11 16 12 Skau Grievance Materials Combined 0204 063341

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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, 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 J udge Sferrazza authorized service of the notice of the hearing by
email...which J udge Sferrazza denies (in fairness to Mr. Skau...its possible the J udge
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 RJ C 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 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 J uly 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 J oe Goodnight gathered the three 911 calls.
Sincerely,
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
Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
Download all

From: "Creighton C. Skau" <skauc@reno.gov>
To: zachcoughlin@hotmail,com
Cc: "Jeannie Homer" <HomerJ@reno.gov>
Date: 11/09/2012 11:45 AM
5ubject: Fwd: FW: Case No. RCR2011-063341
--~v.e~~+~..,=.vmw-m@~, --- @- ~~->r -- -v.+.,;.- --......+>. - .
Page 1 of 10
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly,
authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alteratives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion.
Unfortunately, I cannot replicate the attachments. However, they consisted mostly of documents you
purportedly served, so you should be familiar with them. Also, I am providing alterative means for you to
obtain the documents, as set forth hereafer.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th
St.,
Reno, NV 89 512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you
were apparently not there. Today, Reno Carson Messanger Service again attempted to serve you there at
around 11 : 00 a.m. They called my ofice and were directed to leave the Judges Order and the City'S motion at
the front of that address. They have provided me with a photograph of the packet left at the front door.
(Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick
up at our Offce, third foor of City Hall.
The Judge's signed Order, entered November 8, 2012, states:
IN THE JUSTICE COURT OF RNO TOWNSHIP
STATE OF
NEVADA,
Plaintiffs,
COUNTYOF WASHOE, STATE OF NEVADA
vs.
COUGHLIN, ZACHARY BARKER
Defendant.
:ASENO.:
tCR011-063341
)EPT. NO.: 2
? P WtDL L DLDtPDt
This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorney's Office ("RCAO") represents a number of City of Reno employees who have
been named in subpoenas. The RCAO contacted Court personnel on November 7,2012 to request a time to
appear for an order shortening time regarding a motion to quash and for protective order. Due to the proximity
of the trial date in this matter, November 19 , 2012, the Court directed the RCAO to file and serve its
substantive motion and provide notice that the matter would be heard on November 8, 2012 at 9: 00 am. The
City of Reno fled its motion on November 7, 2012.
B. At the hearing on this matter on November 8, 2012, Deputy City Attorey Creig Skau appeared on
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l3,
Page 2 of 10
behalf of the RCAO and the City employees requesting protective relief. Zack Young was present in court.
Mr. Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public Defender's
office represented Mr. Coughlin, that the Public Defender was served believing this was service upon Mr.
Coughlin, that he leared Mr. Coughlin represented himself this moring and attempted to call and lef a voice
mail message with a phone number believed to be Mr. Coughlin's at 8:30 this moring.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal
Deputy City Attorney, Dan Wong, may also have received subpoenas and filed requests for relief similar to the
RCAO's requests.
D. The Court read the RCAO's motion in preparation for the hearing. Due to the absence of notice to Mr.
Coughlin, no argument was received on the merits of the motion. However, the Court fnds that the RCAO's
motion and supporting materials present a sufcient evidentiary basis to issue this Order.
The Court deeming itself suffciently informed and good cause appearing therefore,
b MV LHL as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November
2012. Oral presentations shall be limited to 10 minutes each. The Clerk shall notify Mr. Bosler and Mr. Wong
of the hearing.
2. Any subpoena not properly issued by the clerk or otherwise not properly issued in accordance with
NRS 174.305 is hereby quashed. Any subpoena not personally served by a non-party or otherwise properly
served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on any other grounds
such as relevancy or undue burden until the hearing on the merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective until the hearing on this
matter on November l3, 2012, to the effect that upon service of this Order on Defendant Zachary Barker
Coughlin, Defendant Coughlin shall not thereafer issue or cause to be issued or serve or attempt to serve or
cause to be served any subpoena or subpoena duces tecum in this case unless he has first presented the
proposed subpoena or subpoena duces tecum to the Court for the Court's review regarding adequacy, relevancy
and necessity of the subpoena or subpoena duces tecum, and suffciency of the proposed method of service.
4. Counsel from the Reno City Attorney's Ofce is directed to promptly attempt to serve a copy of this
Order and the RCAO's motion and any supplements by personal service upon Zachary Barker Coughlin at the
address in the Court's file, 1471 E. 9
th
Street, Reno, NY 89512, with a copy mailed to said address. Service
shall also be attempted by email at .. zachcoughlin@hotmail.com ...
Dated this _[8] _ day of November, 2012.
lsi
JUSTICE OF THE PEACE
The City of Reno's Motion states:
JOHN J. KADLIC
RenoCity Attorey
CREIGTON SKAU
Deputy City Attorney
NevadaState Bar No. 34
P.O. Box1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attore)sforCiqofBeno
IN THE JUSTICE COURT OF RENO TOWNSHIP
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D
Page J of 10
COUNTYOF W ASHOE, STATE OF NEVADA
I
STATE OF NEVADA,
Case No. RCR2011-063341
Plaintiffs,
Dept. No.2
vs.
COUGHLIN, ZACHARY BARKER,
_1PbM b1DPb PD
tPDt bb1PD b1DPb
COMES NOW, City of Reno ("City"), as the employer and on behalf of Reno Police Department
Ofcers Ron Rosa and Thomas Alaksa, and Court Marshall Joel Harley and Reno Emergency Communication
Center employees Savannah Montgomery and Scott Weese (and any other City employees (collectively "City
employees") whose names were unreadable in subpoenas), by and through their counsel of record, John J.
Kadlic,Reno City Attorey, and Creig Skau, Deputy City Attorey, and hereby moves this Court for an order
to quash the subpoenas claimed to have been served on for these City employees in violation of Justice Court
Rules of Civil Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
11/
JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and
any additional or further evidence the Court deems just and proper.
. b1312H2D1of 3c1s
The following procedural background is relevant to this matter:
1. On October 26, 2012, City of Reno Emergency Communication Center employees (ECOMM) Suzy
Rogers and Kelley Odom received emails from Zach Coughlin containing nine (9) Subpoenas, copies of
which are attached as Exhibit "I" and incorporated herein by reference.
2. On November 2,2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him,
among other things, the City of Reno Police Report and City of Reno ECOMM materials regarding Case
Number RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno
for $] 08. A copy of the letter is attached as Exhibit "2" and incorporated herein by reference. On
November 5, 2012, this same letter was sent again to Mr. Coughlin by certified mail to the same two
addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served
regarding the appearance of the City employees Ron Rosa, Thomas Alaksa, Savannah Montgomery and
Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b).
The letter indicated because service of the subpoenas for these four (4) individuals was ineffective, these
individuals would not be appearing on November ]9, 2012. (Exhibit "2").
4. On November 1, 20]2, Mr. Coughlin delivered twelve (12) subpoenas and a "Notice of Errata and
Revised Supplemental Motion For a New Trial" by sliding them
through the security glass in the front ofce of the Reno Police Department at approximately 4:50 p.m.
afer being told the ofce was closed. Three (3) subpoenas contained in this packet are duplicates. As
such, this packet appears to contain the same ten (10) subpoenas he previously sent to Reno ECOMM
employees Kelley Odom and Suzy Rogers. A copy of this packet is attached as Exhibit "3" and
incorporated herein by reference.
5. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM
employees, Kelley Odom and Kariann Beechler, seeking documents previously requested in earlier
subpoenas duces tecum. These subpoenas also contained multiple pages of requests for materials
unrelated to Case RMC RCR201 ]-063341. A copy of these documents is attached as Exhibit "4" and
incorporated herein by reference.
6. On November 5, 2012, Deputy City Attorey Robert Bony received a telephone call from Mr. Coughlin
regarding the letter this ofce mailed on November 2.2012. Among other things.Mr. Coughlin did not
indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery
and Scott Weese. Mr. Coughlin did state to have these witnesses ready for trial.
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party"
Page 4 of 10
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum
containing seventeen (17) pages of blended documents regarding matters pending before Reno Justice
Court on November 19 , 2012 and the State Bar Of Nevada Norther Nevada Disciplinary Board to the
Reno Police Department. The subpoena duces tecum on the first page of the packet contains many
unreadable names. A copy of the packet is attached as Exhibit "5".
1. On November 6,2012 City employee Marshall Joe Harley was handed a packet of materials from an
unidentifed person. The cover sheet of the packed is entitled "Subpoena Duces Tecum" regarding Case
RCR2011-063341. This document also appears to contain names of other individuals but the
handwriting is unreadable. It is not known if the other individuals on this subpoena are City employees.
A headnote on the Subpoena indicates that if the requested documents are e-mailed to Mr. Coughlin,
personal appearance may not be required. A copy of the packet is attached as Exhibit "6".
A. Service
. PtguH2u1
JCRCP 45 addresses subpoenas. In pertinent part it states:
(b) Service.
(1) A subpoena may be served by any person who is not a party and is not less than 18 years
of age. Service of a subpoena upon a person named therein shall be made by delivering a copy
thereof to such person and, jf the person's attendance is commanded, by tendering to that person
the fees for one day's attendance and the mileage allowed by law. When the subpoena is issued
on behalf of the State or an officer or agency thereof fees and mileage need not be tendered.
Prior notice, not less than 15 days, of any commanded production of documents and things or
inspection of premises before trial shall be served on each party in the manner prescribed by
Rule 5(b).
The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on October
26, 2012 and November 3, 2012 and re-delivered to the Reno Police Department on November 2, 2012 and
November 6,2012 commanding the appearance of the many different City employees above are deficient and
ineffective as they fail to comply with personal service requirement ofJCRCP 45(b). Accordingly, service was
ineffective and all of the subpoenas should be quashed.
In addition to the failure of personal service, all of Mr. Coughlin's subpoenas referenced in Exhibits "1", "3",
"4" and "5", also:
1. Violate JCRCP 45( a)( 1 )(D) in that they do not set forth the text of subdivisions (c) and (d) of JCRCP
45.
2. ViolateJCRCP 45(b)(l ) which states that a "subpoena may be served by any person who is not a
to the proceeding. All of the subpoenas were e-mailed to City ECOMM employees Kelley Odom,
Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2, 2012 and
November 6, 2012 by Mr. Coughlin, a party in this matter.
1. Violate JCRCP 45(b)( I) which states that service of a subpoena commanding attendance requires that
payment for one day's attendance and the mileage allowed by law. No witness fee or mileage fee has
been submitted by Mr. Coughlin for the appearance any named City employee.
2. Violate JCRCP 45(c) which states that a party or attorey responsible for the issuance and service of a
subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to
the subpoena. Mr. Coughlin is serving a litany of subpoenas on many City departments and City
employees regarding this case. However, he is also serving subpoenas on City departments and City
employees on a multitude of other cases and proceedings that are unrelated to the instant action. These
subpoenas are unduly burdensome, duplicative, irrelevant, unintelligible, oppressive, harassing, seek
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2.
Page J of 10
information that is irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the subpoenas for all City
employees to appear on November] 9, 2012 must be quashed. The City
also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann
Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate to the City or to
this matter.
B. Protective Order
In accordance with JCRCP 26, the City seeks a protective order in this matter. As described above, Mr.
Coughlin, a Nevada attorey with a suspended license, is abusing the subpoena process granted to him by this
Court. He is e-mailing multiple City employees or dropping off the same subpoenas (some of which relate to
this matter and many which relate to a State Bar proceeding or other criminal matters) at multiple City
deparments. This is creating confusion and leading to a waste of time and resources of public safety
employees. As an attorey, Mr. Coughlin should be aware of the subpoena process. This is not the frst matter
in which Mr. Coughlin has abused a court procedural matter. For this Court's information, Reno Municipal
Court Judge Holmes issued a Sua Sponte Order Denying Relief Sought in Improper Document on March] 3,
20]2 fnding, among other things, that Mr. Coughlin failed to follow proper legal procedure in preparing and
fling motions in a matter pending before that Court and that Mr. Coughlin blatantly abused that Court's fax
fling process. As such, that Court ordered that Mr. Coughlin be prohibited from faxing any documents to that
Court. A copy of this Order is attached as Exhibit "7".
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully seeks an Order from
this Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this Court for
review prior to issuance and service to ensure Mr. Coughlin is seeking relevant information regarding a
specifc case and is following the appropriate legal process.
. ^b^
Based on the above, it is respectfully requested that this Court issue an order:
I. To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel
Harley or any other City employee whose names were unreadable in the subpoenas for failure to comply
with JCRCP Rule 45;
To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann
Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate to the
City or to this matter because they failed to comply with JCRCP Rule 45.
3. Grant a protective order to the City pursuant to JCRCP 26 requiring Mr. Coughlin to submit any
subpoena he intends to serve in this matter to this Court for review prior to issuance and service to ensure
Mr. Coughlin's subpoenas are relevant and follow the appropriate legal process.
PWP^
The undersigned does hereby affirm that the preceding document filed in this court does not contain the
social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLJC
Reno City Attorey
By:
CREIGTON SKAU
Deputy City Attomey
P.O. Box 1900
Reno, NY 89505
H//orc)sforCiq ofBcno
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receiving party.
Page o of 10
As to the other matters addressed by you below, I work in the Civil Division and I have no knowledge or
authority to address them. I suggest that you take up those matters with the attorney(s) assigned to them.
Sincerely,
Creig Skau
Deputy Reno City Attorey
-----Original Message-----
From: Jeannie Homer <homerj@reno.gov>
To: "'bonyr@reno.gov'" <bonyr@reno.gov>. "'skauc@reno.gov'" <skauc@reno.gov>
Date: Fri. 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
8ent: Thursday. November 08.20128:36 PM
To: HomerJ@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov;
fflaherty@dlpfd.com; patrickk@nvbar.org;tsusich@nvdetr.org
8ubject: RE: Case No. RCR2011-063341
couldn't open them, and l don't accept service of anything form you ... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices
violation of the RMC Rules to the extent there is not difference technologically
anymore between an email and a fax:
Rule 5: Motions/Pleadings by Facsimile
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings
filed by facsimile, except as otherwise specified in this rule.
S. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior cour approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the
cover sheet and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the person's name,
address, fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firr's name, address, fax nurber
and telephone number. In addition, the attorney's state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by
facsimile when the receiving party is a governmental agency, an attorney, or with the consent of the If
service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the
time for response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the folio wing court day.
Rule 6: Continuances
No continuance shall be
g
ranted, includin
g
a stipulated continuance, except for
g
ood cause. A motion or stipulation for continuance
must state the reason therefore and whether or not any continuance has previously been sought or granted.
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ZachCoughli n@hotmail +com
ce_1_\cc.Ccm
( 17753344226).
Page 1 of 10
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich Hili getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-
03015 and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a
six week vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11
CR 22176, but then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the
stipulate to a continuance an blaming it on the Court.
Pursuant to RMCR Rule S(H), the City Attorney's Office does not have my consent to serice via any means other than the traditional
snail mail, usps, or personal service. And I am not currently included amongst those who are "attorneys", so you are stuck with that.
Your office on the other hand, fits within both the 'governmental agency" and "attorney exceptions" ... someone needs to tell
Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served where he has
been. Take, for instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules
in withdrawing from representation:
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the
same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same.
The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?
Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction
trespass case). Also, you will want to query the RMC's 02 and Lisa Gardner as to why Coughlin has a confirmation of delivery of
his timely under NRS 189.010 Notice of Appeal in 11 cr 26405, yet 02 failed to file it, and the appeal in cr12-1262 was dismissed in
light of the combination of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The
delivery confirmations say otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these tors. SBN, please
provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound I3report
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Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32generaI693298
( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From:
0:
Subject: Case No. RCR2011-063341
Please see attached documents from Creig Skau, Deputy City Attorney:
JD 28
1) Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding Issuance of Subpoenas (part 1
& 2)
2) Ex Parte Emergency Order Pending Hearing (set for November 13, 2012 at 9: 0 0a.m.)
hank you.
Jeannie Homer
Legal Secretary
I East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homer'@reno. OV
ATTORNEY-CLIENT PRIVILEGE
his e-mail message transmission and any documents, files or previous e-mail messages attached to it are confdential, and are
protected by the attorey-client privilege and/or work product doctrine. If you are not the intended recipient or a person responsible
for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or
use of any of the information contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED, If you have
received this transmission in en-or, please immediately notify us by forwarding this e-mail to the sender or by telephone at (775)
334-2050 and then delete the message and its attachments,
\ttachments:
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file:///R|/...20a%20NEW%20temp/11%208%2012%20emails%20to%20dogan,%20kandaras%20and%20skau%200204.htm[11/16/2012 1:24:04 PM]
Close Print
nrs 174.345
RE: Case No. RCR2011-063341
Sent: Thu 11/08/12 8:39 PM
To: bdogan@washoecounty.us (bdogan@washoecounty.us); jleslie@washoecounty.us
(jleslie@washoecounty.us); lgray@washoecounty.us (lgray@washoecounty.us);
enovak@washoecounty.us (enovak@washoecounty.us)
why didn't you send out a subpoena in the misdemeanor trial in 063341 in accord with the mailing
allowable under NRS 174.345? To Nicole Watson et al?
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
Sent: Thu 11/08/12 8:36 PM
To: HomerJ @reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org);
hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov
(robertsp@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org)
couldn't open them, and I don't accept service of anything form you... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
the RMC Rules to the extent there is not difference technologically anymore between
an email and a fax:
Rul e 5: Mot i ons/Pl eadi ngs by Fac si mi l e
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax
number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
the receiving party is a gover nment al agenc y, an at t or ney, or with the consent of the receiving party. If service of the
motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
J . Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
Rul e 6: Cont i nuanc es
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
state the reason therefore and whether or not any continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
becuase he has lied numerous times, on the record about not being served where he has been. Take, for
instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed
to follow RMC Rules in withdrawing from representation:
Rul e 3: Aut hor i zat i on t o Repr esent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
may rule on the motion or set a hearing.

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound fax report
Inbox x
J un 27
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
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J un 27
Hi zachcoughlin,
J un 28
Hi zachcoughlin,
J un 28
Hi zachcoughlin,
Vox ox noreply@voxox.com
to me
to me
to me
to me
LITIGATION HOLD NOTICE
J un 28
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
To: zachcoughlin@hotmail.com

1) Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding Issuance of Subpoenas (part 1 & 2)

2) Ex Parte Emergency Order Pending Hearing (set for November 13, 2012 at 9:00a.m.)

Thank you.

J eannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov


This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and
are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a person
responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying,
dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is STRICTLY
PROHIBITED. If you have received this transmission in error, please immediately notify us by forwarding this e-mail to the
sender or by telephone at (775) 334-2050 and then delete the message and its attachments.

to me
Sent: Fri 11/09/12 2:52 AM
To: mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
in rcr2012-067980 I was denied a phone call upon being booked for over 20 hours.
YOU ARE ON A LITIGATION HOLD NOTICE, ESPECIALLY WITH RESPECT
TO THE FRAUD OF "NURSE KATHERINE" (THE THIN, PETIT, DARK
BRUNETTE HAIRED NURSE) AND DEPUTY VAN DER WALL AND
BEATSON'S MISCONDUCT. ALSO, I WAS BEATEN BY DEPUTY HOEKSTRA
AND DEPUTY VAN DER WALL WRENCHED MY ARM.
Please mail me a certified check for $150,000 in settlement of these torts committed
against me under color of law in violation of Sec 1983 and numerous other statutes.
Additionaly, very valuable date was destroyed on both my smart phone and micro sd
card incident to the 37 days in which they were withheld from me. The phone itself
(HTC G2 $400 value) and the 32 GB micro sd card (not even counting the value of the
data, just the card itself is a $100 value) were destroyed prior to being returned to me.
Please issue me a check for those damages as well and mail it to the address below.
Further, please include in the materials produced in response to my various subpoenas
and copies or reproductions of any materials searched incident to any of my arrests, and
obviously included digital reproductions or hard copy reproductions created from digital
copies.
OBVIOUSLY, THE LITIGATION HOLD NOTICE EXTENDS TO THE
UNLAWFUL CONFISCATION AND DESTROYING OF THE MATERIALS
"BOOKED INTO EVIDENCE" (Yeah) INCIDENT TO THE 2/27/12 ARREST. As
the period of time in which a search incident to arrest was quite obviously passed (and
really, Court Marshals arguably do not have the authority to copy and or look through
hard drives, data cards, or smart phones....RPD and or WCSO's Office might under
Diaz, but not Court Marshals for Municipalities). The WCSO's Office has admitted
that the Reno Marshals returned and retrieved these items on 2/28/12, and it was not
within Judge Nash Holmes authority to Order that, so who did? Not without a warrant
that property cannot be release back to the RMC Marshals. A little late to try to
suggest it was "booked into evidence" at the WCDC the whole time, now isn't it? And
now DDA Young is teetering on the edge of being an accomplice to some rather
untenable fraud by persisting with these wrongful, retaliatory, pretextual prosecutions.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
file:///R|/...homer%20and%2011%209%2012%20skau%20reno%20city%20attorney's%20office%20emails%20063341.htm[11/16/2012 1:24:05 PM]
Close Print
Case No. RCR2011-063341
Fwd: FW: Case No. RCR2011-063341
From: J eannie Homer (HomerJ @reno.gov)
Sent: Thu 11/08/12 2:48 PM
3 attachments
Motion for Protective Order toQuash Subpoenas and for Protective Order Regarding
Issuance ofSubpoenas.pdf (2.2 MB) , Motion for Protective Order toQuash Subpoenas and
for Protective Order Regarding Issuance of Subpoenas[Part 2].pdf (1442.4 KB) , Ex Parte
Emergency Order PendingHearing.pdf (81.0 KB)



Thank you.

Jeannie Homer
Legal Secretary
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov


This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by
the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a person responsible for delivering it to the
intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information
contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please
immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and then delete the message and its
attachments.

From: Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
Cc: J eannie Homer (HomerJ @reno.gov)
1 attachment
photo[1].J PG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly,
authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion.
Unfortunately, I cannot replicate the attachments. However, they consisted mostly of documents you purportedly
served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the
documents, as set forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were
apparently not there. Today, Reno Carson Messanger Service again attempted to serve you there at around 11:00
a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that
address. They have provided me with a photograph of the packet left at the front door. (Attached). Accordingly,
you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at
our Office, third floor of City Hall.
The Judge's signed Order, entered November 8, 2012, states:



STATE OF NEVADA,
Plaintiffs,
vs.

COUGHLIN, ZACHARY BARKER

Defendant.

CASE NO.: RCR2011-
063341

DEPT. NO.: 2

EX PARTE EMERGENCY ORDER PENDING HEARING
This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorneys Office (RCAO) represents a number of City of Reno employees who have
been named in subpoenas. The RCAO contacted Court personnel on November 7, 2012 to request a time to
appear for an order shortening time regarding a motion to quash and for protective order. Due to the proximity of
the trial date in this matter, November 19, 2012, the Court directed the RCAO to file and serve its substantive
motion and provide notice that the matter would be heard on November 8, 2012 at 9:00 am. The City of Reno
filed its motion on November 7, 2012.
B. At the hearing on this matter on November 8, 2012, Deputy City Attorney Creig Skau appeared on behalf
of the RCAO and the City employees requesting protective relief. Zack Young was present in court. Mr.
Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public Defenders office
represented Mr. Coughlin, that the Public Defender was served believing this was service upon Mr. Coughlin, that
he learned Mr. Coughlin represented himself this morning and attempted to call and left a voice mail message
with a phone number believed to be Mr. Coughlins at 8:30 this morning.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal Deputy
City Attorney, Dan Wong, may also have received subpoenas and filed requests for relief similar to the RCAOs
requests.
D. The Court read the RCAOs motion in preparation for the hearing. Due to the absence of notice to Mr.
Coughlin, no argument was received on the merits of the motion. However, the Court finds that the RCAOs
motion and supporting materials present a sufficient evidentiary basis to issue this Order.

The Court deeming itself sufficiently informed and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November 13,
2012. Oral presentations shall be limited to 10 minutes each. The Clerk shall notify Mr. Bosler and Mr. Wong of
the hearing.
2. Any subpoena not properly issued by the clerk or otherwise not properly issued in accordance with NRS
174.305 is hereby quashed. Any subpoena not personally served by a non-party or otherwise properly served in
accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on any other grounds such as
relevancy or undue burden until the hearing on the merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective until the hearing on this
matter on November 13, 2012, to the effect that upon service of this Order on Defendant Zachary Barker Coughlin,
Defendant Coughlin shall not thereafter issue or cause to be issued or serve or attempt to serve or cause to be
served any subpoena or subpoena duces tecum in this case unless he has first presented the proposed subpoena or
subpoena duces tecum to the Court for the Courts review regarding adequacy, relevancy and necessity of the
subpoena or subpoena duces tecum, and sufficiency of the proposed method of service.
4. Counsel from the Reno City Attorneys Office is directed to promptly attempt to serve a copy of this Order
and the RCAOs motion and any supplements by personal service upon Zachary Barker Coughlin at the address in
the Courts file, 1471 E. 9
th
Street, Reno, NV 89512, with a copy mailed to said address. Service shall also be
attempted by email at zachcoughlin@hotmail.com.
Dated this _[8]_____ day of November, 2012.

/s/
JUSTICE OF THE PEACE

The City of Reno's Motion states:

JOHN J. KADLIC
RenoCityAttorney
CREIGTON SKAU
NevadaState Bar No. 34
P.O. Box1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneys for City of Reno


STATE OF NEVADA, Case No. RCR2011-063341
Plaintiffs, Dept. No. 2
vs.
COUGHLIN, ZACHARY BARKER,
__________________________________/
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER
REGARDING ISSUANCE OF SUBPOENAS

COMES NOW, City of Reno (City), as the employer and on behalf of Reno Police Department Officers
Ron Rosa and Thomas Alaksa, and Court Marshall Joel Harley and Reno Emergency Communication Center
employees Savannah Montgomery and Scott Weese (and any other City employees (collectively City
employees) whose names were unreadable in subpoenas), by and through their counsel of record, John J. Kadlic,
Reno City Attorney, and Creig Skau, Deputy City Attorney, and hereby moves this Court for an order to quash the
subpoenas claimed to have been served on for these City employees in violation of Justice Court Rules of Civil
Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
///

JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and
any additional or further evidence the Court deems just and proper.
I. Statement of Facts
The following procedural background is relevant to this matter:
1. On October 26, 2012, City of Reno Emergency Communication Center employees (ECOMM) Suzy Rogers
and Kelley Odom received emails from Zach Coughlin containing nine (9) Subpoenas, copies of which are
attached as Exhibit 1 and incorporated herein by reference.
2. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him, among
other things, the City of Reno Police Report and City of Reno ECOMM materials regarding Case Number
RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno for $108. A
copy of the letter is attached as Exhibit 2 and incorporated herein by reference. On November 5, 2012,
this same letter was sent again to Mr. Coughlin by certified mail to the same two addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served
regarding the appearance of the City employees Ron Rosa, Thomas Alaksa, Savannah Montgomery and
Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The
letter indicated because service of the subpoenas for these four (4) individuals was ineffective, these
individuals would not be appearing on November 19, 2012. (Exhibit 2).
4. On November 1, 2012, Mr. Coughlin delivered twelve (12) subpoenas and a Notice of Errata and Revised
Supplemental Motion For a New Trial by sliding them
through the security glass in the front office of the Reno Police Department at approximately 4:50 p.m. after
being told the office was closed. Three (3) subpoenas contained in this packet are duplicates. As such, this
packet appears to contain the same ten (10) subpoenas he previously sent to Reno ECOMM employees
Kelley Odom and Suzy Rogers. A copy of this packet is attached as Exhibit 3 and incorporated herein by
reference.
5. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM
employees, Kelley Odom and Kariann Beechler, seeking documents previously requested in earlier
subpoenas duces tecum. These subpoenas also contained multiple pages of requests for materials unrelated
to Case RMC RCR2011-063341. A copy of these documents is attached as Exhibit 4 and incorporated
herein by reference.
6. On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call from Mr. Coughlin
regarding the letter this office mailed on November 2, 2012. Among other things, Mr. Coughlin did not
indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery and
Scott Weese. Mr. Coughlin did state to have these witnesses ready for trial.
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum containing
seventeen (17) pages of blended documents regarding matters pending before Reno Justice Court on
November 19, 2012 and the State Bar Of Nevada Northern Nevada Disciplinary Board to the Reno Police
Department. The subpoena duces tecum on the first page of the packet contains many unreadable names. A
copy of the packet is attached as Exhibit 5.
1. On November 6, 2012 City employee Marshall Joe Harley was handed a packet of materials from an
unidentified person. The cover sheet of the packed is entitled Subpoena Duces Tecum regarding Case
RCR2011-063341. This document also appears to contain names of other individuals but the handwriting is
unreadable. It is not known if the other individuals on this subpoena are City employees. A headnote on
the Subpoena indicates that if the requested documents are e-mailed to Mr. Coughlin, personal appearance
may not be required. A copy of the packet is attached as Exhibit 6.
II. Argument :
A. Service
JCRCP 45 addresses subpoenas. In pertinent part it states:
(b) Service.
(1) A subpoena may be served by any person who is not a party and is not less than 18 years of
age. Service of a subpoena upon a person named therein shall be made by delivering a copy thereof
to such person and, if the person's attendance is commanded, by tendering to that person the fees for
one day's attendance and the mileage allowed by law. When the subpoena is issued on behalf of the
State or an officer or agency thereof, fees and mileage need not be tendered. Prior notice, not less
than 15 days, of any commanded production of documents and things or inspection of premises
before trial shall be served on each party in the manner prescribed by Rule 5(b).

The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and re-delivered to the Reno Police Department on November 2, 2012 and November
6, 2012 commanding the appearance of the many different City employees above are deficient and ineffective as
they fail to comply with personal service requirement of JCRCP 45(b). Accordingly, service was ineffective and
all of the subpoenas should be quashed.

In addition to the failure of personal service, all of Mr. Coughlins subpoenas referenced in Exhibits 1, 3, 4
and 5, also:
1. Violate JCRCP 45(a)(1)(D) in that they do not set forth the text of subdivisions (c) and (d) of JCRCP 45.
2. Violate JCRCP 45(b)(1) which states that a subpoena may be served by any person who is not a party to
the proceeding. All of the subpoenas were e-mailed to City ECOMM employees Kelley Odom, Kariann
Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2, 2012 and
November 6, 2012 by Mr. Coughlin, a party in this matter.
1. Violate JCRCP 45(b)(1) which states that service of a subpoena commanding attendance requires that
payment for one days attendance and the mileage allowed by law. No witness fee or mileage fee has been
submitted by Mr. Coughlin for the appearance any named City employee.
2. Violate JCRCP 45(c) which states that a party or attorney responsible for the issuance and service of a
subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to the
subpoena. Mr. Coughlin is serving a litany of subpoenas on many City departments and City employees
regarding this case. However, he is also serving subpoenas on City departments and City employees on a
multitude of other cases and proceedings that are unrelated to the instant action. These subpoenas are
unduly burdensome, duplicative, irrelevant, unintelligible, oppressive, harassing, seek information that is
irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the subpoenas for all City
employees to appear on November 19, 2012 must be quashed. The City
also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann
Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate to the City or to
this matter.
B. Protective Order
In accordance with JCRCP 26, the City seeks a protective order in this matter. As described above, Mr. Coughlin,
a Nevada attorney with a suspended license, is abusing the subpoena process granted to him by this Court. He is
e-mailing multiple City employees or dropping off the same subpoenas (some of which relate to this matter and
many which relate to a State Bar proceeding or other criminal matters) at multiple City departments. This is
creating confusion and leading to a waste of time and resources of public safety employees. As an attorney, Mr.
Coughlin should be aware of the subpoena process. This is not the first matter in which Mr. Coughlin has abused
a court procedural matter. For this Courts information, Reno Municipal Court Judge Holmes issued a Sua Sponte
Order Denying Relief Sought in Improper Document on March 13, 2012 finding, among other things, that Mr.
Coughlin failed to follow proper legal procedure in preparing and filing motions in a matter pending before that
Court and that Mr. Coughlin blatantly abused that Courts fax filing process. As such, that Court ordered that Mr.
Coughlin be prohibited from faxing any documents to that Court. A copy of this Order is attached as Exhibit 7.
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully seeks an Order from this
Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this Court for review
prior to issuance and service to ensure Mr. Coughlin is seeking relevant information regarding a specific case and
is following the appropriate legal process.

III. CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
1. To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel Harley or
any other City employee whose names were unreadable in the subpoenas for failure to comply with JCRCP
Rule 45;
2. To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler
and Suzy Rogers and/or submitted to the Reno Police Department which do not relate to the City or to this
matter because they failed to comply with JCRCP Rule 45.
3. Grant a protective order to the City pursuant to JCRCP 26 requiring Mr. Coughlin to submit any subpoena
he intends to serve in this matter to this Court for review prior to issuance and service to ensure Mr.
Coughlins subpoenas are relevant and follow the appropriate legal process.
AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in this court does not contain the
social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLIC
Reno City Attorney

By:
CREIGTON SKAU
P.O. Box 1900
Reno, NV 89505
Attorneys for City of Reno

As to the other matters addressed by you below, I work in the Civil Division and I have no knowledge or
authority to address them. I suggest that you take up those matters with the attorney(s) assigned to them.
Sincerely,
Creig Skau
Deputy Reno City Attorney

-----Original Message-----
From: J eannie Homer <homerj@reno.gov>
To: "'bonyr@reno.gov'" <bonyr@reno.gov>, "'skauc@reno.gov'" <skauc@reno.gov>
Date: Fri, 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Thursday, November 08, 2012 8:36 PM
To: HomerJ @reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov;
fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Subject: RE: Case No. RCR2011-063341

couldn't open them, and I don't accept service of anything form you... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation
of the RMC Rules to the extent there is not difference technologically anymore
between an email and a fax:

Rul e 5: Mot i ons/Pl eadi ngs by Fac si mi l e
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed
by facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover
sheet and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address,
fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile
when the receiving party is a gover nment al agenc y, an at t or ney, or with the consent of the receiving party. If service of
the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for
response.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the follo wing court day.
Rul e 6: Cont i nuanc es
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
state the reason therefore and whether or not any continuance has previously been sought or granted.

Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176,
but then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a
continuance an blaming it on the Court.

Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means other than the traditional
snail mail, usps, or personal service. And I am not currently included amongst those who are "attorneys", so you are stuck with that.
Your office on the other hand, fits within both the 'governmental agency" and "attorney exceptions"...someone needs to tell
Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served where he has been.
Take, for instance

Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in
withdrawing from representation:
Rul e 3: Aut hor i zat i on t o Repr esent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the
same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The
court may rule on the motion or set a hearing.

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely
under NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the
combination of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery
confirmations say otherwise.

Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please

Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
utbound fax report
Inbox x
Voxox noreply@voxox.com J un 27
Hi zachcoughlin,
You r Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox?
to me
Get Voxox: http://download.voxox.com and adjust your Notifications in the Settings/Preferences window. Voxox
by TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
Hi zachcoughlin,
Hi zachcoughlin,
Hi zachcoughlin,
Hi zachcoughlin,
to me
to me
to me
to me
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov



Thank you.

Jeannie Homer
Legal Secretary
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov


This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected
by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a person responsible for delivering it
to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the
information contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. If you have received this transmission in
error, please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and then delete the message
and its attachments.

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