7 8 13 0204 Filed But Submitted 11 9 12 61901 Amendment To Opposition

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Electronically Filed
Jul 08 2013 02:34 p.m.
Tracie K. Lindeman
Clerk of Supreme Court
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IN THE SUPREME COURT OF THE STATE OF NEVADA
In Re Matter of:
ZACHARY BARKER COUGHLIN, ESQ.
10 Nevada Bar No: 9473
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AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION
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Zach Coughlin, files this on his own behalf, the above title document.
Columbus Prop. Inc. v. I S K S Realty Corp., 621 N.Y.S.2d 277 N.Y.City.Civ.,1994 Because
petitioner in summary proceeding under Real Property Actions and Proceedings Law obtains benefit
of expedited and simplified procedure which bypasses many of usual procedural steps of plenary
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action, petitioner must prove strict compliance with all requirements for summary proceeding; as
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omission of required act of service is fatal to plenary.
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FACTS
1.
On February 27th, 2012, while awaiting trial before Judge Nash Holmes in 11 TR
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26800, and in a private meeting with Reno City Attorney Allison Ormaas in one of the private
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conference/meeting rooms outside the interior doors to the court room, RMC Marshal Harley entered
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the room and purported to personally serve Coughlin a document in the appeal of the eviction from
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Docket 61901 Document 2013-19877
Coughlin's former home law office, in CV11-03628, apparently at the direction of Richard G. Hill,
Esq., on behalf of his client Merliss (the landlord, whom all three of the appointed defenders provided
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by the RMC to Coughlin refused to subpoena, apparently because it would cut into their $7K fee from
the RMC and because of an apparent desire to torpedo Coughlin's defense, despite Merliss being a
material witness. Further, it is believed OFficer Carter and Sargent Lopez were subpoened by the
City, and perhaps by Coughlin, though a continuance was denied upon their faling to appear).
Washoe County Sheriff's Deputy John Machen filed a false Affidavit of Service on November 7th,
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2011, in RJC Rev2011-001708 alleging to have "personally served" Coughlin. This is arguably a
violation of the "courthouse sanctuary" doctrine.
When Judge Nash resume the proceedings in 11 TR 26800 (which Coughlin was not
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appaently noticed on in writing and did not attend, though he did file a Request for Continuance of
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some sort on or about March 9th, 2012) the audio record of that Trial begins with the Court Marshal
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confirming with Judge Nash Holmes and City Attorney Ormaas that they want him to "lock that door"
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so "no one else can come in".... At that hearing judge Nash found at the 3 min. 32nd mark goes on to
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detail her explanation of how it is Reno meeting court could keep retain and failed to return even after
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Coughlin's mother filed a motion for the return thereof the hundred dollars that she deposited with
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Reno many court to get Coughlin released one day early from his five-day summary criminal
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contempt conviction that judge Nash Holmes entered on favorite 27 2000 and well incident to the
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traffic citation matter stemming from Richard Hill's Locke's cock and she alludes to the jail releasing
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Coughlin in their upon rebooking him or something based upon some Reno justice court matter but
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some fact is you taking someone who is incarcerated or detained back down the the booking counter
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is not quite tantamount releasing them sufficient to allow the Reno Municipal Court retain some
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hundred dollars that it agreed to accept should the defendant be released from jail there is little bit of a
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difference there between being released from jail and having a deputy the Milwaukee down the the in
handcuffs to the booking counter for 2 min. to check off some box and it's it's intellectually dishonest
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for judge Nash Holmes to suggest otherwise. Judge Nash Holmes then goes on to make some
tortuous attempt to find submitting a request to proceed informal pauperis that included an affidavit of
financial condition that was several months old to be tantamount to an attempt to commit some fraud
on the court (apparently broke people are supposed to pay a notary $5 each and every time the submit
an IFP under NRS 12.015 (even where there is not right to appeal the inevitable denial thereof, and
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even where one's financial condition may have only gotten much worse from late November 2011 to
March 2012)..
Uh....what?... Judge Nash Holmes then at the 6 min. mark proceeds to detail her lack
of understanding of NRS 178.405 wherein she purports to diagnosis Coughlin as suffering from some
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sort of disability or lack of competency only to then go on in purport to find by clear and convincing
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evidence some alleged file a shins of the rules of professional conduct seeing as how judge Nash
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Holmes at that point transmogrified a traffic citation trial into a full-blown disciplinary hearing.
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All of the allegations herein also relate to "irregularities" in the proceedings and prosecutorial
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misconduct" justfying the relief requested herein. Coughlin's ability to get this exculpatory video
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wherein Sargent Lopez admits RPD Officer Carter and Richard Hill, Esq. and Casey Baker, Esq. lied,
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under oath (in Hill's case) at the June 18th, 2012 Trial and in violation of NRCP Rule 11 (in Baker's
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case in his November 21st, 2011 Opposition to Coughlin's Motion to Contest Personal Property Lien)
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was severaly compromised, to an excusable neglect extent, and to a good cause standard, by the
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various fraudulent, retaliatory arrests and incarcerations (which often involve arbitrary denial of
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detainee's medications and access to even one sheet of paper, even where indigent, to file a
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document), and the fraudulent attempts by RPD in sending out Officer Warren (who is a specialized
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officer in that regard and may well have good intentions, but the City Attorney and the RPD do him
no favors where they attempt to cover over police misconduct by diagnosing the victim of it) and
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others to alienate Coughlin from his family and any other type of a support system, all in the name of
covering up wrongful arrests by the WCPD, and or WCSO and or wrongful "summary contempt"
findings, including those in 11 TR 26800, RCR 2012-065630 (Sargent Sifre's order to arrest Couglin
on January 14th, 2012 for "misuse of emergency communications" NRS 207.245 (because reports of
police misconduct or harassment never qualify as a "perceived emergency" according to Kariann
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Beechler of ECOMM) (though, Judge Clifton does seem to have a bit of a fairness streak within him,
and may indeed reveal a penchant for demonstrating the extent to which, no term limits be damned,
the judiciary in Washoe County is not going to be pushed around and once it becomes clear that DDA
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Young is trying to pull an In Re Beckett (57280) on Coughlin, even where Young is violating RPC
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3.8 in that he lacks probable cause to so amend his Complaint, well...)
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NRS 207.245 seeks to amend the politically trick y to maintain NRS 207.245 misuse of 911 by a
domestic violence victim (as adjudge in FV12-00187 and 188) charge to a misdemeanor giving him
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far more "leverage", the offense of Resisting, Delaying, or Obstructing a Public Officer in violation of
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NRS 199 . 280(3), in light of Coughlin's chosen profession, attorney, and SCR 111(6), attorney's
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convicted of crimes requiring Bar Counsel seek to take away one's license upon a conviction::( 6).
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Definition of serious crime. The term serious crime means (1) a felony and (2) any crime less
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than a felony a necessary element of which is, as determined by the statutory or common-law
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definition of the crime, improper conduct as an attorney, interference with the administration of
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justice, false swearing, misrepresentation, fraud, willful failure to file an income tax return, deceit,
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bribery, extortion, misappropriation, theft, or an attempt or a conspiracy or solicitation of another to
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commit a serious crime. Compare:
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NRS 207.245 Use of system providing telephone number to be used in emergency when no actual or
perceived emergency exists. 1. As used in this section, system means a system established to
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provide a telephone number to be used in an emergency. 2. It is unlawful for any person knowingly or
willfully to make or cause to be made any telephonic access to a system if no actual or perceived
emergency exists. 3. Any person who violates any provision of this section is guilty of a gross
misdemeanor.
NRS 199.280 Resisting public officer. A person who, in any case or under any
circumstances not otherwise specially provided for, willfully resists, delays or
obstructs a public officer in discharging or attempting to discharge any legal duty of
his or her office shall be punished: 1. Where a firearm is used in the course of such
resistance, obstruction or delay, or the person intentionally removes, takes or attempts
to remove or take a firearm from the person of, or the immediate presence of, the
public officer in the course of such resistance, obstruction or delay, for a category C
felony as provided in NRS 193.130. 2. Where a dangerous weapon, other than a
firearm, is used in the course of such resistance, obstruction or delay, or the person
intentionally removes, takes or attempts to remove or take a weapon, other than a
firearm, from the person of, or the immediate presence of, the public officer in the
course of such resistance, obstruction or delay, for a category D felony as provided in
NRS 193.130. 3. Where no dangerous weapon is used in the course of such
resistance, obstruction or delay, for a misdemeanor.
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(which DDA Zach Young, Esq is now seeking to amend to a "lesser" crime, which, conveniently for
the WCDA's Office just so happens to be one (false statement to a public officer) that fits nicely into
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the "serious offense" rubric of SCR 111(6), and therefore leverages far greater damage to Coughlin's
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professional career than would the original charge, which is now some 11 months old (though Judge
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Clifton couldn't be bother to actually let Coughlin elucidate how that might present some prejudice to
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Coughlin' defense, to allow Young to so amend the charge, and where such a Motion is so obviously
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transparent, made for an impermissible purpose, and violative of RPC 3.8 in that Young lacks
probable cause for making it (so, Coughlin allegedly saying to a 911 dispatcher that an officer was
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shining a flashlight in his face is "a lie" according to Young because, what, the officer was shining the
flashlight on Coughlin's shoulder? Okay....and since when is "using profanity" tantamount to and,
apparently the WCDA and or Young can put little yellow 'post it' notes on their Motions that read
"please give to judge to review before hearing" (that's an ex parte communication or attempt to get
something heard on a clandestine order shortening time or something) on the July 31st, 2012 Motion
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to Amend his criminal complaint of January 22nd, 2012 for a hearing on August 6th, 2012 which
neither WCPD Jim Leslie nor Biray Dogan (they made it a a "combo-hearing", and sometimes they
make things "combo-trials") want to get into too deeply just how exactly their office noticed Coughlin
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on (they didn't, then tried to play it like they "saved the day with their brilliant advocacy" when
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Coughlin "failed to show up" (which Court records indicate is now a basis for incarcerating Couglin
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and or denying bail in light of this alleged "failure" on Coughlin's part, despite Jim Leslie's assistant
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Linda Gray admitting their office did not notice Coughlin in any way on that August 6th, 2012
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hearing....(which WCPD Biray Dogan and Judge Clifton feel quite strongly that criminal defendants
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like Coughlin have no right to know where filed or to be provided a copy thereof, regardless of
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whether Coughlin had previously sent express written notice that he demanded as much, as politely as
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possible in RCR2012-065630) , in addition to WCSO Deputy Machen's fraudulent arrest of Coughlin
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on June 28th, 2012, including the fraudulent "Sixth Amendment representation by WCPD Jim Leslie
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and Biray Dogan (in RCR 2012-065630 and RCR2012-067980) in those matters)) (if Marshal Harley
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is going to follow Coughlin into the restroom, then peer through a restroom stall and, as alleged by
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Judge Nash Holmes in her 3/12/12 Order following a hearing that Coughlin was not appropriately
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noticed on by the RMC, despite it being aware of Coughlin's then current address at the time it mailed
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a 2/28/12 Order in 11 TR 26800 to Coughlin...and Judge Nash Holmes is going to enter and Order
finding Coughlin to be guilty of "summary criminal contempt" (which isn't even an actual charge
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under NRS), then Marshal Harley and or Judge Nash Holmes need to sign affidavits to the extent
those Ordes explicitly reference alleged conduct in a bathroom stall, ie, not, allegedly "committed in
the court's presence" under any section of NRS 22)), then Marshal Harley needs to sign an affidavit,
which he has not done. And RMC Marshal Coppa should perhaps focus less on critiquing Coughlin's
alleged wearing of "pajama bottoms" to the RMC filing office coutner while checking a traffic
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citation, and more on whether he violated the Fourth Amendment and other laws incident to his
conduct on February 27th, 2012 in pulling into a back room in the sally bay at the WCDC WCSP
Deputy Cheung and seeking to, upon information and belief, commit some misconduct (and the RMC
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Marshals coming back to the WCDC on June 28th, 2012 and retrieving Coughlin's smart phone,
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phone, and micro sd card is not a "search incident to arrest", and a warrant needs to be produced to
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show how the RMC and or the Marshal did not violate the Fourth Amendment. Further, the RMC
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needs to answer for why it has flouted Nevada law in failing to transmit the appropriate materials in
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response to Coughlin's filing, on March 7th, 2012, of a NOtice of Appeal (see NRS 189.010-.050) in
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11 TR 26800). Further, if any "recording device" was "dissassembled" during a bathroom break, then
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how could Coughlin's answers to Judge Nash Holmes sua sponte interrogation, incident to improper
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suggestions made to her by the Reno Marshals and or City Attorney Allison Ormass, possibly be
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appropriate? Further, in CR12-0376 Coughlin's rights were raped by the court system, and WCPD
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Biray Dogan and Jeremy Bosler, and Judge Elliot's incarcerating Coughlin on April 19th, 2012 until
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April 26th, 2012 (incident to a fraudulent filed letter by Lake's Crossing of April 18t, 2012, signed by
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Dr. Bill Davis, and Dr.Farmer, though Davis disclaims and connection to that letter, amazingly)
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provides a further excusable neglect basis, as does the fraudulent conduct of the RJC and or the
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WCSO (including Deputy Machen) of June 28th, 2012 in the custodial arrest (with impermissible
denial of a phone call, for now reason at all, thanks to the misconduct of Deputy Van der Wall and
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"Nurse Katherine", and Deputy Beatson, in denying Coughlin a phoen call for 20 hours, for no reason
whatsoever (despite WCDC policy and or the law requiring one within 3 hours), in addition to the
fraud of Nevada Court Services (partners with RMC court appointed defender Lew Taitel, whom
represented Couglin in this very matter, 11 CR 26405, despite an obvious conflict). Also, the fraud
by Ltn. Kevin Brown, Sargent Oliver Miller, Officer Alan Weaver, and Sargent Dye of the RPD in
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connection with the incarceration of Coughlin from July 3rd, 2012 to July 21st, 2012 contributed to
preventing Coughlin from (as did the fraud by the WCDC in refusing to timely file Coughlin's court
filings so submitted, including one's in this case and in the sister case appeal in cv11-03628 wherein
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during his incarceration Coughlin was prevented from opposing or otherwise addressing an
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outrageous $40,050 attorney's fees award to Richard G. Hill, Esq. incident to the appeal of the
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wrongful summary eviction in RJC Rev2011-001708 by Richard. G. HIll, ESq., and further curious is
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RMC Judge Gardner's 11/30/11 transferring of the ridiculous wrongful arrest for "jaywalking" of
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Coughlin on January 12th, 2012 incident to Coguhlin's peacefully filming Hill's crew loading up
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personalty from Coughlin's former home law office to take to the town dump, wherein HIll lied to
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RPD Officer Alan Hollingsworth, i na criminal violation by Hill, eventually leading to a wrongful
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custodial arrest of Coughlin for jaywalking in RMC 12 CR 00696 (the case "Administrative Judge"
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William Gardner of the RMC just so happened to transfer to Judge Nash Holmes (to go along with all
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the work she was puttin' in for thr RMC on 11 TR 26800, the triple traffic citation incdient to
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Coughlin seeking the return of his client's files and state issued indentification from Richard G. Hill,
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ESq. on NOvember 125th, 2011, following Coughlin's relesae from 3 days incarceration incident to
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the fraudulent and wrongful custodial arrest of Coughlin on NOvember 13th, 2011 in 11 CR 26405 by
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RPD Officer Carter and Sargent Lopez.. Everytime, Coughlin has been wrongfully arrested (which is
everytime Coughlin has been arrested) the WCDC has impermissibly withheld Coughlin's
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medications from him while the WCDA's Office and REno City attorney and or the RMC and RJC
have sought to violate NRS 178.405 and NRS 5.010 in plowing ahead with Trials and settings during
the pendency of an Order for Competency Evaluation (including the one's detailed in Coughlin's
previous filing in this regard). Add to that the fraud of Northwinds in RJC reve2012-001048, the
fraud of GAyle Kern and WNM's Sue King in the Coughlin v. Park Terrace Town Homes HOA in the
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RJC and that of Jeff Nichols in Couglhin v NIchols (another landlrod tenant matter in the RJC) and its
excusable neglect any extent to which Coughlin did not previously produce this excuplatory video,
particularly where it was wrongfully withheld from his under an unlawful rent distraint or other
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impermissilbe action by a landlord, and how that is excusable neglect is obvious, no matter what
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RMC Judge Howard's lack of appreciation of what being a tenant subjected to fraud by a landlord
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may have revealed in 11 CR 22176 or the misconduct of Pam Roberts, Esq., City attorney in that
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matter (and all the fallout of the decisions and action by those two therein).
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1.1
January 13th, 2012 RPD Sargent Marcia Lopez and Officer Travis Warren and Officer
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Avila respond to a call for help regarding a domestic disturbance from Zach Coughlin relating to the
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attacks by his housemates, Christopher "Erin" Allaback and Laura Foreshee for which Coughlin
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ultimately received two Orders of Protection in FV12-00187 and FV12-00188. Sargent Lopez
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subjected Coughlin to a custodial arrest for criminal trespass in Reno Municipal Court case 11 CR
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26405, on November 13th, 2011 (which resulted in Coughlin being convicted for criminal trespass
following the June 18th, 2012 Trial wherein Richard Hill testified as follows:
The admission by Sargent Lopez was captured on a high 8mm video camera that Coughlin
bought from a thrift store for five dollars after his then housemate ruined his digital smart phone
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video recorder by throwing hot coffee on it an Coughlin. Coughlin then transferred the tape from that
high 8mm to a digital version by filming a television with a digital video camera later obtained, while
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it was playing that high 8mm tape. The file was name "0201 cropped Carter Lopez 26405.wmv, and
the following represents and accurate transcription thereof, in relevant part:
Coughlin: Sargent Lopez are you going to arrest Nevada court
services for trespass?
Lopez: I'm not going to arrest them for trespass.
Coughlin: but you arrested me for trespass.
Lopez: because you were squatting in the property.
Coughlin: why do you say that you have any evidence of that? (5
seconds of silence is Sargent Lopez's response) did you
announce that you were Reno PD prior to kicking the door in?
Lopez: I didn't kick the door in.
Coughlin: did you announce that you are Reno PD prior to
anybody kicking the door in?
Lopez: I didn't have to,
Coughlin: so nobody announced that they were Reno PD?
Lopez: because the guy who kicked it in had to kick in his own
door because you were squatting in his place.
Coughlin: so you are admitting that you guys didn't announce that
you were Reno PD.
Lopez: you are wearing my patience thin, Sir, okay. I am trying
to come here to help you, and I bring a specialized officer
(motioning to RPD Officer Travis Warren, whom has been
described as some sort of RPD Officer with some specialty in
"mental health" related areas).
Coughlin: that's interesting, you admit that you and Officer Carter
never announced that you are Reno PD, and that you never asked
me to leave, did you, prior to the door being kicked in?
Officer Travis Warren: She didn't have to do anything like that.
Coughlin: you didn't have to! That's great, but that means you
didn't either.
Warren: hold on Zach. You asked us to come here because you
needed help now you are being confrontational.
Coughlin: no I'm not, no not. Anybody who asked you a question
is confrontational, I guess, huh?
Warren: Zach, let's try to stay on topic.
Coughlin: On topic? I'm not on the topic you want me to be on.
Warren: Zach the topic that I'm interested in...
Coughlin: Is the one that covers your ass!
Warren: No, it's not.
Coughlin: Yes, it is."
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...
Coughlin: So, Sargent Lopez you have admitted that you did not
ask me to leave and you did not announce that you are Reno PD
either you or your partner either of those things when you
arrested me for trespass. Are you been arrest Nevada Court
Services for the trespass that there is video evidence of on
YouTube right now? Are you can a do that, Sargent? Sargent, are
you?
Warren: Zach, that's not the topic were on.
Coughlin: Are you going to do that, Sargent? Sargent, are you?
Lopez: are you going to fill out your statement?
Coughlin: sure. Are you going to do that?
Lopez: I am not going to arrest Nevada Court Services.
Coughlin: Why, are they your buddies?
Lopez: because they did their job.
Coughlin: wait a did their job by going behind my back fence and
banging on my windows for 45 minutes three times a time a day?
Interesting...
Lopez: Zach, we need you to fill out the paper.
Coughlin: Interesting how it works down there at the Reno PD.
You know, there is a lots of documentary filmmakers out there
these days, Sargent Lopez? Do you have anything you would
like to say?
Lopez: Zach, you need to finish your statement.
Warren: Zach, you call us here to help you, and now your are...
Coughlin: well apparently not because you arrest me for trespass
when you either didn't tell me to leave for announced that you
were the PD (police Department) and then you have video
evidence of Nevada Court Services doing trespassing harassing
banging on windows for 40 min. at a clip three times a day,
behind a back gate is obviously trespassing, and you are seeing
you are not going to do anything...
Lopez: have you had your day in court on that yet?
Coughlin:That is coming up.
...
Warren: Zach, we really need to stay on topic, okay?
Coughlin: What is the topic? Nevada Court Services? The
buddies of Sargent Lopez?
Warren: No...
...
Coughlin: are you guys going to do anything on this call because
the last time you didn't run anybody's priors and if you had it
would have been interesting what you would have found, what
did you say? Is that proper procedure children somebody's priors?
Lopez: The priors for who?
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Coughlin: because you guys didn't do that... Well who would I be

talking about?
Lopez:(smirking) Yourself, maybe? The priors for yourself?
Coughlin: Oh, is that a...do you think you are funny?
Lopez: I think it is funny, yeah. I think everything is funny,
actually. I am amused by a lot of stuff.
Coughlin: Really? Do you think it's funny when your partner
says that Richard Hill pays him a lot of money to arrest whom he
says to?
Lopez: I am pretty sure he didn't..
Coughlin: and you were there? And you didn't follow up with the
questions of whether Richard Hill had given me a bill for rent that
month and yet you still arrested me for trespass?
Lopez: 5 min. Zach.
Coughlin: I think that's funny, that you think it's funny.
Lopez: 4 min. Zach
...
Lopez:, did the management give you an eviction notice?
Coughlin: what are you getting involved in civil matters now?
You are going above and beyond, Sargent Lopez, getting
involved in civil matters...
Lopez: Zach did they give you an eviction notice or not?
Coughlin: wow you are working of the storm over there aren't
you
Lopez: Yes or no:
Warren: you could say no comment, Zach.
Coughlin: thank you, counselor. I appreciate your advice. Now,
what criminal matter were you investigating here?
Lopez: I am asking you a question.
Coughlin: About a what? A civil matter?
Lopez: Zach, did you get an eviction notice from these guys
(Sargent Lopez is referring to Western Nevada Management
posting a John Doe 30 day eviction notice, allegedly, on the door
of the 1422 E. 9th St. #2 town home that WNM (which, like
NCS, commits the unauthorized practice of landlord tenant law)
had agreed to some deal with Coughlin's housemates (or maybe
they were his sublessors? Coughlin rented a room from them off
of Craigslist, but to some extent they were held out to be
employees or partners of WNM, and WNM did testify at a
February 23rd, 2012 hearing after Coughlin filed an interruption
of essential services complaint against WNM, Gayle Kern, Esq.,
LTD, and Park Terrace Townhomes that former WNM manager,
Robyn Batalado received approval from the Park Terrace Town
Homes Homeowners Associattion to allow Coughlin's sublessors
to live their in exchange for some handyman work (and perhaps
in light of the lessened insurance costs associated with not having
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the unit vacant incident to some scenario where the PTTHOA

bought the unit at a foreclosure sale).
Warren: We will take that as a yes or no, or a maybe, who
knows? All right, Zach? You are not going to be able to bait us
into saying things?
Coughlin: Well, I've been listening to you here whether you've
been baited or not, you have said a whole lot today.
...
Coughlin:... What if Richard Hill sent me a Bill for rent for the month of November, should
you follow phone that before you make it trespass arrest? And what did you say to that? You
say no we are not going to that Richard Hill pays us a lot of money, and we are going to arrest
whom he says to arrest, did you hear that Sargent Lopez?
Warren: Zach, let's stay on topic.
Coughlin: this could be your star turn... This could be your star
turn.
Lopez: you need some help, brother.
Coughlin: really?
Lopez: Yeah, you do.
...(Sargent Lopez and Officers Warren and Avila then leave
shortly thereafter, and Coughlin has the following exchange with
his housemate's/abusers teenage daughter):
Coughlin: look someday, you are trying to support yourself and
someone steals your license plate, and slashes your tires, and
locks you out after you have given them the last money you had...
Teenage Girl's Friend: well, someday we won't be an assh*le like
you
Coughlin:What is an "assh*le" about that?
Teenage Girl: you are f*cking r*tarded, you are being r*tarded,
you're making my dad not like you, you steal his knives. His
steak knives, like seriously?
Coughlin: You mean the one of he held while chasing me up the
stairs with saying he was gonna kill me?
Teenage Girl: He didn't f*ckin' chase you up the stairs and tell
you he was gonna kill you. Why would he say that, he's not like
that. And if he say's it, it doesn't mean he means it. You make
him say that, you f*ckin' pr*ck." (Coughlin was later awared two
different Temporary Protectio Orders against those house mates
in FV12-00187 and FV12-00188).
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It is interesting to compare the transcripts of the "Zach's arrest 010" and 011.mp4 video files
taken by Hill and landlord Merliss and Coughlin's October 24, 2012 filing matter, especially when
reviewing the materials testing Exhibit 1 which includes Hill's and Baker sworn testimony of June 18,
2012 criminal trespass trial for Reno Municipal Court Judge William Gardner in the police report
which includes Hill's written witness statement, and narrative by November 13, 2011 (after some
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apparent coaching or lawyering up considering how markedly it differs from Officer Carter's more
contemporaneous written account in his Arrest Report and Declaration of Probable Cause (ARDPC))
Arrest Report and Declaration of Probable Cause, which RPD Officer had to have completed at the
time of Coughlin's booking (ie, no time to get the City Attorney or some other helper to add all that
appears in Officer Carter's Narrative time stamped at 5:12 pm...sure the ARDPC has a stamping of
4:45 pm that is not handwritten (it, its a stamp or digitally created indication, compared to time of the
arrest being listed in Carter's own handwriting of 12 noon and the offense date, again in Carter's own
handwriting being listed as 1 pm...with Carter listed as the transporting office. There is no indication
Carter hung around the WCDC until 4:52 pm...as such his ARDPC is more contemporaneous, and
therefore bares more indicia of reliability as to the facts than his subsequent Narrative, which was
actually created and printed at 5:12 pm on November 14th, 2011, a full 30 hours after arrest time of
noon on 11/13/11. Apparently, a lot of "facts" came back to Carter's memory which just happened to
align with the essential elements of the charge of criminal trespass under the RMC Code 8.10.010.
2000 and
January 12th, 2012 custodial arrest for "pedestrian failing to use sidewalk where available" (aka,
jaywalking) in front of Coughlin's former home law office at 121 River Rock St., Reno, NV 89501.
(in the video Coughlin begins filiming from the parking lot in
fron of his former home law office and walks towards the
property, where Hill's contractor Phil Stewart is already there (for
some reason Hill kept making a deal about how Coughlin was
"already at the property" when Stewart returned their from the
transfer center, but that is not true, Coughlin actually took almost
30 minutes to get to the River Rock Property after the talks at the
transfer center, as Coughlin had to go retrieve his hi 8mm video
camera from his E. 9th St. address on that date.
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Coughlin: What would the contractor's board say about you

submitting fraudulent bills? (said to Hill's contractor, Phil
Stewart, owner and operator of Nevada Building Industries
(NBI), whose bill for $1,060 for "securing" the property was
submitted as an attachment in Hill's Memorandum of Costs and
in Hill's Opposition to Coughlin's Motion to Contest Personal
Property Lien under a personalty lien theory citing to NRS
118A.460, which allows for reasonable costs for "moving,
storage, and inventorying" a tenant's personal property). Would
they be okay with that? Neck carpet right there that's Dr. Merliss's
property if you throw it away, you are throwing away the carpet,
so you are on notice and you should tell Richard Hill, if he tries
to sue me for the carpet, and you throw it away, I will sue you for
fraud.
...
(Coughlin is seen in the video walking a few feet off the sidewalk
in light of the fact that Hill's contractor's crew have taken up the
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whole of the sidewalk (Stewart's white dumptruck is parked so as

to extend from the drive way out onto the street so as to
completely block the sidewalk, and beyond that, the sidewalk is
dotted with various items Stewart's crew is in the process of
moving from the former home law office) on the southern facing
side of the property in furtherance of their efforts to load up the
rest of Coughlin's personalty and take it to the dump (as there was
apparently an incredibly urgent need to do something with the
property, despite the fact that, to this day, over one year later, it
still remains un-rented).
Coughlin: gentlemen, you are under notice this is my property
and I want it. I believe I might have some legal recourse against
you for destroying my property. I could be wrong. You are
certainly welcome to listen to your boss. You know what is
interesting is that I have proof right here that you used my own
plywood to board up the property and then you try to charge a
thousand dollars for it and for fixing a leak that's my plywood
Phil or whatever your name is, guy with a contractor's license.
(Coughlin is saying this while in the parking lot of the studio
apartments that abuts the backyard fence to his former home law
office (ie, not on the sidewalk even. One of Stewart's laborers
walk up to Coughlin within about 8 feet of him and snaps a flash
photo):
John Doe: What's up?. (snaps another photo of Coughlin in the
parking lots of the Mill Place studio apartments)
Coughlin: Hi, how are you doing? What's your name?
John Doe: John Doe.
Coughlin: John Doe, really?
Doe: Don't get mouthy, buddy.
Coughlin: What's that?
Doe: I said don't get crowley, buddy.
Coughlin: What's "crowley"?
Doe: "Crowley" means like "Crowley Lake".
Coughlin: I don't know what you mean. Anyways Phil what do
you have to say about the fact that you fraudulently submitted a
Bill for thousand dollars for boarding up the property to fix a leak
yet you used my plywood to do it, Phil?
John Doe: Hey, can you stay away from him (motioning to Phil
Stewart)?
Coughlin: I am on a public spot right here (actually, Coughlin is
still standing in the Mill Place studio apartment's parking lot at
this time). I am not bothering him you guys just expect people to
watch you use their own property to board up a place?
Phil Stewart: do you have a receipt for that?
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Coughlin: yeah I do. It was submitted into evidence guy. You

guys submitted it into evidence as a bill. (Coughlin then walks
out of the Mill Place parking lot and around Stewart's white dump
truck (which was completely blocking the sidewalk) and out a
few feet into the road on Court St west of River Rock, where the
camera's view reveals Stewart's crew has set a couch and some
other personalty on the sidewalk, where Stewart and John Dow
walk onto towards the front of the property on River Rock St. to
talk with Richard G. Hill, Esq.) are you going to ask Richard
about that? I even ask Richard about the fact they used my own
property to board up the property and charged with thousand
dollars for it this gotta be an easier way to make money was and
ain't that easy to be an attorney as you can see, Phil.
Stewart: you obviously need to start taking your medication.
Coughlin:(Coughlin has retreated back to the Mill Place parking
lot at this point) what did you say? Are you making some sort of
accusation or insult about taking medication? Is that what you are
doing? You know it is funny because a lot of this property
could've been used to feed families in need. Phil are you going to
throw away the carpet and then try to bill before it is that what
you are going to do some pretty sure that that would be fraud
Phil. Sir, I am putting you on notice that carpet belongs to Dr.
Merliss (a couple members of Stewart's crew are now seen
picking up the rolled up bundles of carpet that Coughlin, whom
has now walked around to the front of the property to River Rock
St. walking just off the sidewalk (though a large tan/brown
Silverado style pickup truck parked on the North Side of Court
Street, that Coughlin recalls seeing a large manilla folder in with
the notation, in hand writing, "Sargent Bradshaw" is an obstacle
Coughlin must walk around, especially where Stewart himself is
utilizing the sidewalk, and given John Doe's very recent request
that Coughlin "stay away" from Stewart, it would seem cautious
of Coughlin not to attempt to walk on the same small patch of
sidewalk off Court Street as Stewart and his laborers.) Hey, Phil?
Phil? The carpet, there was also some more of it right around
there... Hopefully you haven't thrown it away already...
Hopefully, you do not try to bill me for it Phil....
(Coughlin is now standing on the sidewalk on the western side of
River Rock, parallel with the northern boundardy line of the
property, when John Doe appears from around the corner off of
Court Street and snaps another flash bulb photograph at
Coughlin).
Coughlin: Sir, this is a public street. This is a public street you do
not on the sidewalks are have you ever heard of a documentary?
You know there's a lot of guys making documentaries these days
about the bad things people do.
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(up rolls RPD Officer Hollingsworth on his motorcycle, and RPD

dispatch chatter can be heard describing a "suspect in a larceny".
Officer Hollingsworth has been called to the scene by Richard G.
Hill, Esq. and Phil Stewart. Hill shows up seconds after
Hollingsworth. Now, neither Hill nor Stewart were charged with
"misuse of emergency services like Coughlin was in RCR2012065630. So in this video Stewart talks with officer Hollingsworth
for a few moments until Richard Hill arrives...)
Coughlin: hey Rich how are you doing?
Hill: Great, Zach, thank you buddy.
Coughlin: would you prefer of psychology Mr. Hill?
Hill: I would, Zach.
Coughlin: Mr. Hill, how are you doing? Hey that is a cool
"skulls" shirt, Mr. Hill (Hill is wearing a black Ed Hardy style
bowling shirt with flaming red skulls on it.. Hill begins doing his
Reno PD thing with Officer Hollingsworth, Coughlin stands back
about 12 feet from their communique).
Hill: (to Officer Hollingsworth) can we get him out of here? (and
therein, besides calling 911/RPD dispatch in the first place where
no legitimate reason existed to, Hill proceeds to leverage law
enforcement acting with color of law to prevent opposing counsel
from collectin evidence for a wrongful eviction damages
analysis).
Hollingsworth: first of all of gotta figure out if I have legal
authority to do so.
Hill: Re: court order evicting him from the property, subsequently
we had him arrested for trespass is lost his appeal (which was
totally not true when Hill made that false statement to a police
officer seeking to have Coughlin arrested, on January 12th, 2012,
given that the appeal would not be decided for months), he's
lost.... Now we have been talking to our workers
Hollingsworth: Have you tried to get a protection order?
Hill: no but we do have an order from the court disposition of the
premises (unintelligible...)
Coughlin: what about the sidewalk bridge you on the sidewalk?
Hill: is been over to the transfer station Sargent Bradshaw I just
left from there is Sargent Bradshaw who is been on
(unintelligible)... These over here just generally being a pain in
the ass
Coughlin: freedom of the press, Rich. (Hill starts making some
big gesticulating motions to Officer Hollingsworth like a child
whom is not being given the toy he wanted for Christmas or
Veruca Salt throwing a fit in Charley's Chocolate Factory). They
have important things to do rich they are busy. (Helen Stewart
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continued talking the Hollingsworth by this time Officer Del

Vecchio is showed up, it looks like Officer McQuattie is there
(actually, that might be then trainee Officer Leedy, Officer Look
is there now too)
Officer Look: hey how are you doing
Coughlin: Hi, Sir, good to see you again. I didn't catch your
name last time I recognize you from the the day..
Look: with officer look
Coughlin nice to see you again I think I saw you the other day
when came out on a call with Officer Gannon, for a domestic
disturbance a run East-Sage
look: I honestly don't remember
Coughlin: Yeah, I think you guys are up in my bedroom...
Look: Right on Scottsdale
Coughlin: Satan E. 9th St., Park Terrace Town homes... Freedom
of the press, Rich.
Look what you guys have going on today?
Hill: contempt of court Mr. Coughlin!
Coughlin: well, that carpet belongs to your client, Mr. Hill if you
try to throw it away and then build me for it
Hollingsworth: (comes over to talk to Coughlin) can you turn that
off, Sir, for a second stuff over here on over on the sidewalk
(Coughlin was already on the sidewalk, but Hollingworth leads
them further North along the River Rock side walk's western
side). Okay so what's the deal today why are we here?
Coughlin: I don't know, sir.
Hollingsworth did used to live here?
Coughlin: I prefer to just keep my privacy as a private citizen.
But I mean you no disrespect Sir.
Hollingsworth no problem, I can respect that here's the deal you
understand here in the sidewalk no problem you on it student run
tape no problem but you can't interfere with them doing their job
and they're probably enough apply for temporary station order
against you in which he/she can be within 100 yards of there or
them. (Hill gets into his $100,000 Porsche Carrera where he goes
off the Reno Justice Court and gets a TPO signed by Judge
Schroeder within 40 minutes of the application being stamped in.
Behind Hill's Porsche is Officer Look's patrol car and the patrol
car being utilized by Officer Leedy and his training, tenured
Officer, Officer Del Vecchio. These vehicles are in addition to
the motorcycle ridden by Officer Hollingsworth. Richard Hill's
wife/legal assistant Sheri Hill is parked in the lot on the east side
of River Rock in her maroon Lexus SUV. Contractor Stewart is
seen jaywalking across River Rock to the lot where Sheri Hill is
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parked, but he is not arrested.). All they are trying to do is get

their business or taking care of
Coughlin: I'm trying to take care of my business, too.
Hollingsworth: okay is there something we can help you with?
Coughlin: I don't believe so, sir. I called the police recently I told
them somebody threatened my life the the day that in six see fit to
arrest anybody so apparently Richard Hill is a national treasure.
Hollingsworth: Okay, well, I don't know who that is, all I know
is I'm here today and you are here with the camera and you're not
breaking any laws that I can see but they're gonna try to get it to
where you are violating a temporary protection order
Coughlin I understand it threatening abuse of process and
malicious prosecution
Hollingsworth: so it would be helpful if maybe you could find
something else to do this afternoon because I have been listening
on the radio and we've had two or three calls for service for you
already today and would like to be evidence of do some other
work today, no one I mean
Coughlin okay well I hear what you're saying
Hollingsworth is basically a second help you with
Coughlin: if you wouldn't mind telling me your last name
Hollingsworth: Hollingsworth
Coughlin thank you, Sir, Goodbye Officer Look, good to see you
again, Sir.(Coughlin then proceeds to walk back towards the mill
place parking lot Western Lane along court street he does not
walk in the street but rather uses the sidewalk which is now
cleared of Stewart's laborers and any of the personalty they are
seeking to take to the dump however the white dump truck belong
to Stewart is still blocking the sidewalk. Coughlin Fox all the
way back to the area in the Mill's Place parking lot immediately
to the west of the fenced, gated backyard to his former home law
office, and can view Officer Hollingsworth pull away on his
motorcycle heading north on River Rock. Footage of contractor
Stewart's white dump truck reveals how extremely implausible
Stewart sworn testimony was at the February 23, 2012 Order to
Show Cause hearing (which Hill had Coughlin personally served
Notice of by WCSO Deputy Machen (by way of RMC Marshal
Harley) incident to Coughlin arriving and waiting at the RMC for
the traffic citation Trial in 11 TR 26800 stemming from the three
traffic citations RPD Sargent John Tarter had issued to Coughlin
incident to the November 15 incident at Hill's law office where
Coughlin ventured upon being released from three days
incarceration following the November 13, 2011 criminal trespass
rests at Coughlin's former law office Coughlin went to Hill's
office to retrieve his keys state issued drivers license and or
identification his wallet and his client's files, which Hill refused
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to release. It took until November 22nd, 2011 before Hill turned

over Coughlin's wallet and driver's license to Coughlin. It took
until December 22nd, 2011 before Hill turned over Coughlin's
client's files, causing Coughlin to incur great expense in arranging
for alternatives. Coughlin starts to make his way back towards the
front of the property and decides to walk along the edge of the
parked Tan Brown pickup truck instead of venture near it be
laborers working for Stewart who are now utilizing the sidewalk
on the north side of court street once again. Coughlin notices the
large manila envelope and the dashboard of the track with a large.
Written note indicating Sargent Bradshaw on the outside of of the
folder. Coughlin then crosses the street in a straight continuation
from the northern sidewalk on Court St. to the parking lot on the
east side of River Rock, just as any pedestrian would (except
Contractor Stewart actually just walked out in the middle of the
road when he crossed River Rock earlier, rather than in a straight
continuation of the sidewalks. Coughlin notices Contractor
Stewart milling about on the west sidewalk of River Rock just
north of his former law office. This group includes Stewart, Del
Vecchio, Leedy, and Look, whom are now joined by Sargent
Sifre. Officer Hollingsworth has left to do some real police work
by this time. Sheri Hill is still watching on from her maroon
Lexus SUV in the parking lot).
Coughlin: (talking vaguely in the direction of Contractor Stewart
who is approximately 30 feet away) you might when I try to
make sure you don't throw away that carpet over there because I
will dispute it if you guys try to bill me for it. (Coughlin then
positions himself to get a shot of the interior of the former home
law office where a he sees a very sentimental item to him that he
forgot to grab at the last second during the mad rush to move his
property out to whatever extent possible by the 5 PM deadline
December 23 this item is a 5" x 16" caricature of his former
domestic partner of the preceding four and a half years from a
relationship that ended in late May 2011 and himself done during
the early stages of their relationship. This was amongst
Coughlin's most treasured possessions and was only left atop a
crown molding during the move with the idea that it would be the
last thing Coughlin would grab, and therefore he would be able to
place it in a safe place on his U-Hauls dash board or somewhere
else where it would be safe. However, the chaos incident to
Richard Hill's showing up in demanding everyone be off the
property by exactly 5 PM under the threat of arrest caused
Coughlin to overlooked grabbing this treasured sentimental item.
This caricature is visible in the video)
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Coughlin: that is that sentimental picture that I told them about of

Melissa and I. the caricature... And I believe the dolphin
windchime mobile, one of the last things my grandmother gave
me before she died is in there...oh, and look at that there is $150
appliance. (to Contractor Stewart). Sir I season sentimental
heirloom keepsakes in their that I guess you are just going to
throw it away you don't care, the last thing my grandmother gave
me before she died very sentimental thing (at this point
Contractor Stewart turns to the camera an makes a revolting
gesture). Sir when you put a padlock on the back fence? (Hill's
placing a padlock on the back fence only just about the time that
it was Coughlin's right to remove his property resulted in
Coughlin's progress in moving all his personalty being severely
impeded.).
...
(At this point in the video Coughlin returns to the parking lot of
Mill's Place, private property, behind the fenced back yard of his
former home law office. Like a couple of goons approaching,
Officer's Leedy and Officer Look venture into that private
property, the Mill's Place parking lot:
Officer Leedy: Mr. Coughlin could talk to for second?
Coughlin: I mean neither confirming that that's my name, Sir, but
you are the law under asking to speak to somebody so.
(at this point Officer Look approaches Coughlin very rapidly and
immediately grabs Coughlin's wrist, Couglin holding his video
camera, which is, obviously, still filming, as Officer Leedy and
Officer Look immediately jump straight to applying excessive
force to Coughlin's wrists. Officer Look jumps at Coughlin from
Coughlin's left side and Officer Leedy sneeks around behind
Coughlin and grabs Coughlin's camera out of his right hand and
turns it off)
Officer Look: video camera down, put your camera down.
Coughlin:Whoa! Whoa! Why are you touching me! (Officer
Look is captured on video breaking back Coughlin's left wrist and
wrenching Coughlin's left arm behind his back, prior to any sort
of attempt to peaceably approach Coughlin, a license attorney,
whatsoever, but then accidentally turns it back on a second later,
a fact to which he is unaware. Officer Leedy places both of his
hands on Coughlin's right side and right arm and wrist in a
display of excessive use of force.)
Officer Leedy: We don't want your camera....
Coughlin why are you touching me this is not their properties,
Sir? (the camera goes black for a moment)
Coughlin: Owww!. You are breaking my wrist!! Oww! Owww!!
Help!!! Help!!! My wrist hurts, somebody call 911. Owww!!
Owww!!! Somebody help!!! Somebody help!!! Sir, there is no
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need to break my wrist like that, Sir. Oww!!!. Oww!!!Why are

you handcuffing me, Sir?
Officer Leedy: You are being placed under arrest.
Coughlin: For what? For what?
Sargent Paul Sifre: They'll explain everything to you in a little bit
(but, actually, Coughlin would not be told what he was charged
with for over an hour and a half, and in the intervening period
while he was handcuffed and placed in the Officer Leedy's patrol
car, with tenured training Officer Del Vecchio (whom had
handcuffed Coughlin, and placed him in the back of his patrol car
on night in July 2011 incident to Del Vecchio drawing his
weapon, or appearing to, on both Coughlin (whom was walking
his bike at the time) and another bicyclist in front of Coughlin's
former home law office at approximately 10 pm at night, all
because Officer Del Vecchio felt the light on Coughlin's bike was
"not up to code").
Sargent Sifre: I am going to shut your camera off so the battery
will not run down.(Officer Del Vecchio can be seen in the video
at this point walking around in his acid wash jeans).
Coughlin: I don't wan't it shut off, Sir. You are obstructing
justice if you shut it off! (Sargent Paul Sifre then shuts off the
video camera whereupon Officer's Look and trainee Officer
Leedy continuing applying the wrongful use of excessive force to
Coughlin's arms and wrists as they pin him face down to the
concrete with a smug, nauseating Californian transplant name
Sargent Paul Sifre (whom incident to another wrongful detention
of Coughlin on March 29th, 2012 told Coughlin he doesn't like
Nevada or Reno, but the job he has pays him so much, and he has
so little chance of finding such an arrangement in any local more
to his liking, that he essentially has a pair of "golden handcuffs"
tying him to Northern Nevada, which he detests, before going on
to tell Coughlin about how he lead his little league team in both
home runs and strike outs, then proceeding to ramble on
unconvincingly about how he was "trying to get you the help you
need", in a tone that was more suggestive of a veiled threat to
Coughlin, the import of which was clear, ie, that Coughlin better
not complain anymore about the RPD's police misconduct, such
as Coughlin did in his written complaints to the RPD on
September 7th, 2011 and January 8th, 2012 wherein Coughlin
complained of the police misconduct by RPD Officers Nick
Duralde and Ron Rosa during the wrongful arrest of Coughlin on
August 20th, 2011in RCR2011-063341 (written complaint
submitted to the RPD on September 7th, 2011 and supplemental
on January 8th, 2012, at which time a written complaint against
Nevada Court Services, RPD Officer Chris Carter, Jr., and
Sargent Marcia Lopez incident to their police misconduct during
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the November 13th, 2011 wrongful arrest of Coughlin in RMC 11

CR 26405. Sargent Sifre would again order Coughlin arrested
less than 48 hours later in RCR2012-065630 for "misue of
emergency communications services". In between these two
arrests RPD Officer Duralde would get a chance to retaliate
against Coughlin incident to pulling Coughlin over in his car in
the early morning hours of January 13th, 2012, after Coughlin
bailed himself out of jail and use a combination of a cab ride and
walking to get to his car in 20 degree whether on a very windy
night. Coughlin instantly recognized Sifreon January 14th, 2012
from seeing him on January 12th, 2012 as on both days fact that
Sifre was wearing a short sleeves uniform shirt emphasizing his
tribal armband tatoos, and body builder biceps.
1
2
3
4
5
6
7
8
9
...
See attached in Exhibit 1 the videos from all of these varius
wrongful arrests by local law enforcemtn of Coughlin
10
11
While it may be expendient for some in local law

enforcement to discredit Coughlin or have him "committed", it
does not make it legal, and it does not vitiate the import of law
enforcement misconduct in all of the wrongful arrests of
Coughlin since August 19th, 2011.
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15
16
It is c
Coughlin was just informed by his mother that this same Officer Travis Warren, along with
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another RPD Officer and "two social worker types" met with Coughlin's mother, Very Special Arts of
19
Nevada (VSAN) Program Director Mary Barker, and Coughlin's father, Dr. Timothy D. Coughlin,
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MD, of Reno Family Physicians at Dr. Coughlin's medical office in an purported attempt to have
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Coughlin "committed" sometime in approximately February 2012. Such a meeting is conveniently
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and suspiciously close in time to the video transcribed above wherein Sargent Lopez essentially
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admits that she and Officer Carter lacked probable cause for a criminal trespass arrest of Coughlin
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(and, upon information and belief, the RPD was served a subpoena by Coughlin requiring Carter and
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Lopez's presence at Trial, though neither managed to show up, despite the City Attorney's having
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previously subpoenaed at least one of them for that purpose as well...It seems to City Attorney's
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Office got wind of how terribly fraudulent Officer Carter's probable cause sheet was (and Carter did
tell Coughlin, in the "Zach's arrest 010.mp4" video that Carter would put his name on the "arrest sheet
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if you have any problem with that" in response to Coughlin mentioning to Officer Carter that the
police did need to have probable cause to make such an arrest. Further troubling is the fact that RPD
Sargent Sifre had Coughlin arrested just over 24 hours after Sargent Lopez put her foot in her mouth
her, bringing 5 other RPD Officers with him on January 14h, 2012 to respond to a 911 call by
Coughlin reporting the disappearance of his Pekingese dog, Jackson Pawluck, and the menacing
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statements connected thereto by the house mates against whom Coughlin would eventually be
awarded two different TPO's.
Just about 12 hours prior to Sargent Lopez and Officer Warren and Officer Avila arriving at
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Coughlin's E. 9th St. rental in response to a call by Coughlin reporting a domestic dispute (two of
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Coughlin's tires had been slashed and his license plate had turned up missing), just after Coughlin
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spent his last $160 bailing himself out of jail incident to the January 12th, 2012 "jaywalking" arrest
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ordered by RPD Sargent Paul Sifre, Coughlin was pulled over while driving home his vehicle after
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making his way to it from the Washoe County Detention Center (which had seen fit to release
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Coughlin exactly a couple minutes after the last RTC bus had left for the night (on a night where the
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temperature was a balmy 25 degrees, with a considerable wind chill on top of that) by the same RPD
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Officer Nick Duralde (whose wife is an emergency communications dispatcher, Jessica Duralde,
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which complicates matters considering that the petty larceny of an iPhone case, RCR2011-063341
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stemming from Duralde's wrongful August 20th, 2011 arrest of Coughlin has involved an inquiry
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wherein Duralde's basis for alleging he was justified in conducting a Terry Stop "weapons check pat
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down" and or a search incident to arrest was largely premised upon some purported "information he
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received from dispatch" of a "disturbance or possible fight", despite the fact that none of the
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discovery, 911 logs, dispatch reports, etc. propounded to Coughlin mention a "possible fight", but
they do mention a "disturbance" and "possible larceny of a cell phone" and the "RP (reporting party)
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screaming at the accused". DDA Young may need to answer for just where this whole notion of
Duralde being dispatched mention of a "possible fight" comes from exactly, other than the
prosecutors wish list of things he wishes there was documentation of to support his hopes of proving
Coughlin's Fourth Amendment rights were not violated by an Officer eager to show up the lawyer in
front of some teen-agers and early twenty-somethings. To be fair, those youths did a fair amount of
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lying that night in their fraudulent attempts to cover up the conduct of Cory Goble, which may be
tantamount to having abandoned (and if Goble did not abandon it, then anyone whom claimed it in
response to the "man holding a six-pack" offering it up and threatening to "throw it in the river if
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someone doesn't claim it right away", arguably "saved" the iPhone from being destroyed in
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connection with Goble's alleged negligence or abandonment of it, and thereby, the iPhone was no
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longer Goble's, if it was, indeed, his to begin with (which is unclear given Goble's contradictory
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statements in that regard where he alleges that he himself bought it three years previously, according
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to Duralde in his Supplemental Declaration incident to his arrest report, in comparison to Goble's
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testimony on the August 29th, 2012 Trial date in RCR2011-063341, wherein Goble alleges his
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brother bought it for him three years previously, not that WCPD Jim Leslie would undertake any
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investigation or issue a subpoena to clarify such a thing, mind you) his three year old iPhone 3G
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(Goble's friend testified that Goble set it down on the concrete ground at around 11:00 pm or so on a
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Saturday evening in the downtown Reno skate plaza in front of City Hall (and Goble's statements in
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his Witness Statement, that he was "skateboarding 15 feet away from the phone" conflicting sharply
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with both Goble's statements on the audio tape of his 911 calls (wherein he admits to having been at
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his Jeep at the relevant time, which was, apparently, according to Goble's friend Nathaniel Zarate's
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testimony, parked on the west side of the skate plaza, on Virginia Street, whereas some still
unidentified "man holding a six-pack" whom Zarate alleges picked up the phone off the ground and
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held it aloft (and Zarate's friend Nicole Watson admitted on a video filmed by Coughlin upon his
being released from 7 days in WCDC, where this lifelong resident of Reno, an attorney, whose entire
immediate family lives here, who had no criminal record previous convictions aside from a January
2003 "dry" reckless driving conviction, was denied an OR release by a retaliatory WCDC staff for 7
days, and where Coughlin's bail was impermissibly inflated by Duralde's fraudulent overcharging as
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felony grand larceny for the purported theft of an item that was three years old and on worth "between
$250 and $300" when it was bought new three years previously. The RMC impermissibly violated
NRS 5.011 when Judge Gardner held Coughlin's arraignment in 11 CR 22716 on October 10th, 2012
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during the pendency of the Order for Competency Evaluation of Coughlin in RCR2011-063341. So,
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Officer Duralde and five other RPD Officers just happened to be hanging around Coughlin's car when
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he finally made his way to it upon his release from jail in the early morning hours of January 13th,
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2012. Coughlin had previously filed a written complaint against RPD Officer Duralde and Officer
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Ron Rosa on September 7th, 2011 and January 8th, 2012, making such a large show of force incident
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to that pull over (for a license plate that just so happened to all the sudden turn up missing", and the
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main suspects would be the RPD, or Coughlin's then house mates, or, finally, some stranger). A
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video of the wrongful arrest was taken by Coughlin, and here is the transcript (of the video Coughlin
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took of the August 20th, 2011 petty larceny arrest in RCR2011-063341):
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RETALIATORY ARREST: "Let him do his job or we will call the Nevada Bar and tell them how you cooperated
with our investigation. How's that runnin' for ya?" and "Now, your're under arrest ofr larceny. Now we can
search you incident to arrest. How's that?"
On the video/audio recording of the arrest ( VID_20110820_232801) the file name of which represent an
accurate time stamping of the time at which the video file began recording on 8/20/11 at 11:28:01 pm incident to the petty
larceny charge Coughlin is currently facing in RCR2011-063341)
(3 second mark)
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Coughlin: I am scared of you young kids...you have nothing to lose, of course I'm scared of
you...please don't hurt me...you have clearly scared me"
(at approximately the 22 second mark RPD Officer Duralde arrives on the scene)
Austin Lichty: We saw it light up in his pocket. He won't give it back.
Robert Dawson: He won't give us the phone he stole.
(27 second mark)
Zarate: I saw the whole thing.
(28 second mark)
Duralde: Do you have the phone?...Is it in your pocket?"
Coughlin: What?
Colton Templeton: The iPhone!
Lichty: Don't play dumb, just give it to us!
Duralde: The iPhone.
(41 second)
Coughlin: Don't I have a right not to answer an Officer when he inquires as to what is in my
pockets? Unless this is a Terry Stop, but I don't think this is a reasonable cause to do a pat
down...
Duralde: It is a reasonable cause to do one.
Coughlin: Perhaps, you might be right.
(54 second mark)
Templeton: And if he calls it and it lights up in his pocket, will that prove it?
Duralde: Set your bike down on the ground, and move over there for a pat down.
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(1:00 minute mark)

Coughlin: This dog likes to run away, Officer, can I tie it to something?
Duralde: Tie it to your bike.
Coughlin: Okay.
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Austin Lichty: Corey, We can call it. Let's call it.
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(1:02 mark).
Duralde: Dude, I am going to be real with you right now, the kid will probably be fine if you give
him the phone back, if not, we are going to get it out of your pocket and you are going to go to
jail.
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(From the 1:08 mark to the 1:28 mark Coughlin ties his dog to his bike and moves several feet
south towards the Siena in response to D's direction.)
Templeton: You want to go to jail over a iPhone that's not yours?
Lichty: You have a touch screen phone
Goble: Seriously, I don't get it, you just said iPhones are played out...
(1:28 mark)
Duralde: Face that way, other hand on the back of your head...this hand on the back of your head,
there you go...
(1:32 mark)
Coughlin: Can, I say one thing Officer? I'm a lawyer.
(1:36 mark)
Duralde (startled): Okay! (strange slipping/click sound emitted on video of arrest at this point)
Coughlin: You just touched my junk! Officer, I don't appreciate you touching my penis. I am a
lawyer, and you haven't even asked me a question yet and you are handcuffing me. I don't see how
this is a Terry Stop. I wish you would tell me why you are proceeding like this.
(2:00 minute mark)
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Alaksa: You are a suspect in a larceny of a phone. You have been identified by a victim as a
suspect in a larceny of a phone. We are conducting an investigational stop. We checked you for
weapons to make sure that you do not have any weapons,.
Zach: Those young men assaulted me, I do not see them being handcuffed.
(2:35 mark)
Duralde: Dude, you are the one who is accused of the frickin' crime.
Coughlin: I am accusing them of assaulting me.
Duralde: Okay, and I am saying that is unfounded how are you injured.
Coughlin: Uh, assault isn't injury, its apprehension of imminent bodily harm.
Duralde: Okay, so what did they do?
Coughlin: They grabbed me, they pushed me, they reached into my pocket, and they pulled my
dog from me,
Duralde: If they touched you its not assault.
Coughlin: ...As a gang of skaters, twenty of them backed me up into oncoming traffic.
(3:05 mark)
Duralde: Citizen's arrest. They wouldn't have been coming after you if you hadn't stolen the kids
phone.
Coughlin: Officer, let me tone this down a little bit, okay. I have respect for you.
Duralde: What is your name?
Coughlin: Zachary Coughlin, Nevada Bar number 9473.
Duralde: I don't care what your bar number is, what is that? How does that bare on this?
Coughlin: Well, maybe it bares towards...okay, you seem to not respect or be willing to hear
anything an attorney says, yet a group of skaters you believe wholeheartedly.
Duralde: Do you have the phone?
Coughlin: I'm not an...well, let me think about that....Do I have the phone? Do I have a right not
to answer your question?
(3:41 mark)
Duralde: Just don't talk anymore.
Coughlin: Okay.
(3:45)
Coughlin: Do you have a right to search my pockets right now?
Duralde: What is your last name, how do you spell it?
(3:55 mark)
Coughlin: Am I under arrest?
Duralde: Dude, you are detained for a crime we have every right to identify you.
Coughlin: So, I think its under the Hiibel case where the guy refused to give the police officer his
name?
Rosa: Its called 171.123, Terry Stop. You can provide your name or be arrested for obstruction.
Coughlin: You know what I'm talking about.
RPD Officer Rosa: Yeah, I know what your are talking about.
Coughlin: Search incident to arrest.
RPD Officer Rosa: That's not what your being...you are being detained, dude.
Duralde: You are not under arrest.
Coughlin: Okay.
(4:15 mark)
RPD Officer Rosa: Provide your name or go to jail for obstruction, and we will call the
Nevada Bar and let them know how you cooperated with our investigation, how is that
runnin' for ya? We are tired, and we are busy tonight, we have got better things to do tonight
than be out here and debate the law with you. Give the man your name and let him do his job. Is
there anything wrong with that?
Coughlin: Well, can I ask you a question?
RPD Officer Rosa: No! You can't, just provide your name and information or go to jail. Those
are your options, we are done discussing the law.
(4:40 mark)
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Coughlin: Am I under arrest?

RPD Officer Rosa: How many times do I have to tell you, your are being detained.
(4:42 mark, dispatch radio traffic can be heard in the background from the Officer's radio saying
"3994", the State failed to produce any dispatch recordings despite being served with a subpoena
and despite the fact that such radio traffic is recorded under RPD policies).
RPD Officer Alaksa: A decision has not been made
(4:46 mark, off in the distance)
Skater voice, likely Templeton's: It will either light up or vibrate.
Coughlin: Okay, Can I just ask a question?
RPD Officer Rosa: What is your question.
Coughlin: I have total respect for you, believe me, I do.
(4:51 mark off in distance)
Goble: He might have switched it over and or flipped it over.
(4:52 mark)
RPD Officer Rosa: Well then give the man your name, show him a little respect.
(4:54 mark)
Goble: He might have flipped it over to the right if it isn't in there then.
Licthy: Yeah, that is what he did.
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(4:58 mark)
Coughlin: Can you ask these kids to back off so we can tone down this situation..
RPD Officer Alaksa: You guys can you leave us along! Back off! I said I would help you out.
Okay, allow me to do my job, okay?
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(5:02 mark, radio dispatch traffic remains audible)
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(5:07 mark)
Duralde: Now, you are under arrest for larceny. Now, we can search you incident to arrest.
How's that?
Coughlin: Well, I mean, I wish you had asked me some questions prior to arresting me, I mean, it
might look better for you.
Duralde: Stand up!
(5:39 mark)
RPD Officer Alaksa: Who do you live with, Sir.
Coughlin: At this point Officer, though I respect you, if you guys want to play so hardcore with
me, you know...
RPD Officer Alaksa: I want to try to help you with your dog and your bike, who can take care of
your dog?
Coughlin: I live alone.
(5:52 mark, RPD Officer Duralde removes Coughlin's HTC G2 smartphone from Coughlin's right
side short's pocket, looks at the screen light up after touching it, and presses the red recording
button to stop the video recording).
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The RPD and or Reno City Attorney's Office misconduct justifies a tolling of any deadline to
file a Motion for New Trial, or Arrest Judgment, or any other deadline given the many instances of
such wrongful conduct, including the following January 14th, 2012 arrest of Coughlin in RJC
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RCR2012-065630 for "misuse of emergency services" (and add to that the repeated fraud by the pre-
trial services staff at the WCDC in lying and comitteing misconduct incident to their retaliatory
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dealings with Coughlin). Here is a transcript, in relevant part, of at least some of the video and or
audio recordings of the momenets prior to the arrest in RCR2012-065630 (and ECOMM and DDA
Young and the RPD/State's misconduct in refusing to turn over excuplatory recordings and materials
in that matter further provides a good cause, tolling, excusable neglect basis for granting the relief
requested herein).
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TRANSCRIPT OF RECORDING OF RPD INTERACTIONS, IN PART, OF COUGHLIN

INCIDENT TO CUSTODIAL ARREST FOR MISUSE OF EMERGENCY SERVICES
INCIDETN TO CUSTODIAL ARREST OF COUGHLIN ON JANUARY 14TH, 2012 IN
RCR2012-065630:
RPD OFFICER SCHAUR: how are you doing over here?
Coughlin: not so good.
Schaur: What's wrong.
Coughlin: My dog is gone.
Schaur: What kind of dog do you have?
Coughlin: Pekingese.
Schaur: Peningese? I didn't see a Pekingese when we were comin' in here...do you have a tracker on
it or somethin' on it, one of those little scanners?
Coughlin: Like a microchip? You have six cops here? Why? I recognize this guy over here
(refercing RPD Sargent Paul Sifre, whom admits to having ordered Coughlin be subjected to a
custodial arrest for "jaywalkign" which obstructed justice incident to Coughlin collecting evidence for
a wrongful eviction lawsuit stemming from RJC Rev2011-001708.) You arrested me for jaywalking
the other day.
RPD Sargent Paul Sifre: No, I didn't arrest you for jaywalking but I was on the scene.
Coughlin: what was your name?
Sargent Sifre: Here's the deal...what do you need today?
Coughlin: My dog is gone, threatening statements and smirks were made by the two women or girls
in here and the man...
...
Sifre: You are not injured or anything?
Coughlin: No, sir.
Sifre: are these your roomates?
Coughlin: she wasn't she moved in afterwards, it's my understanding she is supposed to be living with
her mother. Can I go in there an here what they are saying (motioning to the RPD interviewing Laura
Foreshee and Stephanie Allaback).
Sifre: No, you have to stay here, we have to figure out if you even have a domestic relationship.
Coughlin: So, you didn't arrest me the other day?
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Sifre: No, I was on the scene, though.

Coughlin: So, who did arrest me?
Sifre: its on the paperwork.
Coughlin: Who did arrest me? Officer Leedy, the trainee, or Officer Del Vecchio, the observer?
Sifre: Officer Leedy, the trainee,.
Coughlin: So Leedy was the trainee but he was making the arrest?
Sifre, Yeah, but he was still sworn personnel. How long have you been livin' here, man?
Coughlin: why wouldnt' you tell me what the arrest was for?
Sifre: Yeah, they told you.
Coughlin: What was it?
Sifre: Pedestrian in a roadway.
Coughlin: is that normally necessitate a custodial arrest?
Sifre: It can be.
Coughlin: Why did it need to be a custodial arrest, Sir?
Sifre: That one, because I said it was?
Coughlin: Why did you make that choice?
Sifre: Because we had several incidents involving you yesterday, or, uh, Thursday.
Coughlin: And just because they involved me, it necessitated a custodial arrest?
Sifre: Yeah, you didn't qualify for a citation?
Coughlin: Why was that?
Sargent Sifre: I just told you, we had several incidents involving you...
Coughlin: But, what if I was the victim in each incident?
RPD Sargent Sifre: then you shouldn't keep putting yourself in that situation.
Coughlin: Oh, okay. (Coughlin previously worked as a domestic violence attorney/advocate at
Washoe Legal Services and is well familar with the "blaming the victim" methodology employed here
by RPD Sargent Sifre)/
Sargent Sifre: That is why you got served with the TPO (temporary protection Order filed by Richard
G. HIll, Esq., incident to his abuse of process and successful attempts to obstruct justice in
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The cases wherein Coughlin was a victim of opposing party and or law enforcement
misconduct justifying the relief sought herein, include, but are not limited to
REV 2012-001082 Northwind Apts. Vs Zach Coughlin
REV 2012-001083 Northwind Apts. Vs Zach Coughlin
REV 2012-075658 Zach Coughlin vs Jeff Nichols
RJC 2012-076746 Zach Coughlin vs Northwind Apts.
REV 2012-00374 Park Terrace Townhomes vs Zach Coughlin
REV 2012-074408 Zach Coughlin vs Park Terrace Townhomes
REV 2012-001048 Northwind Apts vs Zach Coughlin
RJC RCP2012-000287 Milan Krebs (Northwinds maintenance man) v. Zach Coughlin (another TPO
the RPD fraudulently induced a landlord to procure against Coughlin, thanks to RPD Officer Alan
Weaver, Sargent Oliver Miller, and Ltn. Keith Brown).
REV 2011-001492 Matt Merliss vs Zach Coughlin
REV 2011-001708 Matthew Merliss vs Zachary Coughlin
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RJC 2012-078432 Zachary Barker Coughlin vs Superior Mini (in this matter, on approximately
September 22nd, 2012, besides RPD Officer Weaver calling up Coughlin's mother an attempt to
coerce her into assisting him and the RPD In violating Soldal v. Cook County, the RPD and Officer
Weaver and Sargent Oliver Miller also attempted to induce Superior's Matt Grant to file another
fraudulent "distrubing the peace" charge against Coughlin shortly after Weaver swaggeringly, and in
a smug manner, threatened to fraudulently arrest Coughlin again for another "failure to secure a load"
citation and conduct another impermissible "search incident to arrest" or "inventorying" of Coughlin's
vehicle. RPD Sargent Dye and Officer Weaver had also violated criminal laws in attempting to
dissuade Couglin from testifying at to their misconduct in RMC 12 CR 12420 on September 5th,
2012 (SArgent Dye tracked Coughlin down while he was deliverying materials incident to his part
time job, shortly after midnight on September 5th, 2012 to attempt to intimidate Coughlin in a
Scolari's desolate parking lot, and Officer Weaver made menacing gesticulations to Coughlin in court
while they waited for the 12 CR 12420 case to be called, wherein Reno City Attorney committed
professional misconduct in violating RPC 3.8 in amending the criminal complaint in that matter to
charge Coughlin with trespassing, and RMC "defenders" Keith Loomis, Esq. and Henry Sotelo both
violated NRS 178.405 and NRS 5.010 at various times by failing to abide by the stay required therein
and in obtaining orders allowing their withdrawal (of course, the kept their monthly, princely $7K
"side gig" payment from the RMC, which for all purposes seems to be made in exchange for their
selling their criminal indigent client's down the river and or subjecting them to impromptu cross
examination demanding answers to which they are not entitled, especially in Loomis's case, and
otherwise withholding from criminal indigent defendant's the few inviolable rights they have,
including, the right to counsel under the Sixth Amendment, the right to subpoena or call witnesses,
and the decision on whether or not to testify.
Storage. Loomis also committed fraud in assisting in having Coughlin incarcerated wrongfully for
nearly 20 days in July 2012, including his failure to forward to the RMC the proof of insurance
Coughlin provided Loomis (which had already been provided to charlatan police officer's Weaver and
Dye anyways), and in coercing wrongfully from Coughlin some purported consent to view Coughlin's
HIPAA protected medical records (something WCDC social worker Jan Guidetti also sought to do
on behalf of RMC Judge Nash Holmes)
Coughlin also took a video of the January 12th, 2012 "jaywalking" arrest in RMC 12 CR
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00696, and Coughlin also took a video of at least part of the January 14th, 2012 arrest for "misuse of
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emergency services" (a gross misdemeanor) in RCR2012-065630. Both arrests were ordered by
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Sargent Sifre, as admitted by Sifre himself in the video Coughlin took of at least part of the January
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14t, 2012 arrest. And, curiously, the RPD, ECOMM, and DDA YOung, despite having been loaded
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up with visible cameras and audio recorders (amongst the various 6 officers dispatched in response to
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Coughlin's 911 call of that night) have so far failed to propound (despite WCPD Dogan purporting to
have made such requests and or served the appropriate subpoenas...though everything with Dogan has
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been rather "murky", with his supervisor Jim Leslie hovering around the case exacting a similar toll
upon Coughlin's defense as that Leslie has done to two other cases wherein he purports to be
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"defending" Coughlin (in RCR2011-063341, the iPhone petty larceny case, which Coughlin finally
managed to get Leslie booted from on October 22nd, 2012, leaving Coughlin little time to prepare for
the November 19th, 2012 resumption of that Trial, particularly where Leslie has still failed to comply
with an Order in that matter requiring him to digitally transmit various materials from Coughlin's file
to Coughlin; and in RCR2012-067980, the "false statement to a public officer" retaliatory prosecution
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that DDA Young is bringing against Coughlin incident to a wrongful arrest by ol' WCSO Deputy
Machen on June 28th, 2012, stemming from a Summary Eviction Order that Judge Schroeder of the
RJC managed to sign despite numerous written correspondences to the RJC and the Sparks Justice
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Court providing a "heads up" that the 5 day unlawful detainer served by ol' Northwind Apartments
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Associates, LLC (a corporation, and therefore, not entitled to appear without an attorney under NRCP
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11, nor entitled to utilize an entity committing the unauthorized practice of law, though they did, in
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hiring "eviction consulting and process services" firm Nevada Court Services, in RJC REV2012-
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001048, whose licensed process service Robert Wray (or maybe it is Ryan Wray?) filed a fraudulent
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declaration of service alleging he personally served Coughin on June 14th, 2012 a 5 day unlawful
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detainer notice incident to Wray and Northwind's Manager Duane Jakob attempting to break into
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Coughlin's rental #29 at Northwind's Apartments on that date, a rental with no windows whose door
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was closed and locked, though Wray alleges to have "personally served" the notice (and thereby cut
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short by 3 days the amount of time the tenant had to file a Tenant's Affidavit...though Coughlin did
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submit just that to the court listed as having jurisdiction on the Nevada Court Services prepared June
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14th, 2012 5 day notice (which "mistakenly" listed Sparks Justice Court" as the forum to file such a
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Tenant's Answer or Affidavit), Sparks Justice Court, on June 26th, 2012 (and the SJC faxed as much
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over to the RJC on June 28th, 2012). Deputy Machen arrested Coughlin on June 28th, 2012, alleging
it did
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Officer Warren To be fair, Officer Travis Warren did a rather professional and admirable job
recently in coordinating, with RPD Officer Wilson, a "civil standby" of sorts at Northwind
Apartments, on or about October 10th, 2012 when Coughlin went there to retrieve what remained of
his personalty after he was unable to remove it all from his three different rentals at Northwinds on
during the 16 hours allotted on August 13th-14th, 2012. A Northwind's apartment maintenance man
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was able to assist his employer in subverting the civil eviction process along with some inspiration
and coaxing by Reno Police Department officer Alan Weaver and Sargent Dye by obtaining a
temporary order protection against Coughlin on July 5, 2012 in RJC RCP2012-000287 (Milan Krebs
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v. Zach Coughlin). Officer Weaver and Sargent Dye had arrested Coughlin on July 3, 2012 (in RMC
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12CR12420, which has now seen granted two different Motions to Withdraw by Coughlin's court
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appointed Counsel in that matter: Keith Loomis, Esq. (and Loomis obtained yet another Order
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granting his withdrawal incident to "representing" Coughlin on the July 3rd, 2012 custodial arrest by
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RPD Alan Weaver and Sargent Brian Dye where they pulled him over for "failure to secure a load"
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on ones vehicle in 12 RMC 12420 ) and, the, the same from Henry Sotelo, Esq. Court appointed
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defender former prosecutor Keith Loomis, McGeorge 1982; court appointed defender former
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prosecutor Henry Sotelo, McGeorge 1987; Loomis has been busy puttin' in work for the RMC of late
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with respect to Coughlin, managing to torpedo Coughlin's defense in the criminal trespass matter
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before Judge William Gardner in 11 CR 26405 by flat out refusing to subpoena either Sargent Lopez
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or Officer Carter, or landlord Merliss, despite all three being the only other eye witnesses to the
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events to the November 13th, 2011 arrest scene (besides the seemingly conveniently edited videos
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Hill and Merliss filmed, which Hill seemingly never bothered to view as they expressly contradict his
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sworn testimony at the June 18th, 2012 Trial in that matter) incident to pulling him over for a minor
traffic violation and alleged in plastic tub had fallen off his vehicle wherein they charged him with
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failure to secure load and failure to maintain proof of insurance, despite the fact that Coughlin
provided proof of his vehicles and should current insurance in the form of a PDF high-resolution
image of his insurance card on his 5 inch smart phone screen to which officer Weaver declared that
the proof needed to be on actual paper at which point officer Weaver arrested Coughlin for disturbing
the peace incident to some alleged statement by Coughlin that morning at Northwind apartments
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wherein Milan Krebs asserts Coughlin said something all along the lines of "don't mess with my locks
again or else you'll be sorry" (which Coughlin did not even say, though Coughlin did arrive at his
rental at Northwind's on that July 3rd, 2012 morning to find "someone" had placed some sort of glue
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in the key slot of the lock on his rental's door), though Krebs's statements in his application for an
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order of protection compared to those he makes in his witness statement incident to the July 3 arrest
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of Coughlin contains some glaring inconsistencies particularly with respect to the protection order
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going into some alleged propensity of Coughlin to carry around large butcher knives where is the
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witness statement in connection with the July 3 disturbing the peace arrest fails to mention such a
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minor detail. Krebs also makes an allegation that Coughlin burglarized his truck despite the fact that
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Coughlin has a video of the incident Krebs refers to wearing Krebs admits under of at the extension
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hearing on his application for a temporary protection order that he was not present during incident
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wherein his coworker Luke idea and his manager Dwayne Jakob indicated him that they caught
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Coughlin attempting to burglarized his truck. Coughlin also has a video of the incident wherein Krebs
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alleges Coughlin was following him for 5 minutes and screaming out threats and inciting in the
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violence. Also may be critical of Coughlin's propensity to film things one might ask himself where
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Coughlin would be had he not all these exculpatory videos proving the perjury of various individuals
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including Officer Weaver, Northwind's Apartment's Associates, LLC (part of the monolithic ACG-
AMPI, Inc., doing business in ten states operating enormous apartment complexes that are known for
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cheating it's tenants out of their damage deposits by asserting especially spurious rationale in support
for failing to so return such deposits) Manager Dwayne Jakob (who lied under oath at the July 31st,
2012 Hearing related to various Motions Coughlin filed in connection with a wrongful arrest of June
28th, 2012, wherein the Washoe County Sheriff's Office's Deputy Machen (the same deputy whose
fraudulent affidavit of service filed November 7, 2011 asserted that it personally served Coughlin the
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lockout order on November 1, 2011 incident the eviction from Coughlin's former home law office
despite the fact. Mansions supervisor Washoe County Sheriff's office civil division supervisor Liz
digital admits and had February 2012 e-mail to Coughlin that matching merely posted. Summary
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eviction order on the door to Coughlin's former law office when no one was home and proceeded to
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then effectuate a lockout, and thereby failed to comply with the dictates of NRS 40.400 (which
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incorporate the Nevada Rules of Civil Procedure into landlord tenant summary eviction proceedings
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and unlawful detainer actions under NRS 40. Arrested Coughlin (and, yes, that arrest was captured on
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video tape as well, and is providing another basis for DDA Zach Young to further hone his retaliatory
prosecution chops).
CONCLUSION
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Please expunge this SCR 111(4) Peition and or overturn the conviction for criminal trespass
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or Order a New Trial (or Order the trial court to file in the Notice of Appeal that it timely received on
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June 28th, 2012), to the extent doing so is within this Court's jurisdiction or, where a Writ of Mandate
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is required for such a request, please treat this as such.
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DATED this November 7th, 2012
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_/s/ Zach Coughlin

Zach Coughlin
Respondent
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Proof of Service:
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On this date, I, Zach Coughlin electronically served a true and correct copy of the foregoing
document to all registered electronic filers or those otherwise consenting to electronic service in a
waiver of the application of NRCP as set forth in SCR 109, and to those whom are not I placed a true
and correct copy of the foregoing document in the USPS mail on this date and or complied with all
service requirements set forth in SCR 109:
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Patrick O. King, Esq. Assistant Bar Counsel

9456 Double R. Blvd Suite B
Reno, NV 89521
David A Clark, Esq., Bar Counsel
State Bar of Nevada
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Address: 600 East Charleston Blvd.
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Las Vegas , NV 89104
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Phone Number: 702-382-2200
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Fax number: 702-385-2878

J. Thomas Susich, Esq., Chairman NNDB
Nevada Employment Security Division
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Address: 1675 E. Prater Way, Suite 103
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Sparks , NV 89434
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Phone Number: 775-284-9533
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Fax number: 775-284-9513
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Dated this November 7th, 2012
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/s/ Zach Coughlin

Zach Coughlin
Pro Per Attorney
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7 8 13 0204 Filed But Submitted 11 9 12 61901 Amendment To Opposition

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7 8 13 0204 Filed But Submitted 11 9 12 61901 Amendment To Opposition

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1

IN THE SUPREME COURT OF THE STATE OF NEVADA

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

omission of required act of service is fatal to plenary.

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

police misconduct or harassment never qualify as a "perceived emergency" according to Kariann

3.8 in that he lacks probable cause to so amend his Complaint, well...)

bribery, extortion, misappropriation, theft, or an attempt or a conspiracy or solicitation of another to

commit a serious crime. Compare:

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

possible in RCR2012-065630) , in addition to WCSO Deputy Machen's fraudulent arrest of Coughlin

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

Coughlin: because you guys didn't do that... Well who would I be

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

the unit vacant incident to some scenario where the PTTHOA

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

Coughlin: What would the contractor's board say about you

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

whole of the sidewalk (Stewart's white dumptruck is parked so as

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

Coughlin: yeah I do. It was submitted into evidence guy. You

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

(up rolls RPD Officer Hollingsworth on his motorcycle, and RPD

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

continued talking the Hollingsworth by this time Officer Del

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

parked, but he is not arrested.). All they are trying to do is get

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

to release. It took until November 22nd, 2011 before Hill turned

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

Coughlin: that is that sentimental picture that I told them about of

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

need to break my wrist like that, Sir. Oww!!!. Oww!!!Why are

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

the November 13th, 2011 wrongful arrest of Coughlin in RMC 11

While it may be expendient for some in local law

Coughlin "committed" sometime in approximately February 2012. Such a meeting is conveniently

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

took of the August 20th, 2011 petty larceny arrest in RCR2011-063341):

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

(1:00 minute mark)

Austin Lichty: Corey, We can call it. Let's call it.

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

Coughlin: Am I under arrest?

(5:02 mark, radio dispatch traffic remains audible)

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

TRANSCRIPT OF RECORDING OF RPD INTERACTIONS, IN PART, OF COUGHLIN

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

Sifre: No, I was on the scene, though.

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION

emergency services" (a gross misdemeanor) in RCR2012-065630. Both arrests were ordered by

AMENDMENT TO OPPOSITION TO BAR COUNSEL'S SCR 111(4) PETITION