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From: Paul Elcano (pelcano@washoelegalservices.org) You moved this message to its current
location.
Sent: Fri 5/01/09 8:52 AM
To: zachcoughlin@hotmail.com
Cc: Kathy Breckenridge (kathy@kbreckenridgelaw.com)
1 attachment
ltrCoughlin2ndDraft.doc (30.5 KB)
Letter attached.








































Dear Zach,
I have been authorized by the Board to handle this matter.
1. Your current suspension was a result of the order entered by J udge Gardner in
the J oshi matter;
2. Suspension means that you are no longer to participate as a lawyer in any case
assigned to you by WLS until further notice. You may appear on your own
behalf to litigate the order of sanctions entered by J udge Gardner. If any
lawyer contacts you about a WLS case you must refer them to Caryn
Sternlicht or Marc Ashley;
3. According to the Courts order, you were sanctioned for arguing incessantly,
being unprepared, making sarcastic and derogatory remarks to the Court, and
for rude and disrespectful conduct. You were personally fined $934 as a result
of this conduct;
4. I could not evaluate your conduct at trial until I received the tape of the
hearing; this tape was promptly ordered, and was finally received on
Thursday, April 23
rd
. I have not yet reviewed this tape in its entirety.
5. You have requested a copy of your personnel file. This has been made
available to you;
6. We have delivered a copy of the tape of the J oshi matter to you;
7. You requested a formal response to your complaint concerning Rhonda. This
was investigated by me within 48 hours of your complaint. There is no
question that your office behavior (which included yelling, and calling her a
hall monitor, etc.) upset her, and as a direct result she made a comment to you.
She was counseled as to the type of language she used, and specifically told
that even though she was upset this language (bite me) was not appropriate
for the workplace. I did not realize you wanted a formal response to this
incident. Please consider this your formal response. I am unaware of any
specific written complaints other than the one you made to me about Rhonda.
Please provide me with copies of all other written complaints sent by you to
me prior to the entry of J udge Gardners order. Please make sure they are
dated. I will review them and indicate to you what the disposition of those
matters may be.









































8. Counseling for difficulties in office interaction had already been scheduled
when I received J udge Gardners order. You did not appear for the mandatory
meeting at which I announced this counseling;
9. We have received a copy of a 50 page motion for reconsideration you filed in
the J oshi matter. I will review this in its entirety. If there is any other written
material you want me to review in determining whether or not your
employment should continue with WLS you must provide it to me by 5:00 pm
Monday, May 4
th
. I will be happy to pick up any such material at a reasonable
time and place if you are not comfortable emailing it to me.
Based on the forgoing I will be taking the following action:
1. I will review the tape in the J oshi matter, your fifty page motion for
reconsideration and any other written material you provide to me. If your conduct
was as represented by J udge Gardner you will be terminated. This termination
will be based exclusively on the manner in which you conducted this hearing, and
will not be related to any ultimate outcome regarding the sanctions order. WLS
can not maintain an employment relationship with a lawyer who argues
incessantly, appears unprepared and makes sarcastic and derogatory remarks to
the court, and otherwise conducts his or her case in a rude and disrespectful
manner. This determination will be made by me by 10:00 am Wednesday
morning, May 6, 2009.
2. If the hearing tape does not justify J udge Gardners order WLS will require you to
participate in the previously referred to employee counseling pursuant to the
directives of our industrial psychologist. This counseling is currently going on
with other employees at WLS. The counselor will determine the extent to which
you will participate and maintain a case load. You will maintain your employment
status, and will receive pay and benefits throughout this course of counseling.
3. If you wish to discuss any resolution of this matter between now and Wednesday
morning at 10 am I will be available to meet with you at any convenient time and
place, including this weekend. You may bring any person you would like to a
resolution discussion. I will come alone unless you request otherwise.
This has been sent to you by email. Please advise me as to the address to which a hard
copy of this transmittal should be delivered.
Sincerely,
Paul Elcano