and FM: 949 667 740:
CC; BDogan@washoecounty.lIs
Subject: 91 1 Case
Date: Fri, 7 Dec 2012 17:09:08 +
Mr. Coughlin:
PAGE 24/39
Attached are the discovery materials I the above-referenced case that you had requested and we had made an
additional copy of for you in response to your equest. Please note that the July 27, 2012, cover letter was for
your pick up and you never picked it up. Note also that te July 27, 2012, packet encloses a copy of the April
i 7, 2012, hand delivery transmittal of te very same documents which you received.
Since we have been removed fom the 91 1 case, we are closing our file. The attached materials were sitting at
our front desk. Since you failed to retrieve them, we provide te attached courtesy copy before fUlal closue of
our fe.
No esponse to this transmittal is required from you.
James B. Leslie. Esq.
Chief Deputy Pblic Defender
Washoe County Pblic Dfender's Office
350 South Center Steet
fifh Foor
Reno. N 89509
1 -800-762-803 1
12/18/2012 10:19 7753375732
PAGE 25/39
Direct Dinl: 1153314828
raK: 775-3374856
n\e (ontents or this ecmmurtlcldon lnd all lccomply1nl dcurent1nd 1rhlenr. Dntln CONFlta1INFORTlON, art lepl1y pl"lVllesd; and lr Intlnded
fot ute nd revew only by to PAr $cmdllA ,.,me It the Intndld r!cpi!mt If you ar not the Intended pl(nt yCu anhlby notncd that an} dl:lo$ure, copyng.
dl.tbuQJl, Wil or tkng any lCol rellint on ,Id conttltr afO CONFIDENL and stcy prohlbll'd. IfyQI, received tis communimtIn eror, pleaR
Immedltely nQdf u. at 77S3374aOO to lnnRt retr oft tlrn:1 tsmlttll. Thlnkyou.