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City Attorney Skau, updated discovery in iPhone
case, dispatch recordings, don't seem to reveal
basis for "a possible fight" assertions in office
testimony and prosecutors's filings and argument
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/14/12 2:09 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net
(nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org);
tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com
(je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com);
eifert.nta@att.net (eifert.nta@att.net); rhrc@laketahoelaw.com
(consult@laketahoelaw.com); stuttle@washoecounty.us
(stuttle@washoecounty.us); kadlicj@reno.gov (kadlicj@reno.gov);
wongd@reno.gov (wongd@reno.gov); schornsby@nvdetr.org
(schornsby@nvdetr.org); jleslie@washoecounty.us
(jleslie@washoecounty.us); jgoodnight@washoecounty.us
(jgoodnight@washoecounty.us); jbosler@washoecounty.us
(jbosler@washoecounty.us)
Dear DDA Young and Bar Counsel and Panel Members,
The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is
what started all this off (by "all this" I mean the 46 days in jail, the 10
different trips to jail, the five to six different evictions, all summary, the
competency evaluations, and all the associated grievances. This arrest and
prosecution have largely been based on and the office and prosecutor have
cited to, their contention that the information from ECOMM or dispatch told
the RPD Officers (and the arresting Officer Nick Duralde is married to a
dispatcher working that night and perhaps whose voice is on these files,
3/5/13 Outlook Print Message
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finally given to me only today, by Reno City Attorney's Office Creighton
Skau, after he secured my attendance at a hearing that I do not believe was
noticed in a legal since by sending me an email saying Judge Sferrazza
authorized service of the notice of the hearing by email...which Judge
Sferrazza denies (in fairness to Mr. Skau...its possible the Judge did say
that...Mr. Young could maybe shed some light on that, as apparently their was
a sort of group meeting with he, the Reno City Attorney and the WCPD on or
about November 8th, 2012 in rCR2012-063342, that I was not noticed on
and, of course did not attend).
Anyways, DDA Young and Officer Duralde have constantly harped on how
dispatch reported a "possible fight" and how that somehow justified the rash
approach taken by Officer Duralde, the overcharging of "oooh, that's a
felony" Felony Grand Larceny (7 days in jail, the eviction notice in the
Richard Hills summary eviction from my former home law office was served
during the interim in RJC Rev2011-001708) for a three year old iphone that
the alleged owner, Cory Goble, testified was worth about $80 at the time....
(and the overcharging of a felony enabled Officer Duralde to conduct a search
incident to arrest for a misdemeanor not committed in his presence, after 7
pm...which Nevada law prohibits, particularly where, as here, there was no
citizen's arrest (Coughlin himself called 911 and there is a video of the time
prior to arrest where Coughlin is heard imploring the skater youths to stay
peaceful and wait for law enforcement to arrive so a civil resolution of the
dispute could be garnered).
I am writing now and providing this new production of ECOMM/911
dispatch recordings that would seem to be the State's last hope of proving that
the Officers were told of, by dispatch, "a possible fight" and therein provide
some factual basis for that which Officer Duralde and DDA Young have
testified to, and filed pleadings in that matter arguing that reports of "a
possible fight" justified the subsequent terry stop weapons check pat down,
and search incident to arrest (remember, Officer Duralde announced 20
seconds into arriving on scene that he was going to arrest Coughlin and do a
search of Coughlin's pockets prior to conducting any of the pretexutal
"investigation" that he later testified to...its just that Officer Duralde did not
realize he was being recorded when he said that....no matter how he "remixed"
things in his Supplementary Declaration (filed within 48 hours of arrest) or
his Narrative (by all indications, the Narrative was only filed some three
3/5/13 Outlook Print Message
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months after the arrest and apparently after the RPD and City Attorneys Office
became aware that the video of the arrest was publicly available).
I have listened closely to these dispatch recordings and hear nothing about "a
possible fight". Does that make the Officer's Testimony perjury and DDA
Young's conduct misconduct? DDA Young, I have a Hearing in a few hours
on 11/14/12 at the SBN's Office on Double R. Blvd. I ask that you attend and
explain these matters as this arrest is pled in Bar Counsel Kings SCR 105
Complaint.
Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure
to subpoena the dispatch recordings until October 3, 2012 (despite the Trial
occuring on May 7th, 2012 (in violation of NRS 178.405, no less), and again
on July 16th, 2012....and, again on August 29th, and September 5th,
2012....and then please explain why you feigned inability to personally serve
subpoenas as a basis for failing to get Nicole Watson (easily found and or
served via a certified mailing under NRS 174.345, at the addresses your
investigator refused to turn over to me until November 2012 upon a court
order (you guys are supposed to help defend the accused, not the County or
local law enforcement against their potential civil liability for ego driven
foolish arrests) as a student at McQueen High School along with Lucy
Byington, both percipient witnesses, and where Watson was captured on tape
admitting to the "man with a six-pack" holding the phone aloft and offering it
up, and announcing, very loudly, that he woud "throw it in the river" if it was
not immediately claimed (therein presenting yet another claim of right defense
and further vitiating the legitimacy of DDA Young's retaliatory, deficiently
pled, amending of the Complaint on December 5th, 2012 to included
"possessing or receiving stolen property from another".
I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein
the City Attorney's gained an advantage and prejudiced my ability to defend in
both NG12-0204, etc. (the Bar Hearing) and the petty larceny Trial (in
RCR2011-063341). I will note that at least Joe Goodnight gathered the three
911 calls.
Sincerely,
3/5/13 Outlook Print Message
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Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 66 files to share with you on SkyDrive. To view them, click the links below.
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-45 PM Source_ID = 44.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 1.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-49 PM Source_ID = 31.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-00 PM Source_ID = 36.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-06 PM Source_ID = 38.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21.wav
Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
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