INDEX TO SBN CONSOLATION BOX OF 3,094 PAGES OF DOCUMENTS INSTEAD OF

ACCORDING COUGHLIN HIS RIGHTS UNDER SCR 105(2)(C) INCIDENT TO PANEL CHAIR
ORDER OF 10/31/12 in 62337:
http://www.scribd.com/doc/163691036/11-7-12-0204-62337-Bates-1-to-3-094-State-Bar-of-NevadaExcuse-for-Failing-to-Obey-SCR-105-2-c
The 3,094 bates stamped production to Coughlin by the SBN delivered on 11/7/12 came in the
form of one large box within which such documents were separated into four different volumes, bound
together only by a rubber ban and singular piece of cardboard style card stock placed at the back of
each volume, with such volumes each including a cover page that appeared to be a photocopy of the
outside of a folder baring the following names:
1 - 618
619-1654
1655-2700
2701-3,094

Pleading Created by Zach Coughlin Volume 1

Pleading Created by Zach Coughlin Vol 2
RMC Justice Court Docs folder
Formal Hearing File SBN v. Zachary B. Coughlin

Bates No:

Description of Documents

1 - 618
2-9

Pleading Created by Zach Coughlin Volume 1

2/21/12 Coughlin's Notice of Appearance; Motion to Dismiss in RCR2012-065630
(1/14/12 arrest ordered by RPD)
03/05/12 Coughlin's Notice of Appearance as Co-Counsel and Motion to Dismiss in
criminal trespass case before RMC Judge William Gardner in 11 CR 26405 (61901).
Index to Exhibits to 3/5/12 filing page 36 of 40 on fax header
Exhibit 1 cover page
page 38 of 40 of fax, Certificate of Service of 11/1/11 by Hill's Office
page 40 of 40 of fax (so page 39 was omitted, where such page consisted of WCSO
Civil Division Supervisor Liz Stuchell's admission that Deputy Machen's Affidavit of
Service alleging he personally served eviction order to Coughlin on 11/1/11 was false)
11/30/11 Notice of Appearance, Motion for Continuance in RMC 11 CR 22176 (see
60838)
TX Report (RMC serves RCA by email, yet takes issue with Coughlin utilizing email) by
D4 RMC of 12/15/11 Judge Howard Order re: emailing
page 1 of 24 Fax Cover Sheet fax header of 7:41 am of 12/16/11 followed by Coughlin's
Notice of Denial of Service, IFP Application, etc. in 22176
for no apparent reason, the Exhibit 1 cover page to Coughlin's 12/13/11 Notice of Appeal,
Motion to Vacate, Motion for Recusal with hand interlineated 893 pages plus CD of 5
files from Reno City Atty (2 videos) AP, codec to view files, 1 recording of John Ellis
Walmart retaliation in 22176
Coughlin's 3/7/12 Notice of Appeal of Summary Contempt Order, Motion to Return
Personal Property Confiscated by RMC, Motion for New Trial and to Alter or Amend
Summary Contempt Order in RMC 11 TR 26800 before Judge Holmes (224 page fax of
1:58pm consisting of 54 page Motion and 166 page Exhibit 1)
3/9/12 1238pm 218 page fax of Motion to Return Cell Phones, Motion to Set Aside
Summary Contempt Order, Notice of Appeal of Summary Contempt Order in 26800.

10 - 48
45
46
47
48
49-126
127
128-151
152-170

171-394

395-612
1/31

613-618 email from Coughlin to RMC Chief Marshal Roper of 12/14/11 re Complaint
about Marshal Menzel and never receiving copy of 11/30/11 Contempt Order, and RMC's
Veronica Lopez failing to fax such as she had agreed to.
613
emails to Coughlin from RMC Chief Marshal Justin Roper indicating such is responsive
to voice mail Coughlin left on 12/13/11 making complaint regarding Marshal Menzel's abusive
approach at 10/11/11 arraignment in Wal-Mart candy bar petty larceny case resulting in 60838
temporary suspension, and Menzel's nearly knocking over RMC's Ballard on 12/13/11 in attempts to
intimidate Coughlin while Coughlin sought to timely file his Notice of Appeal and Motion to Set Aside
conviction of 11/30/11, and Roper's failing to address Coughlin's contention that the 11/30/11 Order
Punishing Summary Contempt (FHE11) in 11 CR 22176 was not provided to nor served on Coughlin
by the RMC or any of its Marshals on 11/30/11 where Roper, rather, focuses on the 11/30/11
Judgment of Conviction and Court Order (attached in FHE1 to King's 8/23/12 Complaint) and to the
SCR 111(6) Petition in 60838) where Roper fails to alleged such FHE11 was similarly provided to
Coughlin or booked into his property, referencing RMC Judge Howards Judicial Assistant Veronica
Lopez, whom later lied to Coughlin on during a 12/5/11 telephone Coughlin in responding to
Coughlin's request for a copy of any Order finding Coughlin in contempt (as Coughlin was absolutely
not provided such on 11/30/11 or anytime thereafter until such was included in the ROA filed in the
appeal in CR11-2064, though, such being made in absentia of one of the parties (RCA prosecutor
Pamela Roberts, Esq.).
613-618
Coughlins' email response to RMC Chief Marshal Roper's 12/14/11 email responding to
Coughlin's 12/13/11 voice mail regarding 11 CR 22176 (FHE1, FHE11, etc.): "Subject:
RE: Message left on 12/13/2011 From: Zach Coughlin (zachcoughlin@hotmail.Com)
Sent Wed 12/14/11 6:52 PM To: roperj@reno.Gov; fiskg@reno.Gov; ballardd@reno.Gov;
renomunirecords@reno.Gov.
619-1654
620-621

Pleading Created by Zach Coughlin Vol 2

email from Coughlin to SBN King of 4/16/12 Subject: Mr. King's assertion in his 3/16/12
letter wherein Coughlin writes: Anyway, I deny guilt on each an every allegation
made against me by Hill, Judge Nash Holmes, and whoever else has filed a grievance or
complaint and also with respect to any criminal charge against me, including that which resulted
in a conviction in 11 CR 22176, which, I think will ultimately reveal was replete with
prosecutorial misconduct, lying by the Wal-Mart loss prevention associate, and lying by the two
RSIC police officers, in additional to abuse of discretion and other errors by Judge
Howard....
622-623
More possible SCR 121 breach of confidentiality violations by the SBN in inadvertently
including materials from something involving Maria Campos and Leslie Moon Subject: Rio and
Maria@accessnv.org.
625
page 2 of 63 page fax of 10/3/12 at (9:26 am from Coughlin to SBN of Motion for OSC
, in 60838, which is verbatim to, aside from the caption, coughlin's 10/16/12 file stamped
Motion for OSC in the disciplinary matter now on appeal in 62337)
686
fax cover sheet page 1 of preceding 63 page fax from Coughlin to SBN stamped
received by SBN 10/3/12 (indicating there should be at least such a stamped received
fax from Coughlin of 9/18/12 consisting of Coughlin's Motion to Dismiss, though there is
no such document in the SBN's 3,094 page production, which is dubious given the salient
importance of such in light of Coughlin's argument that DCR 13(3) provides that King's
failure to oppose such may be taken as an admission thereof.
2/31

688

page 1 of 40 page fax from Coughlin to RMC of 3/5/12 fax header 10:56 am Notice of
Appearance as Co-Counsel and Motion to Dismiss in RMC 11 CR 26405 criminal
trespass case before Judge W. Gardner referred to in King's 8/23/12 Complaint
702
page 15 of Coughlin's 3/5/12 Motion to Dismiss in 26405 (proving 3 5 12 0204 26405
Motion to Dismiss's page 16 excised from 11 7 12 SBN production between bates 702
and 703 detailing burglary by Hill, WCSO, RPD, Gayle Kern, Esq., Nevada Courts
Services, Park Terrace, Northwind Apartments, Superior Storage, etc, incident to failure
to accord 24 hours to tenant from receipt of lockout order per NRS 40.253), which,
contrary to RMC Judge W. Gardner's judicial misconduct display in ruling such motion lacks merit,
actually exposes the Nev. Const. Art. 4 Sec. 21 violations that the judiciary in Washoe County and
Reno have been countenancing in doing much more than turning a blind eye to the state sponsored
burglaries by the Washoe County Sheriff's Office in failing to accord tenants the 24 hours from the
tenant's receipt of the (summary removal) order prior to the WCSO conducting a lockout incident
to a summary eviction, where page 16 thereof (which, again, was excised by either the RMC in
providing such to the SBN, or by the SBN, but clearly not by Coughlin in faxing such to the RMC as
the fax headers and pagination therein tell the tale and lock the SBN and RMC in a finger pointing
contest.
703
page 17 of Coughlin's 3/5/12 Motion to Dismiss in 26405
724
illegible page 39 of 40 page fax to RMC from Coughlin with WCSO Stuchell's admission
that Deputy Machen's Affidavit of Service is incorrect where it alleges Coughlin was
personally served where version included by King in 4/16/12 23 Exhibit presentation
to NNDB Screening Panel excised such page.
726-760
page 1 of 35 page fax from Coughlin to RMC in 11 CR 26405 trespass case Judge W.
Gardner Notice of Appeal, Motion to Vacate, Motion for Recusal, IFP (with such page
listing Coughlin as an Esq. with his NV Bar Number above caption), responding to
2/2/12 Order granting RMC defender Puentes' Motion to Withdraw.
733
Index to Exhibits to Coughlin's 2/16/12 Motion indicating Ex. 1 consists of 26 pages of
correspondence between Coughlin and Puentes detailing the burglaries on Coughlin's
former home law office by Hill, WCSO, and RPD.
761
page 1 of 8 of Coughlin's fax to RJC in RCR2012-065630 Notice of Appearance, Motion
to Dismiss that RJC Judicial Secretary Lori Townsend emailed to SBN on 4/11/12.
769
duplicate of preceding 8 page faxed Motion to RJC by Coughlin duplicated for no
apparent reason.
777-811
Coughlin's 2/13/12 fax header 2:57 pm to RMC of 35 page Notice Motion to was
duplicated inadvertently by Coughlin's faxing such again on 2/16/12 in trespass case
before Judge W. Gardner.
812-846
Coughlin's 2/16/12 fax header 8:10 am 35 page Notice Motion in RMC 11 CR 26405
criminal trespass case Judge W. Gardner
847-885
Coughlin's 40 page faxed motion to RMC of 3/5/12 header 10:56 am with RMC Ballard
certification.
884
page 38 of 40 of Coughlin's faxed Motion (note page 39 of 40 is missing in light of page
885
being page 40 of 40, with such excised page being WCSO Stuchell's 2/12/12 admission in
an email to Coughlin that Deputy Machen's Affidavit of Service indicating Coughlin was
personally served the Eviction Order in the summary eviction handled by Hill's firm
was actually merely posted on Coughlin's door, and not personally served on 11/1/11).
885
page 40 of 40 of faxed Motion to Dismiss in RMC 26405.
3/31

886-925

924
926-928
929-1003
1002
1003
1004-1093

1094
1095
1096-1171

1172
1192
1216
1217

page 1 of 40 of Coughlin's 3/3/12 fax header 3:09 pm fax to RMC of same 40 page
Notice of Appearance, Motion to Dismiss immediately preceding with RMC's providing
to SBN likely indicative of annoyance as receiving same fax twice, though is not clear
whether one copy was faxed to chambers for RMC's convenience or if Coughlin was
simply having problems adjusting to his new Voxox fax desktop computer internet based
faxing application.
page 39 of 40 page fax to RMC by Coughlin of 3/3/12 consisting of 2/7/12 emailed
admission by WCSO Stuchell that she considers posting an order on Coughlin's law
office door when no one is present to be personal service.
apparently inadvertently sent by RMC to SBN materials form Mandi Wolf and Patrick
Parker relating to their traffic matters in the RMC
page 1 of 76 page fax header 802 am to RMC of 12/16/11 fax cover sheet identifying
Coughlin as attorney followed by Supplemental to Notice of Appeal/Motion to Vacate in
RMC 11 CR 22176 (60838) before RMC Judge Howard.
page 74 of 76 per fax header (ie, page 75 of 76 was excised in consideration of
incongruity between SBN bates stamping of 11 7 12 and pagination per fax header of
12/16/11 fax from Coughlin to RMC where Page 75 was Coughlin's Index to Exhibits)
page 76 of 76
page 1 of 92 of Coughlin's faxed to the RMC on 12/19/11 fax header 5:24 pm
Declaration and Supplement to Motion for New Trial where at bates 1,052 is Coughlin's
CV08-01709 filing before 2JDC Judge Flanagan (page 50 of 92 page fax) and bates 1,082
is filing by Coughlin before NVB Judge Beesley in NVB-10-05104 Cadle Co. v. Keller.)
Coughlin's 2/24/12 fax header 10:14 pm RMC Record Request dated requesting copy of
Contempt Order file stamped 2/27/12 in RMC 11 CR 22176 (60838).
Case Docket from RMC in 11 CR 22176 (60838) before Judge Howard.
page 1 of 76 page fax from Coughlin to RMC of 2/24/12 fax header 9:00 pm file stamped
2/27/12 at 8:14 am same day at traffic citation trial leading to summary contempt
incarceration of 5 days by Judge Nash Holmes in 11 TR 26800 listing 1422 E. 9th St. #2
as Coughlin's address where Holmes had 2/28/12 Contempt Order (FHE4) sent to 121
River Rock address she knew Coughlin had been evicted from.
Coughlin's 12/16/11 24 page fax header to RMC 7:41 am in RMC 11 CR 22176 (60838)
with fax cover page to RCA Roberts followed by Coughlin's Notice of Denial of Service.
page 21 of 24 of such fax
last page of portion of Coughlin's 12/13/11 filing in RMC 11 CR 22716 lacking a fax
header version hand delivered to RMC
page 2 of 24 page fax filed with the RMC from Coughlin 12/16/11 Notice of Denial of
Service with RMC Ballard Certification where page 1 of 24 was excised where such was
a fax cover page listing Coughlin as an attorney and providing his NV Bar No. in a
fraudulent attempt by RMC, Ballard, and SBN to support bogus IFP allegations.

1655-2700

RMC / Justice Court Docs folder

1656
1657

11/15/11 Notice Setting Trial date of 11/30/11 in RMC 11 CR 22176 (60838)

Additional Case Information listed for original 11/14/11 date of bench trial indication:

4/31

3 city witnesses had appeared for bench trial...DEFENDANT WAS IN CUSTODY

AT TIME AND DATE OF BENCH TRIAL; DEFENDANT WAS TRANSPORTED BUT NOT
BROUGHT INTO COURT...BAIL FORFEITURE CANCELLED where such references RMC
Judge Howard's having revoked Coughlin's bail, setting it at $1,000 where such is normally $360.00 on
11/14/12 upon Howard allegedly believing Coughlin failed to appear. However, this 11/15/11 Notice
Setting Trial proves that Howard was aware that Coughlin did not fail to appear, incident to which the
BAIL FORFEITURE CANCELLED, however, in denying the Motion for Continuance Coughlin
submitted on 11/29/11 (where this 11/15/11 Notice Setting the Trial Date was not appropriately served
on Coughlin in that it was mailed to the very 121 River Rock St. address from which Coughlin had
informed the RMC he had been wrongfully summarily evicted via his 10/26/11 Application and
Affidavit for Appointment of Legal Defender thereof.
1659-1792

Cover sheet for folder titleZACHARY COUGHLIN CASE NO. 11CR22176

JUDGE KEN HOWARD DEPARTMENT FOUR
In this folder King and the SBN attempt to obfuscate matters further by including filings,
and orders from matters presided over by two judges other than RMC Judge Howard where items from
the criminal trespass case before Judge W. Gardner in 26405 and the traffic citation case before Judge
Holmes in 26800 are included.
1662
RMC Marshal Moser report of 12/13/11 harassment of Coughlin by Marshal Menzel
1654
RMC Marshal Menzel report of 12/13/11 court as police state approach of RMC Marshals
1671
Coughlin's email to King and Peters of 10/3/11 detailing fears related to providing
his physical address (NOTE: King hides this hear to further his lame SCR 109
approach vis a vis the fraudulent 8/23/12 Affidavit of Service by Peters attached to
Complaint).
1672
RMC Court Administrator Jackson sends an SCR 111 letter for 61901 (the criminal
trespass conviction before RMC Judge W. Gardner in 11 CR 26405 of 6/18/12) on
6/21/12 where she and or the RMC failed to in 60838 (making the inclusion of such in a
folder identified at 1659 as being that of a package related to (though not clearly from, and perhaps
being the items collected from Coughlin's case in Department 4 referenced in Judge Holmes' 3/14/12
letter to the SBN, though, as always, King obfuscates such as much as possible in his bad faith attempts
to obstruct the disciplinary process (and who knows how many other instances of an attorney being
convicted of a crime despite SCR 111(3) requiring that the clerk of any court in which an attorney is
convicted of a crime...shall transmit a certified copy of proof of the conviction to the supreme court
and bar counsel within 10 days after its entry) for 11/30/11 conviction, much less for either criminal
contempt criminal convictions. The SBN's LCL Coordinator Coe Swobe told Coughlin he probably
did not need to report the candy bar petty larceny conviction during an early January 2012 discussion
with Coughlin, however, Coughlin did anyways.
1677
fax from Reno City Attorney to Richard G. Hill, Esq., that Hill provided to SBN
consisting of 2JDC Judge Elliott's Order dismissing Coughlin's appeal of criminal
trespass conviction in RMC 11 CR 26405 (61901) 3 pages from 9/10/12 containing
8/27/12 Order in CR12-1262
1680
RMC Judge Howard's 11/30/11 OPSC twice, both times lacking any Certificate of
Mailing
1684
Coughlin's 12/13/11 5:01 pm filed Notice of Appeal, Motion to Vacate or Set Aside,
Motion for Recusal in RMC 11 CR 22176 (60838) lacking entirety of exhibit 1's 893
pages which was emailed for filing to RMC (by permission from D. Ballard, which she
5/31

fraudulently failed to include in ROA transmitted to 2JDC).

RMC Judge Nash Holmes 3/13/12 Order Striking Fugitive Document filed on 3/7/12
(Coughlin's IFP Motion/Affidavit in Support of and Request for Audio of 2/27/12 trial
before Holmes in 11 TR 26800 (NG12-0434)
3/12/12 Order by Holmes in 26800 that became FHE5
11/30/11 Coughlin's Notice of Appearance Motion for Continuance in RMC 11 CR 22176
(60838)
RCA Hazlett's Motion to Continue trespass trail in RMC 26405 because Richard G. Hill,
Esq., witness, will be on vacation.
10 10 11 Notice Setting trial for 11 14 11 Coughlin notates Marshal Menzel's bullying
behavior 22176
11/30/11 Order Continuing Trial by RMC Judge W. Gardner in trespass case 11 CR 26405
(61901) makes no sense for it to be within folder for Judge Ken Howard

1694
1701
1707
1785
1790
1792
1793-1823

Cover Sheet for folder titled Zachary Coughlin Case no 11TR26800 Judge D. Nash
Holmes Department 3
NOTE: though the SBN's presentation of such within the 3,094 bates stamped production
provides absolutely no indication of such, it appears the items in this folder may represent the materials
from the matter before her that Judge Holmes indicates in FHE8's 3/14/12 letter to the SBN that she is
including within the box of materials she or what she refers to as our staff had gathered for
transmission to the SBN, as none of the materials contained within such folder (between bates 17931823) are from any date post-3/14/12, the date of Judge Holmes' letter to the SBN. However, tellingly
FHE3's 4/13/09 Order After Trial by 2JDC Judge L. Gardner is not included amongst these items, and,
in fact, such 4/13/09 Order appears to have been purposefully placed far away from the materials with
which both Judge Nash Holmes and King (though he remained purposefully vague in his 4/19/12 email
to Coughlin admitting the clerk of court provided such FHE3 to him at his request, which only begs
the question of why he failed to therein identify which court such clerk resided in (especially wehre the
FHE3 Order issued from a 2JDC Family Court Judge and King actually received such from Jude
Holmes' RMC Department 3... Should it be true that such 4/13/09 OAT by 2JDC Judge L. Gardner
was not included amongst these items in the folder identified as that for 26800 before Holmes (and why
would it be in such folder, if Holmes included it in her original box of materials attached to her
3/14/12 letter, it would not logically be placed amongst a folder devoted to 26800)...
So, where King and Holmes ultimately had to admit that King obtained 2JDC Judge L.
Gardner's 4/13/09 Order After Trial from Judge Holmes after Holmes's clerk of court(where King
coyly fails to identify which court in an attempt to sweep widespread judicial misconduct having a
prejudicial effect on then pending cases involving Coughlin presided over by the very judges
committing such misconduct) provided it to King at King's request, King and the SBN have been
caught attempting to manipulate the record in this matter within the 3,094 bates stamped page
production where the first King positions such FHE3 4/13/09 2JDC Judge L. Gardner Order After Trial
within the holder devoted to the NG12-0204 Richard G. Hill, Esq. grievance file (wherein it comes
immediately after a similarly non-sensical placement of Judge Holmes' 3/14/12 FHE8 letter to the
SBN. Such attempts to obfuscate and obstruct the disciplinary process in bad faith resulted in the
FHE3 appearing with and at the following bates stamped pages:
2955-3017
6/31

Grievance File #NG12-0204 A: Zachary Coughlin G: Richard Hill, Esq.

2959
RMC Judge Nash Holmes' grievance letter to the SBN (why on earth such is
placed in the folder for Hill's grievance, other than being another attempt at obfuscation by
King, is not clear at all)
2961
2JDC Judge L. Gardner's 4/13/09 Order After Trial, FHE3 compare 5 in 15 of
Received Mar 15 2012 to other versions (ditto).
1824-1964

Cover Sheet for Case No. 11CR22176 Judge Ken Howard Department Four
NOTE: King and the SBN further attempt to manipulate the record as to SCR
105(2)(c) materials at bates 1824, where, rather obviously, King has simply taken the Cover Sheet for
the folder within the box of materials provided with Judge Holmes 3/14/12 FHE8 letter to the SBN
and included in such folder between bates 1824-1964 (and to be clear, there were no physical folders
in the box of 3,094 bates stamped pages produced to Coughlin four judicial days prior to the formal
hearing, but rather, such box contained four very large stacks of photocopies separated by a single sheet
of cardboard backing each and a large rubber band around each, and where King and Peters refused to
answer any clarifying question, either written or verbal from Coughlin seeking any sort of reference
points or context in connection with identifying the source of the materials included therein. Where
Coughlin refers to folders, other than the four main folders separated by rubber bands and a sheet
of heavy card stock backing such, he is referring to instances within those four folders wherein a cover
sheet of sorts appears to identify the materials appearing thereafter as forming a collection of
documents that would comprise the contents of a physical folder had photocopying a folder been done,
which, clearly, the SBN did not do, which further obstructed Coughlin's ability to synthesize and
analyze these materials, particulary where only a scant four judicial days were afforded to Coughlin to
do so, even though SCR 105(2)(c) requires such be available to Coughlin 30 day's prior to the hearing.
Within this hodge podge of materials culled by King (some of which are obviously connected to
Richard G. Hill (as revealed by the fax headers indicating such are being faxed from the Reno City
Attorney's Office to Hill's office found atop the Orders by 2JDC Judge Elliott in Coughlin's appeal of
the criminal trespass case in 26405 wherein Hill signed the criminal complaint therein and also testified
at the 6/18/12 trial before RMC Judge W. Gardner) and likely produced to the SBN by Hill as a
supplement to his purported initial email to King of 1/14/12 (which brings up the question as to why
there is no appearance of the 8/28/12 Order in CV11-03628 by Judge Flanagan that would operate as
Brady material here, which King emailed to Coughlin as an attachment on 8/30/12 and which
completely undermines Hill and King's assertion the FHE2 is a sanction, and thereby vitiates the
offensive collateral estoppel on steriods approach the Panel cheered King on in attempting to apply to
such FHE2.
The remained of the materials found in the folder beginning with a RMC Judge Howard
cover sheet at bates 1824-1964 Cover Sheet for Case No. 11CR22176 Judge Ken Howard
Department Four seem to consist largely of vindictive and amateurish attempts by RMC court staff to
conduct a smear campaign of Coughlin where Coughlin had brought to light the egregious misconduct
of the RMC filing office supervisor Donna Ballard, the clerks she supervises, the RMC Marshals, and
RMC Court Administrator Cassandra Jackson (much of which was brought to NVB Judge Beesley's
attention in Coughlin's 3/30/12 filing in 10-05104, which Beesley was so speciously silent to in his
sworn testimony. Beesley's curious failure to mention such in any way makes all the more
unacceptable the SBN and Beesley's continued refusal to provide that to which Coughlin is absolutely
entitled, the letter to the SBN regarding Coughlin that Judge Beesley testified about.
7/31

Having been caught in his original lies upon Coughlin comparing King and Peters statements
during in person discussions with Coughlin, telephone conversations, and written correspondence
between the three, King was left with few options as to where to place such FHE3 within the 3,094
page bates stamped production, but, ultimately, and not surprisingly, King chose the most fraudulent
and bad faith attempts to obstruct the disciplinary process evincing placement for such FHE3 by
placing such within the folder devoted to the Richard G. Hill, Esq. grievance (either King could not
remember that he had emailed Coughlin a backtracking email of 4/19/12 seeking to ameliorate the lies
in his email to Coughlin of 4/2/12, indicating such FHE3 was received from the court clerk (where
King figured his coyly failing to specify which court would prevent Coughlin from forcing both RMC
Judge Gardner and RMC Judge Holmes into admitting the gross judicial misconduct they engaged in
with 2JDC Judge L. Gardner and RMC Judge Howard vis a vis promoting a vacated order as a basis for
permanently disbarring an attorney in addition to poisoning the well as to those judges then still
presiding over criminal prosecutions against Coughlin via such extrajudicial sources of a highly
prejudicial nature, especially where W. Gardner failed to recuse himself from the trespass case and
where RMC court staff conducted a smear campaign of Coughlin where many indications support the
view that such was done with the blessing, and encouragement, even, of RMC Judges (Judge Howard's
to King Cassandra Jacksons' email to RMC Judges are particularly instructive in this regard) or, more
likely, he just assumed the Nevada Supreme Court would be too busy and apathetic to notice such
attempts by King to obfuscate, even if Coughlin, however unlikely it seems to King and the SBN,
managed to synthesize all these materials into a a cohesive analysis identfying the fraud attendant to
King and the SBN's presentation of SCR 105(2)(c) materials and its conduct throughout this matter in
consideration of King's fraudulent juxtopositioning of FHE3 as set forth above. King places such
FHE3 at bates 1943, intially, within a folder identified as pertaining to RMC Judge Howard and the
petty larceny matter, only to then place such FHE3 (the NG12-0435 Judge Linda Gardner Grievance
File motherboard within the folder devoted to Hill's NG12-0204 grievance (within which King also
fraudulently places Judge Nash Holmes FHE8 letter of 3/14/12 to the SBN).
King's fraudulent approach is revealed in comparing his 4/2/12 written statement that The
Grievance from Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v Barti
Joshi, Case Number DV08-01168 with his 4/19/12 written statement that You wanted to know how I
learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009. It was sent
to me by the clerk of the court at my request, pursuant to my investigation. King actually did not
even indicate which department he received such Linda Gardner order from, in a further demonstration
of King's attempt to obfuscate the misconduct of L. Garnder, W. Gardner, K. Howard, and Judge
Holmes vis a vis the extrajudicial source rule and the promotion of a grievance against Coughlin based
upon an order that 2JDC Judge L. Gardner knew she had vacated, where she either informed the other
judges that such had been vacated or not, with the former making those judges an accomplice, and the
latter not being dispositive as to such judges innocence or guilt.
1943

FHE3 the vacated 4/13/09 Order After Trial by 2JDC Judge L. Gardner (RMC
Judge W. Gardner's sister) with the SBN's ultra shady RECEIVED MAR 15 2012
STATE BAR OF NEVADA RENO OFFICE stamping, with the 5 in the 15 being drawn in
by hand made all the more questionably by SBN King and Peters fraudulent attempts to pass of
NG12-0435 (or 0434 depending on which email of King's one goes by) as being a grievance
received from 2JDC Judge L. Gardner.
http://www.scribd.com/doc/168160062/11-21-11-to-2-1-13-All-Emails-Between-Coughlin-andSBN-Format-Text-Only-Wordpad-Version-Redone
8/31

RE: Mr. King's assertion in his 3/16/12 letter From: Patrick King (PatrickK@nvbar.Org) Sent: Thu
4/19/12 2:28 PM To: zachcoughlin@hotmail.Com (zachcoughlin@hotmail.Com) April 19, 2012 Zach
Coughlin
Dear Mr. Coughlin, A screening panel of the Northern Nevada Disciplinary Panel met on
Tuesday April 10, 2011 to address the grievances filed against you. The panel directed me to proceed to
a formal disciplinary hearing. As such, I will be preparing a formal Complaint... You wanted to know
how I learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009. It
was sent to me by the clerk of the court at my request, pursuant to my investigation. It would help me
and perhaps yourself, if you would respond and explain why you were convicted of theft and why you
were held in contempt of Court. You may be well served to explain what remedial measures you are
taking to make sure you do not repeat the conduct complained about. I cannot give you legal advice.
However I can suggest you cooperate with Bar counsels investigation and that you respond
specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to the
office of Bar Counsel. Patrick King
RE: my attempt to be provided access to the grievances filed today
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Tue 3/27/12 9:24 AM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
March 27, 2012
Dear Mr. Coughlin,
Perhaps you are not fully aware of your behavior. At our brief meeting yesterday I perceived
you as very hostile and even threatening. Under those circumstances I felt it better to terminate the
meeting.
If it was not your intent to appear hostile or to attempt to intimidate me then you might
consider how I perceived your conduct. I had intended to try to listen to you and determine how my
office could best help you address the grievances that I have received. You said you did not have
time and simply wanted to argue about your receipt of e-mail or mail. I did not say that I did not care if
you received the information I sent to you, I said I did not care how your received it, so long as you
received it. I do care that you receive the information that I send to you. As I attempted to explain, I
will be meeting with a panel to have them make a determination about the grievances that have been
made against you by Mr. Hill and the Judge from Department 3 that you read at my office. I have
asked for a written response to those grievances. In response I received many e-mails with
attachments. I will soon be sharing the grievances with a disciplinary panel and will advise them of
your responses to date.
I will keep you advised of the panels determination.
Sincerely, Patrick King
One has to imagine the SBN and Beesley wanted to keep Beesley's name out of this as much as
possible given Mirch hangover associated with Beesley's name and all the allegations therein that
Beesley demonstrated a wanton approach to seeking to leverage the SBN and NNDB as his own
personal profit generation apparatus and competitive advantage producer.
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zolt
RE: my attempt to be provided access to the grievances filed today
From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Mon 4/02/12 3:57 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Dear Mr. Coughlin,
I have opened 3 disciplinary files against you. They are identified by number below:
NG12-0204 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Mr. Hill
NG12-0435 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Holmes
NG12-0434 Zachary B. Coughlin, Esq. Bar No. 9473 (2005) Judge Gardner
You have received the grievance from Mr. Hill and also the grievance from Judge Holmes. The
Grievance from Judge Gardner relates to her Order After Trial in the case of Ashwin Joshi v Barti
Joshi, Case Number DV08-01168, wherein she describes your conduct at pages 12 and 13. I have
received certified copies of the contempt orders, a certified copy of the conviction at Wal-Mart, and an
incident report from Marshals Thompson and Coppa regarding your conduct on March 22, 2012. I
also have the recordings of the court proceedings at issue.
At this time, I do not expect to be providing you with any additional information. If you have
additional information that you want me to be made aware of in response to the grievances identified
above please feel free to mail them to me.
Sincerely, Patrick King, Assistant Bar Counsel
Well, shoot, given the SBN stamping such L. Gardner 4/13/09 Order After Trial (FHE3)
as received on 3/15/12, such either was not recieved amongst the box of materials that Holmes
referenced in FHE8 as providing to King with her 3/14/12 letter, or such was included and the SBN's
King and or Peters attempted to fraudulently misdirect reviewers from gleaning that Judge Holmes so
included such FHE3 therewith, or, Judge Holmes did not included such FHE3 within the box of
materials accompanying her 3/14/12 letter (King eventually indicated in his 4/19/12 email to Coughlin
that he requested a copy of such order from the clerk of court being careful not to specify which clerk
of which court King received such from in response to King's requesting such (which brings up the
question of just how King became aware of such FHE3, and received such in such close proximity
(3/15/12 compared to 3/14/12 dates received stamps on FHE3 and FHE8, respectively if it was not
from the RMC and or Judge Holmes from who King learned of FHE3 (versus FHE3 having been
referred to King pursuant to Canon 2, Rule 2.15 by a judge, much less the judge whom presided over
the divorce case from which FHE3 issued).
In which case RMC Judge Holmes (whom was careful in her sworn testimony to avoid such
inquiry as much as possible) ought be made to explain why she apparently absconded from her NCJC
Canon 2, Rule 2.15 duty to report apparent lawyer misconduct to the SBN, the appropriate authority
in such a case...and certainly the suggestion of a cover up by the RMC Judges Holmes, Gardner,
Howard (and possibly Dilworth) is present therein, where the subsequent admission by Judge W.
Gardner, upon Coughlin forcing his hand during the 4/10/12 trial in 26506 Gardner attempted to hold in
violation of NRS 178.405 (and W. Gardner's statements on the record there are very telling and indicate
a coordinated agreement between W. Gardner and Holmes that the FHE3 order by W. Gardner's sister
would not be provided to the SBN by RMC Judge Holmes (as well as W. Gardner's inaccurate accounts
of whether any competency issues are referenced in the orders by Judge Holmes Coughlin put to him at
such point (really, W. Gardner was totally going to go through with the trial on 4/10/12, until Coughlin
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finally cornered Loomis to displaying some sembleance of professionalism (it does not come easy to
Keith) and where Coughlin's cross-examination of W. Gardner resulted in Gardner becoming too
flustered to go forward, whereupon, rather than recognizing the NRS 178.405 duties attendant to Judge
Holmes 3/12/12 Order suspending the trial in 26800 and Holmes FHE8 letter to the SBN (both of
which reference Coughlin's alleged competency issues, mental instability, and decompensating),
W. Gardner rather passed his off suspending the trial of 4/10/12 (but only after he, Loomis, and RCA
Hazlett-Stevens got some motion work addressed, etc, official copy of such trial date of 4/10/12 in
26405 before W. Gardner available here (and such was provided to both the SBN and Panel prior to the
11/14/12 formal hearing: http://www.youtube.com/watch?v=VVPx1zoVw5c Also, some real bon mots
to be hear in the official audio from the RMC of the 5/8/12 hearing in that same 26405 criminal
trespass case: http://www.youtube.com/watch?v=SW76cMukZPc ) as being in response to something
other than all the corners Judge Holmes' behind the scenes machinations put W. Gardner in.
Clearly, Judge Holmes and the SBN's King come from the same school of manufacturing the
appearance of the outrage of others (FHE8: The accompanying box of materials demonstrates some of
the problems with the practice of this attorney being experienced by myself and the other three judges
in Reno Municipal Court....You will have the full cooperation of myself, the other judges, and the
staff of Reno Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a
vexatious litigant in our court, antagonizing the staff and even our pro temp judges on the most simple
traffic and misdemeanor matters....), combining that with consistently attempting to obfuscate what
came first, the request for information, filings, or other materials from Asst. Bar Counsel King and the
SBN, or some independent, voluntary, NCJC Canon 2, Rule 2.15 referral by a judge (versus by some
employee of a court who is not a judge) (FHE8 I apologize for taking two days to get this package to
you... wrote Judge Holmes to King (indicating King requested she and the RMC provide such
materials rather than Holmes and or the RMC do so independent thereof.).
However, again, if Holmes did not included the FHE3 2JDC Judge L. Gardner Order that she
admits to having been passed by RMC Judge W. Gardner (whom admits having been passed such by
his sister, 2JDC Judge L. Gardner, whom issued it in the matter she presided over...), then why did
Holmes not so provide such to the SBN (SBN King's email to Coughlin of 4/19/09 finally comes clean,
somewhat as to how King and the SBN received FHE3 (though, clearly, King is still attempting to
cover up the judicial misconduct by 2JDC Judge L. Gardner, RMC Judge W. Gardner, RMC Judge
Holmes, RMC Judge Howard, (possibly RMC Judge Dilworth, though, being the seasoned veteran that
he is, Judge Dilworth wisely recused himself from the ridiculous prosecutions of Coughlin goon for the
Reno City Attorney Chief Wong is currently insisting on bringing against Coughlin in RMC 13 CR
3913 and 3914 (wherein Wong is prosecuting Coughlin over the most ridiculous alleged violations of a
Workplace Harassment TPO and EPO ever alleged (accusing Coughlin of violating such by submitting
documents for filing with the Clerk of Court of the SBN in a then pending matter...so much for due
process, huh? These people are humiliating the State Bar of Nevada and the Nevada Supreme Court in
the process if this goes on much longer) as a favor to his old coworker at the Attorney General's Office,
current SBN Asst. Bar Counsel King (whom attempted to get Wong to provide him Coughlin's criminal
history (see 3,094's bates 2723 email of 4/10/12 to SBN from RCA Dan Wong regarding SBN will be
unable to get Coughlin's criminal history (Pennie Colter, etc)). Judge Dilworth apparently decided
(beyond the decision that at least the appearance of impropriety and or bias called for such recusal) that
this was RMC Judge W. Gardner, Judge Holmes, and 2JDC Judge L. Gardner's mess and they could
deal with it themselves, thank you very much.

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1794
1793
1804
1810
1816

1824-1964
1837

3/13/12 Sua Sponte Order Denying Relief Sought in Improper Document in 26800
3/13/12 Order Striking Fugitive Document Filed on 3/7/12 26800
3/12/12 Order in 26800 with clear and convincing language
2/28/12 Order in 26800
RMC Donna Rae Ballard Statement describing 12/13/11 exchange with Coughlin and
Marshal Menzel (NOTE: of course, the SBN excised both this Statement by the RMC's
Donna Ballard and Ballard's own 4/11/12 Affidavit from the 4/16/12 23 Exhibit
presentation to the Screening Panel and anything show the Formal Hearing Panel, given
the fact that Ballard was the SBN's go to for certification on so many Formal Hearing
Exhibits (FHE) whether or not they were documents from the court she works for (RMC)
or not (2JDC, see Ballard's certifications on 2JDC Judge Elliott's Orders in FHE12 and
FHE13). This, combined with Ballard's fraudulent participation in the bogus IFP
misconduct allegations (see entry at 1871), and Ballard's fraudulent failure to accurately
represent the ROA transmitted to the 2JDC in the appeal of the Walt-Mart petty larceny
conviction in 11 CR 22176 (CR11-2064, see 60838) illustrates the gross misconduct
Ballard regularly engages in and for which she must be brought to justice, and, arguably,
removed from her post at the RMC.

Cover Sheet for Case No. 11CR22176 Judge Ken Howard Department Four
3/21/12 RMC stamped on 3/15/12 2JDC Elliott Order Affirming Ruling of the RMC
22176 2064. (NOTE: by virtue of the dates on the items within this folder, which
contains the exact same (other than the bates stamp) font and text of that with a cover page found at
1659, such folder could not have been that representing the materials Judge Nash Holmes and or what
she refers to as our staff in her 3/14/12 FHE8 letter to the SBN collected from Coughlin's case before
Judge Howard in 22176.) Nash Holmes had a Canon 2, Rule 2.15 duty to report the misconduct of
Judge Howard in willfully violating the 2008 Indigent Defense Order in 22176. It is telling that there is
no folder analog for RMC Judge W. Gardner to those at 1659 for Judge Howard and 1793 for Judge
Holmes, despite Holmes' 3/14/12 letter indicating materials were being culled and provided from
Coughlin's case before Judge W. Gardner in 26405 as well. Perhaps Judge W. Gardner's statements on
the record in 26405 on 4/10/12 indicating a distaste for going around collecting other judges orders
was a criticism of Judge Holmes approach here, especially where Judge W. Gardner seemed to be
expressly legitimate surprise upon Coughlin indicating to him, on the record, during the 4/10/12 trial in
26405, that his sister's 4/13/09 Order After Trial (FHE3) had been provided to the SBN by the RMC
and or Holmes. Judge W. Gardner expressed surprised and indicated that's the first I have heard of
that, and otherwise appeared to be annoyed as though a previous agreement not to provided such to
the SBN had not been honored by Judge Holmes.
1865
RMC Donna Ballard Affidavit to SBN of 4/11/12 22176 26405 (see note for entry at bates
1816 and careful excision of this Affidavit by the RMC's Ballard from his 23 Exhibit
Screening Panel presentation by King)
1867
RCA Hazlett's Motion to Strike Motion to Dismiss Complaint
1871
only pages 2 and 3 of Coughlin's 3 page filing of 12/14/12 of a Motion to Proceed IFP
and Affidavit in Support of filed by fax and email which Donna Ballard provided express
authorization of, not even clear which case such is in, but regardless, Coughlin had
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1886-1887
1888

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1891
1893
1897
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1906

1910-1913

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notified court he was an attorney already in both cases in addition to doing so in the
emailed version of these two IFPS in 22176 and 26405, and likely in the fax cover sheet
as well
out of order all three pages of 3 page 12/14/11 fax submitted Motion to Proceed IFP in
26405 Ballard notarized and provided to the SBN though she failed to indicated she had
given permission to file by email to Coughlin and that both Coughlin's email and fax
cover sheet identified him as an attorney, and regardless, all departments of the gossipy
RMC were well aware of that fact, even beyond Coughlin already having stated it on the
record, in court on 11/30/11 in 22176 and at the arraignment on 11/14/12 to Judge W.
Gardner for 26405.
Complete Police Report (ie, containing not just the typical Arrest Report and Declaration
of Probable Cause sheets, but also the Witness Statements and Narrative of the Arresting
Officer, which is not to be released during the pendency of a criminal matter, (this version
has a date printed of 4/4/12, bringing up the question of just how the SBN was able to
obtain such a confidential report, and just whom provided such to the SBN.
arresting RPD Officer Chris Carter, Jr's Narrative in the Police Report for the 11/13/11
criminal trespass arrest at issue in RMC 11 CR 26405 (61901, CR12-1262)
RMC Judge W. Gardner's 4/10/12 Order Suspending Proceedings in criminal trespass
case in 11 CR 26405 sidestepping the fact that Gardner was well aware of his fellow
RMC Judge (see NRS 5.071, NRS 178.405) Judge Nash Holmes' 2/28/12 and 3/12/12
Orders in 11 TR 26800 and her 3/14/12 grievance against Coughlin to the SBN that
indicated she felt Coughlin was decompensating (FHE4, FHE5, FHE8) as providing a
mandatory basis for applying the stay required by NRS 178.405...Further, Judge W.
Gardner first attempted to hold the trial on 4/10/12, then, that appearing to outlandish,
proceeded to allow RCA Hazlett-Stevens, Esq., and RMC court appointed defender Keith
Loomis, Esq., to hold a motion hearing and obtain rulings prior to suspending the
proceedings (similar violations of NRS 178.405 are revealed by the very existence of
Judge W. Gardner's 3/20/12 and 3/21/12 Orders in 26405, in addition to the 3/7/12 Trial
Setting setting 4/10/12 as the date for the Trial in 26405).
RMC Judge W. Gardner's Order #1 in criminal trespass matter in 11 CR 26405
RMC Judge W. Gardner's Order #2 in criminal trespass matter in 11 CR 26405
RMC Judge Holmes' 2/28/12 Order Finding the Defendant in Contempt of Court and
Imposing Sanctions in 11 TR 26800 (FHE4)
RMC Judge Holmes' 3/12/12 Order in 11 TR 26800 (FHE5)
Coughlin's fax filed with the RMC 12/14/12 Motion to Proceed IFP (which was filed via
email pursuant to the permission given in writing by RMC's Filing Officer Supervisor
Ballard, where such email clearly identified Coughlin as an attorney (over and above the
fact that the Arrest Report attached to the Criminal Complaint did so as well) with
certification by Ballard.
12/15/11 Order by RMC Judge Howard in 11 CR 22176 (see 60838) (FHE10) sua sponte
determining that Coughlin had failed to properly serve city attorney, denying indigent
Coughlin's Motion for Publication of Transcript at Public Expense and Motion to Proceed
IFP, and failing to address Coughlin's Motion for Recusal
4/10/12 Affidavit by RMC Marshal Matthew Thompson and Marshal Unit Report
detailing 3/22/12 harassment of Coughlin near RMC filing officer counter admitting to
tape recording Coughlin in courthouse

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1920

1921

1922-1924

1925
1926-1928

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4/10/12 Affidavit by RMC Marshal Scott Coppa detailing 3/22/12 harassment of

Coughlin near RMC filing officer counter admitting to tape recording Coughlin in
courthouse
4/11/12 Affidavit by RMC counter clerk Daniel Casillas (Court Specialist) addressed to
Nevada State Bar detailing 3/22/12 harassment of Coughlin by RMC Marshals Coppa
and Thompson near RMC Filing Office counter, and Casillas refusal to provide a docket
for 11 TR 26800 at time of Coughlin submitting his second Records Request seeking a
copy of the audio of the 2/27/12 traffic citation trial before Judge Holmes at issue in
FHE4,5,8, and FHE9.
RMC Court Administrator Cassandra Jackson's 4/11/12 Affidavit (RE: In the Matter of
Zachary Coughlin) of 4/11/12 detailing alleged YouTube videos, pajamas, and
numerous employees of the RMC expressing concern for their privacy and safety.
Notarized by Jana K. Blair.
email from RMC Court Administrator Cassandra Jackson to SBN's King of 4/9/12 cc'd to
RMC Judges W. Gardner, Nash Holmes, Dilworth, and Howard (impermissible
extrajudicial communications with good luck tomorrow!! echoing the reference at the
4/10/12 Trial in the criminal trespass case (11 CR 26405 see 61901) made by RMC Judge
W. Gardner as to his SCR 123(3) violating awareness of the meeting of the NNDB
Screening Panel on 4/10/12), including links to videos Jackson alleges Coughlin posted to
You Tube regarding his visits and interactions with the RMC staff which Jackson
alleges has been very upsetting to some of the court staff, as Mr. Coughlin mentions
several staff members by name, along with salary information. Some of the staff has
expressed concerns for their safety and privacy. If you have any questions, or need
further information, please let me know and good luck tomorrow!!. My, my...how
terribly, terribly impartial and not at all giving an appearance of impropriety, true pro, that
Cassandra Jackson.
all 3 pages of 3 of the 11/30/11 Judgment of Conviction and Court Order where,
noticeably, page 3 thereof was excised both from King's inclusion of such 11/30/11 Order
in his 23 Exhibit presentation to the Screening Panel, but, curiously, not in the appearance
of such in the 8/23/12 Complaint at ROA 1714... Also note the false assertion in the
Additional Case Information entry at page 3 of 3 (bates 1924) for the arraignment of
10/10/11 that DEFENDANT DID NOT WANT A COURT APPOINTED ATTORNEY,
which is false, but, rather, RMC Judge W. Gardner refused to allow Coughlin to conduct
any sort of conflict check by refusing to provide Coughlin the names of the four
prospective court appointed defenders that the RMC hires on an independent contractor
type basis where such defenders maintain private practices handling both civil and
criminal case (where CV11-03126 and Coughlin's suing the very RMC court appointed
defender Lewis Taitel, Esq's unauthorized practitioners of law fee sharing with nonlawyers business partners, Nevada Court Services, made Taitel's representation in the
criminal trespass matter stemming from Coughlin's arrest at the very former home law
office where NCS had attacked and trespassed against Coughlin, in 11 CR 26405, rather
problematic .
Coughlin Record Request to RMC in 26405
all three pages of the fax filed version (header of 12/14/11 at 12:13 am) (though,
noticeably, not the email filed version Coughlin provided to RMC Ballard upon her
written approval for such filing by email) of Coughlin's Motion to Proceed In Forma

1929

1934

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1940
1943

1957
1960

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Pauperis in the Wal-Mart RMC Judge Howard case in 22176 (60838) (with pages 2 and 3
being the Affidavit of Poverty in Support of Motion to Proceed IFP) that King
fraudulently excised from page 1 for inclusion in his 23 Exhibit presentation to the
Screening Panel.
RMC DCA Pamela Robert's Esq.'s 12/15/11 Notice of Denial of Service in Case No.
IC11-0627, which is not the correct case number, though it appears she meant to file
such in 11 CR 22176 (60838) though RMC Judge Howard made no sua sponte ruling
striking Robert's Notice in that regard, unlike Judge Howard's patently biased FHE10 and
similar such order of 12/16/11 and 12/21/11 in 22176 (60838).
RMC Judge Howard's 12/16/11 Order in 22176 demonstrating abuse of the contempt
power in threatening such in response to indigent, recently evicted Coughlin's utilizing
email in his attempt to access justice, especially where Howard had denied Coughlin his
right to counsel under the Sixth Amendment and unconscionably refused a stay of any
length to then practicing attorney Coughlin prior to Howard's outlandish 3 day summary
incarceration for summary contempt (FHE11) of 11/30/11. (note 1936 and so many
other instances of the Reno City Attorney, RMC court appointed defenders, and the RMC
allowing service upon each other via email, or filing, only to refuse such to indigents
(well, except for when RMC Ballard lied to Coughlin, in writing, in November 2011December 2011 regarding the written permission she provided to Coughlin to file via
email, and the concomitant fraud Ballard and the RMC committed with respect to the
deficient ROA from 22176 in CR11-2064).
Coughlin's Record Request for the audio transcript of the 11/30/11 trial in 22176
submitted in person by Coughlin to the RMC for filing on 12/8/11, where the RMC only
file stamped such on 12/13/11 in a successful attempt to prejudice Coughlin's' preparation
of his appeal and Motion for New Trial.
FHE11 RMC Judge Howard's 11/30/11 Order for Summary Punishment of Contempt,
completely lacking any Certificate of Service where such Order was most definitely not
provided to Coughlin as anytime on 11/30/11, or at anytime thereafter until being
included in the ROA the RMC transmitted to the 2JDC in Coughlin's appeal both the
summary contempt incarceration and the 11/30/11 Judgment of Conviction and Court
Order, where the 2JDC failed to adjudicate Coughlin's appeal of the summary contempt
incarceration.
FHE10 RMC Judge Howard's 12/16/11 Order
FHE3 the vacated 4/13/09 Order After Trial by 2JDC Judge L. Gardner (RMC Judge W.
Gardner's sister) with the SBN's ultra shady RECEIVED MAR 15 2012 STATE BAR
OF NEVADA RENO OFFICE stamping, with the 5 in the 15 being drawn in by
hand made all the more questionably by SBN King and Peters fraudulent attempts to pass
of NG12-0435 (or 0434 depending on which email of King's one goes by) as being a
grievance received from 2JDC Judge L. Gardner.
12/16/11 Order by RMC Judge Howard regarding Coughlin's emailing with RMC Ballard
certification
Certified Copy of Docket by RMC in 22176 with Ballard Certification indicating 9/14/11
as the date of filing of the Criminal Complaint filed charging Defendant with Petit
Larceny where Ballard, the RMC, RCA, and Reno Sparks Indian Colony all refused to
allow Coughlin to purchase or in any way obtain a copy of even the two page Arrest
Report and Declaration of Probable Cause that is attached to all criminal complaints (with

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1998

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RMC Ballard alleging the RMC did not even have the Complaint, much less the attached
ARDPC) and would not, until after the 10/10/11 arraignment. Donna Ballard is super
shady, especially where the same docket then immediately thereafter listed for 9/14/11,
the Arrest Report and Declaration of Probable Cause.
RMC Cassandra Jackson's Certificate of Transmittal of Complete Record on Appeal for
22176 to the 2JDC of 12/22/11.
Certificate of Service of such ROA by the RMC in 22176 to Coughlin listing the very 817
N. Virginia St. #2 address for Coughlin that FHE4 and Judge Nash Holmes failed to send
such 2/28/12 Order Punishing Contempt by Holmes to Coughlin at, much less to the 1422
E. 9th St. #2 address the RMC was updated with for Coughlin on 1/9/12, where Holmes
instead sent such to the very 121 River Rock address she had been informed on
numerous occasions that Coughlin was wrongfully evicted from in November 2011.

Unadorned or unidentified in any way Index to Exhibits from the 23 Exhibit

presentation King (?) provided to the Screening Panel at the second meeting thereof,
upon King being informed after the 4/10/12 initial presentation to the Screening
Panel that he had not met his burden?
Exhibit 1. Order filed December 16, 2011
Exh. 2. Order Affirming Ruling of the Reno Municipal Court by 2JDC Judge Elliott in
CR11-2064 of 3/15/12 (FHE12) as to RMC Judge Howard 11/30/11 Ruling in 22176
(60838).
Exh. 3. Order for Summary Punishment of Contempt Committed in the Immediate View
and Presence of the Court (summary incarceration for three days beginning 11/30/11)
Exh. 4. Amended Criminal Complaint filed December 5, 2011, RJC Case No. RCR 2011063341 (iPhone petty larceny arrest of 8/20/11)
Exh. 5. Criminal Complaint filed January 23, 2012, RJC Case No. RCR 2012-065630
(1/14/12 misuse of 911 arrest)
Exh. 6. Notice of Appearance, Entry of Plea of Not Guilty, Waiver of Right to
Arraignment; Motion to Dismiss filed February 21, 2012, RJC Case No. RCR 2012065630
Exh. 7. Criminal Complaint, Arrest Report and Declaration of Probable Cause entered
November 14, 2011 in Case No. 11-22185 (11 CR 26405) (NOTE: actually this exhibit
from bates 2001 to 2003 includes the Narrative of RPD Officer Chris Carter, Jr. from
Police Report (printed 4/4/12) which is not publicly available during a pending criminal
investigation/pendency of a criminal prosecution. Further, the Written Statement by
witness Richard G. Hill, Esq., has curiously been excised from the Police Report from
which such Narrative is drawn, which is highly dubious considering Hill's Written
Statement falsely alleged that Coughlin was served eviction papers on 11/1/11 where
such, clearly, in light of Iorio, Russell v. Kalian, and Mayes v. UVI, is patently not true,
particularly where Hill's Office and the WCSO and RPD were actually burglarizing
Coughlin's former home law office in their failure to abide by the requirement in NRS
40.253(5)(a) that the passing of 24 hours must occur from the tenant's receipt of such
summary removal order. The 4/4/12 date of printing of RPD Officer Carter's
Narrative necessarily demonstrates that such was not attached to the 11/14/12 filed

Criminal Complaint in the RMC, and the SBN must explain how and from who it
obtained such a confidential Narrative from a police report in a pending criminal
prosecution.
2000
Arrest Report and Declaration of Probable Cause Sheet by RPD Officer Chris Carter Jr.
filed with Criminal Complaint for trespass by Richard G. Hill in RMC 11 CR 26405 on
11/13/11 listing Coughlin as an attorney, further vitiating SBN and RMC's fraudulent
assertion that Coughlin failed to disclose fact he is an attorney.
2004
Exh. 8. Order Suspending Proceedings filed April 10,2012, Case no. 11 CR 26405
2006
Exh. 9. Notice of Appearance as Co-Counsel and Motion to Dismiss filed March 5, 2012,
Case No. 11 CR 26405 (NOTE: page 39 of 40 (as well as the fax headers for every page
of this fax filed by Coughlin with the RMC Motion to Dismiss) has been fraudulently
removed by King in an attempt to get around the fact that the WCSO, RPD, and
Hill and Baker burglarized Coughlin's former home law office (see note at bates 1998, and note
the fact that the, 3,094 page production of 11/7/12 by the SBN does, in other instances, contain
such page 39 of 40, ie, WCSO Civil Division Supervisor Stuchell's emailed admission of 2/7/12 to
Coughlin vis a vis the burglary by Deputy Machen (ie, personally served dubious position)
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2049
2052
2057

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where SBN King excised WCSO Stuchell's 2/7/12 emailed admission to Coughlin that
her office views personally served to included posting on door of Coughlin's former
home law office when nobody was present therein, the 24 hour lockout eviction order, in
violation of NRS 40.253, coverup smoking gun, Pat King should be disbarred. (NOTE:
where is fax headers from Coughlin's fax filing of such to the RMC that is present in
every other appearance of such 3/3/12 or 3/5/12 Notice of Appearance, Motion to Dismiss
by Coughlin?)
Exh. 11. Order #2 filed March 21, 2012, Case No. 11 CR 26405 dubiously declaring
Coughlin's arguments in Coughlin's 3/5/12 Motion to Dismiss in 26405 and exposing of
the burglary by Hill, the WCSO, and RPD as without merit.
Exh. 12. Order Finding the Defendant in Contempt of Court and Imposing Sanctions filed
February 28, 2012, Case No. 11 TR 26800 21
Exh. 13. Order filed March 12, 2012, Case No. 11 TR 26800 21 (compare the overall
legibility thereof to the version King actually attached to the 8/23/12 Complaint in ROA
Vol 1, then to the version King attached within FHE1, as well as to that found at bates
1901).
Exh. 14. Financial Inquiry Application and Motion to Proceed Informa Pauperis filed
December 14, 2011, Case No. 11 CR 26405 21
2065 curiously blank page follow by dubiously excised page 1 of 3 of the pdf version of
Coughlin's 12/14/12 Motion to Proceed IFP and Affidavits in support thereof (both 3
pages each) that Coughlin emailed for filing to RMC Ballard in accordance with her
written permission provided to Coughlin allowing such filing by emailing, where King
and or Ballard has fraudulently utilized this version of such filing (here in 26405, where
the other, essentially identical version was adorned with case number for 22176) was
clearly printed using the pdf version Coughlin attached to his 12/14/12 email to RMC
Ballard, rather than the versions of either 12/14/12 Motion to Proceed IFP/Affidavit in
Support thereof baring fax headers for Coughlin's 12/14/11 copied via facsimile
transmission to the RMC

2067

2070
2075
2080

2091
2094
2097
2242

2176
2177-2178

2046
18/31

Exh. 15. Affidavit of Poverty in Support of Motion to Proceed Informa Pauperis filed
December 14, 2011, Case No. 11 CR 26405 21 (NOTE: 1871 only pages 2 and 3 of
Coughlin's 3 page filing of 12/14/12 of a Motion to Proceed IFP and Affidavit in Support
of filed by fax and email which Donna Ballard provided express authorization of, not
even clear which case such is in, but regardless, Coughlin had notified court he was an
attorney already in both cases in addition to doing so in the emailed version of these two
IFPS in 22176 and 26405, and likely in the fax cover sheet as well... see, also bates 1903
Coughlin's fax filed with the RMC 12/14/12 Motion to Proceed IFP (which was filed via
email pursuant to the permission given in writing by RMC's Filing Officer Supervisor
Ballard, where such email clearly identified Coughlin as an attorney (over and above the
fact that the Arrest Report attached to the Criminal Complaint did so as well) with
certification by Ballard....see, also 1926-1928 all three pages of the fax filed version
(header of 12/14/11 at 12:13 am) (though, noticeably, not the email filed version
Coughlin provided to RMC Ballard upon her written approval for such filing by email) of
Coughlin's Motion to Proceed In Forma Pauperis in the Wal-Mart RMC Judge Howard
case in 22176 (60838) (with pages 2 and 3 being the Affidavit of Poverty in Support of
Motion to Proceed IFP) that King fraudulently excised from page 1 for inclusion in his 23
Exhibit presentation to the Screening Panel.)s
Exh. 16. Order filed December 15, 2011, Case No. l1 CR 22176 by RMC Judge Howard
Exh. 17. Affidavit of Matthew Thompson w/attached Marshall's Report
Exh. 18. Affidavit of Scott Coppa w/attached Marshall's Report and emails of 12/14/11
between Coughlin and RMC Chief Marshal Justin Roper re Marshal Menzel's hostile
harassing of Coughlin and RMC Department 4 Judge Howard's Judicial Assistant
Veronica Lopez's fraudulent failure to provide Coughlin a copy of the 11/30/11 Order
Punishing Summary Contempt (FHE11)
Exh. 19. Affidavit of Daniel Casillas, Court Specialist, RMC
Exh. 20. Affidavit of Cassandra Jackson, Court Administrator for Reno Municipal Court
followed by Jackson's incredibly inappropriate email to King of 4/9/12.
Exh. 21. Notice of Appearance, Motion for Continuance, Etc. filed November 30, 2011,
RMC Case No. 11 CR 22176 21
Exh. 22. Notice of Appeal of Summary Contempt Order; Motion to Return Personal
Property Confiscated By Reno Municipal Court and its Marshals; Motion for New Trial
and to Alter or Amend Summary Order filed March 7, 2012, Case No. 11 TR 26800
(NOTE: this Exhibit 22 is actually a jumbled hodgepodge by the SBN of materials from
that Wal-Mart petty larceny RMC matter in 11 CR 22176).
RMC Judge Howard's 2176 11/30/11 Judgment of Conviction and Court Order
(where page 3 of 3 thereof has been excised by King, noting the center of the bottom of
the page applied bates stamping on such documents (ie, 191...192, etc)).
Where the Proof of Service ought be for the 11/30/11 Judgment of Conviction and Court
Order by RMC Judge Ken Howard, of course, there is none to be found, (especially
noteworthy considering the page 3 of 3 quasi Certificate of Service by bullying RMC
Marshals is to be found elsewhere in such 3,094 page production by the SBN) which
is particularly noticeable for that which is not satisfied by any rendition standard, ie, the
alleged 11/30/11 Order Punishing Summary Contempt in RMC 11 CR 22176, all
fraudulently ignored by the SBN's King, at best.
Exh. 10. Order #1 filed March 20, 2012, Case No. 11 CR 26405 dubiously declaring

Coughlin's arguments in Coughlin's 2/13/12 filed Motion in 26405 and exposing of the
burglary by Hill, the WCSO, and RPD as without merit.
2181
Coughlin's emailed to RMC Ballard (with an email that clearly identifies Coughlin as an
attorney provides his NV Bar No, where the RMC was already fully apprised of that fact
on numerous occasions previously, including in writing, see Coughlin's 11/30/11 Motion
for Continuance in 22176) pdf version of 12/14/11 Motion to Proceed IFP and Affidavit
in Support thereof
2184
RMC Howard's 12/16/11 Order in 22176 (FHE10)
2186
incongruously placed continuation of RCA Robert's 12/15/11 Notice of Denial of Service
in 22176 (at bates 2187:lines 10-11 RCA Roberts notes the aforementioned emails
contain links and attachments that the City and I will not open as we have concerns about
computer viruses... Apparently the anthrax in the USPS mail scare following the events
of 9/11 failed to engender such an approach from Roberts vis a vis USPS
mail.
2190
RMC Howard's 12/16/11 Order regarding indigent Coughlin's emailing (threatening to
abuse the contempt power some more by Judge Howard) where 2192 reveals the, uh,
arrangement between the RMC and RCA in such Certificate of Service where Inneroffice mail following ordinary business practices is checked as the means of providing a
copy of such Order to the Reno City Attorney (not even inter-office, but, rather, the
apparent Freudian slip of inner-office mail).
2193
Here, it is as if King and the RMC/RCA are showing off, where the TX Report
establishing the service by the RMC on the RCA (inner-office mail, apparently)
reveals such 12/16/11 Order was emailed by the RMC to the RCA, where such Order
itself threatens the abuse of the contempt power by RMC Judge Howard against Coughlin
for Coughlin's allegedly emailing something to the RMC, and where Howard's 12/15/11
Order (FHE10) sua sponte denies all of Coughlin's 12/13/11 Motions (well, actually such
Order admits it just plain refuses to address Coughlin's Motion for Recusal) sua sponte,
prior to the passing of the time allotted for Coughlin to even begin running as to
Coughlin's right to file a Reply or some other responsive filing to RCA Robert's 12/15/11
Notice of Denial of Service in 22176.
2194
Coughlin's fax cover sheet to RCA Roberts and twenty three page Notice of Denial of
Service, Opposition City of Reno's Notice of Denial that, curiously, does not contain a fax
header (RMC Ballard did file in, selectively, some of Coughlin's submitted via email only filings, after
all...) sent to the RMC via pdf in an email). (compare to bates 128-151 page 1 of 24 Fax Cover Sheet
fax header of 7:41 am of 12/16/11 followed by Coughlin's Notice of Denial of Service, IFP Application,
etc. in 22176 and bates 1172 Coughlin's 12/16/11 24 page fax header to RMC 7:41 am in RMC 11 CR
22176 (60838) with fax cover page to RCA Roberts followed by Coughlin's Notice of Denial of
Service and bates 1217 page 2 of 24 page fax filed with the RMC from Coughlin 12/16/11 Notice of
Denial of Service with RMC Ballard Certification where page 1 of 24 was excised where such was a
fax cover page listing Coughlin as an attorney and providing his NV Bar No. in a fraudulent attempt by
RMC, Ballard, and SBN to support bogus IFP allegations.) (NOTE: in many instances in Coughlin's
reproduction of the SBN's 11/7/12 production to Coughlin of 3,094 pages Coughlin has replaced the
identical versions of some of the longer filings by Coughlin (which Coughlin already had in digital pdf
format, exported directly from a word processor, which renders a sharper pdf that utilizes less storage
space or megabytes, etc. than would scanning in all such instances of Coughlin's longer filings found in
such 3,094 page production (though, if anyone wants to test it, Coughlin did scan in such 3,094 pages,
19/31

painstakingly, and Coughlin ethically one ups the bar here where he points this out rather than taking
the tact that King took in inserting a cleaner, more legible copy of RMC Judge Holme's 3/12/12 Order
as Exhibit 3 to King's 8/23/12 Complaint (at ROA 20 or so) in its cleaner incarnation in FHE1,
especially where the legibility of process is far more integral to these proceedings than the legibility of
some random filing by Coughlin within such 3,094 page production, however, in no instance (save
maybe the 6 page per page versions of Coughlin's Exhibit 1 to his 12/13/11 filing in 22176, did
Coughlin utilizing his digital versions of such longer filings render an illegible document legible,
whereas the SBN's approach in the 2/13/13 ROA did such time and time again, in the reverse direction,
particularly with respect to the exhibits to Coughlin's filings).
2218
Coughlin's 12/8/11 submitted RMC Records Request for the audio transcript of the
11/30/11 Trial, which the RMC waited until 12/13/11 to file stamped (the day a Motion
for New Trial would have been due, nice...but litigants an attorneys are allegedly required to obtain a
judges permission to audio record a proceeding they are a party to, or advocating on behalf of a client
in? Who wants to bet the RCA/RMC court appointed defenders never get asked if they are recording
and or get same day copies of any audio they request, emailed to them, versus the ol' you have to drive
down her to pick up the disc and it will not be ready for a week that the RMC consistently announces
to normal litigants).
2219
page 3 of 3 (quasi-Proof of Service by bullying RMC Marshals (see or hear the audio
transcript (and attempts to transcribe by Coughlin in his 6/18/12 filing in 60838) of the
final minutes of such recording for an idea of what such purported service entailed, but, clearly, such
in no way included that found in the 8/23/12 Complaint at ROA 8, 10, 16 and in FHE1, FHE11 (see
ROA 1712, 1714, 1720, 1791 (and compare the actual signature (or one that at least is not so obviously
of the rubber stamp variety as that found at ROA 10 and 1714 on the 11/30/11 Order for Summary
Punishment of Contempt) on 1792 by Judge Howard to the obvious rubber stamp job on the 11/30/11
Judgment of Conviction and Court Order, both from 11 CR 22176, making sure to note the curious fact
that, while the 11/30/11 Order for Summary Punishment of Contempt does bare some unattributed
initials hand interlineated atop the file stamp, the 11/30/11 Judgment of Conviction and Court Order
fails to included any such initiling by a clerk or anyone else, for that matter, whatsoever...making even
further dubious RMC Judicial Assistant Veronica Lopez's fraudulent contention that she was not
required to mail or in any other way provide Coughlin a copy of such 11/30/11 Order Punishing
Summary Contempt in light of her incorrect (at best) assertion that Coughlin was served a copy of such
as the conclusion of the 11/30/11 trial...) etc. where neither the 11/30/11 Judgment of Conviction and
Court Order in 22176 or the 11/30/11 Order for Summary Punishment of Contempt bare anything in
the way of a Houston style time stamping for such summary contempt orders where the body of
jurisprudence related thereto makes quite clear such must be nearly contemporaneous with the
rendition of such summary incarceration orders (FHE4's time stamping of 3:47 pm on 2/28/12 for a
summary incarceration occurring at 4:00 pm on 2/27/12 is telling, almost as much as the hand
interlineation on the oft excised by King and or the RMC Page 3 of 3 of the 11/30/11 Judgment of
Conviction and Court Order wherein a quasi-Proof of Service by a bullying RMC Marshal (it saves the
RMC the cost of a stamp and the Marshals get to flex on people daily incident thereto, so the Marshals
and RMC are 'bout it) lists 8:23 p.m. as the time at which the DEFENDANT refused to sign his
name thereto to some preprinted text that would hardly operate, regardless, as anything sufficient to
meet a Mikohn standard (also, note the ultra dicey rubber stamped signature of (by?) RMC Judge
Howard stamped onto such Page 3 of 3 of such 11/30/11 Judgment of Conviction and Court Order
(what Court Order? Certainly there is nothing in such 3 pages to support a summary contempt order
per the Houston specificity requirements...perhaps such alludes to the subsequently crossed out
20/31

community service requirement (nice, Howard admits his mistake in think Coughlin caused the
continuance of the 11/14/11 trial in 22176 (rather than the jail bringing Coughlin to court in
Administrative Segregation mental health issues jail reds preventing Judge Howard from being able
to hold the trial he sought to preside over on that date...) and, instead of a new trial, or recognizing the
impropriety attendant to his both denying a continuance in addition to violating the Sixth Amendment
Right To Counsel (to say nothing of the abuse of the contempt power he demonstrated, and patent bias
in each and every ruling he made that day, particularly those of an evidentiary nature) Howard simply
had the community service requirement excised....Note bates 2219 of the 11/7/12 3,074 page
production and the bates stamping of 233 applied in the center of the bottom of the page, which,
conveniently, obscures the pagination otherwise viewable on such 11/30/11 Judgment of Conviction,
etc. One has to hand it to the SBN, it really is puttin' in big work when it has bates
stamps so artfully (and, conveniently) applied.
2222
for no apparent reason the cover page to Coughlin's Exhibit 1 to his 12/13/11 Motion for
New Trial in 22176 is included here, with Coughlin's handwritten interlineation that such
Exhibit (was provided to RMC Ballard via email upon her giving Coughlin written permission to do so,
which Ballard then fraudulently failed to abide by in the ROA the RMC transmitted from 22176 to the
2JDC in CR11-2064 on 12/22/11...another RMC Court Administrator Cassandra Jackson/Donna
Ballard fraudulent production) that such Exhibit 1 consisted of 893 pages plus CD of 5 files from
Reno City Attorney (2 videos APm codec, verint files, a recording of John Ellis Wal-Mart retaliation
2226 to 2240 (NOTE: here Coughlin has scanned in at 300 dpi (the quality of a laser printer that
NRAP 10 or 11 references, which the RJC and RMC and SBN consistently, and conveniently (to the
courts and prosecutors) fail to abide by, selectively) such pages exactly as produced to Coughlin on
11/7/12 by the SBN (and presumably as they appeared upon the SBN presenting such to the Screening
Panel) as a comparision of the legibility of such to the digital version of the same materials that
Coughlin inserted in place of a 300 dpi scanning of the SBN/RMC's photocopying of such is quite
illuminating (and such became of extreme relevance in the appeal of such Wal-Mart conviction in
22176 in the ROA that Judge Elliott (see FHE12) found so lacking in justifying denying Coughlin's
appeal of such conviction. (compare the differences between such 6 pages per page digital version at
bates 156 to 170 with the scanned at 300 dpi versions of the same materials found at
bates:
2226-2240 (which latter version is still much more legible than the scanned at 75 dpi version thereof
the RMC included in the ROA for 22716 in transmitted to the 2JDC in Coughlin's appeal
of the conviction and contempt order resulting in his current temporary suspension (well, the
conviction for petty larceny therein, at least, as the 2JDC refused to adjuciate Coughlin's appeal of the
summary contempt order in FHE11, which was convenient to the SBN/Panel's attempt to apply SCR
111(5) to even those allegation of Coughlin's violating RPC's that contains completely different
elements than those found in a NRS 22.030 analysis. Chair Echeverria coyly refrained from harping on
how Coughlin's appeal was denied with respect to such convictions for criminal contempt (as no
appeals were allowed, whether in light of 2JDC Judge Elliott refusing to adjudicate such or with
respect to RMC Judge Holmes disobeying NRS 189.010 in striking Coughlins' Notices of Appeal of
both the Orders in FHE4 and FHE5, even where Echeverria cheerfully sua sponte trumpeted on about
how the district court denied Coughlin's appeals of the Wal-Mart petty larceny conviction in 22176
and the criminal trespass conviction.
2467
21/31

Exh. 23. Motion to Return Cell Phones; Motion to Set Aside Summary Contempt Order;
and Notice of Appeal of Summary Contempt Order filed March 12, 2012, Case No. 11

2686

TR 26800
Exh. 24. 2JDC Judge L. Gardner's (FHE3) 4/13/09 Order After Trial filed April 13, 2009,
Case No. DV08-01168

2701-3,094 Formal Hearing File SBN v. Zachary B. Coughlin

2702-2793

Grievance File #NG12-0435 A: Z. Coughlin, Esq. G: Judge Dorthy (sic) Nash

Holmes
2705
King forwards Peters Coughlin's 4/27/12 email Subject: Update and a Requesting
2706
King forwards Peters Coughlin's 4/19/12 email Subject: RE: Mr. King's assertions in his
3/16/12 letter wherein Coughlin denies all allegations
2716
Brian Gonsalves email referring to other attorney fee awards makes curious King's
only requesting Coughlin pay Hill's landlord client's award in King's closing
argument.
2717
King's SCR 111(6) Petition in 60838, placed in NG12-0434 makes no sense
2718
RJC Judicial Secretary Lori Townsend's 4/11/12 email to King containing documents
from RCR2011-063341 (Judge Sferrazza) and RCR2012-065630 (Judge Clifton) RJC
Chief Civil Clerk told Coughlin Judge Clifton told her not to respond to Coughlin's
10/30/12 SCR 110 subpoena and subpoena duces tecum
2720
RMC Judge Howard (11 CR 22176 conviction leading to 60838 temp. suspension)'s
4/4/12 email to King regarding U-tube postings A Sampling, Events at RMC 3/12/12;
City of Reno Marshal Harley, Allison Ormaas; RMC bounced by Reno Marshals
apparently Coughlin was at the RMC on 3/12/12 and just did not know the trial in 26800
was continuing.
2721
RMC Court Administrator Cassandra Jackson email to RMC Judges faxed by Nash
Holmes (?) just page 2 of 3 of 3/22/12 1:17 pm fax apparently to SBN
2722
list (provided to SBN by RMC?) detailing Coughlin's offenses between 9/9/11 and
1/12/12
2723
email of 4/10/12 to SBN from RCA Dan Wong regarding SBN will be unable to get
Coughlin's criminal history
2726
Holmes or someone with the RMC's fax to SBN of 3/22/12 1:17 pm page 3 of 3
containing Coughlin's 3/22/12 FOIA Request and Second Record Request for audio of 2/27/12 trial
indicating Ballard indicated Coughlin's first request for such audio was not processed, and seeking
anything related to the confiscation of Coughlin's personal property on 2/28/12 from the Washoe
County jail, requesting chain of custody information, RMC Marshal's reports, etc.
2727-2732 has display issues likely RMC defender Puentes 1/17/12 Motion to Withdraw from
criminal trespass case before Judge W. Gardner in 11 CR 26405
2733-2734 3/27/12 Order in CV11-03628 2JDC Judge Flanagan appeal of summary eviction with
Hill and Baker as opposing counsel Denying Hill's Baker's 1/21/12 Motion for Order to
Show Cause after hearing on 3/23/12 and 3/26/12
2736
RMC Cover Sheet with List of documents attached 3/13/12 details five documents
from traffic case before Holmes: 2/28/12 Order (contempt); 3/7/12 Notice of Appeal, Mtn
for Return of Personal Property Confiscated by RMC Marshals (224 pages); 3/12/12
22/31

Motion to Return Cell Phones (218 pages); 3/12/12 Order (5 pages); 3/13/12 Order
Striking Fugitive Document filed on 3/7/12
2738-2739 4/16/12 fax from RMC Dept. 2 (Judge W. Gardner) 1 and 2 of 2 page Arrest Report and
Probable Cause Sheet for 11/13/12 custodial criminal trespass arrest with PC Sheet by
RPD Carter and Hill's Criminal Complaint
2740-41
RMC Marshal JP Jean-Pierre Moster report from 12/13/11 Marshals James Menzel,
Matthew Thompson; Witness 1 Donna Ballard, Witness 2 Tom Bartoldo:
2742-2744 RMC Marshal James Menzel incident report detailing Coughlin's filing a Notice of
Appeal and or Motion for New Trial and seeking a copy of the audio of the 11/30/11 trial
in 11 CR 22176 (60838), references gossip with RJC Chief Bailiff Michael Sexton, well
paid city and county Marshals and Bailiffs really don't like working until closing time
2745-2748 RMC Marshal Scott Coppa and Matthew Thompson incident reports detailing Coughlin's
3/22/12 visit to RMC filing counter to file Second Request for Audio of the 2/27/12 trail before Holmes
in 11 TR 26800, which begat NG12-0434...Judge Holmes immediately faxes SBN Coughlin's FOIA
Request in her desperate fear that her misconduct will be exposes incident to RMC Marshals violating
Fourth Amendment at her direction in retrieving from jail on 2/28/12 what had already been booked
into Coughlin's persona property (where Marshal Coppa pulled Deputy Cheung into back room of sally
bay at jail to discuss such confiscation)
2749
3/22/12 email from Coughlin to King Subject Re Hello from Zach Coughlin referencing
Gessin and Christiansen
2753
Coughlin's 4/2/12 email to King RE: my attempt to be provided access to the
grievances filed today seeking materials from 26800 and clarification regarding
whether Judge L. Gardner herself filed grievance.
2754
King's email to Coughlin detailing 3 grievances, lying about NG12-0434 being a
grievance received from Judge Gardner, King announces he is reneging on his
previous indication that Coughlin would be afforded a review of the materials submitted
in connection with the grievances, references RMC Marshals Coppa and Thompson's
3/22/12 report to SBN (where King initially attempts to affix NG12-0434 to the grievance
received from 2JDC Judge L. Gardner, rather than the NG12-0435 number ultimately
assigned to such grievance
2756
Coughlin email to SBN Peters of 3/26/12 referencing domestic violence he has
experienced and concomitant obstruction of his mail
2757
Coughlin's 3/26/12 email to SBN memorializing King's refusal to allow access to
grievance materials previously offered
2759
Coughln's 3/29/12 email to SBN indicating King had made no request for any written
response to any grievance by Gardner or Holmes, Coughlin's detailing manipulative use
of Coughlin's physical stature size by King, which King lied about at 1/4/13 TPO
extension hearing in RJC RCP2012-000607.
2760Lots of emails between Coughlin and the SBN quite cooperative and responsive to
any an all SBN requests for information or cooperation in any investigations
whether relating to Hill, Gardner, or Nash Holmes, etc.
2772
Coughlin's email to WCSO detailing Deputy Machen's burglary with Hill's associate
Baker of 11/1/11, Machen's false affidavit regarding personally serving Coughlin 24
hour lockout order on 11/1/11 burglary by Hill's associate Baker of that date
2790
Coughlin's 3/16/12 email to King indicating he has yet to finish sending everything in
response to Hill's grievance.
23/31

2792

USPS Certified Mail Track & Confirm ending in 6578 for King's mailing of 3/16/12
(purported letter from King to Coughlin that King was too afraid to/conflicted over/ to
seek admission thereof at 11/14/12 formal disciplinary hearing) that was undeliverable
as addressed given domestic violence abuser housemates obstruction of Coughlins' mail
in conjunction with Gayle Kern, Esq.
2793
King's 3/16/12 letter to Coughlin indicating the OBC has received several
grievances concerning your conduct as a lawyer...I will make available for your
review and inspection the supporting documents and audio recordings
Note King's including the same 3/16/12 letter with the Hill grievance file and the
slippery approach by King in failing to actually specify which district court judge the order he
references as being attached (and just which order was attached is not made clear from King's
manipulation of these SCR 105(2)(c) materials in this 3,094 page bates stamped production.
(at bates 2958 3/16/12 letter from SBN King to Coughlin regarding several grievances oddly placed
with Hill's grievance file when 3/16/12 letter references Justice Court (The Office of Bar Counsel
has received several grievances concerning your conduct as a lawyer. The grievances include
supporting evidence in the form of: audio of your conduct in court proceedings and copies of
pleadings and documents prepared and filed by you in Justice and District Court such purported
3/16/12 letter to Coughlin from King reads) (so, there, King, like with the Judge L. Gardner
grievance in NG12-0435, is caught lying again in asserting supporting evidence for grievances the
OBC received consisting of Coughlin's filing in Justice and District Court (in an obvious attempt
to extend the scope of his hit piece beyond just Hill and the RMC). Such represents the extent to which
King constantly tried to characterize as having been received in the form of a grievance that which
King himself requested from the RJC's Judicial Secretary Lori Townsend, and which resultedin
Townsend's 4/11/12 email to King,)
2794
2795-2796

2797-99

2800
2802
2806
2849
2911
24/31

FORMAL PLEADINGS FILE

10/9/12 Affidavit of Laura Peters (NOTE: incongruously placed at the most recent filing
in this formal pleadings file where such 10/9/12 Affidavit of Laura Peters bares a file
stamped obviously prior in time to the filings placed immediately before it in what is
otherwise the typical reverse chronological order (most recent filings on top) law
office/filing office work in progress case file (before the ROA is then reconstituted in
correct bates stamped first in time to most recent filing chronological order).
Order of 10/31/12 by Panel Chair Echeverria (Coughlin's 10/31/12 file stamped Pre
Hearing Motion to Dismiss/Summary Judgment/Memorandum of Law should have been
included here by the SBN as such was placed in its possession at 4:45pm on 10/30/12,
and, therefore, could have gone out with the materials King alleges were sent to the
printed on 11/1/12)
Order of 10/30/12 Order Appointing Formal Hearing Panel by NNDB Chair J. Thomas
Susich, Esq.
SBN King's 10/24/12 Opposition to Respondent's Motion to Bifurcate Hearing, Motion to
Dismiss
Coughlin's 10/16/12 Motion to Review/Inspect Bar Records, Motion to Bifurcate, Motion
to Dismiss, etc.
Coughlin's Motion for Order to Show Cause
Coughlin's Motion to Dismiss

2915

page 4 of 5 of Coughlin's Motion to Dismiss where SBN excised Exhibit 1 to Coughlin's

filing, a tell tale give away being the incongruous placement of page 5 there from with a
bates stamp of 2914 where page 4 thereof is given SBN bates stampe 2915, which consisted of an
Index to Exhibits (1. Exhibit 1: 9 9 12 Letter to Susich and King) where SBN excised that letter Coughlin
attached as Exhibit 1 thereto.
2916
2926

page 3 of 3 of 11/30/11 Judgment of Conviction and Court Order from RMC Judge Howard in 11
CR 22176 with quasi-Proof of Service of x Refused (illegible initials only) 11/30/11 @ 20:23
following preprinted form in blank following I understand and promise to obey this order. Defendant), which
SBN King fraudulently excised from the version he included in his 23 Exhibit presentation to the NNDB
Screening Panel, which underscores the RMC and SBN's fraudulent approach vis a vis the non service of the
11/30/11 Order Punishing Summary Contempt which formed FHE11.

2954
2955-3017
2956

8/23/12 Affidavit of Service of Complaint by Peters attached to Complaint

Grievance File #NG12-0204 A: Zachary Coughlin G: Richard Hill, Esq.

Copy of envelope USPS Certified Mail # 7010 2780 0003 5429 6578 SBN sent to
Coughlin on 3/16/12 (where FHE6 at the 2/13/13 ROA by the SBN at ROA 1779
demonstrates King's letter to Coughlin referencing a grievance by Hill was purportedly mailed on
2/14/12) with USPS yellow sticker UNABLE TO FORWARD FOR REVIEW dated 3/31/12 (ie, this
is an obvious attempt at misdirection by King where such 3/16/12 USPS Certified Mailing corresponds
with either the Holmes grievance in 0434 or the L. Gardner grievance in 0435, or both, where proof
that the SBN knew such was not delivered to the SBN is very problematic to King's allegation that
Coughlin violated RPC 8.1 Disciplinary Matters as to either the Holmes or L. Gardner
greivances...King placing this envelope here (note the USPS yellow sticker corroborates Coughlin's
accounts respecting the interference with his mail during such period of time) represents a fraudulent
attempt to obfuscate matters.
2958
3/16/12 letter from SBN King to Coughlin regarding several grievances oddly placed
with Hill's grievance file when 3/16/12 letter references Justice Court (The Office of
Bar Counsel has received several grievances concerning your conduct as a lawyer. The grievances
include supporting evidence in the form of: audio of your conduct in court proceedings and copies
of pleadings and documents prepared and filed by you in Justice and District Court such purported
3/16/12 letter to Coughlin from King reads) (so, there, King, like with the Judge L. Gardner
grievance in NG12-0435, is caught lying again in asserting supporting evidence for grievances the
OBC received consisting of Coughlin's filing in Justice and District Court (in an obvious attempt
to extend the scope of his hit piece beyond just Hill and the RMC). Such represents the extent to which
King constantly tried to characterize as having been received in the form of a grievance that which
King himself requested from the RJC's Judicial Secretary Lori Townsend, and which resultedin
Townsend's 4/11/12 email to King,
Tellingly, King fails to include such RJC Judicial Secretary Townsend's email to King (which
King then attempted to pass off as a grievance received from a Justice Court judge, apparently, in
King's sworn testimony at the 1/4/13 Workplace Harassment TPO extension hearing in RCP2012000699...Clearly, King seeks to blur the lines between bar counsel work product and grievances
received from Judges (relevant to the NCJC Canon 2, Rule 2.15 defensive collateral estoppel analysis)
with materials emailed to him by RMC Court Administrator Cassandra Jackson and RMC Filing
Officer Supervisor Donna Ballard, and RMC worker Eva Cabral, which carry no such offensive
25/31

collateral estoppel leveraging or potential of...and King constantly tries to have it both ways, ie,
something is bar counsel work product and not subject to SCR 105(2)(c) or SCR 121(11) when King
needs for it to be (the enclosures to Hill's 1/14/12 email to King that King refused to provide
Coughlin...and indication as to just exactly what was included with the box of materials Judge
Holmes references as including with her FHE8 3/14/12 grievance letter against Coughlin addressed to
the SBN (some of which Holmes takes credit for enclosing only to then pass the buck off to our
staff for providing King the audio tapes of Coughlin' hearing in Departments 2 and 5 (where D2 is
Judge W. Gardner and D4 is Judge Howard) Judge Ken Howard, Department 4, had a case on Mr.
Coughlin late last year that is now on appeal to the Second Judicial District Court. Judge Bill Gardner,
Department 2, also has a matter currently pending in his court with Mr. Coughlin as the defendant. I
have enclosed some copies of documents from those matters, in chronological order, simply because
they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made
you some audio tapes of Coughlin hearings in Departments 2 and 4 so you can hear for yourself how
this attorney acts in court.) ...records of the requests for materials that King made to all the various
judges, judicial assistants, judicial secretaries, and clerks (ie, RJC Judicial Secretary's Townsend's
4/11/12 email to King certainly fails to come across as the first correspondence or communication
between the two...as such, especially where King attempts to pass of the attachments to Townsend's
4/11/12 email to King as a part of the supporting evidence in the form of...copies of pleadings and
documents prepared and filed by you in Justice and District Court (see King's 3/16/12 letter to
Coughlin (which, of course, fails to then indicate or be followed thereafter by anything explicating just
what King was so enclosing in its placement in the 3,094 page production) (that King apparently
included as Exhibits 8 to 10 therein, in the 4/16/12 23 Exhibit presentation to the NNDB at the second
opportunity King was given to get some SCR 105 go ahead approval therefrom) within the folders for
the grievances received from either Hill, Judge L. Gardner...only to included such in the folder for
the Holmes grievance ( between 3,094 page bates 2702-2793 is Grievance File #NG12-0435 A: Z.
Coughlin, Esq. G: Judge Dorthy (sic) Nash Holmes, which includes at bates 2718 RJC Judicial
Secretary Lori Townsend's 4/11/12 email to King containing documents from RCR2011-063341 (Judge
Sferrazza) and RCR2012-065630 (Judge Clifton) RJC Chief Civil Clerk told Coughlin Judge Clifton
told her not to respond to Coughlin's 10/30/12 SCR 110 subpoena and subpoena duces tecums
2959

RMC Judge Nash Holmes' grievance letter to the SBN (why on earth such is placed in the
folder for Hill's grievance, other than being another attempt at obfuscation by King, is
not clear at all, especially where what follows after this letter in the SBN's 3,094 bates
stamp production rather obviously fails to evince just what was in that box of materials this FHE8
3/14/12 letter to the SBN by Judge Nash Holmes references as being included therewith where Judge
Flanagan's 6/25/12 Order follows immediately afterwards (ie, such did not even exist to be included
within box of materials as the time such 3/14/12 FHE8 letter by Holmes was written)
2961
2JDC Judge L. Gardner's 4/13/09 Order After Trial, FHE3 compare 5 in 15 of
Received Mar 15 2012 to other versions (ditto).
Well, shoot, given the SBN stamping such L. Gardner 4/13/09 Order After Trial (FHE3)
as received on 3/15/12, such either was not recieved amongst the box of materials that Holmes
referenced in FHE8 as providing to King with her 3/14/12 letter, or such was included and the SBN's
King and or Peters attempted to fraudulently misdirect reviewers from gleaning that Judge Holmes so
included such FHE3 therewith, or, Judge Holmes did not included such FHE3 within the box of
materials accompanying her 3/14/12 letter (King eventually indicated in his 4/19/12 email to Coughlin
that he requested a copy of such order from the clerk of court being careful not to specify which clerk
26/31

of which court King received such from in response to King's requesting such (which brings up the
question of just how King became aware of such FHE3, and received such in such close proximity
(3/15/12 compared to 3/14/12 dates received stamps on FHE3 and FHE8, respectively if it was not
from the RMC and or Judge Holmes from who King learned of FHE3 (versus FHE3 having been
referred to King pursuant to Canon 2, Rule 2.15 by a judge, much less the judge whom presided over
the divorce case from which FHE3 issued).
In which case RMC Judge Holmes (whom was careful in her sworn testimony to avoid such
inquiry as much as possible) ought be made to explain why she apparently absconded from her NCJC
Canon 2, Rule 2.15 duty to report apparent lawyer misconduct to the SBN, the appropriate authority
in such a case...and certainly the suggestion of a cover up by the RMC Judges Holmes, Gardner,
Howard (and possibly Dilworth) is present therein, where the subsequent admission by Judge W.
Gardner, upon Coughlin forcing his hand during the 4/10/12 trial in 26506 Gardner attempted to hold in
violation of NRS 178.405 (and W. Gardner's statements on the record there are very telling and indicate
a coordinated agreement between W. Gardner and Holmes that the FHE3 order by W. Gardner's sister
would not be provided to the SBN by RMC Judge Holmes (as well as W. Gardner's inaccurate accounts
of whether any competency issues are referenced in the orders by Judge Holmes Coughlin put to him at
such point (really, W. Gardner was totally going to go through with the trial on 4/10/12, until Coughlin
finally cornered Loomis to displaying some sembleance of professionalism (it does not come easy to
Keith) and where Coughlin's cross-examination of W. Gardner resulted in Gardner becoming too
flustered to go forward, whereupon, rather than recognizing the NRS 178.405 duties attendant to Judge
Holmes 3/12/12 Order suspending the trial in 26800 and Holmes FHE8 letter to the SBN (both of
which reference Coughlin's alleged competency issues, mental instability, and decompensating),
W. Gardner rather passed his off suspending the trial of 4/10/12 (but only after he, Loomis, and RCA
Hazlett-Stevens got some motion work addressed, etc, official copy of such trial date of 4/10/12 in
26405 before W. Gardner available here (and such was provided to both the SBN and Panel prior to the
11/14/12 formal hearing: http://www.youtube.com/watch?v=VVPx1zoVw5c Also, some real bon mots
to be hear in the official audio from the RMC of the 5/8/12 hearing in that same 26405 criminal
trespass case: http://www.youtube.com/watch?v=SW76cMukZPc ) as being in response to something
other than all the corners Judge Holmes' behind the scenes machinations put W. Gardner in.
A closer consideration of what the SBN placed in the Hill grievance file and why further details
the SBN's fraud:
2955-3017 Grievance File #NG12-0204 A: Zachary Coughlin G: Richard Hill, Esq.
2956
Copy of envelope USPS Certified Mail # 7010 2780 0003 5429 6578 SBN sent to
Coughlin on 3/16/12 (where FHE6 at the 2/13/13 ROA by the SBN at ROA 1779
demonstrates King's letter to Coughlin referencing a grievance by Hill was purportedly mailed on
2/14/12) with USPS yellow sticker UNABLE TO FORWARD FOR REVIEW dated 3/31/12 (ie, this
is an obvious attempt at misdirection by King where such 3/16/12 USPS Certified Mailing corresponds
with either the Holmes grievance in 0434 or the L. Gardner grievance in 0435, or both, where proof
that the SBN knew such was not delivered to the SBN is very problematic to King's allegation that
Coughlin violated RPC 8.1 Disciplinary Matters as to either the Holmes or L. Gardner
greivances...King placing this envelope here (note the USPS yellow sticker corroborates Coughlin's
accounts respecting the interference with his mail during such period of time) represents a fraudulent
attempt to obfuscate matters.
2958
3/16/12 letter from SBN King to Coughlin regarding several grievances oddly placed
with Hill's grievance file when 3/16/12 letter references Justice Court (The Office of
Bar Counsel has received several grievances concerning your conduct as a lawyer. The grievances
27/31

include supporting evidence in the form of: audio of your conduct in court proceedings and copies
of pleadings and documents prepared and filed by you in Justice and District Court such purported
3/16/12 letter to Coughlin from King reads) (so, there, King, like with the Judge L. Gardner
grievance in NG12-0435, is caught lying again in asserting supporting evidence for grievances the
OBC received consisting of Coughlin's filing in Justice and District Court (in an obvious attempt
to extend the scope of his hit piece beyond just Hill and the RMC). Such represents the extent to which
King constantly tried to characterize as having been received in the form of a grievance that which
King himself requested from the RJC's Judicial Secretary Lori Townsend, and which resultedin
Townsend's 4/11/12 email to King,
Tellingly, King fails to include such RJC Judicial Secretary Townsend's email to King (which
King then attempted to pass off as a grievance received from a Justice Court judge, apparently, in
King's sworn testimony at the 1/4/13 Workplace Harassment TPO extension hearing in RCP2012000699...Clearly, King seeks to blur the lines between bar counsel work product and grievances
received from Judges (relevant to the NCJC Canon 2, Rule 2.15 defensive collateral estoppel analysis)
with materials emailed to him by RMC Court Administrator Cassandra Jackson and RMC Filing
Officer Supervisor Donna Ballard, and RMC worker Eva Cabral, which carry no such offensive
collateral estoppel leveraging or potential of...and King constantly tries to have it both ways, ie,
something is bar counsel work product and not subject to SCR 105(2)(c) or SCR 121(11) when King
needs for it to be (the enclosures to Hill's 1/14/12 email to King that King refused to provide
Coughlin...and indication as to just exactly what was included with the box of materials Judge
Holmes references as including with her FHE8 3/14/12 grievance letter against Coughlin addressed to
the SBN (some of which Holmes takes credit for enclosing only to then pass the buck off to our
staff for providing King the audio tapes of Coughlin' hearing in Departments 2 and 5 (where D2 is
Judge W. Gardner and D4 is Judge Howard) Judge Ken Howard, Department 4, had a case on Mr.
Coughlin late last year that is now on appeal to the Second Judicial District Court. Judge Bill Gardner,
Department 2, also has a matter currently pending in his court with Mr. Coughlin as the defendant. I
have enclosed some copies of documents from those matters, in chronological order, simply because
they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made
you some audio tapes of Coughlin hearings in Departments 2 and 4 so you can hear for yourself how
this attorney acts in court.) ...records of the requests for materials that King made to all the various
judges, judicial assistants, judicial secretaries, and clerks (ie, RJC Judicial Secretary's Townsend's
4/11/12 email to King certainly fails to come across as the first correspondence or communication
between the two...as such, especially where King attempts to pass of the attachments to Townsend's
4/11/12 email to King as a part of the supporting evidence in the form of...copies of pleadings and
documents prepared and filed by you in Justice and District Court (see King's 3/16/12 letter to
Coughlin (which, of course, fails to then indicate or be followed thereafter by anything explicating just
what King was so enclosing in its placement in the 3,094 page production) (that King apparently
included as Exhibits 8 to 10 therein, in the 4/16/12 23 Exhibit presentation to the NNDB at the second
opportunity King was given to get some SCR 105 go ahead approval therefrom) within the folders for
the grievances received from either Hill, Judge L. Gardner...only to included such in the folder for
the Holmes grievance ( between 3,094 page bates 2702-2793 is Grievance File #NG12-0435 A: Z.
Coughlin, Esq. G: Judge Dorthy (sic) Nash Holmes, which includes at bates 2718 RJC Judicial
Secretary Lori Townsend's 4/11/12 email to King containing documents from RCR2011-063341 (Judge
Sferrazza) and RCR2012-065630 (Judge Clifton) RJC Chief Civil Clerk told Coughlin Judge Clifton
told her not to respond to Coughlin's 10/30/12 SCR 110 subpoena and subpoena duces tecums
28/31

2959

RMC Judge Nash Holmes' grievance letter to the SBN (why on earth such is placed in the
folder for Hill's grievance, other than being another attempt at obfuscation by King, is
not clear at all, especially where what follows after this letter in the SBN's 3,094 bates
stamp production rather obviously fails to evince just what was in that box of materials this FHE8
3/14/12 letter to the SBN by Judge Nash Holmes references as being included therewith where Judge
Flanagan's 6/25/12 Order follows immediately afterwards (ie, such did not even exist to be included
within box of materials as the time such 3/14/12 FHE8 letter by Holmes was written)
2961
2JDC Judge L. Gardner's 4/13/09 Order After Trial, FHE3 compare 5 in 15 of
Received Mar 15 2012 to other versions (ditto).
Clearly, Judge Holmes and the SBN's King come from the same school of manufacturing the
appearance of the outrage of others (FHE8: The accompanying box of materials demonstrates some of
the problems with the practice of this attorney being experienced by myself and the other three judges
in Reno Municipal Court....You will have the full cooperation of myself, the other judges, and the
staff of Reno Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a
vexatious litigant in our court, antagonizing the staff and even our pro temp judges on the most simple
traffic and misdemeanor matters....), combining that with consistently attempting to obfuscate what
came first, the request for information, filings, or other materials from Asst. Bar Counsel King and the
SBN, or some independent, voluntary, NCJC Canon 2, Rule 2.15 referral by a judge (versus by some
employee of a court who is not a judge) (FHE8 I apologize for taking two days to get this package to
you... wrote Judge Holmes to King (indicating King requested she and the RMC provide such
materials rather than Holmes and or the RMC do so independent thereof.).
However, again, if Holmes did not included the FHE3 2JDC Judge L. Gardner Order that she
admits to having been passed by RMC Judge W. Gardner (whom admits having been passed such by
his sister, 2JDC Judge L. Gardner, whom issued it in the matter she presided over...), then why did
Holmes not so provide such to the SBN (SBN King's email to Coughlin of 4/19/09 finally comes clean,
somewhat as to how King and the SBN received FHE3 (though, clearly, King is still attempting to
cover up the judicial misconduct by 2JDC Judge L. Gardner, RMC Judge W. Gardner, RMC Judge
Holmes, RMC Judge Howard, (possibly RMC Judge Dilworth, though, being the seasoned veteran that
he is, Judge Dilworth wisely recused himself from the ridiculous prosecutions of Coughlin goon for the
Reno City Attorney Chief Wong is currently insisting on bringing against Coughlin in RMC 13 CR
3913 and 3914 (wherein Wong is prosecuting Coughlin over the most ridiculous alleged violations of a
Workplace Harassment TPO and EPO ever alleged (accusing Coughlin of violating such by submitting
documents for filing with the Clerk of Court of the SBN in a then pending matter...so much for due
process, huh? These people are humiliating the State Bar of Nevada and the Nevada Supreme Court in
the process if this goes on much longer) as a favor to his old coworker at the Attorney General's Office,
current SBN Asst. Bar Counsel King (whom attempted to get Wong to provide him Coughlin's criminal
history (see 3,094's bates 2723 email of 4/10/12 to SBN from RCA Dan Wong regarding SBN will be
unable to get Coughlin's criminal history (Pennie Colter, etc)). Judge Dilworth apparently decided
(beyond the decision that at least the appearance of impropriety and or bias called for such recusal) that
this was RMC Judge W. Gardner, Judge Holmes, and 2JDC Judge L. Gardner's mess and they could
deal with it themselves, thank you very much.
FHE8, Judge Holmes' 3/14/12 letter to the SBN reads:
Judge Nash Holmes' 3/14/12 grievance to bar counsel reads:
Re: Zachary Barker Coughlin, Nevada Bar No. 9473
29/31

Dear Mr. Clark:

This letter constitutes a formal complaint of attorney misconduct and/or disability against
Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the
problems with the practice of this attorney being experienced by myself and the other three
judges in Reno Municipal Court. My two most recent Orders in what should be a simple traffic
citation case are self-explanatory and are included, together with copies of massive documents
Me. Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in
this matter are also included. He failed to appear for the second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our
Department I judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't
seem to locate him between cases very easily. We are setting that case for trial and attempting to
serve him at the most recent address we have (1422 E. 9th St. #2 Reno NY 89512), although I
heard today he may be living in his vehicle somewhere. We do have an address for his mother,
however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on
appeal to the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter
currently pending in his court with Mr. Coughlin as the defendant. I have enclosed some copies of
documents from those matters, in chronological order, simply because they appear to demonstrate
that he is quickly decompensating in his mental status. Our staff also made you some audio tapes
of Coughlin in Departments 2 and 4 so you can hear for yourself how this attorney acts in court.
You can see his behavior in my traffic citation case does not appear to be an isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this
attorney. My Judicial Assistant was contacted by the Washoe Public Defender in February when I
had Mr. Coughlin jailed for Contempt of Court and they stated that they represent him in a Gross
Misdemeanor matter in RJC. I have no other information on that.
You will have the full cooperation of myself, the other judges, and the staff of Reno
Municipal Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a
vexatious litigant in our court, antagonizing the staff and even our pro temp judges on the most
simple traffic and misdemeanor matters. I do think this is a case of some urgency, and I apologize
for taking two days to get this package to you; our IT person was ill and could not make the
copies of the audios of Mr. Coughlin's hearings until today, and I felt it was important that the
audios be included in the materials to be considered by the State Bar. On February 27, 2012, Mr.
Coughlin told me he was actively practicing law and had appointments with clients. I do not
know if that was true, but if so, he could be causing serious harm to the practice of law in
Northern Nevada and could be jeopardizing someone's freedom or property interests.
/s/ Judge Dorothy Nash Holmes, Reno Municipal Court. Encls."
Of course, its very cute for King to then place immediately thereafter in the folder
indentified as the NG12-0204, Richard G. Hill, Esq. Grievance File 2JDC Judge Flanagan's 6/25/12
Order (FHE2)
2975
6/25/12 Order by 2JDC Judge Flanagan in CV11-03628 $42,065 attorney fee award
(NOT A SANCTION, rather a prevailing party attorney's fee award based upon a
misapplication of NRS 69.050, which applies only to judgments, not summary eviction orders, and
where NRS 40.400 makes quite clear that NRAP applies to appeals of summary eviction orders. The
only basis for an attorney fee award in NRAP is NRAP 38, which requires a finding of sanctionable
30/31

conduct for the issuance of any such attorney's fee award. As such, where 2JDC Judge Flanagan's
8/28/12 Order in CV11-03628 makes explicitly clear that his 6/25/12 Order (FHE2) was not a sanction,
and where King himself sent Coughlin a letter with a copy of such 8/28/12 Order)
2979
SBN Bar Counsel Clark forwards on Coughlin's 1/23/12 self report of conviction in
60838 to King and Peters
2981
FHE7 Coughlin's 3/9/12 fax to SBN reg 2/14/12 letter from King only received on 3/9/12,
requesting all correspondence be copied via email and fax due to obstruction of
Coughlin's mail (which, of course, King, Peters, and the SBN fail to do...so much for
that SOLACE program, huh?)
2983
SBN King's 2/14/12 letter to Coughlin (FHE6)
2984
SBN King's letter to Hill regarding grievance Hill purportedly emailed to King, compare
to the letter King sent Coughlin refusing to investigate Coughlin's grievances against
RMC defender Loomis and WCPD Dogan.
2985
King's email to Clark and Peters detailing youtube video of 8/20/11 RPD misconduct in
wrongful arrest of Coughlin at issue in RJC RCR2011-063341 containing Hill's forward
to King of Coughlin's email to WCSO, WCPD, RCA, Hill's associate Baker, etc. of
2/10/12 detailing Baker and WCSO Deputy Machen's burglary of 11/1/11 in Rev2011001708, CV11-03628 at 121 River Rock
3004
Coughlin's 1/14/12 Opposition to Motion for Attorney Fees in CV11-03628 detailing
Hill's misconduct incident to Coughlin's 1/12/12 jaywalking arrest in front of 121 River
Rock former home law office.
3013-3017 Hill's 1/14/12 email to King, five page grievance, unsigned, unsworn (interstingly, either
Hill failed to really include such disclosures or King excised such, inappropriately,
from this 3,094 SCR 105(2)(c) production of 11/7/12, causing much prejudice to
Coughlin's defense.
3018-3043 Grievance File #NG12-0434 A: Zachary Coughlin G: Judge Linda Gardner
3019 -3043 purported printout of 3/15/12 regarding prosecutorial misconduct in various states
summaries thereof from http://zachcoughlinesq.wordpress.com
with header that reads Page 1 of 1094 and a stamped FYI seemingly superimposed
on the first page. (NOTE: nothing to indicate anything was received from 2JDC Judge L.
Gardner).
3044
3048
3050
3055
3065
3077
3080
3091

31/31

Zach Coughlin 111 Petition

Coughlin's application for legal defender and 10/27/11 RMC Judge Howard Order
Denying Legal Defender
RCA Pamela Roberts, Esq. Opposition to Motion for New Trial of 12/21/11 in 11 CR
22176 (60838) (NOTE: lacks the actual exhibits to such motion, and instead is
misleadingly followed by the Exhibits to King's 10/15/11 SCR 111(4) Petition in 61901
Exhibit 1 to King's SCR 111(4) Petition in 61901
SCR 111(4) Petition in 61901 of 10/15/12
60838 Order of Temporary Suspension and Referral to Disciplinary Board of 6/7/12
SCR 111(6) Petition in 60838
5/8/12 stamped USPS Domestic Return Receipt PS Form 3811 60838 Certified Mailing
7010 2780 0003 5429 6752