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Index of emails from Coughlin's ZachCoughlin@hotmail.com to various @nvbar.

org email
addresses responsive to Bar Counsel's requests 020:
12/24/12 Subject: Challenge for Cause Etc. COURTESY COPY O !"!#$%
12/21/12 Subject: ! a& 'r(t(ng to re)uest a fee 'a(*er of the +earl+ ,-.. efle/ charge%
12/2./12 Subject: ( th(n0 ( alrea1+ re2orte1 th(s3 but%
12/14/12 Subject: court refus(ng to f(le 1ocu&ents an1 e/h(b(ts &(ss(ng% 5TT5C67E#TS
12/14/12 Subject: R7C cert(f+(ng Secon1 8u1(c(al f(l(ngs to S9# e/h(b(t 1: fro&
11/14/12 'as ne*er 2ro*(1e1 to coughl(n%
12/1;/12 Subject: 2rotect(on or1er aga(nst <CP= 8(& "esl(e3 Es).%
12/14/12 Subject: 8(& "esl(e (s a scra22+ 1u1e RE: Coughl(n%
12/1-/12 Subject: The Three E>s? 'c21 fa(lure to 2ro*(1e essent(al 411 call c1 1(sco*er+ of ;/1- an1
;/1@3 2.12 to Coughl(n (n rcr2.12A.:B:-.% 5TT5C67E#TS
12/.B/12 Subject: Please ta0e not(ce <: +our e&a(l 'as unrea1able%
12/.4/12 Subject: &ore of the for&al gr(e*ance aga(nst S0au3 Young3 "esl(e3 an1 =ogan RE: for&al
'r(tten gr(e*ance aga(nst S0au3 Young3 "esl(e3 =ogan3 etc. <: 411 calls &(ss(ng
fro& 'hat 'as 2ro1uce1 b+ C(t+ 5ttorne+ S0au%
12/.4/12 Subject: for&al 'r(tten gr(e*ance aga(nst S0au3 Young3 "esl(e3 =ogan3 etc. <: 411 calls
&(ss(ng fro& 'hat 'as 2ro1uce1 b+ C(t+ 5ttorne+ S0au %5TT5C67E#TS
12/.-/12 Subject: State 9ar of #e*a1a refus(ng to f(le sta&2 Res2on1ent>s 2lea1(ngs%
11/-./12 Subject: P"E5SE =!$!T5""Y TR5#S7!T 7Y E#T!RE !"E TO 7E !77E=!5TE"Y%
11/2@/12 Subject: <: =(s2osal of Personal Pro2ert+ at R(*er Roc0% 5TT5C67E#TS
11/2:/12 Subject: 2lease attache1 f(l(ng of 11 2: 12 #ot(ce of 6(ll an1 9a0er>s 7alfeasance%
5TT5C67E#TS
11/2:/12 Subject: RE: Su22le&ental to 11 2- 12 corres2on1ence regar1(ng 1(sco*er+ (n 8osh( B4;443
52r(l 2..4 Or1er sanct(on(ng Coughl(n%
11/2B/12 Subject: Su22le&ental to 11 2- 12 corres2on1ence regar1(ng 1(sco*er+ (n 8osh( B4;443 52r(l
2..4 Or1er sanct(on(ng Coughl(n% 5TT5C67E#TS
11/2-/12 Subject: "!T!$5T!O# 6O"= #OT!CE October 4th3 2.12 cert(f(e1 &a(l(ng of #ot(ce of
!ntent to ta0e =efault%
11/2-/12 Subject: 11 2- 12 57E#=E= SUPP"E7E#T5" TO RESPO#=E#T>S E7ER$E#CY
7OT!O# TO SET 5S!=E3 5"TER OR 57E#= 5"" OR=ERS SO 5R 9Y
##=93 S9#3 P5#E"3 OR 9O5R=3 5#= #OT!CE O !RRE$U"5R!T!ES
O PROCEE=!#$S T6US 5R an1 SUPP"E7E#T TO CER!!E=
5#S<ER OR RESPO#SE TO <65TECER ED%
11/2-/12 Subject: Ch(ef 7arshal Ro2er an1 7arshal 6arle+ on sett(ng the recor1 stra(ght (n #$12A
.4-B%
11/22/12 Subject: 2lease (n1(cate so&e res2onse to &+ sub2oena an1 1(sco*er+ re)uests%
5TT5C67E#TS
11/22/12 Subject: or&al re)uest for na&es of those on &+ Screen(ng PanelE%
11/22/12 Subject: 8u1ge 6o'ar1 an1 Cassan1ra 8ac0son 'ant to e/2la(n% 5TT5C67E#TS
11/22/12 Subject: <ashoe "egal Ser*(ces Paul Elcano an1 State 9ar of #e*a1a>s Coe S'obe>s contacts
'(th &+ fa&(l+% 5TT5C67E#TS
11/21/12 Subject: RE: 7r Coughl(n%
11/21/12 Subject: RE: 7r Coughl(n%
11/2./12 Subject: <: 9ar 51&(ss(on an1 e&2lo+&ent %5TT5C67E#TS
11/14/12 Subject: gr(e*ance aga(nst Cre(g S0au3 Es).3 Reno C(t+ 5ttorne+>s Off(ce%
1/:
0434, 0435 60838












































11/1;/12 Subject: RE: 1oes R(char1 6(ll ha*e stan1(ng to f(le a gr(e*ance%
11/14/12 Subject: ne' =(sco*er+ f(nall+ 2ro1uce1 b+ Reno C(t+ attorne+ on 1/12/12 8a+'al0(ng arrest
(n SCR 1.B Co&2la(nt%
11/14/12 Subject: C(t+ 5ttorne+ S0au3 u21ate1 1(sco*er+ (n (Phone case3 1(s2atch recor1(ngs3 1on>t
see& to re*eal bas(s for Fa 2oss(ble f(ghtF assert(ons (n off(ce test(&on+ an1
2rosecutors>s f(l(ngs an1 argu&ent%
11/1-/12 Subject: S9# an1 or Panel '(ll be brea0(ng the la' b+ hol1(ng a hear(ng to&orro' (n
*(olat(on of SCR 1.BG2HGcH 2roof attache1%
11/12/12 Subject: SCR Rule 1.4G-H Co&2la(nt f(le1 aga(nst 9ar Counsel I(ng an1 Cler0 of Court
Peters%
11/12/12 Subject: "!T!$5T!O# 6O"= #OT!CE P"E5SE RET5!# 5"" EC!=E#CE%
11/11/12 Subject: Tr(bal Pol(ce not allo'e1 to arrest for &(s1e&eanors <: Case #o. RCR2.11A
.:--41%
11/11/12 Subject: <: %
11/11/12 Subject: E&ergenc+ E/ Parte 7ot(on #$12A.2.43 .4-43.4-B%
11/.;/12 Subject: RE: Case #o. RCR2.11A.:--41%
11/.:/12 Subject: F(n*est(gatorF Peters 2utt(ng the bl(n1fol1 on herself:%5TT5C67E#TS
11/.:/12 Subject: G#o SubjectH%
11/.:/12 Subject: G#o SubjectH%
11/.:/12 Subject: Subject: has share1 a fol1er '(th +ou%
11/.:/12 Subject: Subject: has share1 a fol1er '(th +ou%
11/.:/12 Subject: Subject: has share1 a fol1er '(th +ou%
11/.B/12 Subject: <: #E: ST5CEY R!SSO#E CS. 8O6# =5C!= $ESS!# G5R9H: Sub2oena
=uces Tecu&: CC1.A.1-41%5TT5C67E#TS
11/.4/12 Subject: RE: con*(ct(ng attorne+ of su&&ar+ cr(&(nal conte&2t 1ur(ng 2en1enc+ of Or1er for
Co&2etenc+ E*aluat(on%
11/.4/12 Subject: RE: 7r. I(ng>s assert(on (n h(s -/1:/12 letter%
11/.-/12 Subject: con*(ct(ng attorne+ of su&&ar+ cr(&(nal conte&2t 1ur(ng 2en1enc+ of Or1er for
Co&2etenc+ E*aluat(on% 5TT5C67E#TS
11/.-/12 Subject: <: 7r. I(ng>s assert(on (n h(s -/1:/12 letter% 5TT5C67E#TS
11/.2/12 Subject: RE: S9# st(ll has not 2ro*(1e1 Coughl(n access to the &ater(als he (s ent(tle1 to to
2re2are for 11/14/12 6ear(ng%
11/.2/12 Subject: S9# st(ll has not 2ro*(1e1 Coughl(n access to the &ater(als he (s ent(tle1 to to
2re2are for 11/14/12 6ear(ng% 5TT5C67E#TS
11/.1/12 Subject: <h+ no Case+ 9a0er3 Es).3 5ll(son Or&aas3 Es).3 <CSO =e2ut+ 7achen3 or R7C
7arshal 6arle+3 <CP= 9(ra+ =ogan3 ==5 Jach Young%
11/.1/12 Subject: RE: Recor1s%
11/.1/12 Subject: RE: Coughl(n: Pet(t larcen+ case%
11/.1/12 Subject: RE: Coughl(n: Pet(t "arcen+ case AA 6an1AOff Trans&(ttal% 5TT5C67E#TS
1./2-/12 Subject: &+ ne' a11ress%
1./22/12 Subject: gr(e*ance aga(nst Ie(th "oo&(s3 Es). an1 Chr(sto2her 6aKlettASte*ens3 Es).3 "e'
Ta(tel3 Es).3 an1 6enr+ Sotelo3 Es).3 an1 <CP= 9(ra+ =ogan an1 8(& "esl(e%
1./1;/12 Subject: bar gr(e*ance aga(nst R(char1 6(ll3 Case+ 9a0er3 an1 Ie(th "oo&(s3 Roberto
Puentes3 "e' Ta(tel%
1./1@/12 Subject: <: u21ate 2roof of ser*(ce%
1./1@/12 Subject: "!T!$5T!O# 6O"= #OT!CE re*2.11A..1@.; c*11A.-:2;3 :.--1 :1-;-3 S9# *.
Coughl(n C5SE #U79ER #$12A.2.43 #$A.4-B3 #$ .4-4 5TT5C67E#TS%
2/:












































1./1@/12 Subject: u21ate 2roof of ser*(ce%
1./1B/12 Subject: "!T!$5T!O# 6O"= #OT!CE re*2.11A..1@.; c*11A.-:2;3 :.--1 :1-;-%
5TT5C67E#TS
1./11/12 Subject: RE: Coughl(n: RCR11A.:--41 GPet(t "arcen+H an1 RCR12A.:@4;. GRes(st(ngH an1
RCR2.12A.:B:-. G&(sue of 411H %5TT5C67E#TS
1./11/12 Subject: RE: #ot(f(cat(on of Electron(c (l(ng (n !# RE: =!SC!P"!#E O J5C65RY
COU$6"!#3 #o. :.;-;%
1./11/12 Subject: RE: 2en1(ng f(nal 1(s2os(t(on of 1(sc(2l(nar+ 2rocee1(ngs....language SCR 111G@H
*ersus SCR 111G;H an1 the 8une @th3 2.12 Or1er of the #C. S. Ct.%
5TT5C67E#TS
1./1./12 Subject: <: 2en1(ng f(nal 1(s2os(t(on of 1(sc(2l(nar+ 2rocee1(ngs....language SCR 111G@H
*ersus SCR 111G;H an1 the 8une @th3 2.12 Or1er of the #C. S. Ct.%
1./1./12 Subject: 2en1(ng f(nal 1(s2os(t(on of 1(sc(2l(nar+ 2rocee1(ngs....language SCR 111G@H *ersus
SCR 111G;H an1 the 8une @th3 2.12 Or1er of the #C. S. Ct.%
1./.:/12 Subject: <: #ot(f(cat(on of Electron(c (l(ng (n !# RE: =!SC!P"!#E O J5C65RY
COU$6"!#3 #o. :.;-;% 5TT5C67E#TS
1./.:/12 Subject: <: #ot(f(cat(on of Electron(c (l(ng (n !# RE: =!SC!P"!#E O J5C65RY
COU$6"!#3 #o. :.;-;%
1./.:/12 Subject: <: &ot(on to 1(s&(ss attache1% 5TT5C67E#TS
1./.-/12 Subject: &ore courtes+ co2(es%
1./.-/12 Subject: &+ 2h+s(cal a11ress%
1./.-/12 Subject: courtes+ co2(es of 'hat 'as f(le1 to1a+% 5TT5C67E#TS
1./.2/12 Subject: 2roble& '(th the f(le (n RCR2.11A.:--41%
1./.1/12 Subject: <: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T% 5TT5C67E#TS
4/24/12 Subject: c(tat(on to legal author(t+%%
4/24/12 Subject: Cler0>s l(ab(l(t(es for fa(l(ng to f(le 1ocu&ents sub&(tte1 <: 7ot(on to =(s&(ss
S9# *. Coughl(n% 5TT5C67E#TS
4/24/12 Subject: <: 7ot(on to =(s&(ss S9# *. Coughl(n% 5TT5C67E#TS
4/1;/12 Subject: 7ot(on to =(s&(ss S9# *. Coughl(n% 5TT5C67E#TS
4/1;/12 Subject: <: &ot(on to 1(s&(ss attache1% 5TT5C67E#TS
4/1@/12 Subject: &ot(on to 1(s&(ss attache1% 5TT5C67E#TS
4/12/12 Subject: =(sc(2l(nar+ 6ear(ng for Coughl(n on Se2te&ber 2Bth3 2.12 at S9# 4 a&%
5TT5C67E#TS
4/.;/12 Subject: gr(e*ance' f(le1 (n 52r(l +et to be ac0no'le1ge1 or g(*en a case nu&ber <: Please
see attache1 5TT5C67E#TS%
4/.;/12 Subject: gr(e*ance an1 co&2la(nt aga(nst ==5 Young an1 <CP= =ogan3 "esl(e3 an1 9osler%
5TT5C67E#TS
4/.B/12 Subject: conf(1ent(al(t+ of gr(e*ances/bar co&2la(nts%
4/.B/12 Subject: 5ugust 2rth3 2.12 gr(e*ance aga(nst 8(& "esl(e3 <CP=%
;/-./12 Subject: ! 1on>t get 1(sbarre1%
;/24/12 Subject: RE: #RS :44..2.G1H...l(cense1 as a b(ll collector%%
;/24/12 Subject: <"S "et Ta(tel3 confl(ct3 2rofess(onal &(scon1uct3 cr(&(nal &(scon1uct%
;/21/12 Subject: a co&2la(nt an1 gr(e*ance aga(nst R7C a22o(nte1 1efen1ers an1 Reno C(t+ 5ttorne+
Prosecutors3 an1 R(char1 6(ll an1 Case+ 9a0er% 5TT5C67E#TS
;/21/12 Subject: gr(e*ance an1 or co&2la(nt% 5TT5C67E#TS
;/21/12 Subject: unauthor(Ke1 2ract(ce of la' (n su&&ar+ e*(ct(on 2rocee1(ngs gr(e*ance an1
co&2la(nt% 5TT5C67E#TS
-/:















































;/21/12 Subject: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T% 5TT5C67E#TS
;/21/12 Subject: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T% 5TT5C67E#TS
;/2./12 Subject: G#o SubjectH% 5TT5C67E#TS
;/2./12 Subject: G#o SubjectH% 5TT5C67E#TS
;/1@/12 Subject: 6ear(ng 1ate%
;/1-/12 Subject: 2lease f(n1 enclose1 &+ Pet(t(on un1er SCR 1.2G4HG1H an1 SCR 111G@H%
5TT5C67E#TS
;/.4/12 Subject: a2olog+ for ta/(ng +our fa/ &ach(nes an1 <: Reno e*(ct(on not(ce1 for S2ar0s
8ust(ce Court%
;/.4/12 Subject: f(l(ngs (n !n re Coughl(n :.;-; an1 :.4@B% 5TT5C67E#TS
;/.;/12 Subject: 12A144.2 SCR 11B 5ff(1a*(t !n Re Coughl(n :.;-;% 5TT5C67E#TS
;/.1/12 Subject: 7atr(/% 5TT5C67E#TS
;/.1/12 Subject: 7atr(/% 5TT5C67E#TS
@/-1/12 Subject: re)uest for cons(1erat(on of global resolut(on%
@/-1/12 Subject: resen1(ng th(s <: 52olog+ an1 Subject: 2rescr(2t(on &e1(cat(ons (nfor&at(on%
5TT5C67E#TS
@/-1/12 Subject: re2ort(ng con*(ct(ons an1 sus2ens(on of 5TT5C67E#TS
1./.-/12 Subject: courtes+ co2(es of 'hat 'as f(le1 to1a+%
1./.2/12 Subject: 2roble& '(th the f(le (n RCR2.11A.:--41%
1./.1/12 Subject: <: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T%
4/24/12 Subject: c(tat(on to legal author(t+%%
4/24/12 Subject: Cler0>s l(ab(l(t(es for fa(l(ng to f(le 1ocu&ents sub&(tte1 <: 7ot(on to =(s&(ss S9#
*. Coughl(n%
4/24/12 Subject: <: 7ot(on to =(s&(ss S9# *. Coughl(n%
4/1;/12 Subject: 7ot(on to =(s&(ss S9# *. Coughl(n%
4/1;/12 Subject: <: &ot(on to 1(s&(ss attache1%
4/1@/12 Subject: &ot(on to 1(s&(ss attache1%
4/12/12 Subject: =(sc(2l(nar+ 6ear(ng for Coughl(n on Se2te&ber 2Bth3 2.12 at S9# 4 a&%
4/.;/12 Subject: gr(e*ance' f(le1 (n 52r(l +et to be ac0no'le1ge1 or g(*en a case nu&ber <: Please
see attache1%
4/.;/12 Subject: gr(e*ance an1 co&2la(nt aga(nst ==5 Young an1 <CP= =ogan3 "esl(e3 an1 9osler%
4/.B/12 Subject: conf(1ent(al(t+ of gr(e*ances/bar co&2la(nts%
4/.B/12 Subject: 5ugust 2rth3 2.12 gr(e*ance aga(nst 8(& "esl(e3 <CP=%
;/-./12 Subject: ! 1on>t get 1(sbarre1%
;/24/12 Subject: RE: #RS :44..2.G1H...l(cense1 as a b(ll collector%%
;/24/12 Subject: <"S "et Ta(tel3 confl(ct3 2rofess(onal &(scon1uct3 cr(&(nal &(scon1uct%
;/21/12 Subject: a co&2la(nt an1 gr(e*ance aga(nst R7C a22o(nte1 1efen1ers an1 Reno C(t+ 5ttorne+
Prosecutors3 an1 R(char1 6(ll an1 Case+ 9a0er%
;/21/12 Subject: gr(e*ance an1 or co&2la(nt%
;/21/12 Subject: unauthor(Ke1 2ract(ce of la' (n su&&ar+ e*(ct(on 2rocee1(ngs gr(e*ance an1
co&2la(nt%
;/21/12 Subject: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T%
;/21/12 Subject: 5TTOR#EY $R!EC5#CE OR CO7P"5!#T%
;/2./12 Subject: G#o SubjectH%
;/2./12 Subject: G#o SubjectH%
;/1@/12 Subject: RE: 6ear(ng 1ate%
;/1@/12 Subject: 6ear(ng 1ate%
4/:













































;/1-/12 Subject: 2lease f(n1 enclose1 &+ Pet(t(on un1er SCR 1.2G4HG1H an1 SCR 111G@H%
;/.4/12 Subject: a2olog+ for ta/(ng +our fa/ &ach(nes an1 <: Reno e*(ct(on not(ce1 for S2ar0s
8ust(ce Court%
;/.4/12 Subject: f(l(ngs (n !n re Coughl(n :.;-; an1 :.4@B%
;/.;/12 Subject: 12A144.2 SCR 11B 5ff(1a*(t !n Re Coughl(n :.;-;%
;/.1/12 Subject: 7atr(/%
;/.1/12 Subject: 7atr(/%
@/-1/12 Subject: re)uest for cons(1erat(on of global resolut(on%
@/-1/12 Subject: resen1(ng th(s <: 52olog+ an1 Subject: 2rescr(2t(on &e1(cat(ons (nfor&at(on%
5TT5C67E#TS
@/-1/12 Subject: re2ort(ng con*(ct(ons an1 sus2ens(on of 5TT5C67E#TS
@/2:/12 Subject: a )uest(on%
@/2B/12 Subject: 7atr(/% 5TT5C67E#TS
@/24/12 Subject: Scr 111%
@/.2/12 Subject: <: Reno e*(ct(on not(ce1 for S2ar0s 8ust(ce Court% 5TT5C67E#TS
:/2@/12 Subject: <: ro& 5ss(stnat 9ar Counc(l3 Patr(c0 I(ng%
:/.@/12 Subject: RE: R8C tr(al 1ate A RCR 2.11A.::-41% 5TT5C67E#TS
B/2B/12 Subject: ! ha*e to f(le so&eth(ng (n O22os(t(on...! th(n0...% 5TT5C67E#TS
B/22/12 Subject: u21ate for !n Re Coughl(n SCR 111%
B/14/12 Subject: 52olog+ an1 Subject: 2rescr(2t(on &e1(cat(ons (nfor&at(on% 5TT5C67E#TS
B/.2/12 Subject: <: release of (nfor&at(on to &+ attorne+% 5TT5C67E#TS
4/2@/12 Subject: U21ate an1 a Re)uest%
4/1@/12 Subject: RE: CORRECT!O# C65#$E O 5==RESS 5TTOR#EY Subject: 3 ESL.%
4/1:/12 Subject: 7r. I(ng>s assert(on (n h(s -/1:/12 letter%
4/1:/12 Subject: RE: CORRECT!O# C65#$E O 5==RESS 5TTOR#EY Subject: 3 ESL.%
4/1:/12 Subject: CORRECT!O# C65#$E O 5==RESS 5TTOR#EY Subject: 3 ESL.%
4/14/12 Subject: off(c(al change of a11ress for& attache1% 5TT5C67E#TS
4/1-/12 Subject: Please see attache1% 5TT5C67E#TS
4/1-/12 Subject: chang(ng &+ a11ress on 2ortal%
4/.2/12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
4/.2/12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
4/.2/12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/-./12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/-./12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/24/12 Subject: r21 sargent s(fre loses J coughl(n>s 1og 8ac0son (s gone *o(ce&a(l fro& G@@BH @:2A
1B4B at 4:2@ P7%
-/24/12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/24/12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/2;/12 Subject: <: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
5TT5C67E#TS
-/2;/12 Subject: RE: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/2;/12 Subject: 2lease note &+ ne' a11ress3 SO"5CE PRO$R57 RELUEST% 5TT5C67E#TS
-/2:/12 Subject: &+ atte&2t to be 2ro*(1e1 access to the gr(e*ances f(le1 to1a+%
-/2:/12 Subject: Please note &+ ne' &a(l(ng a11ress.%
-/2:/12 Subject: O!5 RELUEST%
-/24/12 Subject: RE: =ue Process concerns relate1 to the Fgr(e*ancesF% 5TT5C67E#TS
-/24/12 Subject: <: =ue Process concerns relate1 to the Fgr(e*ancesF% 5TT5C67E#TS
B/:




















-/24/12 Subject: =ue Process concerns relate1 to the Fgr(e*ancesF% 5TT5C67E#TS 5rrange b+
-/2-/12 Subject: O!5 Re)uest RE: 1oes R(char1 6(ll ha*e stan1(ng to f(le a gr(e*ance%
5TT5C67E#TS
-/2-/12 Subject: RE: 1oes R(char1 6(ll ha*e stan1(ng to f(le a gr(e*ance%
-/2-/12 Subject: O!5 RELUEST? 7ot(on to =(s&(ss $r(e*ance for lac0 of stan1(ng%
-/2-/12 Subject: 1oes R(char1 6(ll ha*e stan1(ng to f(le a gr(e*ance%
-/22/12 Subject: Change of 511ress%
-/22/12 Subject: RE: hello fro& Subject: %
-/22/12 Subject: RE: hello fro& Subject: %
-/22/12 Subject: RE: hello fro& Subject: %
-/22/12 Subject: RE: hello fro& Subject: %
-/21/12 Subject: hello fro& Subject: %
-/14/12 Subject: bar gr(e*ance re2ort(ng unauthor(Ke1 2ract(ce of la'% 5TT5C67E#TS
-/14/12 Subject: su22le&ent to res2onse to gr(e*ance% 5TT5C67E#TS
-/14/12 Subject: $ess(n ghost'r(t(ng (ssue% 5TT5C67E#TS
-/1:/12 Subject: su22le&ent to R(char1 6(ll th(ng% 5TT5C67E#TS
-/1:/12 Subject: &ore on the 'a+% 5TT5C67E#TS
-/1:/12 Subject: Character an1 (tness3 Ie*(n Iell+3 Pete Chr(st(ansen3 Patr(ce E(ch&an%
-/1:/12 Subject: RE: Contact% 5TT5C67E#TS
-/.4/12 Subject: res2onse to gr(e*ance fro& #C 5TT5C67E#TS
:/:
Print Close
Challenge for Cause Etc. COURTESY COPY OF FILING
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 12/24/12 8:04 PM
To: patrickk@nvbar.org (patrickk@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); davidc@nvbar.org
(davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); je@eloreno.com (je@eloreno.com);
cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com);
mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net);
ROSEC@NVBAR.ORG (rosec@nvbar.org)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
12 24 12 0204 refaxed to sbn with corrected caption NOTICE OF APPEARANCE AND 11 15 12 61383 CHALENGE FOR
CAUSE AND MOTION TO RECUSE ECHEVERRIA AND KENT ETC RECONSIDER BIFURC.pdf

I am writing to request a fee waiver of the yearly $300 eflex charge
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 12/21/12 5:03 PM
To: CourtTech@washoecourts.us (courttech@washoecourts.us); filing@washoecourts.us
(filing@washoecourts.us); judge.hardy@washoecourts.us (judge.hardy@washoecourts.us);
david.hardy@washoecourts.us (david.hardy@washoecourts.us); joey.hastings@washoecourts.us
(joey.hastings@washoecourts.us); info@abanet.org (info@abanet.org); rsweet@nvcourts.nv.gov
(rsweet@nvcourts.nv.gov); training@nvcourts.nv.gov (training@nvcourts.nv.gov);
staffattorney@nvcourts.nv.gov (staffattorney@nvcourts.nv.gov); zyoung@da.washoecounty.us
(zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
stuttle@washoecounty.us (stuttle@washoecounty.us); katy.englehart@americanbar.org
(katy.englehart@americanbar.org); bill.pritchard@americanbar.org (bill.pritchard@americanbar.org); )
(patrickk@nvbar.org) (patrickk@nvbar.org); ( (ncjdinfo@judicial.state.nv.us); ( (renodirect@reno.gov); (
(kadlicj@reno.gov); nvscclerk@nvcourts.nv.gov (nvscclerk@nvcourts.nv.gov);
tlindeman@nvcourts.nv.gov (tlindeman@nvcourts.nv.gov); janet@ndalclv.org (janet@ndalclv.org);
ndalc@ndalclv.org (ndalc@ndalclv.org); dgordon@nvcourts.nv.gov (dgordon@nvcourts.nv.gov);
cherrym@co.clark.nv.us (cherrym@co.clark.nv.us); mfeldman@nvcourts.nv.gov
(mfeldman@nvcourts.nv.gov); mcherry@nvcourts.nv.gov (mcherry@nvcourts.nv.gov)
000001
Dear Second Judicial District Court,

I am writing based on exigent circumstances to request a fee waiver of the yearly $300 Eflex charge
as my account is currenly deactivated or disabled. I am not copying the State Bar of Nevada or
President Flaherty or the Panel Members (Chair John Echeverria, Clark Vellis, Karen Pearl, Stephen
Kent, or Michael Johnson or Bar Counsel Clark of King becuase I may have had a TPO served
against me recently (I am not entirely sure, and, given the courthouse sanctuary doctrine, I am not
sure it is appropriate for the same RJC Bailiff who threatened to "put my foot up your ass" to WCPD
Jim Leslie, Esq.'s delight, to be attempting serve me anything while I am checking in with the
Department of Alternative Sentencing, which Judge Sferrazza mandated I do, and which, I guess,
incidentally, allows for the States to search my home, office, or personall effects (including
computers, hard drives, etc. and not sure how that "sentence" is not retaliatory given the standard
sentence is $500 or five days in jail, and I had already served 7...but the sentence sure would seem to
help the WCDA's Office, Washoe County, the SBN, and others influence and leverage certain things
from hereforth) just about any hour of the day (despite the fact that the conviction on 11/20/12
violated Shep v. State in addition to pretty much every other constitutional rights criminal defendants
have). I think it is possible I will be murdered soon or incarcerated pretexutally and denied any
ability to file legal documents, so I have to send this out in this manner, but I wish to avoid any ex
parte contact allegations. I wish my filings of 11/2/12 in 11 cr 26405 and thos I submitted for
filing but have only been held by the Nevada Supreme Clerk's Office as "received" but not filed in
61901 will someday see the light of day, including the videos submitted. I am afraid I might be
violating some TPO if I copy Bar Counsel/NNDB/Panel, etc. on this...but would not mind if it was
forwarded to them if not violative of any TPO, rules, or laws. Additionally, I think it is
inappropriate for 60317 to be dismissed, especially given the improperly noticed testimony of WLS's
Paul Elcano, Judge L. Gardner's bailiff's attendance at the 11/14/12 Hearing, RMC "official
transcriptionist" Pam Longoni's connection to the 11/14/12 formal disciplinary hearing, the
multitude willfull violations of my SCR 105(2)(c) rights (including Judge Beesley's participation and
having the 3,000 pages in a box dropped off to my on 11/8/12 for an 11/14/12 Hearing, where the
SBN alleges that complies with the SCR 105(2)(c) dictate that I be afforded access to those materials
"at least 30 days" prior to the 11/14/12 Hearing, particulary where that was co-signed by Panel Chair
Echeverria and both Echeverria and Bar Counsel and the Chair (at least according to King) have
repeatedly attempted to thwart my attempts to filing anything in that case, alternatively required me
to call ahead with 15 minutes warning before appearing to file anything, then calling the police when
I comply with that strange dictate, then, apparently, applying for a protection order or giving me a
trespass notice of some sort whenever I point out their fraudulent conduct, and how easily proven it
is.

I need this Eflex access to defend myself in the formal disciplinary proceedings against
me before the State Bar of Nevada, Nevada Supreme Court, and anything that may issue in
connection with my license to practice patent law before the United States Patent and Trademark
Office. My eflex username is ZachCoughlin. It is disabled. I live in a rented fifth wheel trailer
that I rent for about $75 a month plus incidentals. I get food from food pantries. I have no
000002
money in my one bank account (a Bank of America account) and its been that way for months. I
own no real estate or stocks or have any assets beyond simple household furnishings. I am an
independent jack of all trades/research whose law license is suspened currently in Nevada and I have
next to no income per month...to the point where I am embarrassed about it and it would probably be
an exaggeration to say I am making even $200 a month. My 65 year old mother occasionally helps
me out financially with my rent or some gas money.

As the holdings in In re Ward, 654 So. 2d 549 (Fla. 1995) and In re Fogan, 646 So. 2d 191 (Fla.
1994) indicate, unsolicited contact with the adjudicatory or investigative entity often involves the
judge in impermissible lending of the prestige of office, whether intended or not. It is this appearance
of impropriety judges must strive to avoid.

I have not been provided (though I believe they are required to) by th RJC a copy of the Record on
Appeal in CR12-2025. Certainly, DDA Young and the WCDA have been provided access via elfex
to the 800 page Record on Appeal therein, yet the RJC has failed to mail me my copy. And time is
of the essence. I have already been prejudiced in that regard and I believe NRS 189.030 has been
violated in that the RJC has failed to order the transcripts prepared of all hearings in that matter
yet. Please see CR12-1018 and the recent IFP and Request for Transcript I filed in CR12-2025. I
need eflex access, further, for many of the cases necessary to defending myself in the SBN v.
Coughlin SCR 105 Complaint, and to defending myself against the numerous retaliatory prosecutions
and matters related thereto.

I respectfully request that I be given immediate EFlex privileges and that the yearly dues thereto be
waived.

Further, I believe it would be entirely in appropriate for Judge Elliot to remain on that case, given the
irregularities of his "randomly" being assigned four of my criminal matters, failure to disclose
conflict or recuse himself in cv11-01955 and other matters detailed herein.

As the holdings in In re Ward, 654 So. 2d 549 (Fla. 1995) and In re Fogan, 646 So. 2d 191 (Fla.
1994) indicate, unsolicited contact with the adjudicatory or investigative entity often involves the
judge in impermissible lending of the prestige of office, whether intended or not. It is this appearance
of impropriety judges must strive to avoid.

I have recently been forced to make numerous trips to law libraries far away given the Washoe
County Law Librarie's contention (disputed by me at the meeting of the Board of Trustess of the WC
Law Library when the new law librarian's cv was detailed yearlier this year, wherein Judges Weller,
Walker, and Steinheimmer were present, along with Clerk of Court Orduna Hastings, wherein those
Judges all deferred to the Washoe County District Attorney's Office rather than address my
contentions that the WCLL asserts to the public in writing that the "westlaw contract" forbids certain
things that the contract simply does not forbid, requiring patrons to expend great amounts of money
to print materials, resulting in collection of revenue by the Court and or Library. I have great
respect for the WCLL, and would give them huge donations if I had the means, as its the most
important room in the County, in my opinion). I do have a license to practice before the United
States Patent and Trademark Office but have never filed anything there and have informally
represented to USPTO OED Staff Attorney Tom McBride, Esq. that I will not be representing
000003
anyone there for the foreseeable future given the extremely encumbering nature of my recent legal
troubles and defending myself incident thereto. I would greatly appreciate this waiver of the $48 I
owe pacer and swear under penalty of perjury subject to NRS 53.045 that the information contained
herein is true and correct.

I have previously and will again here complaint in writing that Judge Steven Elliott has "randomly"
(in accord with our local rules) been assigned four of my criminal matters in a row (the appeals of
the RMC conviction in 11 cr 22176 for petty larceny of a "candy bar and some cough crops" which I
vehemently dispute and which resulted in my current six month temporary suspension of my law
license in 60838 (which the State Bar of Nevada managed to get crammed into an unbifurcated
hearing on 11/14/12 that also included something like 10 copied and pasted alleged violations of the
Rules of Professional Conduct (none mentioning any direlection of my duties to clients, other than
Judge Nash Holmes alleging I violating my own duty of competency to myself, etc. where I
represented myself in a "simple traffic citation" trial on 2/27/12 (held in violation of NRS 178.405
and NRS 5.071 where Judge Nash Holmes knew of the competency issues, and where Judge Nash
Holmes continues to violate NRS 189.030 in refusing to process my Notice of Appeal of 3/7/12 and
those materials submitted thereafter
37 A.L.R.4th 1004 (Originally published in 1985)
American Law Reports ALR4th The ALR databases are made current by the weekly addition of relevant new
cases. Disqualification of judge in state proceedings to punish contempt against or involving himself in open court
and in his actual presence

57 A.L.R. 545 (Originally published in 1928)


American Law Reports ALR The ALR databases are made current by the weekly addition of relevant
new cases. Necessity that hearing be allowed before imposition of punishment for contempt

The use of summary criminal contempt power is proper only for charges of misconduct, in open
court, in the presence of the judge, which disturbs the federal court's business, where all of the
essential elements of the misconduct are under the eye of the court, are actually observed by the
court, and where immediate punishment is essential to prevent demoralization of the court's authority
before the public. 18 U.S.C.A. 401; Fed.Rules Cr.Proc.Rule 42(b), 18 U.S.C.A. F.T.C. v.
Trudeau, 606 F.3d 382 (7th Cir. 2010).

Judge Nash Holmes sentenced Coughlin to a summary 5 day incarceration for contempt on 2/27/12,
signed in an Order stamped 2/28/12 in 11 TR 26800 that, combined with a second bite at the apple
Order of 3/12/12 in that case attempts to both convict coughlin of "the misdemeanor of criminal
contempt" in a summary fashion, where there does not seem to be any notice in writing to Coughlin
onf the 3/12/12 continuation of the Trial and where Coughlin filed a Motion for Continuance of any
future hearings and Notice of Appeal on 3/7/12 that divested Judge Nash Holmes and the RMC of
jurisdiction to even hold the 3/12/12 continuation of the Trial (and NRS 178.405, NRS 5.071 further
prohibited such a proceeding...and its really not at all clear how Judge Nash Holmes feels it is propert
to file a grievance with the State Bar of Nevada against Coughlin on 3/14/12 on behalf of herself an
all the other RMC Judges (even the Judges Pro Tem) (which Judge Dilworth vehemently disputes)
000004
including Second Judicial Judge L. Gardner's brother, RMC Judge William Gardner (whom refused
to recuse himself from the criminal trespass conviction Trial against Coughlin in 11 cr 26405, despite
W. Gardner then himself having a grievance against Coughlin in ng12-0434, and despite his being
involved in the filing of the grievance against Coughlin in ng12-0435, which consists solely of his
sister's April 2009 Order sanctioning Coughlin $1,000 (despite Springgate failing to follow NRCP
11's 21 day safe harbor provisions...so basically Springgate and Judge Linda Gardner (whose 2008
campaign contributions list Springgate as a donor and Judge Peter Breen, as well, whom removed
Coughlin from the Mental Health Court in MH12-0032 for Coughlin takign a medication for
ADHD/treatement resistent depression that Coughlin was specifically told was approved and not
probibited prior to Coughlin entering into the Mental Health Court contract, and reviewing the
associated written materials provided by the MHC, Reno Biondo, est. whom subsequently
fraudulently asserted Coughlin was removed from the MHC for not following program rules (the
alleged violation was that Coughlin was taking a medication that he had specifically been told was no
prohibited and that his use of was acceptable. Judge Breen's law clerk at one time was Judge
Linda Gardner, who recused herself from a case wherein Coughlin represent Robert Bell in Bell v.
Greer, a case filed on 8/10/11, proving Coughlin was a commercial tenant practicing law at the 121
River Rock St. location from which Coughlin was summarily evicted, in violation of NRS 40.253
(much less where Coughlin was required to deposit a $2,275 rent escrow deposit that violated Nevada
law, in that no corollary to JCRLV 44 had been published and approved by the N. S. Ct, in
compliance with Nevada's JCRCP 83...) from his former law office, and subsequently subject to a
custodial arrest and prosecution for trespass, signed by opposing counsel Richard G. Hill (whom lied
to the RPD about whether he had been at the office in the weeks prior, in an attempt to avoid the
requirement under the RPC that the lawyer, Hill, withdraw where the likelihood of his becoming a
witness in the case was assured, where Hill told the RPD it was his client Merliss who "noticed"
things in the office in the week prior to the criminal trespass arrest, which was fraudulent anyways,
as detailed in 61901 and 11 cr 22176, especially the 11/2/12 filing in that matter that the RMC did
not included in the record transmitted on 11/29/12 in cr12-1262 (another 'random" assignement to
Judge Elliot...whom failed to disclose and recuse himself from Coughlin's wrongful termination suit
against Washoe Legal Services (who admitted ot fiing Coughlin based solely upon Judge L.
Gardner's April 2009 Order sanctioning Coughlin (which was impermissibly summary in nature
anyways and failed to follow the 21 day safe harbor in NRCP 11 required under NRS 7.085) in cv11-
01955 even where Coughlin was suing for wrongful termination as a former domestic violence
attorney at WLS, and also suing Committee to Aid Abused Women (CAAW) where Judge Elliott was
on CAAW's Executive Board, and started the Nevada Domestic Violence Task Force, and where a 25
year Washoe County District Attorney turned RJC Judge (David Clifton) who was a longtime
domestic violence prosecutor (working with now Judge Linda Gardner in the domestic violence unit
of the WCDA, to go along with their both being from Reno High School's Class of 1975, and WLS's
Director Elcano admitting that Judge Linda Gardner and Master Edmondson has given Coughlin "a
thumb's up" review in February 2009...shortly before Coughlins' suspension and firing from WLS on
4/20/09...the day after Coughlin submitted a complaint in writing to WLS and Elcano regarding the
hostile work environment there...where Elcano and WLS fired Coughlin "solely" based upon Judge
Gardner's April 2009 Order sanctioning Coughlin for his work in the 3/12/09 and 3/17/09 divorce
trial in Joshi, DV08-01168...never mind that Coughlin was encumbered preparing a Nevada
Department of Taxation 20 page appeal brief for Elcano by a 3/10/09 deadline to get Elcano and
WLS out of the jam where the Lease Agreement for the property Elcano had just moved WLS to
required WLS, a non-profit 503(c) to pay the private landlord's property taxes...and where WLS
000005
management failed to timely respond to Coughlin's request for subpoena fees and other discovery
related expenses and where Coughlin emails to his then WLS assistant proves he had culled ALR
support for the positions taken, vis a vis Siragusa, that Judge Gardner had him fired over....Judge L.
Gardner's 2008 campaign expense reports lists CAAW as well, in addition to WLS's Todd Torvinen,
Esq., whom specifically approved of the positions Coughlin took in that Joshi divorce Trial upon
Coughlin following Elcano's direction to seek mentoring and guidance from Torvinen, whom
managed to get the lawsuit against him dismissed in 60302 and 60317 based upon weasley
"legibility" arguments regarding the service of process, which the WCSO messed up in 60302 where
Coughlin was an IFP)

That under some circumstances, even where immediate summary contempt proceedings
would be appropriate, it might be necessary for the contemned trial judge to be disqualified
from sitting therein was recognized by the court in Krueger v State (1977, Fla App D3) 351
So 2d 47, in which it appeared that the appellate court's primary emphasis was on the lack of
objective evidence to support the trial judge's finding that a contempt had actually been committed
by a prosecuting attorney whose intent to appeal a prior ruling had been characterized
by the trial judge as not only frivolous but "absurd," and who replied to this characterization
merely by stating that the judge was entitled to his opinion

Judge Berry's Order in CR12-1018 seems to establish that the RMC had a duty to order the
transcripts prepared in 11 cr 22176 ("randomly" assigned to Judge Elliot in Department 10 in cr11-
2064, where he dismissed my appeal based upon not citing to a transcript that I attempted to have
prepared by the "RMC Official transcriptionist and the only person the RMC will release your audio
transcripts to and whom can prepare a transcript for you, Pam Longoni"...Ms. Longoni refused to
prepare my transcript and hung up on me twice in December 2011. Further RMC Judge Howard
seems to have violated NRS.

So, the transcripts from the convictions in RMC 11 CR 22176 should have been ordered prepared
by RMC Judge Kenneth Howard, and his failure to prejudiced Coughlin in the appeal
("randomly" assigned to Judge Elliott in Cr11-2064, dismissed by him citing to a civil statue about
down payments on transcripts), and in 11 TR 26800 (which the RMC and Judge Nash Holmes
continue to violate NRS 189.030 in failing to process Coughlin's notice of appeal of 3/7/12 etc.
for. Additionally, Judge Elliott was "randomly" assigned Coughlin's appeal of the criminal
trespass conviction that RMC Judge W. Gardner failed to recuse himself from in 11 cr 26405, in
cr12-1262, and dismissed that case where, despite Coughlin showing proof of timely receipt of
his Notice of Appeal in compliance with NRS 189.010 by both the City Attorney and the RMC,
000006
properly submitted for filign by Coughlin, RMC assistant Lisa Wagner is mum about why that Notice
of Appeal was not filed in by the RMC, as is Judge W. Gardner...Further RMC Donna Ballard is
certifying Orders from the Second Judicial District Court for SBN Bar Counsel Patrick King that she
has no right to certify. Further, King is fraudulently alleging to have certified copies of an
admitting as exhibits in the 11/14/12 hearing against Coughlin in the SBN ng12-0204 of Judge
Flanagan's 6/28/12 Order awarding against his former co-worker at Hale Lane, Coughlin
(Flanagan refused to recuse himself despite obvious conflicts set out by Coughlin in cv11-03628)
a preposterous $42,050 in attorney's fees, against a pro se tenant, whom Flanagan apparently ruled a
commercial tenant anyway whose rent was les sthan $1,000, though denied the NRS 118A.385 stay afforded such
litigants.

SBN King similarly fraudulently asserted the April 2009 Order by Judge L. Gardner in dvb08-01168 was certified
where he had it admitted as an exhibit (ordered admitted by Panel Chair John Echeverria, who Judge Steven
Elliott worked for Echeverria's father's law firm, Echeverria and Osborne, and where Chair Echeverria, Judge
Elliott, and WLS's Paul Elcano all went to Stanford University in the late 1960s together, something none of them
disclosed until Coughlin pointed it out...and Elcano, Echeverria, Norman Beesley and other Judges went to Reno
High School together in 1962...along with other former co-workers of Coughlin from Hale Lane (Peek, Dennisson,
Judge Charles McGee, Judge Salcedo, whom Judge Sferrazza mentioned needing to meet with on the record in
another retaliatory prosecution against Coughlin in RJC rcr2011-063341, which, again, Judge Elliott was
"randomly" assigned on 12/6/12, allegedly, in cr12-2025 (which Coughlin has not been provided a copy of the 800
page record on appeal, which seems to involved Judge Sferrazza, in conjunction with the fraudulent conduct of
public defendner Jim Leslie, "disenfecting" the record of Coughlin's 2/15/12 Pre-Trial Motions and Coughlin
8/29/12 Memorandum of Law, etc. (Leslie has no ability to "refuse to join in on" such, especially where Leslie
was not even attorney of record untilsometime in August 2011 and where Coughlin filed a Notice of Appearance
to represent himself while he was still a license attorney and to subsitute out the WCPD's office or to at least
downgrade their involvement to co-counsel in February 2012.)

Additionally, Coughlin has not received any such "Amended Notice of Appeal" in cr12-1262, despite receiving an
email indicating one was filed from Eflex...Coughlin's elfex is currently disabled for non-payment, and Coughlin
hereby request his eflex charges be waived in light of his indigency and the misconduct and irregularities
mentioned above and previously by Coughlin.

Coughlin attempted to proved the testimony by RMC Judge Nash Holmes regarding the order of the bathroom
break and Holme's other patently false and or incorrect statements in her testimony on 11/14/12 at the formal
disciplinary hearing...however Judge Elliott's former Stanford Classmate (whose father's law firm he worked for),
Chair Echeverria (who admits to be "boyhood chums" with fellow wine business owner WLS's Elcano, upon
Coughlin prompting them to divulge further conflicts), Chair John Echeverria refused to allow into evidence the
audio transcript Coughlin bought from the RMC (well, Coughlin had to have his mother, Very Special Arts
Nevada's Mary Barker sneak down to the RMC and buy it becuase Coughlin's previous three or four attempts to
buy it himself were met with obstuctionist tactics by the RMC) for $35, where Bar Counsel King claimed it wasn't
"certified" and the lack of a written transcript made it "worthless" and "devoid of context" (surely the tape could
have shown that the sua sponte interrogation by Judge Nash Holmes regarding her questioning Coughlin if he
was "recording" or had a "recording device" occured AFTER the one and only restroom break in theat 2/27/12 11
tr 26800 "simple traffic trial" and NRS 22.030(3) requirement for an Affidavit for any factual allegations to
support a summary contempt order for any conduct occuring in the "immediate presence" of the Judge would
have been useful, as then RMC Marshal Harley could have maybe gotten his story straight (or Judge Nash Holmes
could have had some more "help" with her "memory" about what Harley "told" her to support Judge Holmes
"finding" that Coughlin "probably lied" about such matters in her 2/28/12 Order, and that Coughlin "lied" and
therefore "violated the Rules of Professional Conduct" in her "second bite at the apple" Order of 3/12/12 (which
violated NRCP 59(a) in that such a sua sponte altering or amending of what was a "civil contempt" Order must be
within 10 days of its entry...where Judge Nash Holmes cites to plenary civil contempt statutes in her ORders (NRS
22.010 and NRS 22.100, curiously avoiding the summary civil contempt statute setting out the Affidavit
000007
requirment that Judge Holmes, the RMC, and Marshal Harley benefitted from avoiding, found in NRS 22.030(3)...

Also, less than 48 hours after Richard G. Hill, Esq. had the RPD arrest Coughlin for jaywalking in RMC 12 CR
00696 (curiously "transferred" to Judge Nash Holmes by Judge W. Gardner on 2/27/12, from RMC Dept. 1), the
RPD again arrested Coughlin on 1/14/12 for "misuse of 911"...but that would be politically awkward for RJC
Judge Clifton to convict Coughlin of in rjc rcr2012-065630, plus, so much better leverage for the SBN (whom
received emails from RJC Judicial Secretrary Lori Townsend containing Coughlin's 2/21/12 filign in that matter
and where Townsend offered to send Coughlin's 2/15/12 filing in rcr2011-063341 to the SBN, unprompted...and
the RJC and SBN are refusing to prove that such transmission by the RJC were not unprompted. Further RMC
Judge Kenneth Howard and RMC Administrator Cassandra Jackson have sent unprompted correspondence to the
SBN seeking to have an effect on Coughlin's formal disciplinary hearing, which is judicial misconduct.

Summary convictions for contempt, during criminal trial, that are unwarranted by the facts will not be
invulnerable to appellate review. Codispoti v Pennsylvania, 418 US 506, 41 L Ed 2d 912, 94 S Ct 2687, conformed
to (Pa) 328 A2d 484.
Denying misdemeanant contemnor an appeal and bail pending appeal, right to which all other misdemeanants
were absolutely entitled under California law, violated equal protection clause. Bell v Hongisto (DC Cal) 346 F
Supp 1392.
Criminal contempt judgments are immediately appealable because they result from a separate and independent
proceeding to vindicate the authority of the court and are not a part of the original cause. 28 U.S.C.A. 1291.
Cobell v. Norton, 334 F.3d 1128 (D.C. Cir. 2003).

33 A.L.R.3d 448
Appealability of contempt adjudication or conviction
Exercise by trial judge of his summary power to punish for contempt of court committed in his presence is
subject to review on appeal. Re Lafferty, 28 Mich App 654, 185 NW2d 189.

RMC Judge Howard attempted to mislead Coughlin as to his right to appeal and seek review of the NRS
22.030 civil summary contempt Order he rendered against Coughlin at the conclusion of the 11/30/12 Wal-Mart
candy bar petty larceny trial in 11 cr 22176 (and now Chair Echeverria is trying to call that one "criminal
contempt" too...seeking to utilize Bar Counsel King's oft repeated, Claiborne ignoring claim, that SCR 111(5)
makes and such "conviction" provide "conclusive proof of guilt" and thereby vitiating and Claiborne duty upon
Bar Counsel of the Panel to ascertain whether a fundamental lapse of due process occurred (or whether such a
"conviction" was void for lack of jurisdiction or not actually a crime anyways under Schaefer...

Further WCDA's Office David Watts-Vial may not seek to Quash Coughlin's subpoenas served upon Clerk
of Court Hastings where Watts-Vial's relation works as a Administrative Assistant to Judge Egan Walker.

In re Eriksson, 36 So. 3d 588 (Fla. 2010) (judge publicly reprimanded for revoking bond for
defendant who sought recusal, thereby punishing defendant for exercising legitimate legal right, and
for employing unduly rigid process in dealing with self-represented litigants, so as to impede their
ability to obtain relief and protection they sought from court).

http://www.flcourts.org/gen_public/courted/bin/judicialethicsbenchguide.pdf
6. What Contact with Investigative or Adjudicatory Bodies Is Permitted?
The case law and committee opinions advise that a judge may not initiate contact with an
investigatory or adjudicatory body determining rights, duties, privileges, or immunities of a person
requesting that the judge contact the body on his or her behalf. Opinion 75-6 (improper to write
character letter for attorney who is principal in disbarment proceeding); Opinion 75-18 (improper to
write letter to bar grievance committee or supreme court in disciplinary proceeding or to
federal judge in criminal sentencing without official request); Opinion 82-15 (improper to write
letter voluntarily to Board of Bar Examiners); Opinion 89-15 (impermissible to appear before
000008
judicial nominating commission to introduce candidate or express opinion about who is best qualified
to serve as judge...See Judge Sferrazza's letter in 2007 on this and Judge Linda Gardner's submitting
numerous letters of recommendation from local judges:
http://www.washoecounty.us/large_files/agendas/071007/35.pdf page 101-104);

Judge Linda Gardner recused herself from Bell v. Greer admitting to a personal bias against
Coughlin (maybe stemming from the Mandamus Petition Coughlin file in 54844 agaisnt her,
which WLS's Elcano claimed to be unaware of in his improperly notice 11/14/12 testimony at
Coughlin formal disciplinary hearing. Panel Chair Echeverria did not care about SCR
105(2)(c)'s requirement that such a Designation of Witnesses and Summary of Evidence be
provided Coughlin "at least" 30 days prior to the 11/14/12 hearing where Bar Counsel King (despite
no "newly discovered" evidence justiying such, no argument by King in support of such a stance,
and have been aware of all that either Judge Beelsey or WLS's Elcano (whom both went to
McGeorge School of Law in 1977 with another witness that day, RMC's Judge Dorothy Nash
Holmes, though none of divulged that...Judge Beesley also worked with WLS's Karen Sabo at
Beesley Peck, and attended at 2008 West Fourth St. Bistro WLS fundraising dinner, RMC Judge
Howard is a 1980 graduate of McGeorge, as is Panel member Stephen Kent, Esq., and Coughlin
"court appointed defender" Keith Loomis in the RMC, who received multiple ORders granting his
Withdraw, is a 1982 McGeorge graduate and whom fraudulently refused to assert the claim of right
defense to the criminal trespass charge set out to him in 11 cr 26405, even where Hill admits to
having sent writings charging the same $900 per month that was charged for "full use and
occupancy" and where Washoe County Sheriff's Officer Liz Stuchell admitted in her 2/5/12 email
to Coughlin that the 11/7/12 Affidavit of Service by Deputy Machen was false in that no personal
service was effect, therby making Hill and the WCSO the trespasses, along with Casey D. Baker,
Esq., especially where the "within 24 hours of receipt" language of NRs 40.253(5) made both the
10/25/11 and 10/27/11 Orders in rev2011-001708 void and or stale, especially where WCSO Roxy
Silva brazenly brags about the stomping on tenant's rights in open violation of such law where the
WCSO knows it is too late and any such Lockout ORder is stale. Oh, then there is the locksmith
from the 11/1/11 lockout at Coughlin former law office admitting that the lockout was effected
outside the "within 24 hours" required in NRS 40.253 (not to mention Sferrazza's Order fails to
include that required language...which in no way amounted to a "trespass warning" anyways).

In re Frank, 753 So. 2d 1228 (Fla. 2000) (retired appellate judge publicly reprimanded for actions
while on bench, including making false or misleading statements under oath concerning his
involvement in divorce litigation of his daughter; not recusing himself from appeals based on his
friendship with attorney in those appeals; improperly interfering with Bar grievance proceeding of
that attorney; threatening to have son-in-law arrested or committed to psychiatric facility during
divorce proceedings involving his other daughter).

Then there is the matter of RJC Clifton on 2/27/12, "somehow" knowing that Judge Elliott would be
"randomly" assigned the case created by Judge Clifton's 2/27/12 Order for Competency Evaluation
(the gross misdemeanor of "misuse of emergency services (911)" case rcr2011-065630 necessitated
the opening of a District Court case, CR12-0376), where Judge Clifton specifically lists "Judge
Elliott" in that 2/27/12 Order and also list's the evaluator Couglin was required to utilized for the
evaluation ("Lake's Crossing Bill Davis, Ph.D....who just so happened to file and sign a fraudulent lie
filled letter in that cr12-0376 case on 4/18/12 resulting in Coughlin being incarcerated from April
000009
19th to April 26th, 2012, though Judge Elliott has failed to put the "why" of it in writing in an sort
of Order...and where DDA Young violated NRS 178.405 in moving for Coughlin to "be remanded
into custody" (as if asking a question about one's HIPAA rights or telling Bill Davis, Ph.D. that
Coughlin would need to "check his records" in response to one question justified such a remanding
into custody or was tantamount to "following all laws"...which DDA Young clearly does not follow
all laws himself given his horific attempts to coerce from Coughlin, in conjunction with RJC Judge
Sferrazza and "stand by counsel" WCPD Jim Leslie, Coughlin's Fifth Amendment rights on
November 19th and 20th, 2012 in rcr2011-063341...see from 4:05 pm to 4:55 pm on 11/19/12 (at
which time RJC Bailiff John Reyes attempted to extort from Coughlin permission to for the RJC to
keep (and probably search and or copy under Diaz) Coughlin's laptops and other trial materials
overnight while Coughlin was in custody, at a time when Coughlin was handcuffed and in custody
awaiting transport to the Washoe County Jail incident to Judge Sferrazza finding Coughlin in
contempt for "making arguement while testifying")
http://www.youtube.com/watch?v=8NsOLy2Unek
http://www.youtube.com/watch?v=w4c7hyhI1RI Witness "standby counsel" WCPD Jim Leslie
trying to aid in coercing from Coughlin his Fifth Amendment and other rights (even more than Leslie
is heard doing on the record during the 8/27, 8/29/, and 9/5/12 Trial dates in 063341) at the 9:05 am
mark

Then there is....this by RJC Judge Clifton and WCDA DDA Zachary Norman Young, Esq.:
http://www.youtube.com/watch?v=WPYCmDZTSXo

/s/ signed electronically Zach Coughlin


Zach Coughlin

law license temporarily suspended in Nevada


NV Bar No: 9473
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com



000010
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
court refusing to file documents and exhibits missing
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 12/19/12 1:14 PM
To: (patrickk@nvbar.org) (patrickk@nvbar.org); (je@eloreno.com) (je@eloreno.com); (davidc@nvbar.org)
(davidc@nvbar.org); (eifert.nta@att.net) (eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com);
(mike@tahoelawyer.com) (mike@tahoelawyer.com); (fflaherty@dlpfd.com) (fflaherty@dlpfd.com);
(skent@skentlaw.com) (skent@skentlaw.com); (nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net);
(ncjdinfo@judicial.state.nv.us) (ncjdinfo@judicial.state.nv.us); (dballard@reno.gov)
(dballard@reno.gov); (ballardd@reno.gov) (ballardd@reno.gov); (jacksonc@reno.gov)
(jacksonc@reno.gov); (renodirect@reno.gov) (renodirect@reno.gov); (kadlicj@reno.gov)
(kadlicj@reno.gov); (joey.hastings@washoecourts.us) (joey.hastings@washoecourts.us);
(judge.hardy@washoecourts.us) (judge.hardy@washoecourts.us); (rsweet@nvcourts.nv.gov)
(rsweet@nvcourts.nv.gov); (training@nvcourts.nv.gov) (training@nvcourts.nv.gov);
(staffattorney@nvcourts.nv.gov) (staffattorney@nvcourts.nv.gov); (zyoung@da.washoecounty.us)
(zyoung@da.washoecounty.us); (jleslie@washoecounty.us) (jleslie@washoecounty.us);
(bdogan@washoecounty.us) (bdogan@washoecounty.us); (mkandaras@da.washoecounty.us)
(mkandaras@da.washoecounty.us); (stuttle@washoecounty.us) (stuttle@washoecounty.us);
(info@abanet.org) (info@abanet.org); (katy.englehart@americanbar.org)
(katy.englehart@americanbar.org); (bill.pritchard@americanbar.org) (bill.pritchard@americanbar.org)
3 attachments
12 12 12 rcr2011-063341 notice of rjc refusing defendant access to file since 11 19 12 and refusing to
file in documents 0204.pdf (1388.6 KB) , 20121219_113934 rcr2011-063341 robbin baker cathy
wood.jpg (1565.6 KB) , 12 19 12 docket in cr12-2025 from sferrazza's shepp violating 2011-063341
conviction 0204.pdf (254.1 KB)
To Whom it May Concern,
Before I get done away with, I just wanted to try to access justice a little bit more. Been having some real issues with Court's just refusing
to file things (the RJC refusing to file the 12/26/11 Notice of Appeal in rjc rev2011-001708 cited in Judge Flanagan's Order denying my
appeal (or he cited my failure to file such a NOA in CV11-03628 as allowing him not to consider matters stemming from Judge Sferrazza's
12/21/11 order "resolving" (no, I did not "agree" to the Order, I made that very clear on the record...).
Then there is the RJC failing to file my 3/16/12 Notice of Appeal in rjc rev2012-000374, in the other summary eviction by Galye Kern, ESq.
(Judge Linda Gardner's former law partner, and I sued Judge Linda Gardner in 54844, and her Order in dv08-01168 was cited by Washoe
Legal Services Elcano as the sole reason for my firing, which led to 60302, and that April 2009 ORder now "mysteriously" became a
grievance ng12-0435, which Bar Counsel has fraudulently attempted to assert he got from "the clerk of court", but which lacks a certification
000011
from Clerk of Court Hastings (Bar Counsel King likes dealing with the Reno Municipal Court whenever possible, going so far as to have it
certify documents that it lacks authority to certify, then claiming the audio transcripts from the RMC are "not certified...worthless...lacking
context..." when Coughlin tries to offer them to the Panel on 11/14/12 in SBN. V. Coughlin (ng12-0204, 0434, and 0435...which somehow is
supposed to address 60838 despite the "conviction" in 60838 not being addressed at all, which is considering the Court's 6/7/12 ORder and
SCR 111(7) mandate that the matter "is referred to the disciplinary panel for the sole purpose of determining the punishment " for the the
conviction the subject of the SCR 111(6) petition in 60838 (ie, not for what the SBN and NNDB/Panel did, which is try to tranmogrify RMC
Judge Nash Holmes various Order in a "simple traffic citation trial" into some SCR 111(5) "conclusive proof of a conviction" of a bunch of
alleged violations of the Rules of Professional Conduct that Judge Nash Holmes copied and pasted into her second bite at the apple
3/12/12 Order in rmc 11 tr 26800...then there is judge schroeder ruling that gayle kern doesn't even have to respond to coughlin's recent
filings pointing out that she mailed the notice of entry of order to an address coughlin had told her was no good anymore in her may 2012
mailing....then
there is the rjc issuing an eviction order violative of nrs 40.253(5) on 6/28/12, depsite coughlin's filing a tenant's affidavit with the sparks
justice court on 6/26/12, which was the forum listed on the notice in which the tenant must file...and coughlin's writying and callign the
wcso, rjc, sparks justice court, etc., etc. and giving them a heads up on the situation...no matter, Judge schroeder signed the eviction order
and the wcso office arrested coughlin w here he didn't immediately open his door and where the wcso refused to identify themselves, and
where the lockout order was obtained by an unlicensed "eviction consulting service process firm", Nevada Court services in rjc rev2012-
001048, which begat the criminal prosecution fo coughlin in rcr2012-067980 for "resisting or obstructing a public officer" or "false
statement to a public officer....the rjc and the wcda's office criminal and civil division and the wcso goin' together like bread and meat.
Then there is Judge Clifton's "disenfecting" the record from anything I am trying to preserve in rjc rcr2012-065630. Most recently he put a
post-it note "Order" telling Robbin Baker and Cathy Wood to finally file in my 11/28/12 filing in that matter but to file stampe it the day
after the trial started...so file stampe it 12/12/12...which makes it far less operative.. I had permission to fax file as of 11/28/12, and given
Judge Clifton removed public defender Dogan as counsel of record substituting in me as a pro se...I was entitled to file that document (I
believe it was an Motion for Reconsideration of Order allowing wCDA to Amend Complaint (they didn't want to try a "misuse of 911" charge
against this former domestic violence attorney, where Judge Clifton and Judge Gardner worked together in the domestic violence unit at
the Washoe County District Attorney's Office and where Coughlinw as granted two protections orders against domestic violence against the
very peopel he called 911 about, but for which reno pd sargent paul sifre decided to order coughlin arrest for the second time in 2 days (the
first arrest, on 1/12/12 was a custodial arrest for jaywalking...and in the interim the same officer coughlin filed a written complaint against
with the rpd on 1/8/12 pulled coughlin over on 1/13/12 with 5 other officers and harrassed him late at night....).
Plus, the wcpd refused to give coughlin the 8/13 and 8/17/12 cd's of discovery containing the 911 calls in question. DDA Young refused
to provide Coughlin a copy and Judge Clifton claimed his hands were tied to allow Coughlin access to such discovery (though he was sure
to "help" the DA out by turning the 11/27/12 hearing into an arraignment, despite earlier stating on the record that it was not permissible
to do so and how the hearing was for a very limited purpose of hearing argument on the motion to amend the complaint (which was
amended to a scr 111(6) "serious offense" because a conviction there woudl help bar counsel get rid of coughlin, and help the wcda's office
out a lot more than a "misue of 911" charge...the amended charge was "obstructing a public officer"...which is specificaly mnetioned in the
scr 111(6) serious offense rule....though Judge Clifton kept a straight face when indicating to Coughlin "I don't see how "misuse of 911" is
less worse for you than "obstructing a public officer" under a SCR 111(6) analysis...I really don't. " Yeah. uh....sure.
Then there is Judge Clifton refusing to file in many other filing by Coughlin in rcr2012-065630.
Then, Coughlin as of 12/19/12, still has not received the record on appeal in cr12-2025 (one of 4 criminal matters involving Couglin that
have been "randomly" assigned to Judge Steven Elliot, who worked at Panel Chair Echeverria's father's law firm, sat on CAAW's board and
presided over Coughlin's wrongful termination suit against CAAW and Washoe Legal SErvices, did not disclose the conflict, failed to recuse
self, etc...and who went to Stanford in the later 1960s with Elcano (director of WLS) and Panel Chair Echeverria...Oh, and Judge Gardner's
campgain contributions include some from WLS's Torvingen, expense to CAAW, her brother refused recuse self from criminal trespass
prosectuion of coughlin in 11 cr 26405...oh, jeez, its exhausting detailing all this over and over....more copy and pasting necessary..
then judge linda gardner's brother, rmc jduge william gardner failed to file coughlin's timely notice of appeal of the 6/18/12 conviction of
trespass in 11 cr 26405...for cr12-1262...then the rmc failed to order the transcript prepared in the walmart candy bar case in 11 cr 22176,
000012
which became cr11-2064, rmc holds Pam Longoni out as only one who can get the audio to do the transcript, and Longoni refuses to
prepare the transcript, even where coughlin offerred to pay for it under protest (because nrs 4.14(a) applies to civil cases, not criminal
appeals by indigents....(rmc Judge HOward refused Coughlin court appointed counsel, even though he failed to rule that jail time was
absolutely not a possibility, violation aigersinger...and refused even one continuance, though they are freely given to richard g. hill/reno city
attorney...or stipped to by lew taitel, coughlin's then rmc court appointed defender who is the "staff attoreny" for Nevada Court Services,
whom Coughlin as suing at the time...so, no on the conflicts check by Taitel...
Now Judge Clifton and Judge Sferrazza and RJC Administrator STeve Tuttle (with the help of clerk's Robbin Baker and Cathy Wood) have
forbidden Coughlin from fax filing, only allow him 15 minutes a day to be at the counter to review a file (no matter how much of that 15
minutes is eaten up with "delays"...), etc., etc. lots of special unpublished "house rules" applicable only to Coughlin...kind of like the
impermissible rent escrow deposit judge sferrazza order in 10/13/11 in rev2011-001708 in violation of jcrcp 83 in that the rjc has not
published and had approved by the n. s. ct. a corollary to jcrlv 44...though Judge Clifton managed to find "moot" Coughlin's Motion to Set
aside that forced rent escrow deposit in light of the fact that Coughlin did deposit that $2,276 dollars....not exactly moot...kind of like Judge
Clifton saying "your here!" when Coughlin contested the improper notice by public defender leslie of the 12/18/12 hearing in rcr2012-
067980 that Judge Clifton curiously presided over despite it being a Judge PEarson case and Judge PEarson being at work that day...the
whole jcrrt rule about cases being randomly assigned doesn't seem all that hard and fast...like when Jduge Clifton was assigned the
Coughlin v. Park Terrace illegal lockout case, but rjc bailiff sexton came in and moved Jduge SFerrazza onto the matter minutes before the
hearing, whereupon Judge Clifton had "traffic matters" to rule on....
then there is the rmc and judge nash holmes refusing to file in and comply with the dictates of nrs 189.030 in 11 tr 26800 where coughlin
appealed the contempt order of 2/27/12 and 2/28/12....and the whole business of the rmc and its marshall being given coughlin's smart
phone and micro sd card after it was book into coughlin's personal property at the jail on 2/27/12, when the rmc marshals came to the jail
on 2/28/12...and apparently..without a court order or warrant, were allowed to take possession of those items and take them back to the
rmc....and they were returned to coughlin 37 days later, via a 3/30/12 order by judge nash holmes releasing them to coughlin (curious
considering coughlin's 3/30/12 filign in Judge Beelsey's case in the nvb cadle company v keller 10--05104 exposed that whole confiscating
coughlin's property in a manner in no way a search incident to arrest....) and where Judge Beelsey, Judge Nash Holmes, and Washoe Legal
SErvices Elcano all went to McGeorge School of law in 1977....and all three testified at coughlin's 11/14/12 formal disciplinary hearing before
the panel and sbn....hhmmmmmn....
and the recent cr12-1262 appeal of the denial of coughlin's motion for new trial did not include the cd/dvds coughlin attached to his
10/24/12 filign and his 11/2/12 filing (and the 11/2/12 filign was not included in what the rmc transmitted to the district court on 11/29/12?
funny..... lots of attached cd/dvds turnin' up missin' or "weren't never there" despite Robbin Baker admitting they were in the rjc in
rcr2011-063341 and rcr2012-065630 in the jduge sferrazza and judge clifton cases...and in Clifton's 065630 City Attorney Bony's letter about
the subpoenas in 2011-063341 and the envelope addresssed to judge sferrazza is in the file in Clifton's 065630 case? and Judge Clifton
admits that, on the record in 065630 he "looked at the submission on subpoenas" in the judge sferrazza cases...funny, Judge SFerrazza said
there was no cd/dvd's attached to any of Coughlin's pre-trial filings.....and judge sferazza signed the 11/16/12 orders on those "submissions
on subpoenas"...so why would Judge clifton be lookin at them and why are cd/dvd's disappearing?
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
RMC certifying Second Judicial filings to SBN exhibit 16 from 11/14/12
000013
was never provided to coughlin
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 12/19/12 2:22 AM
To: patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com); davidc@nvbar.org
(davidc@nvbar.org); eifert.nta@att.net (eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com);
mike@tahoelawyer.com (mike@tahoelawyer.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
skent@skentlaw.com (skent@skentlaw.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
ncjdinfo@judicial.state.nv.us (ncjdinfo@judicial.state.nv.us); dballard@reno.gov (dballard@reno.gov);
ballardd@reno.gov (ballardd@reno.gov); jacksonc@reno.gov (jacksonc@reno.gov);
renodirect@reno.gov (renodirect@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov);
joey.hastings@washoecourts.us (joey.hastings@washoecourts.us); judge.hardy@washoecourts.us
(judge.hardy@washoecourts.us); rsweet@nvcourts.nv.gov (rsweet@nvcourts.nv.gov);
training@nvcourts.nv.gov (training@nvcourts.nv.gov); staffattorney@nvcourts.nv.gov
(staffattorney@nvcourts.nv.gov)
Dear Administrative Office of the Courts,
I apologize for the rushed nature of this, however, the SBN, RMC and RJC have been
putting me through the paces of late and I never know when they will finish the job on
me, so I want to send this while I can...
and Chair Echeverria and or SBN Bar Counsel King have a duty of candor and can't
sneak it into the file as an "exhibit 16" where Coughlin was not provided a copy at the
hearing on 11/14/12, especially where the 4 exhibits that were included with that filing
(exhibit 16 EMERGENCY EX I'ARTE MOTION TO DISMISS. VACATE. reset or
postpone, etc...)
check out the exhibit page on page 32 of the attachment....notice how none of the
exhibits were included in what was given to the clerk and court reporter purporting to
be a "rule of completeness" sufficient copy of that filing presented as Exhibit 16?
You guys lied enough already (you gave me permission to file by fax, then didn't file
in my faxed filings...you waived subpoena and subpoena duces tecum fees, then lied
and said you didn't sufficient to prevent me from being able to call witness (and you
know that attached keith loomis, esq. subpoena was problematic for you...no wonder
Pat King disposed of the grievance against Loomis so quick...and then you lied when
you said you didn't give me permission to issue my own subpoenas (ie, you said I
would not be required to have them "issued by the court" or embossed or baring a seal
or any of that, but that I could issue my own subpoenas "in the manner an attorney
could" despite my current temporary suspension. You guys are lying
overtime....how many of the Panel are in on it? Vellis? How about you? Its a
000014
nice reputation you have Vellis...would be a shame to see it get all associated with this
despicable miscarriage of justice. Not sure Mike Johnson wants the Supreme Court
knowing he was texting on his iPhone the whole hearing, or twittering or whatever,
because he definately wasn't paying attention or looking professional. And as for
hiding my cd/dvd's attached as exhibits to filings from the Justices of the Nevada
Supreme Court, Panel Member Stephen Kent (McGeorge Class of 1980, interesting
that "Chairman Susich" chose the Panel...sure...Pat....Elcano, Beesley (both of whose
testimony was not noticed until a couple days before the hearing despite nothing about
it being newly discovered to bar counsel...and why hasn't the Beesley letter ever been
produced to Coughlin? And Elcano is not a "practicing attorney"...check his SCR 79
page on www.nvbar.org....inactive status, has been for quite some time...that's why
"wouldn't he be awfully rusty" comments were made when his name was floated for
the ECR deal...
Also, look at the certification by Donna Ballard. She is not authorized to make
certifications for documents from the Second Judicial District Court. Look closely at
the language on her certifcations. Her court does not maintain the "originals" in
cv11-03628, nor in cr11-2064, nor in cr12-1262. That is fraud by both she and Bar
Counsel King for purporting those documents to be certified. Further, its fraudulent
for King to (or have Richard G. Hill, Esq. do it) read a quote from a passage of Richard
G. Hill, Esq.'s associate, Casey Baker, Esq.'s Motion for Attorney's fees and purport it
to be something ordered by Judge Flanagan. Just because Judge Flanagan quotes to
something in one of his Order's does not mean he endorses is as a conclusion of law or
finding of fact or even a part of his Order. He has quoted to things I wrote before.
He commented on something I wrote being "poignant" in dismissing on 3/27/12
Hill's Second Motion for Order To Show Cause once Coughlin destroyed Hill's witness,
contractor Phil Stewart on cross examination at both the 3/23/12 hearing (closely
following by bar counsel ill advised and cryptic email about "the clerk of court in
Department 3" writing the SBN about Coughlin's clothing choice or some high school
gibberish or other. I demand the RMC and Ballard immediately retract those
"certifications".
Please consider this as my resume for the staff attorney position with the
Administrative Office of the Courts and review my filings with the Nevada Supreme
Court.
Not sure its appropriate or Panel Chair Echeverria to be sticking his tongue out at me
000015
throughout the hearing and grinning demonically like some "Boss Hog"...Also, kind of
funny to apply the Court's scr 111(7) citation in its 6/7/12 Order about the "sole purpose
of determining the punishment' to the hearing...but not just to the walmart candy bar
petty larceny conviction, but instead, to a multitude of RPC violations the SBN and or
RMC Judge Nash Holmes copied and pasted into an Order. Chair Echeverria
admitted during the "hearing" on 11/14/12 that he and the Panel and SBN were just
skippin' past the whole being accused of something and having a trial on it and going
straight to the sentencing phase...despite none of the RPC violations being "proven"
(and Judge Nash Holmes, testifying by telephone over Coughlin's objection, was sure
to point out she "wasn't trying to usurp the function of a formal hearing panel" in her
3/12/12 Order, upon which Bar Counsel is trying awful hard to tack on an SCR 111(5)
"conviction is conclusive proof of guilt" easy day at work....but SCR 111 is for
"criminal convictions", Pat King...next time you feed Judges proposed findings and
criminal law violation orders, get the statue right, Pat. That Order from a "simple
traffic citation matter", from which Judge Nash Holmes threw in the Schaefer "clear
and convicing evidence" standard bar counsel prompted her to insert, in her attempt to
transmogrify the 3/12/12 resumption of the traffic citation trial in rmc 11 tr 26800 into
not only a second bit at the apple considering she already issued an order on 2/28/12
(which was attached to the filing in Judge Beesley's NVB court in the adversary
proceeding 10-05104 Cadle Company v Keller...which had to alarm Judge Beesley to
see his 1977 classmate at McGeorge, Judge Nash Holmes and Washoe Legal Services
Paul Elcano having such trouble with Coughlin (not to mention Judge Beesley's former
partner at Beesley Peck, Karen Sabo, Esq. was being sued by Coughlin incident to her
actions at WLS set forth in the wrongful termination lawsuit on appeal with the Court
in 60302...maybe if Bar Counsel had managed to notice Coughlin on Judge Beesley's
testimony more than 2 day prior to the hearing, and not in violation of SCR 105(2)(c),
some of this mess could have been avoided...But another thing is clear...there was no
"misdemeanor of criminal contempt convictions of Coughlin...ever....that would require
a citation to NRS 199.340...which is not summary in nature anyways....NRS 22.030
(Judge Howard cited to the right statute at least), and NRS 22.010 (the one Judge Nash
Holmes attempted to characterize as a "misdemeanor of criminal contempt" along with
NRS 22.100, in justifying her summary 5 day incarceration of a pro se attorney in a
traffic citation trial seconds after he testified that RPD Sargent Tarter "lied when he
said that..."...and boom....contempt citation, 5 days in jail, no stay...prejudice to
Coughlin's client's be damned...and the SBN and Judge Nash Holmes are goign to try
to make hay out of an in forma pauperis application indicating Coughlin employed as a
"jack of all trades" filed after a trial in 11 tr 26800 wherein Coughlin's being an
000016
attorney was discussed extensively? And Bar Counsel wants to object to Coughlin
entering into evidence or using for impeachment both the audio transcript the RMC
sold him and the disc of the same hearing the RMC purportedly gave to Bar Counsel,
then Bar Counsel gave to the Screening Panel, then gave to Coughlin? Yet Donna
Ballard gets to certify Orders by Judge Flanagan and Judge Elliot (who worked at Chair
Echeverria's father's law firm, and who went to Stanford from Reno along with Chair
Echeverria and Washoe Legal Services's Paul Elcano in the later 1960's together....and
Echeverria and Elcano went to Reno High School together in 1962, and were forced to
admit they were "boyhood chums"....no mention of the wine business though at the
hearing or the Basque Board, or the Orlich and Gardner connection with Elcano and
Coughlin's contention that Elcano admitted to Coughlin in February 2009 that Judge
Linda Gardner had approved of Coughlin's work at that time after Elcano querried her
and Elcano citing having done Judge Gardner "a big favor a long time ago" as a basis
for establishing his strong rapport with Judge Gardner, and, apparently, her veracity or
something or other.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 2 files to share with you on SkyDrive. To view them, click the links below.
0204 Coughlin Disciplinary Hearing File cut up with notations revised.pdf.pdf
12 10 12 065630 final motion recuse conflict continuance with exhibits and cover pages.pdf
Download all

protection order against WCPD Jim Leslie, Esq.
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 12/18/12 2:08 PM
To: jleslie@washoecounty.us (jleslie@washoecounty.us); jbosler@washoecounty.us
(jbosler@washoecounty.us); patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org
(davidc@nvbar.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com);
000017
fflaherty@dlpfd.com (fflaherty@dlpfd.com); zyoung@da.washoecounty.us
(zyoung@da.washoecounty.us); mkandaras@da.washoecounty.us (mkandaras@da.washoecounty.us);
stuttle@washoecounty.us (stuttle@washoecounty.us); ncjdinfo@judicial.state.nv.us
(ncjdinfo@judicial.state.nv.us); mike@tahoelawyer.com (mike@tahoelawyer.com); skent@skentlaw.com
(skent@skentlaw.com); joey.hastings@washoecourts.us (joey.hastings@washoecourts.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
12 18 12 rjc tpo application against wcpd jim leslie.pdf

Jim Leslie is a scrappy dude RE: Coughlin
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 12/14/12 1:24 AM
To: Leslie, Jim (jleslie@washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); davidc@nvbar.org (davidc@nvbar.org); mpickesq@msn.com
(mpickesq@msn.com)
Dear Jim Leslie, Esq.,
Jim, I need to get my discovery for the resumption of the trial in rjc rcr2012-
065630...Despite your cries of "wasting county assets" at 9:05am on 11/20/12 when, in
your standby counsel role, you attempted to assist DDA Young and Judge Sferrazza in
further coercing from me my Fifth Amendment rights...you seem intent on wasting
county assets, as your failure to turn over the discovery (the cd recordings of 911 calls
DDA Young alleges he produced to my WCPD on 8/13/12 and 8/17/12 has not
materially prejudiced my defense in rcr2012-065630, in much the same way your
failure to timely transmit my file in rcr2011-063341 did, including your failure to
produce the results and response and production in connection with the subpoena of
10/3/12, and given you were note removed as counsel of record until at the earliest
10/22/12...Kelley Dodma, ECOMM, and you have some 'splainin' to do.
000018
Now you allege that you filed a false police report. Jim, please keep a copy of any
communications you have made to the RPD, and of course the call you reference will
be subpoenaed, and if there exists any recordings (video/audio, whatever) of the
"incidents" you describe (not sure dropping of a written request for one's file/discovery
to your receptionist given the fact that time is of the essence here is "distrubing the
peace", but, to each his one, I guess...however, its curious you never seem to place any
restrictions on your continuing to cash your sweet paychecks week after week,
Jim...now you seem to be seeking some sort of protection against being served written
notices or having them delivered, or making my ability to do some contingent upon
your scheduling a meeting (any such meeting would likely terminate after five minutes,
as they have in the past, with you pulling your Diana Ross-diva act....DDA Young got a
good knowing laugh out of that one on 12/11/12.....). Jim, please do me a favor and
reply to this email, copying the SBN and President of the State Bar and describe just
exactly what occurred during these recent "past several occasions"...and put it in an
affidavit...also, will you finally put in an affidavit your contentions that you "know"
your office sent me notice in writing of the 8/6/12 combo-hearing date in 065630 and
067980 (please also put in writing your refusal to send out subpoenas (easy under nrs
174.345) to ECOMM for any calls to 911 or dispatch related to me in any way since
8/20/12) and any dispatch to law enforcements recordings, and recordings made by law
enforcement or submitted to law enforcement by private parties, since that date as well.
Please further indicate in writing why you are refusing to send the WCSO a subpoena
duces tecum for any materials related to me in any way from their civil division (that
served process of the items detailed in the variosu affidavits of services by Machen et al
that have become of issue in 11 tr 26800, 067980, etc., etc., subpoena Northwinds
Lou Cadia and Duane Jakob...)....See, Jim, you are still getting paid, you need to do
some work here, guy...
So cute how Biray Dogan, in the 8/21/12 Hearing in 065630 mentioned how he "left a
voice mail" for Linda Gray, but just couldn't, gosh darn it, get an answer from her about
whether she did send out written notice of the 8/6/12 combo hearing...(you know, the
one you testified about during our closed Mardsen-lite conflict hearing in
063341...where you alleged you "knew" for sure that notice was sent, but then refused
to provide any specifics as to how you 'knew" or what you did to make sure of that..."
Gray admitted to Coughlin on the phone that she did not mail out any written notice
of the 8/6/12 hearing to Coughlin because your office had marked his "PO BOX 3961"
address as "no longer good" at that time (and the audio of the 7/16/12 aborted Trial date
000019
clearlye establishes Coughlin was not provided the 8/6/12 date at that time, because the
temporary replacement for the suddenly disappeared WCPD Goodnight, and DDA
Young were directed to meet in the hall/counter after the conclusion of the proceeding
on 7/16/12 and pick a date and time, by which time Coughlin was taken back into
custody (where he was serving 18 days in jail due to the fraudulent bail increase in rmc
12 cr1240 (another bogus "disturbing the peace charge" by the RPD...that even the City
of Reno prosecutors had to drop (and we all know how adverse they are to dropping
any charges, ever). Jim, why don't you just go wash the RPD's cars or something if
you want to suck up to them so bad?
Please then explain to those listed above why your cross examination of Cory Goble on
8/29/12 in 063341 seemed to consist solely of an attempt on your part to defeat the NRS
171.136 problem the State faced, including the exclusionary rule application, where the
testimony as to the value of the phone by the "victim" Goble was "about $80"
valuation...well under the $250 needed at the time to support a "oooh, thats a felony"
grand larceny charge (to quote Officer Duralde), and therein vitiate the legitimacy of
any such arrest or search incident thereto (unless a citizen's arrest could be
established....which is what you spent your entire cross of Goble trying to establish, for
the State's benefit...because you are a sleazy, spiteful, lazy, mean spirited, petty, hateful
individual whom the DA wants on the case anytime it really, really needs a win. Just
because you have ascended to Chief Deputy status doesn't mean you are any good at
what you do, Jim, nor does it, in my opinion, provide some sheen of integrity to your
act).
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or
arrest the person for another alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense
is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and the arrest is made in the
manner provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued
pursuant to NRS 33.017 to 33.100, inclusive;
000020
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
Subject: Coughlin
Date: Thu, 13 Dec 2012 00:22:01 +0000
Mr. Coughlin:

Based on your behavior at our offices on several past occasions, including today where we had to call the police due to
you engaging in behavior constituting disturbing the peace, you are hereby directed NOT to come to our offices without
first having confirmed in writing an appointment with your assigned attorney.

If you violate this email notification, we will contact law enforcement.


James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defenders Office
350 South Center Street
Fifth Floor
Reno, NV 89509
000021
1-800-762-8031
Direct Dial: 775-337-4828
Fax: 775-337-4856
Email: jleslie@washoecounty.us

The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL INFORMATION, are legally privileged, and are intended for
use and review only by the party sending same and the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying,
distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly prohibited. If you received this communication in error, please immediately
notify us at 775-337-4800 to arrange return of the original transmittal. Thank you.


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To.) copIaInb@mbm.org (copIainb@) vbar.org, pauicH) vbm.org (pauIcH@nvbar.org ,davidc@)vbm.org)
(davidc@bm.org,|c@clorcno.comgc@clorcno.com,)mm@)kaw.com()mm@)kaw.com,)
cvclli)@bh.com(cvcIII)@bh.com,m@tahocIawycr.com(mm@mcIawycr.com,cikrt.m@a0nct)
(cim.nn@att)ct ,)cvtcIa) @)bcobaI.) ct(vtcla) @)bcobal.)ct ,ro)cc@mbm.org (ro)ccvbm.org ,)
lawap@nvbar.org (Iawap@ber.org, phIIp@bm.org (phIIp@ber.org,c bar.org)
(mbm.org,mamrq@dlpfd.com(ahcqpfd.com,mMdycrlawrc)cc.com)
(mUcrq@dycrIawrcc.com,t)u)Ich@mdcu.org (bIcbvdcu.org, cbmby@dcu.org)
()cbomby@mdcu.org)
Dear Offce of ar CounseI, NND, PaneI, and Presdent FIaherty,
PIease forward this emal on to !ohn Echeverra, Patrck Kin and Davd Clark and the NND Charman 5usich, 5N
Presdent Plaheny, and NND Charman 5usich n case they don't et the transmisson sent here.
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000039
ore oI the Iormal grievance against Skau, Young, Leslie, and Dogan RE: Iormal written grievance
against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing Irom what was produced by City
Attorney Skau
From: Zach Coughlin (zachcoughlinhotmail.com)
Sent: Tue 12/04/12 3:08 PM
To: complaintsnvbar.org (complaintsnvbar.org); patrickknvbar.org (patrickknvbar.org);
davidcnvbar.org (davidcnvbar.org); jeeloreno.com (jeeloreno.com); skentskentlaw.com
(skentskentlaw.com); cvellisbhIs.com (cvellisbhIs.com); miketahoelawyer.com
(miketahoelawyer.com); eiIert.ntaatt.net (eiIert.ntaatt.net); nevtelassnsbcglobal.net
(nevtelassnsbcglobal.net); rosecnvbar.org (rosecnvbar.org); laurapnvbar.org
(laurapnvbar.org); philpnvbar.org (philpnvbar.org); glennmnvbar.org (glennmnvbar.org);
IIlahertydlpId.com (IIlahertydlpId.com); IIlahertydyerlawrence.com
(IIlahertydyerlawrence.com); tsusichnvdetr.org (tsusichnvdetr.org); schornsbynvdetr.org
(schornsbynvdetr.org)
Dear OIIice oI Bar Counsel, NNDB, Panel, and President Flaherty,
Please Iorward this email on to John Echeverria, Patrick King and David Clark and the NNDB
Chairman Susich, SBN President Flaherty, and NNDB Chairman Susich in case they don't get the
transmission sent here.
The video and audio and other materials supporting this greivance are available here:
http://sdrv.ms/YwYabQ
Please add City Attorney John Kadlic to the grievance as at some point he needs to take responsibility
Ior all the dirty deeds done not so cheap by his cadre oI malevolent, corrupt, deputy city attorneys.
Clerk oI Court Peters has been reIusing to allow me to have a Iile stamp copy oI my Iilings, save an
introductory Iew instances...please Order her to do so.
While I was never sent the 10/9/12 AIIidavit oI Laura Peters that the SBN and Peters slipped into the
Formal Disciplinary File, incongruously, inserted, bate stamped, aIter the 10/30/12 Order by Chairman
Susich (strange...how could it be Iile stamped October 10th, 2012, yet be Iiled aIter Chairman Susich's
10/30/12 Order? Eventually that AIIidavit was provided to me on 11/8/12 (6 days beIore the Iormal
disciplinary hearing, buried within 3,000 or more pages oI documents (so instead oI the 27 days to
review them called Ior by SCR 105(2)(c), I was aIIored only, roughly 3 (depending on how you count
the "within 3 days prior" in consdiering SCR 105(4) and NRCP 6(a),(e)...
It is deIinately not my understanding that any Cease and Desist Order by Chair Echeverria or "stay
away" letter by Patrick King means I can no longer Iile documents in this matter, or that any Iailure by
Clerk oI Court Peters to provide me a Iile stamped copy oI my Iilings means they are not Iiled or that
the SBN is Iailing to abide by its express declaration and agreements and pronouncements oI the
procedural policies and rules applicable to this matter wherein King, Peters, the SBN/Panel/Board have
Iailed to provide me any written adopted procedural rules, have made numerous declarations and
1/60
000040
express indications oI speciIic policies and rules attendant to my utilizing subpoenas (which King
Iraudulently mislead the Panel as to in his Motions to Quash and in his argument during the 11/14/12
Hearing...noticeably absent is an AIIidavit Irom King regarding what he communicated to Coughlin
respecting David Clark's ruling on Coughlin's use oI subpoenas and the procedural mechanics attendant
thereto, or, even more noticeable, is an mention by Laura Peters in her 10/9/12 AIIidavit respecting the
permission to Iax Iile granted to Coughlin in this matter.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlinhotmail.com
Zach has a Iile to share with you on SkyDrive. To view it, click the link below.
110812coughlin 063341 Reno City Attorney Skaur at 25 minute mark violates duty oI candor to
tribunal and Iairness to opposing counsel considering 11 9 12 email by Skau.wmv
From: zachcoughlinhotmail.com
To: homerjreno.gov; skaucreno.gov; zyoungda.washoecounty.us; complaintsnvbar.org;
patrickknvbar.org; davidcnvbar.org; jeeloreno.com; skentskentlaw.com; cvellisbhIs.com;
miketahoelawyer.com; eiIert.ntaatt.net; nevtelassnsbcglobal.net; rosecnvbar.org;
laurapnvbar.org; philpnvbar.org; glennmnvbar.org; IIlahertydlpId.com;
IIlahertydyerlawrence.com; tsusichnvdetr.org; schornsbynvdetr.org; bdoganwashoecounty.us;
jlesliewashoecounty.us
Subject: Iormal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing Irom
what was produced by City Attorney Skau
Date: Tue, 4 Dec 2012 14:07:52 -0800
Dear OIIice oI Bar Counsel,
This is a Iormal grievance against City Attorney Skau, Public DeIender Jim Leslie and Biray Dogan,
and DDA Zach Young.
A portion oI a recent email Irom City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341
From: Creighton C. Skau (skaucreno.gov)
Sent: Fri 11/09/12 11:45 AM
To: zachcoughlinhotmail.com
Cc: Jeannie Homer (HomerJreno.gov)
1 attachment
photo|1|.JPG (181.2 KB)
Dear Mr. Coughlin,
2/60
000041
Please be advised that Judge SIeraza authorized service upon you by email in an Order.
Accordingly, authorized service has already been eIIected.
Since you claim you cannot open the pdI attachments to my secretary's last email, I oIIer
alternatives:
1. Set Iorth below is the language oI Judge SIeraza's Order and the language oI the City's Motion.
UnIortunately, I cannot replicate the attachments. However, they consisted mostly oI documents you
purportedly served, so you should be Iamiliar with them. Also, I am providing alternative means Ior
you to obtain the documents, as set Iorth hereaIter.
2. The Court provided us with an address which you provided to the Court. That address is 1471
E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday,
but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
you there at around 11:00 a.m. They called my oIIice and were directed to leave the Judges Order and
the City's motion at the Iront oI that address. They have provided me with a photograph oI the packet
leIt at the Iront door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our OIIice at 334-2050 and request a copy Irom Ms. Homer, which you may
pick up at our OIIice, third Iloor oI City Hall.
Please be advised that Judge SIeraza authorized service upon you by email in an Order.
Accordingly, authorized service has already been eIIected.
Since you claim you cannot open the pdI attachments to my secretary's last email, I oIIer
alternatives:
1. Set Iorth below is the language oI Judge SIeraza's Order and the language oI the City's Motion.
UnIortunately, I cannot replicate the attachments. However, they consisted mostly oI documents you
purportedly served, so you should be Iamiliar with them. Also, I am providing alternative means Ior
you to obtain the documents, as set Iorth hereaIter.
2. The Court provided us with an address which you provided to the Court. That address is 1471
E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday,
but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
you there at around 11:00 a.m. They called my oIIice and were directed to leave the Judges Order and
the City's motion at the Iront oI that address. They have provided me with a photograph oI the packet
leIt at the Iront door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our OIIice at 334-2050 and request a copy Irom Ms. Homer, which you may
pick up at our OIIice, third Iloor oI City Hall...."
But, a listen to around the 9:25 am mark on the audio transcript Iorm the RJC Javs recording oI the
11/8/12 hearing in rcr2011-063341 reveals Mr. Skau Iraudulently procurred Couglin's attendance at the
11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented Irom
eIIecting contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only
Coughlin's Iormal disciplinary hearing but also the petty larceny trial oI 11/19 and 11/20 and is a
straight scum bag move by Creig Skau.
Judge SIerrazza granted Coughlin a waiver oI witness Iees Ior subpoenas and subpoena duces tecums
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000042
at the 48 minute mark oI the second wmv Iile Irom the JAVS audio transwcript oI the 10/22/12
Hearing in RCR2012-063341.
Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a
JCRCP 45 to challenge a subpoena in a criminal misdemeanor case and he Iails to inIorm the court oI
the waiver oI service signed by an individual who indicated she had authority to do so, Gricela Alvarez
(whom, somehow, Judge SIerrazza was apparently aware oI and had opinions on....curiously).
Speaking oI scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs
recording 112012coughlin1 Ior rcr2011-063341 (really, everything Jim Leslie did in this case or any
other in "representing" Coughlin is hall oI Iame sleazy) "I can jump in as stand by counsel iI you Ieels
he is dragging his Ieet, your honor...He's wasting county assets."...Really, Jim, this is a grievance
against you Ior seeking to coerce a waiver oI Coughlin's IiIth amendment rights incident to your reIusal
to utilize any oI the exculpatory media Coughlin provided you at either the Supression Hearing or the
Trial..and a greivance against DDA Young Ior similarly coercing a waiver oI Coughlin's FiIth
Amendment rights (you really need to listent to the last Iile Ior 11/19 and the Iirst Ior 11/20 to get an
idea oI the hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC
BailiIIs asked iI they could keep Coughlin's laptops over night...but there is some really bad audio on
there with Judge SIerrazza and DDA Young getting completely coercive with respect to a waiver oI
Coughlin's FiIth Amendment rights and "you can't put on anything else or any evidence, YOU NEED
TO TESTIFY!" and Young "you Honor, it was my understanding that you let mr. Coughlin out oI
custody on the condition that he testiIy! II he won't do it TAKE HIM BACK INTO CUSTODY!"
add to the grievance against young the Iraudulent testimony and argument he put on where he knows or
should have know that the rpd duralde did not receive any reports Irom dispatch oI "a possible Iight"
where Duralde had leIt his vehicle and the text screen therein prior to the 11:27:11 pm text Irom
dispatch, and thereIore, such allegations oI a report Irom dispatch oI "a possible Iight" did not bare on
Duralde's probable cause/reasonable suspicion analysis. Iurther young put on perured testimony by
Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when Young was
provide a video wherein Zarate admits he only inIerred that. Oh, and Coughlin hereby swears he never
received any such 11/7/12 motion, Iaxed or otherwise Irom Dogan or his assitant Tibbals or anyone
with the WCPD.
And then there is Jim Leslie Iailing to make a hearsay objection when DDA Young asks OIIicer
Duralde what some unnamed bystanders told him upon arriving...yet, every bit oI video evidence and
or testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to
hearing "the man with the six pack" threaten to throw the iPhone "in the river iI someone doesn't claim
it right now" was continually excluded as "hearsay"....
A recent email to Judge SIerrazza and DDA Young (which Judge SIerrazza ordered Coughlin to send
him):
Dear Judge SIerrazza and DDA Young,
This correspondence is Iurther in line with Judge SIerrazza's previous instruction to me to send him
emails aIter the trial directed to my issues with Mr. Leslie's representation (I am too tired to Iully set
4/60
000043
those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
this just because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
receiving, | 484 P.2d 565 | but not oI both
Perhaps one oI my biggest complaints about the ineIIective assistance oI counsel by Mr. Leslie (and to
a much, much lesser extent that oI Mr. Goodnight) relates to Leslie's Iailure to utilize any oI the work I
did to prep this case. For instance, Leslie whiIIed (perhaps intentionally so) on the extent to which
RPD OIIicer Duralde and Rosa could not have received the dispatch text oI 11:27:11 pm reporting
Goble's since proven Iraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so,
OIIicer Duralde and DDA Young are stuck with anything the OIIicer could "hear" on the Dispatch
recordings (and those provided by City Attorney Skau provide a basis Ior mistrial where the cd lacks
Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid oI anything Ior the 6
minutes in which the detaining and arrest occurs (and Iurther, DDA Young and the State were served a
request Ior discovery by Goodnight in November and subpoena which required production oI those
"dispatch logs or recordings...." Yet DDA Iailed to. Then he put on testimon and made argument that
this "report Irom dispatch oI a possible Iight" was the main justiIication Ior the pat down and search
incident to arrest and led to a justiIication Ior not excluding anything "discerned incident to the pat
down"...the only problem is is that Duralde and Rosa already are marked as on the scene by 11:26:00
pm, and thereIore could not have read the text screens in their vehicles to recieved the text only
11:27:11 pm dispatch entry about "someone just socked a minor". Further, the extent to which
Coughlin's 911 call is not reported accurately at all Iurther underscores the unIairness oI depriving
Coughlin the right to cross examine Duralde and the dispatchers.
A review oI the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to
Judge SIerrazza ordering him to produce in response to my subpoena duces tecum to Kelley Odom and
ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct. Two oI the 911
calls are missing. There is no audio oI any RPD-ECOMM/Dispatch communications between the
11:28:17 pm mark and the 11:36:27 pm mark...which is disturbing, considering the RPD and Ecomm
did not know I was Iilming/recording the arrest. Had I not captured a recording oI the arrest, how little
would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many
things revealed by the arrest recording contradict what OIIicer Duralde put in his Supplemental
Declaration and Narrative and the two witness statements? Further, where Zarate does not allege to
have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on
8/29/12 does testiIy to seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw
it light up Irom all the way across the skate park...but wait...come November 19th, 2012 he changes his
story and decides he saw it light up Irom "2 to 3 Ieet away Irom Coughlin"....There a movie Iloating
around somewhere out there that does a timeline oI all these calls, all these videos, superimposes the
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000044
dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc.
And one problem Ior DDA Young and Duralde is Iound in the State's 2/21/12 Opposition, on page 5,
wherein Young writes: "In the instant case, the pat-down search oI the DeIendant was proper under the
totality oI the circumstances. Prior to arriving, OIIicer Duralde learned that the scene involved a loud
disturbance with possible Iight, thereby immediately raising the concern oI weapons and the saIety oI
all those present." And, oI course, OIIicer Duralde responded splendidly to Coach Young's, er, DDA
Young's training regime and sang the "possible Iight...report Irom dispatch oI a possible Iight" tune all
the live long day...which was the basis Ior the reasonable suspicion Ior the pat-down (and Judge
SIerrazza did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less
obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in the
Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson
admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on
video and audio recordings into the record...despite Duralde testiIying to a multitude oI double hearsay
(and not even capture on a recording so close in time to the arrest and at the very same location,
involving the majority oI the players in the arrest itselI...).
It was in the same 11/30/11 email Irom WCPD Goodnight to Coughlin that included the Narrative by
OIIicer Duralde (which has, in the Iooter oI the 4 page document, a Iooter indicating a "printed on"
date oI 11/28/11
Zarate's testimony respecting the scant statements he actually made to OIIicer Duralde reveal the extent
to which OIIicer Duralde paints on to witness statement more speciIic, particularized Iacts in support oI
the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" oI "busting" and
attorney whom dared to answer one oI the oIIicer's questions by asking a question seeking clariIication
as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a Iinding oI
either "reasonable suspicion" to conduct a "weapons check pat down" (the OIIicer's did not receive the
text Irom dispatch reporting Goble's second 911 call wherein he Iraudulently alleged that "someone just
socked a minor" (reIerring to the instance where then 18 year old Austin Lichty (who is captured on the
video oI the moments(Iile named: VID20110820232423 austin lichty templeton goble zarate chan
rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds in length) lying in
asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition
to Goodnights 2/14/12 Motion to Suppress, both Goble, Lichty, and Zarate all have motivations
apparent which preclude them Irom being deemed "reliable citizen witnesses" and OIIicer Duralde
indeed did have, and admitted to in his testimony at trial to being aware oI, the "gross inconsistencies"
Goodnight pointed out between the hearsay and double hearsay Duralde testiIied to at trial aIter
"reIreshing his recollection" upon a review oI either his "Supplemental Declaration" (an attachment to
the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the
question....how was it not misconduct by the State and prejudicial to the point oI declaring a mistrial or
at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem Ior the RPD and the State...the screen lock that Goble and Templeton
testiIied to (the password Ior the phone)...and when Goble alleges Duralde gave him back the
phone...and the call into the iPhone at 11:33 pm Irom OIIicer Duralde's phone...and the call Irom the
iPhone b
Perhaps the worst thing Ior the State and the RPD here is that two hostile witnesses (in addition to
Coughlin's various statements related thereto, during his testimony and on the media admitted into
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evidence) testiIied that RPD OIIicer Duralde committed misconduct by lying about the purported order
or point in time in relation to the arrest and search oI Coughlin and Duralde's Iirst coming into
possession oI the iPhone. Goble testiIied that Duralde removed the phone Irom Coughlin's pocket and
that Duralde had the phone with him when he Iirst presented to Goble to ask question related to the
phone and to veriIy ownership oI the phone (which would include gathering the phone number Ior the
iPhone, which necessarily would mean that Duralde's allegation oI only searching Coughlin aIter
perIorming some call to the iPhone and hearsaying it vibrate (even though multiple witness
(Templeton, Zarate, Goble, Lichty testiIied that they heard no such buzzing or vibrating oI the phone,
hostile witnesses all) Goble testiIied that Duralde already had the iPhone prior to Goble conIerring
with Duralde or otherwise giving Duralde any phone number to call in an attempt to veriIy the phone
revealing an incoming call LED display scree light up alert (Goble's statements that the phone would
"light up" and that he, as Duralde quotes him in the Narrative, "could not hear the phone
I have 30 days Irom the date oI conviction to report a conviction to the State Bar oI Nevada and the
United States Patent and Trademark OIIice (USPTO) Ior these two convictions "possessing or
receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
I note that WCPD Jim Leslie, while still attorney oI record Ior me on this cases RCR2011-063341, had
served (see attached) a subpoena on ECOMM and Kelley Odom on 10/03/12. Given that Mr. Leslie
was not relieved as my counsel until at the earliest 10/22/12 (so Judge SIerrazza's contention that
Coughlin "has had Iorever to get his deIense ready in this case" and that "no continuance will be
granted on account oI the Iormal disciplinary hearing beIore the State Bar oI Nevada" being scheduled
just 5 days prior to the 11/19/12 resumption oI trial in rcr2011-063341 (and despite Judge SIerrazza
indicated some canon preventing him Irom testiIying at the Iormal disciplinary proceeding...that didn't
stop 063341 being speciIically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin,
as was Judge CliIton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
Townsend Irom sending into the SBN Coughlin's 2/12/12 Iiling in that Judge CliIton case rcr2012-
065630 and oIIering to send into the SBN Coughlin's 2/15/12 Iiling in 063341). Add to that the Iact
that Coughlin never received Irom Leslie Goble's call records until Leslie Iinally released them o
October 30th, 2012...and it really is not accurate to say Coughlin had "Iorever" to prepare his case.
Coughlin had to pull together a deIense in his Iormal disciplinary hearing beIore the SBN despite the
SBN gipping him out oI every aspect oI SCR 105(2)(c) (ie, not 30 days notice oI the hearing on
11/14/12 aIter service oI the Complaint and Designation oI Witnesses and Summary oI Evidence is
aIIected pursuant to SCR 109 and SCR 105(4)...But the point is, iI the RJC and both oI you want to be
associate with a SchaeIIer style Mirch-ing, then this may be your chance. But you won't be able to say
you didn't have plenty oI opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena
duces tecum....Mr. Leslie's Iailure to turn over anything to me in the "hand oII transmittal" he insisted
upon (despite a digital transmission being required per the Order oI Judge SIerrazza, I believe) requires
some explanation.
So to requiring explanation is the Iact that the cd provided by Reno City Attorney Skau in an apparent
good Iaith attempt to comply with Judge SIerrazza ordering him to comply with the subpoena duces
tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events surround it oI
8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin
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Lichty's cellular phone, 775 233 8593, which Goble is seen in the attached still Irame picture culled
Irom a video Coughlin took oI the moments prior to the arrival oI the RPD, being handed by the "man
with the gauged ears" Lichty reIerred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton
testiIying that they do not know that man and did not know him prior to that night at all....Coughlin
respectIully demanded oI the RPD OIIicers, at the time oI his arrest, that they gather the identiIy oI the
"man with the gauged ears", however, OIIicer Duralde et al reIused to (claiming Coughlin's allegations
oI their having attacked him and attempting to steal his bike and or dog, reach into his pockets, and
push him up against oncoming traIIic on the Center Street bridge were "unsubstantiated"). Oddly, in the
attached still Irame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin
Lichty that Goble utilized to make his two 911 calls that evening, the Iirst (iI the Iile name time
stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the
ECOMM text logs reveal an E911 entry oI 11:23:36 pm (its unknown whether the exact time a 911 call
comes in is designated on the "Calls Ior Service Inquiry Response" Coughlin was provided recently).
The EComm text logs reveals a second E911 entry Ior the 775 233 8593 number (belonging to Austin
Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law
license away Irom me Ior at least 5 years, iI not Iorever....and DDA Young...over some alleged "skater
sets his iPhone down on the concrete in the middle oI the ice rink plaza downtown on 8/20/11 at 11:20
pm ish in Reno, "man with a six pack oI beer" picks it up, oIIers it up, receiving no response threatens
to "throw it in the river iI someone doesn't claim it immediately" whereupon Goble's Iriend Nate Zarate
apparently (according to RPD Duralde's Narrative oI unknown origin date") told Goble he saw
Coughlin pick it up oII the ground (as Duralde recounts hearing Irom Goble in his Narrative)
contain the 911 call by Coughlin
So, in the Iile named "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11
PM SourceID 17 063341 duralde i'll be out on him" one can hear OIIicer Duralde indicating he will
"be out on him on the Center Street bridge" aIter he has leIt his squad care and is shortly to appear in
the video Coughlin Iilmed oI the arrest, title:
Then, OIIicer Rosa is proven to be on the bridge and not in his squad car reading texts Irom dispatch n
the Iollowing time stamped Iile: "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20,
2011 11-26-30 PM SourceID 12 RPD Rosa saying charles 396 on the other end"
Further, OIIicer Duralde's arrival on the scene is notated in the dispatch log at the
Its not at all clear why Goodnight only apparently received then Iorwarded to his client on November
30th, 2011 the "Original Supplemental" containing OIIicer Duralde's Narrative, that is still oI
indeterminate date oI origin (there are a number oI "date oI printing" variations...).
That I know oI, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc oI phone susps os leIt on
post lighting up in sups pock RP screaming at susp
2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone
just socked a minor, waive that cop down 10 10 with open line
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3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call Irom phone with open
line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin Iilmed three videos that night oI the arrest that are relevant, two just prior to the RPD
arriving (and actually, while Rosa and Duralde were already on the scene and out oI their vehicles aIter
teh 11:26:00 pm mark as indicated by the Ecomm recordings and dispatch logs...
1. VID20110820232413 your all on tape now goble and Iriends.3gp 8 seconds long
2. VID20110820232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery
Coughlin jusrt prior to RPD rcr.3gp 46 seconds
3. VID20110820232801 oIIicer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records Ior the iPhone reveal only Iour calls occurred in or out during the relevant
time Irame:
Goble's AT&T records:
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..."
Previous to that, DDA Young had successIully kept every single witness Irom speciIically identiIying
who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'.
But, Goble is a selI involved twit, who snaps his Iingers "Oh, that's Colton" 8 Ieet Irom Judge SIerrazza
and swaggers out oI the court room. And Leslie reIused to seek admission oI the misconduct oI a
prosecution witness....Goble, batterying Coughlin with a lit cigarette, that Coughlin capture on tape, on
June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on
6/7/12...and had his law license suspended in 60838 Iour hours later by a 3 Justice Panel (including
Justice Hardesty, whom recused himselI Irom Coughlin's wrongIul termination suit against Washoe
Legal Services...and you might not like me Ior that suit, but iI you look at the circumstances oI my
Iiring therein (I was hurrying to Iinish a non-proIit gets stuck with the building's private landlord's
property taxes appeal due on 3/10/12 Ior Paul Elcano, and had a Trial beIore Judge Linda Gardner in a
divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty oI research
beIorehand...I just had some issues printing it out and bringing it with me (my legal assistant couldn't
Iigure that out...WLS took 6 weeks to cut a check Ior subpoena Iees....the usual)...
Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence
exclusively hearsay testimony (oIten unattributed to anyone in particular) to support his win on the
"suIIicient probable cause to support a search incident to arrest" despite NRS 171.136 Iorbidding such
an arrest (where Duralde obviously overcharged the alleged crime as a "Ielony grand larceny"...even
making smug commentary about the "certain beneIits oI charging this as a Ielony" and saying "oooh,
that's a Ielony", both matters that Leslie insisted reIraining Irom getting into while he was attorney oI
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record, and Iurther, despite Coughlin complying with NRS 174.345 (even splurging on the return
receipt requested to go along with the certiIied mail Ior Duralde) Coughlin was denied the right to cross
examine the arresting oIIicer...which is too bad considering his Narrative alternately claims that Goble
told him they
DDA Young's complaint Iails to alleged someone other than Coughlin stole the property, which it must,
to support the receiving or possessing stolen property charge.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation oI NRS 205.275, a misdemeanor, in
the manner Iollowing, to wit:
That the said deIendant on or about the 20th day oI August, 2011, at Reno Township, within the County
oI Washoe, State oI Nevada, did willIully and unlawIully possess or withhold stolen goods having a
value less than Two Hundred FiIty Dollars ($250.00), to wit: an iPhone, at or near 1 North Center
Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, Ior his own gain
or to prevent the true owner Irom again possessing said property, knowing that the property was
obtained by means oI larceny or under such circumstances as should have caused a reasonable man to
know that such goods were so obtained.
POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that
the property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574.
Must allege the good were received Irom someone other than the deIendant: Gaddis, 424 U.S. 544,
Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted oI violating 18
U.S.C. 2113(a), (b), and (d) cannot also be convicted oI receiving or possessing the robbery
proceeds in violation oI 2113(c). HeIlin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State Iailed to prove beyond a reasonable doubt that the automobile had been stolen by a
person other than plaintiII in error, a...The next assignment oI error is that the State Iailed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than
plaintiII inerror. To sustain a conviction oI receiving stolen property the prooI must show (1) that the
property has, in Iact, been stolen by a person other than the one charged with receiving it; (2) that the
one charged with receiving it has actually received the property stolen or aided in concealing it; (3) that
the receiver knew the property was stolen at the time he received it and (4) that he received the
property Ior his own gain or to prevent the owner Irom possessing it. (People v. Piszczek,404 Ill. 465.)
ProoI oI these essential elements constituting the crime oI receiving stolen property may be made by
circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96
N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that iI a
criminal conviction is to be upheld,
| 21 Ill. App.3d 980 |
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394
Ill. 325, 327 (1946)), and must contain the nature and elements oI the oIIense in order that the
deIendant may Iully prepare a deIense and be aIIorded the constitutionally intended protection against
double jeopardy. (People v. GriIIin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the indictment,
drawn upon the conclusional premise that the property was stolen, Iails to allege that it was stolen by a
person other than the one charged with receiving such property and, by this omission, creates the
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presumption that the possessor stole the property himselI. Since one person cannot be both the thieI and
the receiver oI stolen property nor receive stolen property Irom himselI, the Iact that the property
received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310
Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v. Harris, 394 Ill. 325,
329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860,
863-864 (1971).) Lacking this element, the indictment Iailed to charge the oIIense oI receiving stolen
property under section 16-1(d). A conviction under an indictment which does not charge an oIIense is
void. People v. Edge,406 Ill. 490 (1950).
The judgment is, thereIore, reversed....
I Ieel that the majority has misconstrued the eIIicacy oI section 16-1(d) in arriving at a conclusion not
urged by the deIendant. The omission oI the words "stolen by another" in the indictment does not create
the presumption that deIendant had himselI stolen the property Irom the owner. The use oI the words "*
* * knowingly obtain control oI stolen property * * * under such circumstances that would reasonably
induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly
implies that when deIendant obtained control oI the property in question (in any manner whatsoever),
the property had already been stolen by another. That is the plain and ordinary meaning oI the
indictment.
I believe the majority may be conIusing what can and cannot be reasonably implied Irom evidence
introduced at trial with what may be implied Irom the clear phrasing oI the indictment. At trial it is not
| 21 Ill. App.3d 981 |enough Ior the prosecution to merely show that the property in question was
stolen property and that the deIendant was in possession oI that property in order to prove the oIIense
oI theIt under 16-1(d) (the Iormer oIIense oI receiving stolen property). (People v. Baxa (1972), 50
Ill.2d 111, 277 N.E.2d 876.) The deIendant's unexplained possession oI stolen property soon aIter a
theIt is evidence that the deIendant stole the property himselI but is not evidence oI deIendant's
receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d
860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology oI the indictment herein
permits a reader oI the indictment to Iind, even aIter only a cursory reading, the necessary elements oI
the oIIense, i.e., that the property was already stolen by another when the deIendant received it.
While it may be true that the addition oI the words "stolen by another" would make the indictment
more explicit, the addition oI these words would only be grammatically redundant and mere surplusage
legally.
The indictment, thereIore, was suIIicient to charge the deIendant with an oIIense under 16-1(d)(1).
AIter a thorough examination oI the record, I do not believe that the evidence produced at trial was
suIIicient to Iind the deIendant guilty beyond a reasonable doubt. For this reason I, too, would reverse
the deIendant's conviction."
Appellant correctly argues that the standard oI proving value, Ior conviction, is the same in "receiving"
cases as in "larceny" and "theIt" cases. He erroneously urges that the state Iailed to meet that standard
under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "|t|he true
criterion Ior the value oI property taken is the Iair market value oI the property at the time and place it
was stolen iI there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF,
CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
receiving, | 484 P.2d 565 | but not oI both. People v. Taylor, 4 Cal.App.2d 214, 40 P.2d 870 (Cal.
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1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States,
365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States, 418 F.2d 567 (5 Cir.1969);
Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court
declined to give it. This was error, and later acknowledged by the court to be such when it set aside the
receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner
oI handling the error eIIectively cured it. The error was not cured by the setting aside oI the receiving
conviction since there is no way oI knowing whether a properly instructed jury would have Iound the
deIendant guilty oI burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both
convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an
essential element oI the crime oI receiving stolen goods..17. Criminal Law. In prosecution Ior receiving
stolen goods, where instruction given by court Iollowed language oI statute with reIerence to accused's
intention to prevent the |61 Nev. 330, Page 336| owner Irom again possessing property, deIendant was
not entitled to instruction which told jury that goods must have been received with Iraudulent intent oI
depriving owner oI the immediate possession thereoI. Comp. Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court oI Nevad: "At the
conclusion oI a preliminary examination, Henny Bernier was ordered to stand trial Ior possession oI
stolen property, a violation oI NRS 205.275.1 Bernier then petitioned Ior a writ oI habeas corpus
contending the evidence adduced by the prosecution was insuIIicient to establish probable cause that
she had committed the charged oIIense. The district court considered and denied her petition and
Bernier here reasserts the same contention.
Bernier does not deny having possessed the property; rather, she argues the prooI did not show that she
knew the property was stolen and that such knowledge cannot be inIerred Irom mere possession.
We agree that mere possession is insuIIicient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted oI both robbery and receiving stolen property. This
court reversed a conviction Ior possessing stolen property on the ground that the legislature did not
intend to compound the punishment Ior larceny or robbery by permitting a conviction Ior receipt or
possession oI the stolen property against the person who took the property. Point v. State, 102 Nev.
143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that Ior a charge
oI possession oI stolen property to stand, there must be a showing oI all the elements, and
that iI even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession oI stolen property does not in itselI prove guilt oI the oIIense. Staab
v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden oI prooI oI all three elements rests
with the
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606
NYS 2d 607.
Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
Judge Nash Holmes continues to reIuse to allow Couglin to appeal the "summary criminal contempt"
Order, even though, given the incarceration was served, it is a Iinally appealable order, see Gilman 275
V. Comm 474, 657 SE 2d 474.
BiIurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474
Terrell v. Miss. Bar 635 So 2d 1377. Matt oI Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem
929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook
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88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d
1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d
515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
26405 and 03628 trespass case:
unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Iorio, 410 NYS 2d 195
Russell v Kalian, 414 A.2d 462: expired warrant Ior eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the Iollowing two timestamped recordings Iinally provided by City Attorney Skau (WCPD
Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths
prior to the arrival oI the peace to stay peaceIul in Coughlin's reIerences the then recent murder oI
Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
theIt oI a purse, and Lelise preIers to spend his time chiming in, unprompted, on the regard, arrogantly
enough, that he can assist the court iI it Ieels Coughlin is "draggin' his Ieet" incident to the inappropriat
placement by Judge SIerrazza oI Leslie as "stanby counsel" which really amounted to no more than yet
another coercive practice put in place by Judge SIerrazza to Iurther his stated goal oI avenging the
criticisms Coughlin levied upon him incident to Judge SIerrazza's incredibly questionable on-the-Ily
pandering/remixing oI his Order oI 10/13/11 (iI Coughlin, as he, in Iact did, deposit a "rent escrow" oI
$2,275, SIerrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawIul
detainer action...until rich man's opposing counsel Casey Baker, Esq. coached Judge SIerrazza on the
record that "the use oI the term "Trial" was unIortunate, Your Honor..." whereupon Judge SIerrazza .
You are to his constituency by remixing is previous order regardless oI the extent to which Coughlin
was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they
are and where only those aspects oI a summary proceeding that in year to the landlords beneIit were
adhered to where is all oI the procedural and discovery protections attendant to a plenary unlawIul
detainer trial and the ability to bring counterclaims were matters Coughlin was precluded Irom
accessing by judge SIerrazza. Just Rosin is interesting approach to landlord tenant matters continued on
with respect to the manner in which service was aIIected on November 3 in violation the courthouse
sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division Iiling oIIice no less
(and that is the same bailiII Plamondon managed to take the Iilings Coughlin submitted online
November 15 out oI the criminal division Iiling oIIice oI the Reno justice court where Robbin Baker it
Mr. Coughlin let them in her position well prior to the 5 PM closing oI that Iiling oIIice and with DVDs
attached to those Iilings Coughlin swears under penalty oI perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID
18.mp3
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
5.mp3
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In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed Irom
representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public deIender applying
good nicely peers deciding that the night was doing too much to assist Coughlin in deIending himselI
and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy
session while Coughlin was in custody on July Friday, July 13 at approximately 430 man and you good
night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial
on July 16, 2012 Monday morning at 9 AM and it was only upon Coughlin arriving and being brought
to the court in custody seeded Jeremy Bosler was suddenly Iilling in Ior Goodnight with and indication
Goodnight's December 19, 2011 Iile stamp discovery requests served upon the stay and district attorney
Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the DeIendant,
ZACHARY BARKER COUGHLIN, by and through his attorney oI record, Joseph W. Goodnight,
Deputy Public DeIender, and hereby requests the Iollowing discovery pursuant to NRS 174.235 to NRS
174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or
conIessions made by the DeIendant or any witness, or copies thereoI, within the possession, custody or
control oI the State, the existence oI which is known or by the exercise oI due diligence may become
known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings,
including those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs,
written or recorded, generated in connection with this case." It is telling the extent to which on the
record at that July 16 trial date Washoe County public deIender Jeremy Bosler indicated that Jim Leslie
would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And
that Leslie would be prepared to try the case by Friday and that the court could step matter Ior trial on
Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have
completed all the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the
case whether or not that evinced any sort oI concern Ior his client, ability to zealously advocate on his
client behalI or willingness to do so, or indication that Jim Leslie Ielt that the judges oI the Reno Justice
Court would hold him to a standard oI care at all tending to indicate that Mr. Leslie has any skin in this
game whatsoever.
Clearly there is a bases Ior mistrial here were Jim Leslie's entire contribution to the representation oI
Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing
disregard Ior the rules oI proIessional conduct an intentional maniIestation oI Leslie's desire to secure a
conviction the Washoe County District Attorney's OIIice and therein secure added boys Irom local law
enIorcement District Attorney's OIIice and perhaps the Reno justice court itselI. Further Reno
Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County
public deIenders oIIice in connection with February 27, 2012 clandestine status conIerence between
Biray Dogan and Zach Young which neither Dogan nor Young has ever reIuted whether they they have
been sworn prior thereto or not an especially where Dogan's coworker down the hall civil division
deputy Dist. Atty. Mary has been involved throughout the conIiscation without a search warrant or
court order oI any kind (or at least one ever served on Coughlin in any manner) oI Coughlin smart
phone and micro SD card incident Judy impermissible summary contempt Iinding by judge Nash
Holmes just two hours aIter the clandestine status conIerence between Dogan young on February 27,
2012 in RMC case 11 TR 26800 Ior which Dogan and Young stipulated to a continuance in 06 RGC
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065630 in light oI the scheduling conIlict between that traIIic citation trial in the Reno Muni court
which stemmed Irom Coughlin's being retaliated against vice RPD Sargent Tarter in connection with
Coughlin telling Tarter one oI the top 30 highest-paid city oI Reno employees oI and admission to
taking bribes Irom Richard Hill by RPD oIIicer Chris Carter Junior incident to Carter placing Coughlin
in handcuIIs pursuant to a custodial arrest based upon a criminal complaint Ior trespass Iind by Richard
Hill on November 13, 2011. That criminal trespass conviction has now become the subject oI a Nevada
Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent
Marcia Lopez oI the misconduct by herselI oIIicer Chris Carter, Jr. Richard G. Hill, Esq. and his
landlord client, and a summary eviction matter that judge SIerrazza presided over wherein judge
SIerrazza purportedly controlled the civil division oI the Reno justice court to the extent that Coughlin's
notice oI appeal on December 26 submitted Ior Iiling December 26, 2011 was not Iile stamped by the
civil division staII oI the Reno justice court. This impropriety is Iurther problematic where Coughlin
had served upon the Reno justice court's custodian oI records and she civil clerk Karen Stancil (whom
Richard Hill reIerences in his January 12, 2012 letter her grievance against Coughlin to the State Bar oI
Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar oI Nevada, which
ultimately became one oI the three grievances depicted numerically in the caption oI the SBN v.
Zachary Barker Coughlin SCR 105 Complaint Iiled by the State Bar stamped August 23, 2012 (in
addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial
in 11 TR 26800 held in violation oI NRS 178.405 by way oI NRS 5.071 (RJC and RMC under one
rooI, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC
judges including then Administrativ Judge William Gardner, who reIused to recuse himselI Irom the
criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's Iormer
law oIIice upon Coughlin being subject to a custodial arrest by oIIicer Chris Carter on November 13,
2011, resulting in a criminal trespass conviction oI Coughlin in 11 CR 26405 where it RPD Sargent
Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless or
her partner oIIicer Carter issued caught Coughlin a trespass warning prior to eIIectuating a custodial
arrest on that day in where Lopez also admits none oI those individuals or anyone present that day
identiIied themselves as law enIorcement prior to landlord meritless kicking down the door to a
crawlspace about 5 Ieet high underneath the Iormer home law oIIice wherein Coughlin was Iound at a
time when Coughlin still had not receive back Irom the Reno justice court the impermissible $2275 rent
escrow deposit judge SIerrazza ordered in violation oI Nevada law considering judge SIerrazza's
admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was
correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice court rule
44 that may support the secret quote house rules been Iact in the civil division oI the Reno justice court
wherein tenants were in summary eviction matters were subject to Iorced rent escrow deposit in
violation oI justice court rules civil procedure 83 and that the Reno justice court had neither published
nor had approved by the Nevada Supreme Court any sort oI corollary to justice court rule Las Vegas
rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongIul arrest connected thereto
occurred even where the Washoe County SheriII's oIIice deputy Machen Iiled a Ialse aIIidavit on
November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction
Decision and Order and the October 27th Findings oI Fact, Conclusion oI Law, and Order oI Summary
Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial oI
Coughlin Irom which Judge William Gardner reIused to recuse himselI despite the Iact that his sister
judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the
"Clerk oI Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order
sanctioning Coughlin incident to a divorce matter where and he was representing a victim oI domestic
violence on behalI oI our Washoe legal services (a rather interesting approach by Iormer prosecutor
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judge Linda Gardner in comparison to the extremely light touch demonstrated by judge SIerrazza and
judge CliIton oI the Reno justice court incident to deputy district attorney Young's repeated
malIeasance misconduct violations stays pending competency or evaluations Iailure to turn over
exculpatory materials Iailure to propound discovery Iailure to respond reasonable discovery requests
demonstration a retaliatory animus in conjunction with scattershot three, count them three prosecutions
oI Coughlin this year Ior charges which young either amended to in advance implicating Supreme
Court Rule (SCR) 111(6) (in 065630 young amended the criminal complaint Irom a misuse oI 911
charge to do a charge more deleterious to Coughlin's proIessional license as a lawyer and/or patent
agent by amending the charge nearly a year aIter the January 14, 2012 arrest in the matter to a charge
that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good Iaith eIIort
to achieve a plea-bargain and resolve what is a messy case the city oI Reno Police Department and
emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-
000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services
or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely
suspect rolling this year by judge Schroeder oI the Reno justice court against Coughlin in the extremely
quick like 40 min. Irom Iiling quick issuance oI up temporary protection order to Richard G Hill on
January 12, 2012 in connection with Hill's Iraudulent abuse oI process and Ialse statements to police
oIIicers aIIecting the arrest custodial arrest oI Coughlin on January 12, 2012 will jaywalking (Hill lied
to RPD oIIicer Hollingsworth in alleging that Coughlin had already lost his appeal oI summary eviction
matter in 1708 Barber which judge SIerrazza presided and which was then on appeal beIore judge
Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney Iee award against
Pro per appellant Coughlin in the appeal oI the summary eviction order issued by Judge SIerrazza and
1708 on March 30, 2012 incident to and motion Ior attorneys Iees Iiled by Casey D Baker oI Hill's
oIIice on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty.
young Iastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom
"randomly" was assigned to Coughlin appeal oI the petty larceny conviction oI a candy bar and some
cough drops Irom Walmart in 11 CR 22176 (the sole basis Ior Coughlin's current temporary suspension
oI his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming Irom an arrest on
September 9, 2011 that was violative oI Nevada law where tribal police oIIicers aIIected a custodial
arrest Ior a misdemeanor (much less one not alleged to have occurred in their presence) in violation oI
the express dictate against doing so Iound in NRS 171.1255 should especially where Walmarts sole
witness testiIying at the petty larceny trial, would be dentist Thomas Frontino, whom testiIied on behalI
oI the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest Ior misdemeanor petty
larceny" a candy bar and some cough drops in connection with Coughlin's selecting heard just seeing
$83 worth oI groceries allegedly consuming a candy bar and or some cough drops while doing so...
Despite the Iact that that Walmart alleges to have had absolutely no video Iootage supportive oI its
allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and
where French you admit that his supervisors had previously indicated to hand a desire to retaliate
against Coughlin in connection with Coughlin's questioning
some oI Walmarts policies and where John Ellis oI the W. 7th St., Walmart in any as yet unknown loss
prevention associate speciIically and expressly threatening abuse oI process against Coughlin on July 7,
2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and
customer service managers many oI whom have had that position Ior over a decade routinely claim do
not remember the return policy or restated in a manner that depart substantially Irom the policy which
Walmart holds out to the public on its website Walmart.com and which on that website speciIically
makes applicable to in-store purchases that return policy as stated at Walmart.com no matter what the
convenient Ior getting in misremembering oI Walmarts managers may indicate the policy actually is.
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Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 aIIected a
citizen"s arrest oI Coughlin on that date in connection with the alleged petty larceny by Coughlin oI a
candy bar and some cough drops which conveniently Ior the Reno Police Department just days aIter
Coughlin Iiled a written complaint detailing the police misconduct by Reno Police Department oIIicer
Grohl and Rossa incident to the arrest oI Coughlin the wrongIul arrest oI Coughlin on August 20, 2011
in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin
(despite the Iact that the majority viewpoint throughout American jurisprudence that one cannot be
charged with both petty larceny and receiving stolen property oI the same item particularly where the
receiving oI the item is alleged to have been Irom oneselI aIter one had larceny is the item lending an
inIerence that Joe SIerrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as
possible to aIIect the leverage over Coughlin to mitigate the liability Reno justice court may Iace in
connection with its numerous since is violating about law respecting the manner in which evictions are
carried out and or the misconduct oI local law enIorcement and prosecutors in carrying out retaliatory
arrest and prosecution oI Coughlin where the judiciary in Washoe County is oII criticizes being overly
inIluenced by the District Attorney's OIIice. That Walmart petty larceny conviction stemmed Irom a
trial beIore Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school oI law
whom Coughlin's twice Iormer Reno Municipal Court appointed public deIender Keith Loomis (not in
the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed deIender there despite
his express Iailure to rule that jail time was not a possibility in his pretrial order and where mandatory
authority exists requiring that he then appoint Coughlin court appointed counsel particularly where
Coughlin established his indigency. Judge Howard's malIeasance in connection with that conviction oI
Coughlin extends Iurther the extent that he early on in that November 30 trial on it in 2011 reviews
Coughlin Ior causing the November 14 trial setting to have been continued only to in a 3 min. add-on at
the conclusion oI the hearing which are trial which judge Howard down such a matter oI public
concern that he Five city oI Reno employees at the courthouse until nine o'clock at night to get it done
that in Iact judge Howard admitted he was wrong with respect to the cause oI the continuance oI the
14th 2012 trial that was not Coughlin Iault that all and where the Reno Municipal Court had previously
granted a continuance to the city oI Reno prosecutor's in the very criminal trespass prosecution oI
Coughlin stemming Irom Richard G Hill Esquire's criminal trespass complaint (connected to the
summary eviction matter over which judge SIerrazza presided) where the Reno Municipal Court Ireely
granted Richard G are the product the city oI Reno prosecutor's a continuance in light oI Richard G
Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week
vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge
SIerrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction
matter 1708 required by law within 10 days oI Coughlin Iiling his motion to contest personal property
lien on November 17, 2011 even where is extremely suspect that the justice court is now alleging
Coughlin reIused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as
Janice admitted when judge SIerrazza called her is oI his own witness at the December 20, 2012
hearing that was Iinally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be
able to control the justice court in his desired to prevent such a hearing been set until he returned Irom
his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to
contest personal property lien judge SIerrazza ordered Karen Stancil and Joslyn John is oI the Iiling
oIIice oI the Reno justice court to Iile in unsworn statements purporting to prove that Coughlin
somehow Iailed to allow the justice court to setting hearing on his motion to contest personal property
lien however that doesn't explain the extent to which bailiII Plamondon was able to apparently without
Coughlin's permission serve Coughlin a violation oI the courthouse century Dr. and a notice oI it
November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was
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seeking axis justice court Iiling oIIice Ior something unrelated to bailiII Plamondon's desire to aIIect
service oI some notice oI the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed deIendner, admits to having been close Iriends with in law
school and to this day Loomis himselI in 1982 graduate McGeorge school law along with wash County
Dist. Atty. Richard Gammick, both oI whom were one year ahead oI Reno justice court judge CliIton
whom recently granted 2004 graduate McGeorge school oI law deputy district attorney Zach young in
order taking away the ability to Iile by Iax Irom Coughlin a privilege that is accorded any other
criminal deIendants in the Reno justice court despite the Iact that that order was granted at the
November 27, 2012 hearing at which Coughlin's then attorney public deIender Biray Dogan was
relieved as counsel and where at that hearing Dogan himselI admitted that he had not received the
motion young alleged who Iiled on November 26, 2012 seeking such an order Irom judge CliIton
barring Coughlin's ability to Iax Iile or send young it a Iax oI any sort apparently or perhaps Tom
despite the Iact that Coughlin had merely comply with judge CliIton's request that he provide judge
CliIton something supportive oI Coughlin's contention that Biray Dogan had utterly Iailed her by the
advocacy zealous are not oI any sort whatsoever incident to his quote representation oI Coughlin" in
065630).
(again, judge SIerrazza as a Iormal tribal judge and director oI Indian legal services and Coughlin's
Iormer client Pete Eastman, recently admitted to Coughlin both oI the State Bar oI Nevada
communicated he and his wiIe Ialse assertions respecting a non-existent order against Coughlin by
Nevada Bankruptcy Court Judge Beesley (the State Bar oI Nevada listed as having a specialization in
creditors rights at www.nvbar.org) (Iormer law practice partners with an individual Irom Washoe Legal
Services whom Coughlin is suing in 60302, Karen Sabo, Esq., Iormerly oI Beesley Peck, LTD and
whom trashed Coughlin's work beIore him and in Nevada Bankruptcy Court at Coughlin's November
14, 2012 Iormal disciplinary hearing to which judge Beesley's testiIying was not noticed to Coughlin
previous to the hearing and in violation oI Supreme Court rule 109 a violation made all the worse in
light oI the Iact it bar counsel Pat King had known oI any involvement oI judge Beesley in any matters
relative to the ultimate Supreme Court rule 105 complaint against Coughlin Ior over six months at least
and so in no way can be said to just stuII I his last-minute supplementing judge Beesley and
milquetoast attempts to provide Coughlin S supplemental designation oI witness and summary oI
evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services
Executive Director Paul TESTIMONY at the hearing (both oI those gentlemen attended McGeorge
school oI law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both oI them
oIIered strong opinions disapproving oI Coughlin's competency as an attorney at the hearing despite the
Iact that neither oI them could provide anything in the way oI speciIicity with regard to what issues
they would take with any oI the work they reviewed oI Coughlin's or judge Beesley's case Iilings in
judge beIore judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court
Rule 121's conIidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin
Iormal disciplinary hearing him on behalI oI recently as oI November 8, 2012 reinstated attorney
Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 Irom his clients and
using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge
Beesley sees competency in Mr. Harris and could overlook the $755,000 Ior my client where it be $14
worth oI candy bars and cough drops Irom Coughlin and Coughlin's March 30, 2012 Iiling in Cadle Co.
v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at
2:30 pm in representing Mr. Keller that was aIIected by the Iraudulently procured order Ior summary
eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire
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Brown judge Schroeder oI the Reno justice court wherein the audio record Irom that proceeding
indicates a Reno justice court clerk imploring judge Schroeder to hurriedly move the case summary
eviction case against Coughlin through despite Judge Schroeder admittedly having had a diIIerent order
oI hearing the cases planned Ior that morning docket and despite the Iact that the Iax header on the
summary eviction order that was hurriedly moved through indicates a time stamping oI a 8:24 am Ior a
hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County SheriII's oIIice deputies
Cannizzaro entered and broke into Coughlin's rental sometime shortly aIter 1 PM that same day,
3/15/12, without announcing themselves as law enIorcement and where they entered with their guns
and/or pagers drawn in and immediately placed Coughlin in handcuIIs and told him he was detained in
contrast to the typical procedures carried out by the SheriII's oIIice incident to evictions in Washoe
County. Incident to that summary eviction (where the docket, at least, more review is necessary,
indicates that Kern and Western Nevada Management's Sue King switched up their basis Ior an eviction
all the sudden in their 3/15/12 Iiling oI a Landlord's AIIidavit that suddenly changed the basis Ior
seeking an eviction to one Ior non-payment oI rent (seemingly in response to Coughlin Pre Hearing
BrieI pointing out the diIIiculties they would Iace under Glazer in pursuing a No Cause, particularly
against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the
Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably
sublessors to Coughlin). in the third grievance against Coughlin Iorming SCR 105 complaint Ior which
a Iormal disciplinary hearing, the grievance Iiled by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School oI Law together in 1977. Perhaps,
the Iiling that Judge Beesley was reIerring to when he threw Coughlin under the bus at Coughlin's
11/14/12 Iormal disciplinary hearing (with one oI the three grievance numbers listed in the Complaint,
which the SBN and Panel will claim also IulIilled the Hearing required by 60838 Ior the Wal-Mart
candy bar conviction that resulted in the current now 5 month long suspension oI Coughlin's license to
practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin Iiled the Iollowing:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 BrieI
Docket Text: BrieI in Opposition to Notice oI DeIault and Praecipe/Intent to take DeIault with
CertiIicate oI Service Filed by ZACH COUGHLIN on behalI oI SAMANTHA L. HALL, ROBERT
KELLER (Related document(s)49 Notice oI Entry oI DeIault Iiled by PlaintiII CADLE CO.)
(Attachments: # (1) AIIidavit AIIidavit oI Counsel Coughlin Ior Keller in Support oI Opposition# (2)
Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals
and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding
excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 Iax to rmc
regarding deIiciency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF APPEAL AND
MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inIlammatory 3/30/12 Iiling (which curiously seemed to immediately
result in Judge Nash Holmes entering an Order oI the same date in 11 TR 26800 whereby she Order
Coughlin's property released to him, though DDA Mary Kandaras dragged her Ieet until April 7th, 2012
beIore Iinally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately
admitted to having released to the City oI Reno Marshals on 2/28/12, denied having the micro sd card,
denied the micro sd ever being booked into property, alleged to have given Judge SIerrazza's Iormer
tribal court BailiII and Iormer Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the
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jail at Coughlin's request to get Coughlin's keys so Eastman could arrange Ior Coughlin's dog Jackson
Pawluck to be Ied and cared Ior during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead oI his own (where Coughlin would arguably be better oII letting
the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card conIiscating without a
warrant/5 day summary contempt jail sentence Ior testiIying that an RPD Sargent lied in connection
with his testimony about the Richard G. Hill, Esq. retaliatory issuance oI three traIIic citations outside
Hill's law oIIice, where RPD Sargent John Tarter told Coughlin to leave aIter Coughlin presented upon
being released Irom jail incident to a three-day stay stemming Irom Hill's line 2 Reno Police
Department oIIicers and managing caught to get Coughlin subject to custodial trespassing arrest
(detailed at length in 61901) and Hill reIusing to give Coughlin his drivers license law accuser clients
Iiles and Coughlin reporting to Sargent John Tarter at that time that three days prior to that Reno Police
Department oIIicer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him
as he too was on Richard Hill's payroll that RPD OIIicer Chris Carter, Jr admitted to Coughlin: "Yes,
Richard Hill pays me a lot oI money so I arrest who he says to arrest and I do what he says to do..." and
where both oIIicer Carter and Sargent Marcia Lopez reIused to undertake any diligent inquiry response
to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill Ior the Iull
rental value oI the 121 River rock property Ior the month oI November that was commiserate with the
same $900 that Coughlin was previously charged Ior the Iull use an occupancy oI the premises. The
lackluster Iailure to query Hill with any diligence by both oIIicer Carter and Sargent Lopez is
reminiscent oI what Reno Municipal Court Court appointed deIender Keith Loomis Esquire in 1982
graduate McGeorge school oI law told Coughlin at an April 10, 2012 trial date in that criminal trespass
matter wherein Reno Municipal Court judge William Gardner reIused to recuse himselI Irom hearing
that case against Coughlin despite the Iact that at that time he had Iiled a grievance with the State Bar
oI Nevada against Coughlin by way oI the NG 12 0434 grievance that his Iellow RMC judge Dorothy
Nash Holmes Iiled
Judge Beesley Iormerly partnered with now Washoe Legal Services child advocacy director Karen
Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes conIiscating
Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any
permissible interpretation oI a search incident to arrest given Coughlin property had been booked into
his personal property at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily
sentencing Coughlin to 5 days in jail Ior contempt, despite citing to a non summary civil contempt
statute in NRS 22.010 and NRS 22.100, but characterizing her Order as Iinding Coughlin guilty oI the
"misdemeanor oI criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt
statute, which is not summary in nature, and thereIore requires more due process, and despite Judge
Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even
said what Holme's alleged he did in rendering her "second bit at the apple" oI 3/12/12 in comparision to
her 2/28/12 Order Finding DeIendant in Contempt and Imposing Sanctions...In Nevada, a Summary
Contempt Order under NRS 22.030 (which is civil in nature) Ior conduct not committed in the
immediate presence oI the Court (such as the alleged conduct involving a restroom and disassembling a
smart phone or recording device and hiding some component part thereoI in the restroom that Judge
Nash Holmes murkily, hazily, and vaguely testiIied to during Coughlin's 11/14/12 Iormal disciplinary
hearing, and which she included in the Order she rendered in that traIIic citation case stemming Irom
Coughlin being told to leave Hill's law oIIice upon appearing their demanding his keys, wallets, driver's
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license, and client's Iiles shortly aIter being released Irom a 3 day custodial arrest stay in jail incident to
Hill's criminal trespass Complaint against Coughlin at Coughlin's Iormer home law oIIice (in RJC2011-
001708, the eviction matter presided over by Judge SIerrazza). Like the Order Judge Linda Gardner
claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis
FV11-03383 (see attached in Exhibit 1), Judge SIerrazza attempted to characterize the Order he entered
on 12/21/12 Iollowing a very contentious six hour hearing on Coughlin's November 17th, 2011 Iiled
stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to Contest
Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was
certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge SIerrazza
may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere
wherein Richard Hill was permitted to joke along with Reno justice court bailiIIs radius in chieI bailiII
Sexton as to the Iact that he to quote would like to stick some things up Coughlin's ass" in reIerence to
multiple incidents where Reno justice court bailiIIs had either as bailiII arrested told Coughlin that he
would put his Ioot oI Coughlin's ass or made commentary as chieI Sexton did to Coughlin respecting
Sexton's indication oI Coughlin on two diIIerent occasions the week oI Thanksgiving 2011 that
Coughlin indicated that the Iiling oIIice and/or not attempt to Iile documents so close to the 5 PM
closing time oI the Iiling oIIice. (see attached in Exhibit 1).
and him him him him and him In Iact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes,
inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician Irom Chico, CaliIornia. Dr. Merliss owns the
property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was leased to
Mr. Coughlin and his then-girlIriend. The lease expired in February 2011. The girlIriend leIt the
community in approximately May 2011. Dr. Merliss contacted us in approximately August 2011 to
assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that
there were habitability issues with the property that justiIied his withholding rent. All oI his clahns
were decided adversely to his position at the eviction hearing. Justice oI the Peace Peter SIerazza
ordered Coughlin evicted Irom the premises eIIective November 1, 2011. On that date, the Washoe
County SheriIIs Department perIormed their normal eviction procedure: locks were changed and the
eviction notice was posted on the Iront door. We videotaped the home and its contents at that time.
Upon inspection over the next Iew days, it became apparent that "somebody" was breaking into the
home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at
the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true Ior Hill to write "The lease expired in February 2011." The Standard Rental
Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in
accordance with the NRS 118A holdover tenant provision. Further, it is not accurate Ior Hill to write
"Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with
Coughlin's Iormer co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment
payments to make up Ior the Iact that she took Coughlin's $450 contribution to the $900 Ior each oI the
months oI May 2011 and June 2011 and only sent the landlord Merliss $550 Ior May 2011 and nothing
Ior June 2011. Coughlin provided Ms. Ulloa with $450 Ior each oI those months, and thereIore, in
combination with Dr. Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa Irom
a grand larceny charge oI a variety to which the two petty larceny charges Coughlin Iaced shortly aIter
Ms. Ulloa's secretly absconding with Coughlin's rental contributions (which Coughlin was only made
aware, and the concomitant rent due, upon an August 11th, 2011 email Irom the landlord Merliss).
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Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 beIore Judge
SIerrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices,
in violation oI NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an
agreement with Coughlin Ior a rent deduction oI $350 going Iorward in exchange Ior Coughlin
"dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artiIicial turI
installation Coughlin had installed in an enterprising approach which the landlord's landscaper Ior the
other property Merliss owned next door and his quasi real estate broker property manager Darlene
Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually
claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn
Service to "deal with the weeds" at Coughlin's Iormer home law oIIice. "Dealing with the weeds", to
Green Action Lawn Service, included tearing up Coughlin's artiIicial turI installation leaving Street
causing Coughlin's law oIIice substantial losses lost proIits time away Irom work and expenses
associated with immediately mitigating the criminal conduct oI green action lawn service where they
not only tore up the artiIicial turI installation even though they knew it was there prior to submitting
their bid Ior services to landlord Merliss, who apparently did not realize or remember that he had also
assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange Ior Coughlin
quote dealing with the weeds. Green action lawn service sought close the artiIicial turI installation
Coughlin put into place oI his Iormer law oIIice the week prior to their tearing it up and leaving
industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
Hill's grievance oI 1/14/12 to the SBN goes on to allege:
"Someone had been in there since I had last been in several days beIore. Dr. Merliss discovered that the
basement door was barricaded (not locked) Irom the inside. The Reno Police Department was
summoned. They tried to coax whoever was in the basement out, without success. AIter Dr. Merliss had
to kick the door down, it "was discovered that Mr. Coughlin had broken in and was in the basement. He
was arrested and is presently Iacing criminal trespass charges in Reno Municipal Court. See case no. 11
CR 26405 21. He is also Iacing a contempt motion in Iront oI Judge SIerrazza in the eviction case.
SIerazza has stayed that matter pending the resolution oI the criminal trial. That was scheduled Ior
January 10, 2012, but was continued at the request oI Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628,
pending in Department 7. As part oI the eviction process, a lien was asserted against the personal
property that Coughlin leIt behind at the home. On November 16, 2011, Coughlin Iiled a motion to
contest the landlord's lien in the Reno Justice Court. The court tried to promptly set a hearing, but
Coughlin reIused to cooperate in setting the matter, and the court took it oII calendar. Coughlin then
reinitiated that process and a hearing was held in December, at which time the court heard evidence oI
Coughlin's lack oI cooperation in setting the November hearing. You may also want to contact Reno
Justice Court staII, and in particular, chieI clerk Karen Stancil, about Mr. Coughlin's abusive treatment
oI her and her staII. AIter the hearing, the court issued an Order granting Coughlin a two-day time
window to remove his personal property. The Iirst day was Thursday, December 22, 20 11. AIter
Coughlin was allowed into the home that Iirst day, he sent out an e-mail to the eIIect that because he
had appealed Judge SIerazza's order, he was entitled to a stay oI proceedings and was to resume in the
home. As a result, he did very little to remove any oI his personal property that day. On Friday,
December 23, 2011, aIter he learned, again, that his stay had been denied, Coughlin assembled a small
crew and they were able to remove a substantial amount oI his personal property. (You need to
understand that Mr. Coughlin is a hoarder. We have the photos and videos iI you would like to see
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them.) However, Mr. Coughlin did not get all oI his property out. For example, I counted 13 car seats
that he had somehow managed to get down into the basement.
Having Iailed to remove all oI his belongings, Mr. Coughlin then moved beIore Judge Flanagan Ior a
temporary restraining order to prevent the disposal oI his abandoned property in accordance with Judge
SIerazza's order. Attached is Mr. Coughlin's motion, my oIIice's opposition, and Mr. Coughlin's reply.
These documents demonstrate Mr. Coughlin's complete and utter incompetence as an attorney.
On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request Ior a temporary restraining order.
On January 12, 2011, the contractor hired to clean the house commenced work. Mr. Coughlin Ilagged
the contractor down in traIIic when he (the contractor) was on his way to the dump with the abandoned
property Irom the house. Coughlin called the police, who arrived at the transIer station. Coughlin was
Ialsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, Iinally) can be described thusly:
PHONE CALL StartTime Saturday, August 20, 2011 11-22-52 PM SourceID 50 Cory Goble's
Iirst 911 call Irom Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-29 PM SourceID 43
Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-34 PM SourceID 46
Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-06 PM SourceID 13
reporting party advised they are now at Iirst and center.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-22 PM SourceID 21
probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-30 PM SourceID 12
RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-34 PM SourceID 14
unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-25 PM SourceID 41
probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-29 PM SourceID 43
probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11 PM SourceID 17
Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID 18
Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-40 AM SourceID 17
Dispatcher indicating Reno C153 wagon available Ior a male.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-51 AM SourceID 26
someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-19-51 AM SourceID 42
probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-21-02 AM SourceID 28
odd by somebody c153 seems to split in middle yet still one Iile.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-03 AM SourceID 22
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Duralde saying Reno c153 rtI returning.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-10 AM SourceID 27
Duralde's wiIe Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-31 PM SourceID
19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-37-23 PM SourceID
24 man saying come and split that up then Iemale dispatcher saying go ahead with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlinhotmail.com
--Forwarded Message Attachment--
Close Print
in compliance with Judge SIerrazza Order oI 9/5/12 FW: Zach Coughlin has shared a Iolder with you
From: Zach Coughlin (zachcoughlinhotmail.com)
Sent: Tue 11/27/12 8:26 AM
To: psIerrazzawashoecounty.us (psIerrazzawashoecounty.us); zyoungda.washoecounty.us
(zyoungda.washoecounty.us)
re:rcr2011-063341
Dear Judge SIerrazza and DDA Young,
I am sending this in compliance with Judge SIerrazza's indication that I should send him materials aIter
the trial the bare on the ineIIective assistance oI counsel claim and or the coerced waiver oI my FiIth
Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the
email oI 11/5/2012 Irom Court Administrator Mr. Tuttle and the inadvertent Iaxing oI numerous Iilings
to the wrong Iax number by myselI.
https://skydrive.live.com/redir?resid43084638F32F5F28!5141&authkey!APibWiVXTMSWkw0
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
24/60
000063
Tel and Fax: 949 667 7402
ZachCoughlinhotmail.com
in compliance with Judge SIerrazza Order oI 9/5/12 FW: Zach Coughlin has shared a Iolder with you
View photos Download all
You are invited to view Zach's album. This album has 43 Iiles.
11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdI
4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion Ior new trial basis.pdI
11 21 12 notice oI non service 063341 needs ex 1.pdI
11 21 12 Notice oI Irregularities 063341 with ex 1 started revised.pdI
11 30 11 063341 CoughlinDiscovery Received11.30.11 rotated.pdI
11 16 12 skau grievance materials combined 0204 063341.pdI
11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdI
11 13 12 063341 submission oI materials and motion Ior order dmv and cell records or
subpoena.pdI
11 12 12 just 80 pages revised cr11-063341 PRE TRIAL MOTION only pages 1 to 80 just text
oI motion no exhibits.pdI
2 15 12 rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS compressed
pdIIactpro more nuance.pdI
Iinal Motion Ior Mistrial and Memorandum oI Law State v Coughlin rcr2011-063341 -
Copy.pdI
pre trial brieI state oI nevada v coughlin rcr2011-063341 8 29 12 leslie wcpd rpd rjc iphone ocrd
and tagged jbig2 lossy.pdI
2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD
RMC 11 CR 00696 WCSO SUSICH ME.pdI
pre trial brieI state oI nevada v coughlin rcr2011-063341.pdI
rcr11-063341 notice oI appearance coughin Iile 3 3 2012.pdI
rcr11-063341 aIIidavit in support oI motion to Iile pre-trail motions late bw - Copy.pdI
11 27 12 complete with ex 1 063341 notice oI developments.pdI
11 26 12 0204 Notice oI Hill and Baker MalIeasance Ior Motion Ior New Disciplinary Hearing
or Trial 063341 1708 60331 61383.pdI
6 25 12 Order Ior Sanctiosn 03628 0204 Flanagan $40K in attorneys Iees summary eviction
appeal.pdI
10 17 11 email and attached Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing
Order to Baker 1708 0204.pdI
From: stuttlewashoecounty.us
To: zachcoughlinhotmail.com
CC: CWoodwashoecounty.us; RBakerwashoecounty.us
Subject: RE: Zach Coughlin has shared a Iolder with you
Date: Mon, 5 Nov 2012 18:39:02 0000
Mr. Coughlin:
25/60
000064
Reno Justice Court has no record oI your attempted Iiling on 10/18/12. II you choose to pursue this
Iiling action, you will need to bring the documents in because we do not accept Iilings via email. Any
documents Iiled with the court will be retained by the court and we will not make copies Ior you, the
DA or PD. Providing the appropriate parties copies oI your Iiling is your responsibility, not the court.
You may also bring in your conIirmation oI transmission Irom the 10/18/12 Iiling attempt and we will
retain that receipt as part oI the court record. Steve
Steve Tuttle
Court Administrator
Reno Justice Court
From: Zach Coughlin |mailto:zachcoughlinhotmail.com|
Sent: Saturday, November 03, 2012 9:39 PM
To: Tuttle, Steve
Subject: Zach Coughlin has shared a Iolder with you
Dear Mr. Tuttle,
I perused the Iile in RCR2011-063341 and noticed that the document I submitted Ior Iiling on or about
10 18 12 was not Iile stamped or even in the Iile, though I have conIirmation oI receipt oI transmission.
Can you please indicate why it is not appearing in the Iile and Iind attached another copy oI the exhibit
1 thereto.
https://skydrive.live.com/redir?resid43084638F32F5F28!3600
Zach has 460 Iiles to share with you on SkyDrive. To view them, click the links below.
102611coughlin2 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy
Spencer.wmv
102611coughlin1 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy
Spencer.wmv
101211coughlin CRC 11-063341 Competency Evaluation Hearing that got continued.wmv
090512coughlin2 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc
wcso.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc
wcso.wmv
071612coughlin rcr2011-063341 rjc .wmv
082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc
wcso.wmv
26/60
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082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
Goble Zarate testimony - Copy.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
Goble Zarate testimony.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
Goble Zarate testimony.wmv
090512coughlin4 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
090512coughlin5 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
090512coughlin7 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
090512coughlin6 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
090512coughlin1 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde - Copy.wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde
Goble Zarate testimony.wmv
090512coughlin5 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
Share your Iiles with
IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF
TRIAL AND IN CASE ANYTHING GOES MISSING AGAIN
From: Zach Coughlin (zachcoughlinhotmail.com)
Sent: Thu 11/29/12 4:57 PM
To: stuttlewashoecounty.us (stuttlewashoecounty.us); zyoungda.washoecounty.us
(zyoungda.washoecounty.us); psIerrazzawashoecounty.us (psIerrazzawashoecounty.us);
rjcwebwashoecounty.us (rjcwebwashoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
27/60
000066
ZachCoughlinhotmail.com
Zach has 43 Iiles to share with you on SkyDrive. To view them, click the links below.
11 29 12 063341 MOTION FOR NEW TRIAL FINAL WITH 217 MENTION.pdI
EX1 063341 FINAL.pdI
data-2012-11-24-17-43-52 063341 11 19 12 lichty admits phone did not vibrate.wav
data-2012-11-24-17-44-12.wav
data-2012-11-24-18-40-33.wav
data-2012-11-24-18-40-47.wav
data-2012-11-24-18-43-05.wav
data-2012-11-24-18-45-14.wav
data-2012-11-24-18-49-41.wav
data-2012-11-24-18-49-41(1).wav
data-2012-11-24-18-53-39.wav
data-2012-11-24-18-53-39(1).wav
data-2012-11-24-19-00-18.wav
data-2012-11-24-19-00-18(1).wav
data-2012-11-24-19-21-24.wav
data-2012-11-24-19-21-24(1).wav
data-2012-11-24-19-26-17.wav
data-2012-11-24-19-31-25.wav
data-2012-11-24-19-37-26.wav
data-2012-11-24-19-40-46.wav
Download all
911 calls missing Irom what was produced by City Attorney Skau
From: Zach Coughlin (zachcoughlinhotmail.com)
Sent: Mon 12/03/12 2:53 AM
To: psIerrazzawashoecounty.us (psIerrazzawashoecounty.us); zyoungda.washoecounty.us
(zyoungda.washoecounty.us)
Dear Judge SIerrazza and DDA Young,
This correspondence is Iurther in line with Judge SIerrazza's previous instruction to me to send him
emails aIter the trial directed to my issues with Mr. Leslie's representation (I am too tired to Iully set
those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
this just because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
receiving, | 484 P.2d 565 | but not oI both
28/60
000067
Perhaps one oI my biggest complaints about the ineIIective assistance oI counsel by Mr. Leslie (and to
a much, much lesser extent that oI Mr. Goodnight) relates to Leslie's Iailure to utilize any oI the work I
did to prep this case. For instance, Leslie whiIIed (perhaps intentionally so) on the extent to which
RPD OIIicer Duralde and Rosa could not have received the dispatch text oI 11:27:11 pm reporting
Goble's since proven Iraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so,
OIIicer Duralde and DDA Young are stuck with anything the OIIicer could "hear" on the Dispatch
recordings (and those provided by City Attorney Skau provide a basis Ior mistrial where the cd lacks
Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid oI anything Ior the 6
minutes in which the detaining and arrest occurs (and Iurther, DDA Young and the State were served a
request Ior discovery by Goodnight in November and subpoena which required production oI those
"dispatch logs or recordings...." Yet DDA Iailed to. Then he put on testimon and made argument that
this "report Irom dispatch oI a possible Iight" was the main justiIication Ior the pat down and search
incident to arrest and led to a justiIication Ior not excluding anything "discerned incident to the pat
down"...the only problem is is that Duralde and Rosa already are marked as on the scene by 11:26:00
pm, and thereIore could not have read the text screens in their vehicles to recieved the text only
11:27:11 pm dispatch entry about "someone just socked a minor". Further, the extent to which
Coughlin's 911 call is not reported accurately at all Iurther underscores the unIairness oI depriving
Coughlin the right to cross examine Duralde and the dispatchers.
A review oI the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to
Judge SIerrazza ordering him to produce in response to my subpoena duces tecum to Kelley Odom and
ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct. Two oI the 911
calls are missing. There is no audio oI any RPD-ECOMM/Dispatch communications between the
11:28:17 pm mark and the 11:36:27 pm mark...which is disturbing, considering the RPD and Ecomm
did not know I was Iilming/recording the arrest. Had I not captured a recording oI the arrest, how little
would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many
things revealed by the arrest recording contradict what OIIicer Duralde put in his Supplemental
Declaration and Narrative and the two witness statements? Further, where Zarate does not allege to
have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on
8/29/12 does testiIy to seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw
it light up Irom all the way across the skate park...but wait...come November 19th, 2012 he changes his
story and decides he saw it light up Irom "2 to 3 Ieet away Irom Coughlin"....There a movie Iloating
around somewhere out there that does a timeline oI all these calls, all these videos, superimposes the
dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc.
And one problem Ior DDA Young and Duralde is Iound in the State's 2/21/12 Opposition, on page 5,
wherein Young writes: "In the instant case, the pat-down search oI the DeIendant was proper under the
totality oI the circumstances. Prior to arriving, OIIicer Duralde learned that the scene involved a loud
disturbance with possible Iight, thereby immediately raising the concern oI weapons and the saIety oI
all those present." And, oI course, OIIicer Duralde responded splendidly to Coach Young's, er, DDA
Young's training regime and sang the "possible Iight...report Irom dispatch oI a possible Iight" tune all
the live long day...which was the basis Ior the reasonable suspicion Ior the pat-down (and Judge
SIerrazza did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less
obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in the
Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson
admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on
29/60
000068
video and audio recordings into the record...despite Duralde testiIying to a multitude oI double hearsay
(and not even capture on a recording so close in time to the arrest and at the very same location,
involving the majority oI the players in the arrest itselI...).
It was in the same 11/30/11 email Irom WCPD Goodnight to Coughlin that included the Narrative by
OIIicer Duralde (which has, in the Iooter oI the 4 page document, a Iooter indicating a "printed on"
date oI 11/28/11
Zarate's testimony respecting the scant statements he actually made to OIIicer Duralde reveal the extent
to which OIIicer Duralde paints on to witness statement more speciIic, particularized Iacts in support oI
the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" oI "busting" and
attorney whom dared to answer one oI the oIIicer's questions by asking a question seeking clariIication
as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a Iinding oI
either "reasonable suspicion" to conduct a "weapons check pat down" (the OIIicer's did not receive the
text Irom dispatch reporting Goble's second 911 call wherein he Iraudulently alleged that "someone just
socked a minor" (reIerring to the instance where then 18 year old Austin Lichty (who is captured on the
video oI the moments(Iile named: VID20110820232423 austin lichty templeton goble zarate chan
rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds in length) lying in
asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition
to Goodnights 2/14/12 Motion to Suppress, both Goble, Lichty, and Zarate all have motivations
apparent which preclude them Irom being deemed "reliable citizen witnesses" and OIIicer Duralde
indeed did have, and admitted to in his testimony at trial to being aware oI, the "gross inconsistencies"
Goodnight pointed out between the hearsay and double hearsay Duralde testiIied to at trial aIter
"reIreshing his recollection" upon a review oI either his "Supplemental Declaration" (an attachment to
the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the
question....how was it not misconduct by the State and prejudicial to the point oI declaring a mistrial or
at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem Ior the RPD and the State...the screen lock that Goble and Templeton
testiIied to (the password Ior the phone)...and when Goble alleges Duralde gave him back the
phone...and the call into the iPhone at 11:33 pm Irom OIIicer Duralde's phone...and the call Irom the
iPhone b
Perhaps the worst thing Ior the State and the RPD here is that two hostile witnesses (in addition to
Coughlin's various statements related thereto, during his testimony and on the media admitted into
evidence) testiIied that RPD OIIicer Duralde committed misconduct by lying about the purported order
or point in time in relation to the arrest and search oI Coughlin and Duralde's Iirst coming into
possession oI the iPhone. Goble testiIied that Duralde removed the phone Irom Coughlin's pocket and
that Duralde had the phone with him when he Iirst presented to Goble to ask question related to the
phone and to veriIy ownership oI the phone (which would include gathering the phone number Ior the
iPhone, which necessarily would mean that Duralde's allegation oI only searching Coughlin aIter
perIorming some call to the iPhone and hearsaying it vibrate (even though multiple witness
(Templeton, Zarate, Goble, Lichty testiIied that they heard no such buzzing or vibrating oI the phone,
hostile witnesses all) Goble testiIied that Duralde already had the iPhone prior to Goble conIerring
with Duralde or otherwise giving Duralde any phone number to call in an attempt to veriIy the phone
revealing an incoming call LED display scree light up alert (Goble's statements that the phone would
"light up" and that he, as Duralde quotes him in the Narrative, "could not hear the phone
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I have 30 days Irom the date oI conviction to report a conviction to the State Bar oI Nevada and the
United States Patent and Trademark OIIice (USPTO) Ior these two convictions "possessing or
receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
I note that WCPD Jim Leslie, while still attorney oI record Ior me on this cases RCR2011-063341, had
served (see attached) a subpoena on ECOMM and Kelley Odom on 10/03/12. Given that Mr. Leslie
was not relieved as my counsel until at the earliest 10/22/12 (so Judge SIerrazza's contention that
Coughlin "has had Iorever to get his deIense ready in this case" and that "no continuance will be
granted on account oI the Iormal disciplinary hearing beIore the State Bar oI Nevada" being scheduled
just 5 days prior to the 11/19/12 resumption oI trial in rcr2011-063341 (and despite Judge SIerrazza
indicated some canon preventing him Irom testiIying at the Iormal disciplinary proceeding...that didn't
stop 063341 being speciIically pled in the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin,
as was Judge CliIton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
Townsend Irom sending into the SBN Coughlin's 2/12/12 Iiling in that Judge CliIton case rcr2012-
065630 and oIIering to send into the SBN Coughlin's 2/15/12 Iiling in 063341). Add to that the Iact
that Coughlin never received Irom Leslie Goble's call records until Leslie Iinally released them o
October 30th, 2012...and it really is not accurate to say Coughlin had "Iorever" to prepare his case.
Coughlin had to pull together a deIense in his Iormal disciplinary hearing beIore the SBN despite the
SBN gipping him out oI every aspect oI SCR 105(2)(c) (ie, not 30 days notice oI the hearing on
11/14/12 aIter service oI the Complaint and Designation oI Witnesses and Summary oI Evidence is
aIIected pursuant to SCR 109 and SCR 105(4)...But the point is, iI the RJC and both oI you want to be
associate with a SchaeIIer style Mirch-ing, then this may be your chance. But you won't be able to say
you didn't have plenty oI opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena
duces tecum....Mr. Leslie's Iailure to turn over anything to me in the "hand oII transmittal" he insisted
upon (despite a digital transmission being required per the Order oI Judge SIerrazza, I believe) requires
some explanation.
So to requiring explanation is the Iact that the cd provided by Reno City Attorney Skau in an apparent
good Iaith attempt to comply with Judge SIerrazza ordering him to comply with the subpoena duces
tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events surround it oI
8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin
Lichty's cellular phone, 775 233 8593, which Goble is seen in the attached still Irame picture culled
Irom a video Coughlin took oI the moments prior to the arrival oI the RPD, being handed by the "man
with the gauged ears" Lichty reIerred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton
testiIying that they do not know that man and did not know him prior to that night at all....Coughlin
respectIully demanded oI the RPD OIIicers, at the time oI his arrest, that they gather the identiIy oI the
"man with the gauged ears", however, OIIicer Duralde et al reIused to (claiming Coughlin's allegations
oI their having attacked him and attempting to steal his bike and or dog, reach into his pockets, and
push him up against oncoming traIIic on the Center Street bridge were "unsubstantiated"). Oddly, in the
attached still Irame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin
Lichty that Goble utilized to make his two 911 calls that evening, the Iirst (iI the Iile name time
stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the
ECOMM text logs reveal an E911 entry oI 11:23:36 pm (its unknown whether the exact time a 911 call
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comes in is designated on the "Calls Ior Service Inquiry Response" Coughlin was provided recently).
The EComm text logs reveals a second E911 entry Ior the 775 233 8593 number (belonging to Austin
Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law
license away Irom me Ior at least 5 years, iI not Iorever....and DDA Young...over some alleged "skater
sets his iPhone down on the concrete in the middle oI the ice rink plaza downtown on 8/20/11 at 11:20
pm ish in Reno, "man with a six pack oI beer" picks it up, oIIers it up, receiving no response threatens
to "throw it in the river iI someone doesn't claim it immediately" whereupon Goble's Iriend Nate Zarate
apparently (according to RPD Duralde's Narrative oI unknown origin date") told Goble he saw
Coughlin pick it up oII the ground (as Duralde recounts hearing Irom Goble in his Narrative)
contain the 911 call by Coughlin
So, in the Iile named "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11
PM SourceID 17 063341 duralde i'll be out on him" one can hear OIIicer Duralde indicating he will
"be out on him on the Center Street bridge" aIter he has leIt his squad care and is shortly to appear in
the video Coughlin Iilmed oI the arrest, title:
Then, OIIicer Rosa is proven to be on the bridge and not in his squad car reading texts Irom dispatch n
the Iollowing time stamped Iile: "PRIMARY RADIO TRAFFIC StartTime Saturday, August 20,
2011 11-26-30 PM SourceID 12 RPD Rosa saying charles 396 on the other end"
Further, OIIicer Duralde's arrival on the scene is notated in the dispatch log at the
Its not at all clear why Goodnight only apparently received then Iorwarded to his client on November
30th, 2011 the "Original Supplemental" containing OIIicer Duralde's Narrative, that is still oI
indeterminate date oI origin (there are a number oI "date oI printing" variations...).
That I know oI, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc oI phone susps os leIt on
post lighting up in sups pock RP screaming at susp
2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone
just socked a minor, waive that cop down 10 10 with open line
3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call Irom phone with open
line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin Iilmed three videos that night oI the arrest that are relevant, two just prior to the RPD
arriving (and actually, while Rosa and Duralde were already on the scene and out oI their vehicles aIter
teh 11:26:00 pm mark as indicated by the Ecomm recordings and dispatch logs...
1. VID20110820232413 your all on tape now goble and Iriends.3gp 8 seconds long
2. VID20110820232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery
Coughlin jusrt prior to RPD rcr.3gp 46 seconds
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3. VID20110820232801 oIIicer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records Ior the iPhone reveal only Iour calls occurred in or out during the relevant
time Irame:
Goble's AT&T records:
44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..."
Previous to that, DDA Young had successIully kept every single witness Irom speciIically identiIying
who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'.
But, Goble is a selI involved twit, who snaps his Iingers "Oh, that's Colton" 8 Ieet Irom Judge SIerrazza
and swaggers out oI the court room. And Leslie reIused to seek admission oI the misconduct oI a
prosecution witness....Goble, batterying Coughlin with a lit cigarette, that Coughlin capture on tape, on
June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on
6/7/12...and had his law license suspended in 60838 Iour hours later by a 3 Justice Panel (including
Justice Hardesty, whom recused himselI Irom Coughlin's wrongIul termination suit against Washoe
Legal Services...and you might not like me Ior that suit, but iI you look at the circumstances oI my
Iiring therein (I was hurrying to Iinish a non-proIit gets stuck with the building's private landlord's
property taxes appeal due on 3/10/12 Ior Paul Elcano, and had a Trial beIore Judge Linda Gardner in a
divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty oI research
beIorehand...I just had some issues printing it out and bringing it with me (my legal assistant couldn't
Iigure that out...WLS took 6 weeks to cut a check Ior subpoena Iees....the usual)...
Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence
exclusively hearsay testimony (oIten unattributed to anyone in particular) to support his win on the
"suIIicient probable cause to support a search incident to arrest" despite NRS 171.136 Iorbidding such
an arrest (where Duralde obviously overcharged the alleged crime as a "Ielony grand larceny"...even
making smug commentary about the "certain beneIits oI charging this as a Ielony" and saying "oooh,
that's a Ielony", both matters that Leslie insisted reIraining Irom getting into while he was attorney oI
record, and Iurther, despite Coughlin complying with NRS 174.345 (even splurging on the return
receipt requested to go along with the certiIied mail Ior Duralde) Coughlin was denied the right to cross
examine the arresting oIIicer...which is too bad considering his Narrative alternately claims that Goble
told him they
DDA Young's complaint Iails to alleged someone other than Coughlin stole the property, which it must,
to support the receiving or possessing stolen property charge.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation oI NRS 205.275, a misdemeanor, in
the manner Iollowing, to wit:
That the said deIendant on or about the 20th day oI August, 2011, at Reno Township, within the County
oI Washoe, State oI Nevada, did willIully and unlawIully possess or withhold stolen goods having a
value less than Two Hundred FiIty Dollars ($250.00), to wit: an iPhone, at or near 1 North Center
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Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, Ior his own gain
or to prevent the true owner Irom again possessing said property, knowing that the property was
obtained by means oI larceny or under such circumstances as should have caused a reasonable man to
know that such goods were so obtained.
POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that
the property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574.
Must allege the good were received Irom someone other than the deIendant: Gaddis, 424 U.S. 544,
Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted oI violating 18
U.S.C. 2113(a), (b), and (d) cannot also be convicted oI receiving or possessing the robbery
proceeds in violation oI 2113(c). HeIlin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State Iailed to prove beyond a reasonable doubt that the automobile had been stolen by a
person other than plaintiII in error, a...The next assignment oI error is that the State Iailed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than
plaintiII inerror. To sustain a conviction oI receiving stolen property the prooI must show (1) that the
property has, in Iact, been stolen by a person other than the one charged with receiving it; (2) that the
one charged with receiving it has actually received the property stolen or aided in concealing it; (3) that
the receiver knew the property was stolen at the time he received it and (4) that he received the
property Ior his own gain or to prevent the owner Irom possessing it. (People v. Piszczek,404 Ill. 465.)
ProoI oI these essential elements constituting the crime oI receiving stolen property may be made by
circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96
N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that iI a
criminal conviction is to be upheld,
| 21 Ill. App.3d 980 |
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394
Ill. 325, 327 (1946)), and must contain the nature and elements oI the oIIense in order that the
deIendant may Iully prepare a deIense and be aIIorded the constitutionally intended protection against
double jeopardy. (People v. GriIIin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the indictment,
drawn upon the conclusional premise that the property was stolen, Iails to allege that it was stolen by a
person other than the one charged with receiving such property and, by this omission, creates the
presumption that the possessor stole the property himselI. Since one person cannot be both the thieI and
the receiver oI stolen property nor receive stolen property Irom himselI, the Iact that the property
received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310
Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v. Harris, 394 Ill. 325,
329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860,
863-864 (1971).) Lacking this element, the indictment Iailed to charge the oIIense oI receiving stolen
property under section 16-1(d). A conviction under an indictment which does not charge an oIIense is
void. People v. Edge,406 Ill. 490 (1950).
The judgment is, thereIore, reversed....
I Ieel that the majority has misconstrued the eIIicacy oI section 16-1(d) in arriving at a conclusion not
urged by the deIendant. The omission oI the words "stolen by another" in the indictment does not create
the presumption that deIendant had himselI stolen the property Irom the owner. The use oI the words "*
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* * knowingly obtain control oI stolen property * * * under such circumstances that would reasonably
induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly
implies that when deIendant obtained control oI the property in question (in any manner whatsoever),
the property had already been stolen by another. That is the plain and ordinary meaning oI the
indictment.
I believe the majority may be conIusing what can and cannot be reasonably implied Irom evidence
introduced at trial with what may be implied Irom the clear phrasing oI the indictment. At trial it is not
| 21 Ill. App.3d 981 |enough Ior the prosecution to merely show that the property in question was
stolen property and that the deIendant was in possession oI that property in order to prove the oIIense
oI theIt under 16-1(d) (the Iormer oIIense oI receiving stolen property). (People v. Baxa (1972), 50
Ill.2d 111, 277 N.E.2d 876.) The deIendant's unexplained possession oI stolen property soon aIter a
theIt is evidence that the deIendant stole the property himselI but is not evidence oI deIendant's
receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d
860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology oI the indictment herein
permits a reader oI the indictment to Iind, even aIter only a cursory reading, the necessary elements oI
the oIIense, i.e., that the property was already stolen by another when the deIendant received it.
While it may be true that the addition oI the words "stolen by another" would make the indictment
more explicit, the addition oI these words would only be grammatically redundant and mere surplusage
legally.
The indictment, thereIore, was suIIicient to charge the deIendant with an oIIense under 16-1(d)(1).
AIter a thorough examination oI the record, I do not believe that the evidence produced at trial was
suIIicient to Iind the deIendant guilty beyond a reasonable doubt. For this reason I, too, would reverse
the deIendant's conviction."
Appellant correctly argues that the standard oI proving value, Ior conviction, is the same in "receiving"
cases as in "larceny" and "theIt" cases. He erroneously urges that the state Iailed to meet that standard
under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "|t|he true
criterion Ior the value oI property taken is the Iair market value oI the property at the time and place it
was stolen iI there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF,
CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen
by him during the commission oI the burglary charged in Count 2. Since a thieI cannot receive Irom
himselI the Iruits oI his larceny, the jury must be instructed that it could convict oI either burglary or
receiving, | 484 P.2d 565 | but not oI both. People v. Taylor, 4 Cal.App.2d 214, 40 P.2d 870 (Cal.
1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States,
365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States, 418 F.2d 567 (5 Cir.1969);
Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court
declined to give it. This was error, and later acknowledged by the court to be such when it set aside the
receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner
oI handling the error eIIectively cured it. The error was not cured by the setting aside oI the receiving
conviction since there is no way oI knowing whether a properly instructed jury would have Iound the
deIendant guilty oI burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both
convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an
essential element oI the crime oI receiving stolen goods..17. Criminal Law. In prosecution Ior receiving
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stolen goods, where instruction given by court Iollowed language oI statute with reIerence to accused's
intention to prevent the |61 Nev. 330, Page 336| owner Irom again possessing property, deIendant was
not entitled to instruction which told jury that goods must have been received with Iraudulent intent oI
depriving owner oI the immediate possession thereoI. Comp. Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court oI Nevad: "At the
conclusion oI a preliminary examination, Henny Bernier was ordered to stand trial Ior possession oI
stolen property, a violation oI NRS 205.275.1 Bernier then petitioned Ior a writ oI habeas corpus
contending the evidence adduced by the prosecution was insuIIicient to establish probable cause that
she had committed the charged oIIense. The district court considered and denied her petition and
Bernier here reasserts the same contention.
Bernier does not deny having possessed the property; rather, she argues the prooI did not show that she
knew the property was stolen and that such knowledge cannot be inIerred Irom mere possession.
We agree that mere possession is insuIIicient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted oI both robbery and receiving stolen property. This
court reversed a conviction Ior possessing stolen property on the ground that the legislature did not
intend to compound the punishment Ior larceny or robbery by permitting a conviction Ior receipt or
possession oI the stolen property against the person who took the property. Point v. State, 102 Nev.
143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that Ior a charge
oI possession oI stolen property to stand, there must be a showing oI all the elements, and
that iI even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession oI stolen property does not in itselI prove guilt oI the oIIense. Staab
v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden oI prooI oI all three elements rests
with the
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606
NYS 2d 607.
Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
Judge Nash Holmes continues to reIuse to allow Couglin to appeal the "summary criminal contempt"
Order, even though, given the incarceration was served, it is a Iinally appealable order, see Gilman 275
V. Comm 474, 657 SE 2d 474.
BiIurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474
Terrell v. Miss. Bar 635 So 2d 1377. Matt oI Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378. triem
929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook
88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb, 838 NE 2d
1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d
515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
26405 and 03628 trespass case:
unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,
Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Iorio, 410 NYS 2d 195
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Russell v Kalian, 414 A.2d 462: expired warrant Ior eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the Iollowing two timestamped recordings Iinally provided by City Attorney Skau (WCPD
Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths
prior to the arrival oI the peace to stay peaceIul in Coughlin's reIerences the then recent murder oI
Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
theIt oI a purse, and Lelise preIers to spend his time chiming in, unprompted, on the regard, arrogantly
enough, that he can assist the court iI it Ieels Coughlin is "draggin' his Ieet" incident to the inappropriat
placement by Judge SIerrazza oI Leslie as "stanby counsel" which really amounted to no more than yet
another coercive practice put in place by Judge SIerrazza to Iurther his stated goal oI avenging the
criticisms Coughlin levied upon him incident to Judge SIerrazza's incredibly questionable on-the-Ily
pandering/remixing oI his Order oI 10/13/11 (iI Coughlin, as he, in Iact did, deposit a "rent escrow" oI
$2,275, SIerrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawIul
detainer action...until rich man's opposing counsel Casey Baker, Esq. coached Judge SIerrazza on the
record that "the use oI the term "Trial" was unIortunate, Your Honor..." whereupon Judge SIerrazza .
You are to his constituency by remixing is previous order regardless oI the extent to which Coughlin
was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they
are and where only those aspects oI a summary proceeding that in year to the landlords beneIit were
adhered to where is all oI the procedural and discovery protections attendant to a plenary unlawIul
detainer trial and the ability to bring counterclaims were matters Coughlin was precluded Irom
accessing by judge SIerrazza. Just Rosin is interesting approach to landlord tenant matters continued on
with respect to the manner in which service was aIIected on November 3 in violation the courthouse
sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division Iiling oIIice no less
(and that is the same bailiII Plamondon managed to take the Iilings Coughlin submitted online
November 15 out oI the criminal division Iiling oIIice oI the Reno justice court where Robbin Baker it
Mr. Coughlin let them in her position well prior to the 5 PM closing oI that Iiling oIIice and with DVDs
attached to those Iilings Coughlin swears under penalty oI perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID
18.mp3
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
5.mp3
In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed Irom
representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public deIender applying
good nicely peers deciding that the night was doing too much to assist Coughlin in deIending himselI
and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy
session while Coughlin was in custody on July Friday, July 13 at approximately 430 man and you good
night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial
on July 16, 2012 Monday morning at 9 AM and it was only upon Coughlin arriving and being brought
to the court in custody seeded Jeremy Bosler was suddenly Iilling in Ior Goodnight with and indication
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Goodnight's December 19, 2011 Iile stamp discovery requests served upon the stay and district attorney
Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the DeIendant,
ZACHARY BARKER COUGHLIN, by and through his attorney oI record, Joseph W. Goodnight,
Deputy Public DeIender, and hereby requests the Iollowing discovery pursuant to NRS 174.235 to NRS
174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or
conIessions made by the DeIendant or any witness, or copies thereoI, within the possession, custody or
control oI the State, the existence oI which is known or by the exercise oI due diligence may become
known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings,
including those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs,
written or recorded, generated in connection with this case." It is telling the extent to which on the
record at that July 16 trial date Washoe County public deIender Jeremy Bosler indicated that Jim Leslie
would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And
that Leslie would be prepared to try the case by Friday and that the court could step matter Ior trial on
Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have
completed all the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the
case whether or not that evinced any sort oI concern Ior his client, ability to zealously advocate on his
client behalI or willingness to do so, or indication that Jim Leslie Ielt that the judges oI the Reno Justice
Court would hold him to a standard oI care at all tending to indicate that Mr. Leslie has any skin in this
game whatsoever.
Clearly there is a bases Ior mistrial here were Jim Leslie's entire contribution to the representation oI
Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing
disregard Ior the rules oI proIessional conduct an intentional maniIestation oI Leslie's desire to secure a
conviction the Washoe County District Attorney's OIIice and therein secure added boys Irom local law
enIorcement District Attorney's OIIice and perhaps the Reno justice court itselI. Further Reno
Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County
public deIenders oIIice in connection with February 27, 2012 clandestine status conIerence between
Biray Dogan and Zach Young which neither Dogan nor Young has ever reIuted whether they they have
been sworn prior thereto or not an especially where Dogan's coworker down the hall civil division
deputy Dist. Atty. Mary has been involved throughout the conIiscation without a search warrant or
court order oI any kind (or at least one ever served on Coughlin in any manner) oI Coughlin smart
phone and micro SD card incident Judy impermissible summary contempt Iinding by judge Nash
Holmes just two hours aIter the clandestine status conIerence between Dogan young on February 27,
2012 in RMC case 11 TR 26800 Ior which Dogan and Young stipulated to a continuance in 06 RGC
065630 in light oI the scheduling conIlict between that traIIic citation trial in the Reno Muni court
which stemmed Irom Coughlin's being retaliated against vice RPD Sargent Tarter in connection with
Coughlin telling Tarter one oI the top 30 highest-paid city oI Reno employees oI and admission to
taking bribes Irom Richard Hill by RPD oIIicer Chris Carter Junior incident to Carter placing Coughlin
in handcuIIs pursuant to a custodial arrest based upon a criminal complaint Ior trespass Iind by Richard
Hill on November 13, 2011. That criminal trespass conviction has now become the subject oI a Nevada
Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent
Marcia Lopez oI the misconduct by herselI oIIicer Chris Carter, Jr. Richard G. Hill, Esq. and his
landlord client, and a summary eviction matter that judge SIerrazza presided over wherein judge
SIerrazza purportedly controlled the civil division oI the Reno justice court to the extent that Coughlin's
notice oI appeal on December 26 submitted Ior Iiling December 26, 2011 was not Iile stamped by the
civil division staII oI the Reno justice court. This impropriety is Iurther problematic where Coughlin
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had served upon the Reno justice court's custodian oI records and she civil clerk Karen Stancil (whom
Richard Hill reIerences in his January 12, 2012 letter her grievance against Coughlin to the State Bar oI
Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar oI Nevada, which
ultimately became one oI the three grievances depicted numerically in the caption oI the SBN v.
Zachary Barker Coughlin SCR 105 Complaint Iiled by the State Bar stamped August 23, 2012 (in
addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial
in 11 TR 26800 held in violation oI NRS 178.405 by way oI NRS 5.071 (RJC and RMC under one
rooI, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC
judges including then Administrativ Judge William Gardner, who reIused to recuse himselI Irom the
criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's Iormer
law oIIice upon Coughlin being subject to a custodial arrest by oIIicer Chris Carter on November 13,
2011, resulting in a criminal trespass conviction oI Coughlin in 11 CR 26405 where it RPD Sargent
Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless or
her partner oIIicer Carter issued caught Coughlin a trespass warning prior to eIIectuating a custodial
arrest on that day in where Lopez also admits none oI those individuals or anyone present that day
identiIied themselves as law enIorcement prior to landlord meritless kicking down the door to a
crawlspace about 5 Ieet high underneath the Iormer home law oIIice wherein Coughlin was Iound at a
time when Coughlin still had not receive back Irom the Reno justice court the impermissible $2275 rent
escrow deposit judge SIerrazza ordered in violation oI Nevada law considering judge SIerrazza's
admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was
correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice court rule
44 that may support the secret quote house rules been Iact in the civil division oI the Reno justice court
wherein tenants were in summary eviction matters were subject to Iorced rent escrow deposit in
violation oI justice court rules civil procedure 83 and that the Reno justice court had neither published
nor had approved by the Nevada Supreme Court any sort oI corollary to justice court rule Las Vegas
rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongIul arrest connected thereto
occurred even where the Washoe County SheriII's oIIice deputy Machen Iiled a Ialse aIIidavit on
November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction
Decision and Order and the October 27th Findings oI Fact, Conclusion oI Law, and Order oI Summary
Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial oI
Coughlin Irom which Judge William Gardner reIused to recuse himselI despite the Iact that his sister
judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the
"Clerk oI Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order
sanctioning Coughlin incident to a divorce matter where and he was representing a victim oI domestic
violence on behalI oI our Washoe legal services (a rather interesting approach by Iormer prosecutor
judge Linda Gardner in comparison to the extremely light touch demonstrated by judge SIerrazza and
judge CliIton oI the Reno justice court incident to deputy district attorney Young's repeated
malIeasance misconduct violations stays pending competency or evaluations Iailure to turn over
exculpatory materials Iailure to propound discovery Iailure to respond reasonable discovery requests
demonstration a retaliatory animus in conjunction with scattershot three, count them three prosecutions
oI Coughlin this year Ior charges which young either amended to in advance implicating Supreme
Court Rule (SCR) 111(6) (in 065630 young amended the criminal complaint Irom a misuse oI 911
charge to do a charge more deleterious to Coughlin's proIessional license as a lawyer and/or patent
agent by amending the charge nearly a year aIter the January 14, 2012 arrest in the matter to a charge
that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good Iaith eIIort
to achieve a plea-bargain and resolve what is a messy case the city oI Reno Police Department and
emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-
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000375 run the rental at which the domestic violence resulted in Coughlin's calls to emergency services
or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely
suspect rolling this year by judge Schroeder oI the Reno justice court against Coughlin in the extremely
quick like 40 min. Irom Iiling quick issuance oI up temporary protection order to Richard G Hill on
January 12, 2012 in connection with Hill's Iraudulent abuse oI process and Ialse statements to police
oIIicers aIIecting the arrest custodial arrest oI Coughlin on January 12, 2012 will jaywalking (Hill lied
to RPD oIIicer Hollingsworth in alleging that Coughlin had already lost his appeal oI summary eviction
matter in 1708 Barber which judge SIerrazza presided and which was then on appeal beIore judge
Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney Iee award against
Pro per appellant Coughlin in the appeal oI the summary eviction order issued by Judge SIerrazza and
1708 on March 30, 2012 incident to and motion Ior attorneys Iees Iiled by Casey D Baker oI Hill's
oIIice on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty.
young Iastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom
"randomly" was assigned to Coughlin appeal oI the petty larceny conviction oI a candy bar and some
cough drops Irom Walmart in 11 CR 22176 (the sole basis Ior Coughlin's current temporary suspension
oI his law license incident to bar counsel's SCR 111(6) Petition in 60838) stemming Irom an arrest on
September 9, 2011 that was violative oI Nevada law where tribal police oIIicers aIIected a custodial
arrest Ior a misdemeanor (much less one not alleged to have occurred in their presence) in violation oI
the express dictate against doing so Iound in NRS 171.1255 should especially where Walmarts sole
witness testiIying at the petty larceny trial, would be dentist Thomas Frontino, whom testiIied on behalI
oI the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest Ior misdemeanor petty
larceny" a candy bar and some cough drops in connection with Coughlin's selecting heard just seeing
$83 worth oI groceries allegedly consuming a candy bar and or some cough drops while doing so...
Despite the Iact that that Walmart alleges to have had absolutely no video Iootage supportive oI its
allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and
where French you admit that his supervisors had previously indicated to hand a desire to retaliate
against Coughlin in connection with Coughlin's questioning
some oI Walmarts policies and where John Ellis oI the W. 7th St., Walmart in any as yet unknown loss
prevention associate speciIically and expressly threatening abuse oI process against Coughlin on July 7,
2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and
customer service managers many oI whom have had that position Ior over a decade routinely claim do
not remember the return policy or restated in a manner that depart substantially Irom the policy which
Walmart holds out to the public on its website Walmart.com and which on that website speciIically
makes applicable to in-store purchases that return policy as stated at Walmart.com no matter what the
convenient Ior getting in misremembering oI Walmarts managers may indicate the policy actually is.
Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 aIIected a
citizen"s arrest oI Coughlin on that date in connection with the alleged petty larceny by Coughlin oI a
candy bar and some cough drops which conveniently Ior the Reno Police Department just days aIter
Coughlin Iiled a written complaint detailing the police misconduct by Reno Police Department oIIicer
Grohl and Rossa incident to the arrest oI Coughlin the wrongIul arrest oI Coughlin on August 20, 2011
in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin
(despite the Iact that the majority viewpoint throughout American jurisprudence that one cannot be
charged with both petty larceny and receiving stolen property oI the same item particularly where the
receiving oI the item is alleged to have been Irom oneselI aIter one had larceny is the item lending an
inIerence that Joe SIerrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as
possible to aIIect the leverage over Coughlin to mitigate the liability Reno justice court may Iace in
connection with its numerous since is violating about law respecting the manner in which evictions are
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carried out and or the misconduct oI local law enIorcement and prosecutors in carrying out retaliatory
arrest and prosecution oI Coughlin where the judiciary in Washoe County is oII criticizes being overly
inIluenced by the District Attorney's OIIice. That Walmart petty larceny conviction stemmed Irom a
trial beIore Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school oI law
whom Coughlin's twice Iormer Reno Municipal Court appointed public deIender Keith Loomis (not in
the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed deIender there despite
his express Iailure to rule that jail time was not a possibility in his pretrial order and where mandatory
authority exists requiring that he then appoint Coughlin court appointed counsel particularly where
Coughlin established his indigency. Judge Howard's malIeasance in connection with that conviction oI
Coughlin extends Iurther the extent that he early on in that November 30 trial on it in 2011 reviews
Coughlin Ior causing the November 14 trial setting to have been continued only to in a 3 min. add-on at
the conclusion oI the hearing which are trial which judge Howard down such a matter oI public
concern that he Five city oI Reno employees at the courthouse until nine o'clock at night to get it done
that in Iact judge Howard admitted he was wrong with respect to the cause oI the continuance oI the
14th 2012 trial that was not Coughlin Iault that all and where the Reno Municipal Court had previously
granted a continuance to the city oI Reno prosecutor's in the very criminal trespass prosecution oI
Coughlin stemming Irom Richard G Hill Esquire's criminal trespass complaint (connected to the
summary eviction matter over which judge SIerrazza presided) where the Reno Municipal Court Ireely
granted Richard G are the product the city oI Reno prosecutor's a continuance in light oI Richard G
Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week
vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge
SIerrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction
matter 1708 required by law within 10 days oI Coughlin Iiling his motion to contest personal property
lien on November 17, 2011 even where is extremely suspect that the justice court is now alleging
Coughlin reIused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as
Janice admitted when judge SIerrazza called her is oI his own witness at the December 20, 2012
hearing that was Iinally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be
able to control the justice court in his desired to prevent such a hearing been set until he returned Irom
his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to
contest personal property lien judge SIerrazza ordered Karen Stancil and Joslyn John is oI the Iiling
oIIice oI the Reno justice court to Iile in unsworn statements purporting to prove that Coughlin
somehow Iailed to allow the justice court to setting hearing on his motion to contest personal property
lien however that doesn't explain the extent to which bailiII Plamondon was able to apparently without
Coughlin's permission serve Coughlin a violation oI the courthouse century Dr. and a notice oI it
November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was
seeking axis justice court Iiling oIIice Ior something unrelated to bailiII Plamondon's desire to aIIect
service oI some notice oI the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed deIendner, admits to having been close Iriends with in law
school and to this day Loomis himselI in 1982 graduate McGeorge school law along with wash County
Dist. Atty. Richard Gammick, both oI whom were one year ahead oI Reno justice court judge CliIton
whom recently granted 2004 graduate McGeorge school oI law deputy district attorney Zach young in
order taking away the ability to Iile by Iax Irom Coughlin a privilege that is accorded any other
criminal deIendants in the Reno justice court despite the Iact that that order was granted at the
November 27, 2012 hearing at which Coughlin's then attorney public deIender Biray Dogan was
relieved as counsel and where at that hearing Dogan himselI admitted that he had not received the
motion young alleged who Iiled on November 26, 2012 seeking such an order Irom judge CliIton
barring Coughlin's ability to Iax Iile or send young it a Iax oI any sort apparently or perhaps Tom
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despite the Iact that Coughlin had merely comply with judge CliIton's request that he provide judge
CliIton something supportive oI Coughlin's contention that Biray Dogan had utterly Iailed her by the
advocacy zealous are not oI any sort whatsoever incident to his quote representation oI Coughlin" in
065630).
(again, judge SIerrazza as a Iormal tribal judge and director oI Indian legal services and Coughlin's
Iormer client Pete Eastman, recently admitted to Coughlin both oI the State Bar oI Nevada
communicated he and his wiIe Ialse assertions respecting a non-existent order against Coughlin by
Nevada Bankruptcy Court Judge Beesley (the State Bar oI Nevada listed as having a specialization in
creditors rights at www.nvbar.org) (Iormer law practice partners with an individual Irom Washoe Legal
Services whom Coughlin is suing in 60302, Karen Sabo, Esq., Iormerly oI Beesley Peck, LTD and
whom trashed Coughlin's work beIore him and in Nevada Bankruptcy Court at Coughlin's November
14, 2012 Iormal disciplinary hearing to which judge Beesley's testiIying was not noticed to Coughlin
previous to the hearing and in violation oI Supreme Court rule 109 a violation made all the worse in
light oI the Iact it bar counsel Pat King had known oI any involvement oI judge Beesley in any matters
relative to the ultimate Supreme Court rule 105 complaint against Coughlin Ior over six months at least
and so in no way can be said to just stuII I his last-minute supplementing judge Beesley and
milquetoast attempts to provide Coughlin S supplemental designation oI witness and summary oI
evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services
Executive Director Paul TESTIMONY at the hearing (both oI those gentlemen attended McGeorge
school oI law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both oI them
oIIered strong opinions disapproving oI Coughlin's competency as an attorney at the hearing despite the
Iact that neither oI them could provide anything in the way oI speciIicity with regard to what issues
they would take with any oI the work they reviewed oI Coughlin's or judge Beesley's case Iilings in
judge beIore judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court
Rule 121's conIidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin
Iormal disciplinary hearing him on behalI oI recently as oI November 8, 2012 reinstated attorney
Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 Irom his clients and
using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge
Beesley sees competency in Mr. Harris and could overlook the $755,000 Ior my client where it be $14
worth oI candy bars and cough drops Irom Coughlin and Coughlin's March 30, 2012 Iiling in Cadle Co.
v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at
2:30 pm in representing Mr. Keller that was aIIected by the Iraudulently procured order Ior summary
eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire
Brown judge Schroeder oI the Reno justice court wherein the audio record Irom that proceeding
indicates a Reno justice court clerk imploring judge Schroeder to hurriedly move the case summary
eviction case against Coughlin through despite Judge Schroeder admittedly having had a diIIerent order
oI hearing the cases planned Ior that morning docket and despite the Iact that the Iax header on the
summary eviction order that was hurriedly moved through indicates a time stamping oI a 8:24 am Ior a
hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County SheriII's oIIice deputies
Cannizzaro entered and broke into Coughlin's rental sometime shortly aIter 1 PM that same day,
3/15/12, without announcing themselves as law enIorcement and where they entered with their guns
and/or pagers drawn in and immediately placed Coughlin in handcuIIs and told him he was detained in
contrast to the typical procedures carried out by the SheriII's oIIice incident to evictions in Washoe
County. Incident to that summary eviction (where the docket, at least, more review is necessary,
indicates that Kern and Western Nevada Management's Sue King switched up their basis Ior an eviction
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all the sudden in their 3/15/12 Iiling oI a Landlord's AIIidavit that suddenly changed the basis Ior
seeking an eviction to one Ior non-payment oI rent (seemingly in response to Coughlin Pre Hearing
BrieI pointing out the diIIiculties they would Iace under Glazer in pursuing a No Cause, particularly
against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the
Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably
sublessors to Coughlin). in the third grievance against Coughlin Iorming SCR 105 complaint Ior which
a Iormal disciplinary hearing, the grievance Iiled by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School oI Law together in 1977. Perhaps,
the Iiling that Judge Beesley was reIerring to when he threw Coughlin under the bus at Coughlin's
11/14/12 Iormal disciplinary hearing (with one oI the three grievance numbers listed in the Complaint,
which the SBN and Panel will claim also IulIilled the Hearing required by 60838 Ior the Wal-Mart
candy bar conviction that resulted in the current now 5 month long suspension oI Coughlin's license to
practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin Iiled the Iollowing:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104
Entered: 3/30/2012 BrieI
Docket Text: BrieI in Opposition to Notice oI DeIault and Praecipe/Intent to take DeIault with
CertiIicate oI Service Filed by ZACH COUGHLIN on behalI oI SAMANTHA L. HALL, ROBERT
KELLER (Related document(s)49 Notice oI Entry oI DeIault Iiled by PlaintiII CADLE CO.)
(Attachments: # (1) AIIidavit AIIidavit oI Counsel Coughlin Ior Keller in Support oI Opposition# (2)
Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals
and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding
excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 Iax to rmc
regarding deIiciency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF APPEAL AND
MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inIlammatory 3/30/12 Iiling (which curiously seemed to immediately
result in Judge Nash Holmes entering an Order oI the same date in 11 TR 26800 whereby she Order
Coughlin's property released to him, though DDA Mary Kandaras dragged her Ieet until April 7th, 2012
beIore Iinally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately
admitted to having released to the City oI Reno Marshals on 2/28/12, denied having the micro sd card,
denied the micro sd ever being booked into property, alleged to have given Judge SIerrazza's Iormer
tribal court BailiII and Iormer Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the
jail at Coughlin's request to get Coughlin's keys so Eastman could arrange Ior Coughlin's dog Jackson
Pawluck to be Ied and cared Ior during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead oI his own (where Coughlin would arguably be better oII letting
the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card conIiscating without a
warrant/5 day summary contempt jail sentence Ior testiIying that an RPD Sargent lied in connection
with his testimony about the Richard G. Hill, Esq. retaliatory issuance oI three traIIic citations outside
Hill's law oIIice, where RPD Sargent John Tarter told Coughlin to leave aIter Coughlin presented upon
being released Irom jail incident to a three-day stay stemming Irom Hill's line 2 Reno Police
Department oIIicers and managing caught to get Coughlin subject to custodial trespassing arrest
(detailed at length in 61901) and Hill reIusing to give Coughlin his drivers license law accuser clients
Iiles and Coughlin reporting to Sargent John Tarter at that time that three days prior to that Reno Police
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Department oIIicer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him
as he too was on Richard Hill's payroll that RPD OIIicer Chris Carter, Jr admitted to Coughlin: "Yes,
Richard Hill pays me a lot oI money so I arrest who he says to arrest and I do what he says to do..." and
where both oIIicer Carter and Sargent Marcia Lopez reIused to undertake any diligent inquiry response
to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill Ior the Iull
rental value oI the 121 River rock property Ior the month oI November that was commiserate with the
same $900 that Coughlin was previously charged Ior the Iull use an occupancy oI the premises. The
lackluster Iailure to query Hill with any diligence by both oIIicer Carter and Sargent Lopez is
reminiscent oI what Reno Municipal Court Court appointed deIender Keith Loomis Esquire in 1982
graduate McGeorge school oI law told Coughlin at an April 10, 2012 trial date in that criminal trespass
matter wherein Reno Municipal Court judge William Gardner reIused to recuse himselI Irom hearing
that case against Coughlin despite the Iact that at that time he had Iiled a grievance with the State Bar
oI Nevada against Coughlin by way oI the NG 12 0434 grievance that his Iellow RMC judge Dorothy
Nash Holmes Iiled
Judge Beesley Iormerly partnered with now Washoe Legal Services child advocacy director Karen
Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes conIiscating
Coughlin's smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any
permissible interpretation oI a search incident to arrest given Coughlin property had been booked into
his personal property at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily
sentencing Coughlin to 5 days in jail Ior contempt, despite citing to a non summary civil contempt
statute in NRS 22.010 and NRS 22.100, but characterizing her Order as Iinding Coughlin guilty oI the
"misdemeanor oI criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt
statute, which is not summary in nature, and thereIore requires more due process, and despite Judge
Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even
said what Holme's alleged he did in rendering her "second bit at the apple" oI 3/12/12 in comparision to
her 2/28/12 Order Finding DeIendant in Contempt and Imposing Sanctions...In Nevada, a Summary
Contempt Order under NRS 22.030 (which is civil in nature) Ior conduct not committed in the
immediate presence oI the Court (such as the alleged conduct involving a restroom and disassembling a
smart phone or recording device and hiding some component part thereoI in the restroom that Judge
Nash Holmes murkily, hazily, and vaguely testiIied to during Coughlin's 11/14/12 Iormal disciplinary
hearing, and which she included in the Order she rendered in that traIIic citation case stemming Irom
Coughlin being told to leave Hill's law oIIice upon appearing their demanding his keys, wallets, driver's
license, and client's Iiles shortly aIter being released Irom a 3 day custodial arrest stay in jail incident to
Hill's criminal trespass Complaint against Coughlin at Coughlin's Iormer home law oIIice (in RJC2011-
001708, the eviction matter presided over by Judge SIerrazza). Like the Order Judge Linda Gardner
claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis
FV11-03383 (see attached in Exhibit 1), Judge SIerrazza attempted to characterize the Order he entered
on 12/21/12 Iollowing a very contentious six hour hearing on Coughlin's November 17th, 2011 Iiled
stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to Contest
Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was
certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge SIerrazza
may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere
wherein Richard Hill was permitted to joke along with Reno justice court bailiIIs radius in chieI bailiII
Sexton as to the Iact that he to quote would like to stick some things up Coughlin's ass" in reIerence to
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multiple incidents where Reno justice court bailiIIs had either as bailiII arrested told Coughlin that he
would put his Ioot oI Coughlin's ass or made commentary as chieI Sexton did to Coughlin respecting
Sexton's indication oI Coughlin on two diIIerent occasions the week oI Thanksgiving 2011 that
Coughlin indicated that the Iiling oIIice and/or not attempt to Iile documents so close to the 5 PM
closing time oI the Iiling oIIice. (see attached in Exhibit 1).
and him him him him and him In Iact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes,
inaccurately:
"4. We represent Dr. Matthew MerIiss, a physician Irom Chico, CaliIornia. Dr. Merliss owns the
property at 121 River Rock Street, Reno, Nevada. Beginning in March 2010, the property was leased to
Mr. Coughlin and his then-girlIriend. The lease expired in February 2011. The girlIriend leIt the
community in approximately May 2011. Dr. Merliss contacted us in approximately August 2011 to
assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that
there were habitability issues with the property that justiIied his withholding rent. All oI his clahns
were decided adversely to his position at the eviction hearing. Justice oI the Peace Peter SIerazza
ordered Coughlin evicted Irom the premises eIIective November 1, 2011. On that date, the Washoe
County SheriIIs Department perIormed their normal eviction procedure: locks were changed and the
eviction notice was posted on the Iront door. We videotaped the home and its contents at that time.
Upon inspection over the next Iew days, it became apparent that "somebody" was breaking into the
home on a regular basis. On Sunday, November 13, 2011, Dr. Merliss came to town, and I met him at
the home on River Rock Street. As we walked through the home, it was obvious that"
One, it is not true Ior Hill to write "The lease expired in February 2011." The Standard Rental
Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in
accordance with the NRS 118A holdover tenant provision. Further, it is not accurate Ior Hill to write
"Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with
Coughlin's Iormer co-tenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment
payments to make up Ior the Iact that she took Coughlin's $450 contribution to the $900 Ior each oI the
months oI May 2011 and June 2011 and only sent the landlord Merliss $550 Ior May 2011 and nothing
Ior June 2011. Coughlin provided Ms. Ulloa with $450 Ior each oI those months, and thereIore, in
combination with Dr. Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa Irom
a grand larceny charge oI a variety to which the two petty larceny charges Coughlin Iaced shortly aIter
Ms. Ulloa's secretly absconding with Coughlin's rental contributions (which Coughlin was only made
aware, and the concomitant rent due, upon an August 11th, 2011 email Irom the landlord Merliss).
Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 beIore Judge
SIerrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices,
in violation oI NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an
agreement with Coughlin Ior a rent deduction oI $350 going Iorward in exchange Ior Coughlin
"dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artiIicial turI
installation Coughlin had installed in an enterprising approach which the landlord's landscaper Ior the
other property Merliss owned next door and his quasi real estate broker property manager Darlene
Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually
claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn
Service to "deal with the weeds" at Coughlin's Iormer home law oIIice. "Dealing with the weeds", to
Green Action Lawn Service, included tearing up Coughlin's artiIicial turI installation leaving Street
causing Coughlin's law oIIice substantial losses lost proIits time away Irom work and expenses
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associated with immediately mitigating the criminal conduct oI green action lawn service where they
not only tore up the artiIicial turI installation even though they knew it was there prior to submitting
their bid Ior services to landlord Merliss, who apparently did not realize or remember that he had also
assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange Ior Coughlin
quote dealing with the weeds. Green action lawn service sought close the artiIicial turI installation
Coughlin put into place oI his Iormer law oIIice the week prior to their tearing it up and leaving
industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
Hill's grievance oI 1/14/12 to the SBN goes on to allege:
"Someone had been in there since I had last been in several days beIore. Dr. Merliss discovered that the
basement door was barricaded (not locked) Irom the inside. The Reno Police Department was
summoned. They tried to coax whoever was in the basement out, without success. AIter Dr. Merliss had
to kick the door down, it "was discovered that Mr. Coughlin had broken in and was in the basement. He
was arrested and is presently Iacing criminal trespass charges in Reno Municipal Court. See case no. 11
CR 26405 21. He is also Iacing a contempt motion in Iront oI Judge SIerrazza in the eviction case.
SIerazza has stayed that matter pending the resolution oI the criminal trial. That was scheduled Ior
January 10, 2012, but was continued at the request oI Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District Court. See case CVl1-o3628,
pending in Department 7. As part oI the eviction process, a lien was asserted against the personal
property that Coughlin leIt behind at the home. On November 16, 2011, Coughlin Iiled a motion to
contest the landlord's lien in the Reno Justice Court. The court tried to promptly set a hearing, but
Coughlin reIused to cooperate in setting the matter, and the court took it oII calendar. Coughlin then
reinitiated that process and a hearing was held in December, at which time the court heard evidence oI
Coughlin's lack oI cooperation in setting the November hearing. You may also want to contact Reno
Justice Court staII, and in particular, chieI clerk Karen Stancil, about Mr. Coughlin's abusive treatment
oI her and her staII. AIter the hearing, the court issued an Order granting Coughlin a two-day time
window to remove his personal property. The Iirst day was Thursday, December 22, 20 11. AIter
Coughlin was allowed into the home that Iirst day, he sent out an e-mail to the eIIect that because he
had appealed Judge SIerazza's order, he was entitled to a stay oI proceedings and was to resume in the
home. As a result, he did very little to remove any oI his personal property that day. On Friday,
December 23, 2011, aIter he learned, again, that his stay had been denied, Coughlin assembled a small
crew and they were able to remove a substantial amount oI his personal property. (You need to
understand that Mr. Coughlin is a hoarder. We have the photos and videos iI you would like to see
them.) However, Mr. Coughlin did not get all oI his property out. For example, I counted 13 car seats
that he had somehow managed to get down into the basement.
Having Iailed to remove all oI his belongings, Mr. Coughlin then moved beIore Judge Flanagan Ior a
temporary restraining order to prevent the disposal oI his abandoned property in accordance with Judge
SIerazza's order. Attached is Mr. Coughlin's motion, my oIIice's opposition, and Mr. Coughlin's reply.
These documents demonstrate Mr. Coughlin's complete and utter incompetence as an attorney.
On January 11, 2012, Judge Flanagan denied Mr. Coughlin's request Ior a temporary restraining order.
On January 12, 2011, the contractor hired to clean the house commenced work. Mr. Coughlin Ilagged
the contractor down in traIIic when he (the contractor) was on his way to the dump with the abandoned
property Irom the house. Coughlin called the police, who arrived at the transIer station. Coughlin was
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Ialsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, Iinally) can be described thusly:
PHONE CALL StartTime Saturday, August 20, 2011 11-22-52 PM SourceID 50 Cory Goble's
Iirst 911 call Irom Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-29 PM SourceID 43
Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-34 PM SourceID 46
Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-06 PM SourceID 13
reporting party advised they are now at Iirst and center.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-22 PM SourceID 21
probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-30 PM SourceID 12
RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-34 PM SourceID 14
unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-25 PM SourceID 41
probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-29 PM SourceID 43
probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11 PM SourceID 17
Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM SourceID 18
Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-40 AM SourceID 17
Dispatcher indicating Reno C153 wagon available Ior a male.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-51 AM SourceID 26
someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-19-51 AM SourceID 42
probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-21-02 AM SourceID 28
odd by somebody c153 seems to split in middle yet still one Iile.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-03 AM SourceID 22
Duralde saying Reno c153 rtI returning.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-10 AM SourceID 27
Duralde's wiIe Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM SourceID
5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-31 PM SourceID
19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-37-23 PM SourceID
24 man saying come and split that up then Iemale dispatcher saying go ahead with that.wav
Zach Coughlin
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1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlinhotmail.com
Zach has 24 Iiles to share with you on SkyDrive. To view them, click the links below.
PHONE CALL StartTime Saturday, August 20, 2011 11-22-52 PM SourceID 50 Cory
Goble's Iirst 911 call Irom Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-11 PM
SourceID 39 weese 063341 c153 scene 10 N Virginia rink check larceny cell phone susp os also
loud verb disturb.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-29 PM
SourceID 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-24-34 PM
SourceID 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-06 PM
SourceID 13 reporting party advised they are now at Iirst and center.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-25-22 PM
SourceID 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-30 PM
SourceID 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-26-34 PM
SourceID 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-25 PM
SourceID 41 probably Duralde saying Reno C153 twenty three.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-27-29 PM
SourceID 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-11 PM
SourceID 17 Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
PRIMARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-28-17 PM
SourceID 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-40 AM SourceID
17 Dispatcher indicating Reno C153 wagon available Ior a male.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-08-51 AM SourceID
26 someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-16-41 AM SourceID
13 Duralde indicated he will be en route to main station to drop oII Coughlin's smartphone Ior
copying data prior to depart.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-19-51 AM SourceID
42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-21-02 AM SourceID
28 odd by somebody c153 seems to split in middle yet still one Iile.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-03 AM SourceID
22 Duralde saying Reno c153 rtI returning.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-10 AM SourceID
27 Duralde's wiIe Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
PRIMARY RADIO TRAFFIC StartTime Sunday, August 21, 2011 12-38-41 AM SourceID
6 Duralde's wiIe Jessica c151 reno, Alaksa can you switch to share some inIormation call please.wav
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SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-19 PM
SourceID 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-36-31 PM
SourceID 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC StartTime Saturday, August 20, 2011 11-37-23 PM
SourceID 24 man saying come and split that up then Iemale dispatcher saying go ahead with
that.wav
11 30 12 063341 updated motion Ior new trial with ex 1 attached in 2 pages per Iormat.pdI
Download all
--Forwarded Message Attachment--
Close Print
Case No. RCR2011-063341
From: Jeannie Homer (HomerJreno.gov)
Sent: Thu 11/08/12 2:48 PM
To: zachcoughlinhotmail.com
3 attachments
Motion Ior Protective Order toQuash Subpoenas and Ior Protective Order Regarding Issuance
oISubpoenas.pdI (2.2 MB) , Motion Ior Protective Order toQuash Subpoenas and Ior Protective Order
Regarding Issuance oI Subpoenas|Part 2|.pdI (1442.4 KB) , Ex Parte Emergency Order
PendingHearing.pdI (81.0 KB)
Please see attached documents Irom Creig Skau, Deputy City Attorney:
1) Motion Ior Protective Order to Quash Subpoenas and Ior Protective Order Regarding Issuance oI
Subpoenas (part 1 & 2)
2) Ex Parte Emergency Order Pending Hearing (set Ior November 13, 2012 at 9:00a.m.)
Thank you.
Jeannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/Iax
homerjreno.gov
ATTORNEY-CLIENT PRIVILEGE
This e-mail message transmission and any documents, Iiles or previous e-mail messages attached to it
are conIidential, and are protected by the attorney-client privilege and/or work product doctrine. II you
are not the intended recipient or a person responsible Ior delivering it to the intended recipient you are
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hereby notiIied that any review, disclosure, copying, dissemination, distribution or use oI any oI the
inIormation contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. II you
have received this transmission in error, please immediately notiIy us by Iorwarding this e-mail to the
sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
Fwd: FW: Case No. RCR2011-063341
From: Creighton C. Skau (skaucreno.gov)
Sent: Fri 11/09/12 11:45 AM
To: zachcoughlinhotmail.com
Cc: Jeannie Homer (HomerJreno.gov)
1 attachment
photo|1|.JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge SIeraza authorized service upon you by email in an Order.
Accordingly, authorized service has already been eIIected.
Since you claim you cannot open the pdI attachments to my secretary's last email, I oIIer
alternatives:
1. Set Iorth below is the language oI Judge SIeraza's Order and the language oI the City's Motion.
UnIortunately, I cannot replicate the attachments. However, they consisted mostly oI documents you
purportedly served, so you should be Iamiliar with them. Also, I am providing alternative means Ior
you to obtain the documents, as set Iorth hereaIter.
2. The Court provided us with an address which you provided to the Court. That address is 1471
E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday,
but you were apparently not there. Today, Reno Carson Messanger Service again attempted to serve
you there at around 11:00 a.m. They called my oIIice and were directed to leave the Judges Order and
the City's motion at the Iront oI that address. They have provided me with a photograph oI the packet
leIt at the Iront door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our OIIice at 334-2050 and request a copy Irom Ms. Homer, which you may
pick up at our OIIice, third Iloor oI City Hall.
The Judge's signed Order, entered November 8, 2012, states:
IN THE JUSTICE COURT OF RENO TOWNSHIP
COUNTYOF WASHOE, STATE OF NEVADA
STATE OF NEVADA,
PlaintiIIs,
vs.
COUGHLIN, ZACHARY BARKER
DeIendant.
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CASE NO.: RCR2011-063341
DEPT. NO.: 2
EX PARTE EMERGENCY ORDER PENDING HEARING
This matter has come beIore the Court based upon the Iollowing circumstances:
A. The Reno City Attorney`s OIIice ('RCAO) represents a number oI City oI Reno employees
who have been named in subpoenas. The RCAO contacted Court personnel on November 7, 2012 to
request a time to appear Ior an order shortening time regarding a motion to quash and Ior protective
order. Due to the proximity oI the trial date in this matter, November 19, 2012, the Court directed the
RCAO to Iile and serve its substantive motion and provide notice that the matter would be heard on
November 8, 2012 at 9:00 am. The City oI Reno Iiled its motion on November 7, 2012.
B. At the hearing on this matter on November 8, 2012, Deputy City Attorney Creig Skau appeared
on behalI oI the RCAO and the City employees requesting protective relieI. Zack Young was present
in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belieI that the
Public DeIender`s oIIice represented Mr. Coughlin, that the Public DeIender was served believing this
was service upon Mr. Coughlin, that he learned Mr. Coughlin represented himselI this morning and
attempted to call and leIt a voice mail message with a phone number believed to be Mr. Coughlin`s at
8:30 this morning.
C. The Court is advised that the Public DeIender, Jeremy Bosler and the City oI Reno ChieI
Criminal Deputy City Attorney, Dan Wong, may also have received subpoenas and Iiled requests Ior
relieI similar to the RCAO`s requests.
D. The Court read the RCAO`s motion in preparation Ior the hearing. Due to the absence oI notice
to Mr. Coughlin, no argument was received on the merits oI the motion. However, the Court Iinds that
the RCAO`s motion and supporting materials present a suIIicient evidentiary basis to issue this Order.
The Court deeming itselI suIIiciently inIormed and good cause appearing thereIore,
IT IS HEREBY ORDERED as Iollows:
1. A hearing on the merits oI these matters is hereby set beIore this Court Ior 9:00 a.m. on
November 13, 2012. Oral presentations shall be limited to 10 minutes each. The Clerk shall notiIy Mr.
Bosler and Mr. Wong oI the hearing.
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2. Any subpoena not properly issued by the clerk or otherwise not properly issued in accordance
with NRS 174.305 is hereby quashed. Any subpoena not personally served by a non-party or otherwise
properly served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on
any other grounds such as relevancy or undue burden until the hearing on the merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), eIIective until the hearing
on this matter on November 13, 2012, to the eIIect that upon service oI this Order on DeIendant
Zachary Barker Coughlin, DeIendant Coughlin shall not thereaIter issue or cause to be issued or serve
or attempt to serve or cause to be served any subpoena or subpoena duces tecum in this case unless he
has Iirst presented the proposed subpoena or subpoena duces tecum to the Court Ior the Court`s review
regarding adequacy, relevancy and necessity oI the subpoena or subpoena duces tecum, and suIIiciency
oI the proposed method oI service.
4. Counsel Irom the Reno City Attorney`s OIIice is directed to promptly attempt to serve a copy oI
this Order and the RCAO`s motion and any supplements by personal service upon Zachary Barker
Coughlin at the address in the Court`s Iile, 1471 E. 9th Street, Reno, NV 89512, with a copy mailed to
said address. Service shall also be attempted by email at 'zachcoughlinhotmail.com.
Dated this |8| day oI November, 2012.
/s/
JUSTICE OF THE PEACE
The City oI Reno's Motion states:
JOHN J. KADLIC
RenoCityAttorney
CREIGTON SKAU
Deputy City Attorney
NevadaState Bar No. 34
P.O. Box1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneys Ior City oI Reno
IN THE JUSTICE COURT OF RENO TOWNSHIP
COUNTYOF WASHOE, STATE OF NEVADA
STATE OF NEVADA, Case No. RCR2011-063341
PlaintiIIs, Dept. No. 2
vs.
COUGHLIN, ZACHARY BARKER,
/
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE
ORDER REGARDING ISSUANCE OF SUBPOENAS
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COMES NOW, City oI Reno ('City), as the employer and on behalI oI Reno Police
Department OIIicers Ron Rosa and Thomas Alaksa, and Court Marshall Joel Harley and Reno
Emergency Communication Center employees Savannah Montgomery and Scott Weese (and any other
City employees (collectively 'City employees) whose names were unreadable in subpoenas), by and
through their counsel oI record, John J. Kadlic, Reno City Attorney, and Creig Skau, Deputy City
Attorney, and hereby moves this Court Ior an order to quash the subpoenas claimed to have been served
on Ior these City employees in violation oI Justice Court Rules oI Civil Procedure (JCRCP) 45 and Ior
the entry oI a protective order pursuant to the
///
JCRCP 26. This Motion is based upon the attached memo oI Points and Authorities, the attached
Exhibits and any additional or Iurther evidence the Court deems just and proper.
I. Statement oI Facts
The Iollowing procedural background is relevant to this matter:
On October 26, 2012, City oI Reno Emergency Communication Center employees (ECOMM) Suzy
Rogers and Kelley Odom received emails Irom Zach Coughlin containing nine (9) Subpoenas, copies
oI which are attached as Exhibit '1 and incorporated herein by reIerence.
On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail inIorming him,
among other things, the City oI Reno Police Report and City oI Reno ECOMM materials regarding
Case Number RMC 2011-063341were available Ior pick-up provided he submit payment to the City oI
Reno Ior $108. A copy oI the letter is attached as Exhibit '2 and incorporated herein by reIerence. On
November 5, 2012, this same letter was sent again to Mr. Coughlin by certiIied mail to the same two
addresses.
This correspondence also inIormed Mr. Coughlin that the Iour (4) subpoenas he claimed to have served
regarding the appearance oI the City employees Ron Rosa, Thomas Alaksa, Savannah Montgomery and
Scott Weese were ineIIective because oI a Iailure to comply with JCRCP 45(a) and/or JCRCP 45(b).
The letter indicated because service oI the subpoenas Ior these Iour (4) individuals was ineIIective,
these individuals would not be appearing on November 19, 2012. (Exhibit '2).
On November 1, 2012, Mr. Coughlin delivered twelve (12) subpoenas and a 'Notice oI Errata and
Revised Supplemental Motion For a New Trial by sliding them
through the security glass in the Iront oIIice oI the Reno Police Department at approximately 4:50 p.m.
aIter being told the oIIice was closed. Three (3) subpoenas contained in this packet are duplicates. As
such, this packet appears to contain the same ten (10) subpoenas he previously sent to Reno ECOMM
employees Kelley Odom and Suzy Rogers. A copy oI this packet is attached as Exhibit '3 and
incorporated herein by reIerence.
On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM
employees, Kelley Odom and Kariann Beechler, seeking documents previously requested in earlier
subpoenas duces tecum. These subpoenas also contained multiple pages oI requests Ior materials
unrelated to Case RMC RCR2011-063341. A copy oI these documents is attached as Exhibit '4 and
incorporated herein by reIerence.
On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call Irom Mr. Coughlin
regarding the letter this oIIice mailed on November 2, 2012. Among other things, Mr. Coughlin did not
indicate he would be withdrawing his subpoenas Ior Ron Rosa, Thomas Alaksa, Savannah
Montgomery and Scott Weese. Mr. Coughlin did state to have these witnesses ready Ior trial.
On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum
containing seventeen (17) pages oI blended documents regarding matters pending beIore Reno Justice
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Court on November 19, 2012 and the State Bar OI Nevada Northern Nevada Disciplinary Board to the
Reno Police Department. The subpoena duces tecum on the Iirst page oI the packet contains many
unreadable names. A copy oI the packet is attached as Exhibit '5.
On November 6, 2012 City employee Marshall Joe Harley was handed a packet oI materials Irom an
unidentiIied person. The cover sheet oI the packed is entitled 'Subpoena Duces Tecum regarding
Case RCR2011-063341. This document also appears to contain names oI other individuals but the
handwriting is unreadable. It is not known iI the other individuals on this subpoena are City
employees. A headnote on the Subpoena indicates that iI the requested documents are e-mailed to Mr.
Coughlin, personal appearance may not be required. A copy oI the packet is attached as Exhibit '6.
II. Argument :
A. Service
JCRCP 45 addresses subpoenas. In pertinent part it states:
(b) Service.
(1) A subpoena may be served by any person who is not a party and is not less than 18 years oI age.
Service oI a subpoena upon a person named therein shall be made by delivering a copy thereoI to such
person and, iI the person's attendance is commanded, by tendering to that person the Iees Ior one day's
attendance and the mileage allowed by law. When the subpoena is issued on behalI oI the State or an
oIIicer or agency thereoI, Iees and mileage need not be tendered. Prior notice, not less than 15 days, oI
any commanded production oI documents and things or inspection oI premises beIore trial shall be
served on each party in the manner prescribed by Rule 5(b).
The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on
October 26, 2012 and November 3, 2012 and re-delivered to the Reno Police Department on November
2, 2012 and November 6, 2012 commanding the appearance oI the many diIIerent City employees
above are deIicient and ineIIective as they Iail to comply with personal service requirement oI JCRCP
45(b). Accordingly, service was ineIIective and all oI the subpoenas should be quashed.
In addition to the Iailure oI personal service, all oI Mr. Coughlin`s subpoenas reIerenced in Exhibits
'1, '3, '4 and '5, also:
Violate JCRCP 45(a)(1)(D) in that they do not set Iorth the text oI subdivisions (c) and (d) oI JCRCP
45.
Violate JCRCP 45(b)(1) which states that a 'subpoena may be served by any person who is not a party
to the proceeding. All oI the subpoenas were e-mailed to City ECOMM employees Kelley Odom,
Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2,
2012 and November 6, 2012 by Mr. Coughlin, a party in this matter.
Violate JCRCP 45(b)(1) which states that service oI a subpoena commanding attendance requires that
payment Ior one day`s attendance and the mileage allowed by law. No witness Iee or mileage Iee has
been submitted by Mr. Coughlin Ior the appearance any named City employee.
Violate JCRCP 45(c) which states that a party or attorney responsible Ior the issuance and service oI a
subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to
the subpoena. Mr. Coughlin is serving a litany oI subpoenas on many City departments and City
employees regarding this case. However, he is also serving subpoenas on City departments and City
employees on a multitude oI other cases and proceedings that are unrelated to the instant action. These
subpoenas are unduly burdensome, duplicative, irrelevant, unintelligible, oppressive, harassing, seek
inIormation that is irrelevant to this action and violate the applicable procedural rules.
54/60
000093
Based on the above, the requirements oI JCRCP Rule 45 have not been met and the subpoenas Ior
all City employees to appear on November 19, 2012 must be quashed. The City
also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom,
Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not
relate to the City or to this matter.
B. Protective Order
In accordance with JCRCP 26, the City seeks a protective order in this matter. As described above, Mr.
Coughlin, a Nevada attorney with a suspended license, is abusing the subpoena process granted to him
by this Court. He is e-mailing multiple City employees or dropping oII the same subpoenas (some oI
which relate to this matter and many which relate to a State Bar proceeding or other criminal matters)
at multiple City departments. This is creating conIusion and leading to a waste oI time and resources
oI public saIety employees. As an attorney, Mr. Coughlin should be aware oI the subpoena process.
This is not the Iirst matter in which Mr. Coughlin has abused a court procedural matter. For this
Court`s inIormation, Reno Municipal Court Judge Holmes issued a Sua Sponte Order Denying RelieI
Sought in Improper Document on March 13, 2012 Iinding, among other things, that Mr. Coughlin
Iailed to Iollow proper legal procedure in preparing and Iiling motions in a matter pending beIore that
Court and that Mr. Coughlin blatantly abused that Court`s Iax Iiling process. As such, that Court
ordered that Mr. Coughlin be prohibited Irom Iaxing any documents to that Court. A copy oI this
Order is attached as Exhibit '7.
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectIully seeks an Order
Irom this Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this
Court Ior review prior to issuance and service to ensure Mr. Coughlin is seeking relevant inIormation
regarding a speciIic case and is Iollowing the appropriate legal process.
III. CONCLUSION
Based on the above, it is respectIully requested that this Court issue an order:
To quash the subpoenas Ior Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel
Harley or any other City employee whose names were unreadable in the subpoenas Ior Iailure to
comply with JCRCP Rule 45;
To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann
Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate to the
City or to this matter because they Iailed to comply with JCRCP Rule 45.
Grant a protective order to the City pursuant to JCRCP 26 requiring Mr. Coughlin to submit any
subpoena he intends to serve in this matter to this Court Ior review prior to issuance and service to
ensure Mr. Coughlin`s subpoenas are relevant and Iollow the appropriate legal process.
AFFIRMATION
The undersigned does hereby aIIirm that the preceding document Iiled in this court does not
contain the social security number oI any person.
RESPECTFULLY SUBMITTED this day oI November, 2012.
JOHN J. KADLIC
Reno City Attorney
By:
CREIGTON SKAU
Deputy City Attorney
55/60
000094
P.O. Box 1900
Reno, NV 89505
Attorneys Ior City oI Reno
As to the other matters addressed by you below, I work in the Civil Division and I have no
knowledge or authority to address them. I suggest that you take up those matters with the attorney(s)
assigned to them.
Sincerely,
Creig Skau
Deputy Reno City Attorney
-----Original Message-----
From: Jeannie Homer homerjreno.gov~
To: "'bonyrreno.gov'" bonyrreno.gov~, "'skaucreno.gov'" skaucreno.gov~
Date: Fri, 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI
From: Zach Coughlin |mailto:zachcoughlinhotmail.com|
Sent: Thursday, November 08, 2012 8:36 PM
To: HomerJreno.gov; complaintsnvbar.org; hazlett-stevenscreno.gov; robertspreno.gov;
kadlicjreno.gov; IIlahertydlpId.com; patrickknvbar.org; tsusichnvdetr.org
Subject: RE: Case No. RCR2011-063341
couldn't open them, and I don't accept service oI anything Iorm you... See Allison Ormaas comments
on 3/12/12 in 11 tr 26800 with respect to your oIIices violation oI the RMC Rules to the extent there is
not diIIerence technologically anymore between an email and a Iax:
Rule 5: Motions/Pleadings by Facsimile
A. All rules and procedures that apply to motions/pleadings Iiled in person at the court shall also
apply to motions/pleadings Iiled by Iacsimile, except as otherwise speciIied in this rule.
B. All motions/pleadings Iiled by Iacsimile will only be accepted through the clerk's oIIice (775-
334-3824).
C. Except by prior court approval, a motion/pleading by Iacsimile shall not exceed IiIteen (15) pages
in length, including the cover sheet and exhibits. A document shall not be split into multiple
transmissions to avoid the page limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-Iacsimile procedures.
F. All motions/pleadings Iiled by Iacsimile must be accompanied by a cover sheet which must
include the person`s name, address, Iax number and telephone number.
G. All Iacsimile motions/pleadings Iiled by an attorney must include the attorney's name, the Iirm`s
56/60
000095
name, address, Iax number and telephone number. In addition, the attorney`s state bar number must be
conspicuously displayed on the cover sheet.
H. All motions /pleadings Iiled by Iacsimile must be accompanied by prooI oI service. Service may
be accomplished by Iacsimile when the receiving party is a governmental agency, an attorney, or with
the consent oI the receiving party. II service oI the motion/pleading is accomplished by Iacsimile the 3-
day allowance Ior mailing shall not be computed into the time Ior response.
I. A deIense attorney Iiling a motion/pleading in the Iirst instance must also Iile a proper
authorization to represent.
J. Any motion /pleading received by the court aIter 4:30 p.m. or on a non-court day shall be Iiled on
the Iollo wing court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except Ior good cause. A motion
or stipulation Ior continuance must state the reason thereIore and whether or not any continuance has
previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where
(despite Rich HIll getting a continuance agree to by then court appointed deIense counsel Lew Taitel,
whose business partners Coughlin was suing in CV11-03015 and or CV11-03126, Taitel agreed to a
continuance, in violation oI Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at Iirst agreed, in writing, to a continuance in response to Coughlin's
request Ior one in 11 CR 22176, but then retaliated against Coughlin's pointing out her RPC 3.8
violations on the day oI Trial, 11/30/12 by reIusing the stipulate to a continuance an blaming it on the
Court.
Pursuant to RMCR Rule 5(H), the City Attorney's OIIice does not have my consent to service via any
means other than the traditional snail mail, usps, or personal service. And I am not currently included
amongst those who are "attorneys", so you are stuck with that. Your oIIice on the other hand, Iits
within both the 'governmental agency" and "attorney exceptions"...someone needs to tell Christopher
Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served
where he has been. Take, Ior instance
Further, does your oIIice represent any oI the RMC's court appointed deIenders? Taitel, in 11 CR
26405, Iailed to Iollow RMC Rules in withdrawing Irom representation:
Rule 3: Authorization to Represent
A. Attorneys representing deIendants shall promptly serve written notice oI their appearance with
the City Attorney and Iile the same with the Court.
B. An attorney desiring to withdraw Irom a case shall Iile a motion with the court and serve the City
Attorney with the same. The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out oI the blue, is there some record oI what changes were
made and when?
Hazlett-Steven's lies, in part, helped secure a dismissal oI my appeal in cr12-1262 (the appeal oI the
Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner
as to why Coughlin has a conIirmation oI delivery oI his timely under NRS 189.010 Notice oI Appeal
in 11 cr 26405, yet D2 Iailed to Iile it, and the appeal in cr12-1262 was dismissed in light oI the
combination oI both asserting, in one way or another, that the Notice oI Appeal was not received in a
57/60
000096
timely manner. The delivery conIirmations say otherwise.
Please remit $250,000 in the Iorm oI a certiIied check to the address below within 10 days in settlement
oI these torts. SBN, please provide to me the grievance number associate with this new grievance that
is created upon the successIul transmission oI this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlinhotmail.com
utbound Iax report
Inbox
x
Voxox noreplyvoxox.com
Jun 27
to me
Hi zachcoughlin,
You r Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
( 17753344226).
Your Fax was delivered 08:54:28 PM on 2012-06-27.
xoxo,
The Voxox Team
This message was intended Ior renoattorneygmail.com. Want to control which emails you receive
Irom Voxox? Get Voxox: http://download.voxox.com and adjust your NotiIications in the
Settings/PreIerences window. Voxox by TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA
92109.
Voxox noreplyvoxox.com
Jun 27
58/60
000097
to me
Hi zachcoughlin,
Your Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
( 17753344226).
Your Fax was delivered 09:16:58 PM on 2012-06-27.
Voxox noreplyvoxox.com
Jun 28
to me
Hi zachcoughlin,
Your Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
( 17753344226).
Your Fax was delivered 08:13:34 AM on 2012-06-28.
Voxox noreplyvoxox.com
Jun 28
to me
Hi zachcoughlin,
Your Fax was successIully sent to 14021bda-178b-448I-aIcc-1aI150604a18general693298
( 17753344226).
Your Fax was delivered 09:04:24 AM on 2012-06-28.
Voxox noreplyvoxox.com
Jun 28
to me
59/60
000098
Hi zachcoughlin,
Your Fax was successIully sent to 3ad3I15b-3a33-4863-a6cd-7934ec8I8b32general693298
( 17753343859).
Your Fax was delivered 09:05:24 AM on 2012-06-28.
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJreno.gov
To: zachcoughlinhotmail.com
Subject: Case No. RCR2011-063341
Please see attached documents Irom Creig Skau, Deputy City Attorney:
1) Motion Ior Protective Order to Quash Subpoenas and Ior Protective Order Regarding Issuance oI
Subpoenas (part 1 & 2)
2) Ex Parte Emergency Order Pending Hearing (set Ior November 13, 2012 at 9:00a.m.)
Thank you.
Jeannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/Iax
homerjreno.gov
ATTORNEY-CLIENT PRIVILEGE
This e-mail message transmission and any documents, Iiles or previous e-mail messages attached to it
are conIidential, and are protected by the attorney-client privilege and/or work product doctrine. II you
are not the intended recipient or a person responsible Ior delivering it to the intended recipient you are
hereby notiIied that any review, disclosure, copying, dissemination, distribution or use oI any oI the
inIormation contained in, or attached to this e-mail transmission is STRICTLY PROHIBITED. II you
have received this transmission in error, please immediately notiIy us by Iorwarding this e-mail to the
sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
60/60
000099
Print Close
State Bar of Nevada refusing to file stamp Respondent's pleadings
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 12/03/12 10:48 AM
To: Patrick King ( (patrickk@nvbar.org); (davidc@nvbar.org) (davidc@nvbar.org); (tsusich@nvdetr.org)
(tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (mike@tahoelawyer.com)
(mike@tahoelawyer.com); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
(eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com); (skent@skentlaw.com)
(skent@skentlaw.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); schornsby@nvdetr.org
(schornsby@nvdetr.org)
Please incorporate by reference all my filings with the Nevada Supreme Court into any
answer or responsive pleadings you find I have filed.
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 30 files to share with you on SkyDrive. To view them, click the links below.
12 1 12 ex 1 to notice to that laura peters is 0204 screen print bz.pdf
12 1 12 ex 1 to notice that laura peters affidavit is whopper chocked 0204 bate stamped.pdf
12 1 30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs
attachment.pdf
6 7 12 email to gammick and @nvbar.org four hours before 60838 suspension order 0204.htm
6 9 12 Petty theft conviction leads to Reno lawyer's suspension - News - ReviewJournal.com.pdf
6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process 60838 0204.pdf
6 18 12 12-18962 60838 in re coughlin scr 111 filed stamped.pdf
6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf
6 25 12 SCR 115 Affidavit Coughlin 12-19902 0204 60838.pdf
6 25 12 stamped Coughlin's motion for extensio nto file brief and exhibit 60302.pdf
6 25 12 stamped 60302 MOTION FOR PERMISSION TO FILE OPENING BRIEF AFTER DEADLINE HAS RUN.pdf
8 13 12 61426 stamped Coughlins PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf
000100
8 27 12 stamped 60331 APPELLANT'S Motion IFP with attached proposed Opening Brief.pdf
8 28 12 stamped 60302 coughlin v wls appellant's opening brief[1].pdf
8 28 12 stamped 60302 Coughlin's Opening Brief wls 60302 12-27202 0204.pdf
10 5 12 60838 file stamped proof of service of Petition In Re Coughlin.pdf
10 5 12 file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution.pdf
10 5 12 filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 Coughlin.pdf
10 15 12 stamped 61901 Kings SCR 111(4) petition for 26405 trespass conviction.pdf
10 22 12 60203 garin's respondent's brief back from tiff.pdf
Download all
From: zachcoughlin@hotmail.com
To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; mike@tahoelawyer.com;
complaints@nvbar.org; eifert.nta@att.net; cvellis@bhfs.com; skent@skentlaw.com
Subject: RE: Mr Coughlin
Date: Wed, 21 Nov 2012 21:22:16 -0800
Dear SBN and Panel
The Disciplinary Hearing File that Pat King purported to have copied and provided to
me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
not being filestamped...). Echeverria's very ruling on filing he was not mailed (to
the extent that was the case, and perhaps it was a test) concedes at least the
approval of filign by fax (express indication of the permissibility thereof in
accordance with SCR 105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
Please confirm that my filings, all of them, including the Motion to Show Cause of
10/2/12, starting on bate stamp 02849 have been provided to all Panel members as
the SBN has repeatedly indicated they would be (included the copying of all
attachments, including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a
file stamp (and it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs
indicates...which means the SBN failed to Oppose the Motion to Dismiss, and the
Complaint was dismissed prior to any other purported proof of service being
effected (or spurious assertions of Coughlin dodging service given his numerous
000101
written correspondences and calls offering to meet Reno Carson or the SBN...until
Coughlin finally just gave the SBN his physical address on 10/23/12, despite safety
concerns....)
Who gave you this order that you attached in the email of your's included below (the
8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
of these grievances? Did Mr. Susich disclose that conflict incident to the problems
Maureen Cole had in carrying out the duties of her job as an attorney for the NV
DETR and NERC?
Please copy me on anything proving Chairman Susich so disclosed that conflict.
Additionally, more and more frequently, when I question Laura Peters on some
misstatement or attempt to mislead that she makes, she starts talking about getting a
"protection order" or otherwise seeking to abuse process. Speaking of abusing
process, due process namely, Peters was caught signing Certificates of Mailing for
10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes
system that Peters knew would not be picked up by the SBN's mail carrier the day the
certificate of mailing indicated the would be, or at least were placed...Please explain
how your office's certified mailing procedures work and comply with federal law.
Additionally, I have review the materials you had Sierra Legal Duplicating provide
and there is no indication of where materials such as the 8 28 12 Order sanctioning
Coughlin generated from or whom transmitted them to the SBN. I had a discussion
with Bar Counsel Clark over a year ago about whether there was some centralized
method of keeping track of Orders sanctioning attorneys. He indicated there was not.
Please indicate then, who provided you the various different Orders sanctioning
Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial
Family Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of
Court for Department 3" (ie, of the Municipal Court's Department 3, which you fail to
specify in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you
000102
that day about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even
talkin' 'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out
and about.) Pat, you are going to look like such an unbelievably compromised,
crooked, and inept Bar Counsel when it is displayed what a tenuous thread each and
every aspect of all these half baked grievances hang from.
Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
Panel is now in possession of the certified audio of the following transcripts:
April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
minute mark wherein the following exchange took place:
Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
April 2009 grievance onto the State Bar in the last two weeks
Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
will continue to be your attorney today."
At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River
Rock Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction
where the nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any
eviction notice or even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a
case wherein Coughlin was representing a single father in a custody dispute based upon a judicial canon (see
atached).

King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
000103
grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434,
and ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82
worth of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see
60838 and 61426:
60838 Walmart case with Court's June 7th, 2012 Order suspending
Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
S
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
0204 Coughlin Disciplinary Hearing File.pdf
10 31 12 Order by Echeverria 0204.pdf
12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
12 15 11 22176 2064 Order by Howard on transcript costs.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
Download all
> From: PatrickK@nvbar.org
> To: zachcoughlin@hotmail.com
> Subject: FW: Mr Coughlin
> Date: Thu, 30 Aug 2012 20:48:18 +0000
>
> Good Afternoon Mr. Coughlin,
>
> Attached is an Order that pertains to you.
>
> I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
expect to file an Answer?
000104
>
> Thank you.
>
> Patrick King
000105
Print Close
State Bar of Nevada refusing to file stamp Respondent's pleadings
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 12/03/12 10:48 AM
To: Patrick King ( (patrickk@nvbar.org); (davidc@nvbar.org) (davidc@nvbar.org); (tsusich@nvdetr.org)
(tsusich@nvdetr.org); (je@eloreno.com) (je@eloreno.com); (mike@tahoelawyer.com)
(mike@tahoelawyer.com); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
(eifert.nta@att.net); (cvellis@bhfs.com) (cvellis@bhfs.com); (skent@skentlaw.com)
(skent@skentlaw.com); fflaherty@dlpfd.com (fflaherty@dlpfd.com); schornsby@nvdetr.org
(schornsby@nvdetr.org)
Please incorporate by reference all my filings with the Nevada Supreme Court into any
answer or responsive pleadings you find I have filed.
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 30 files to share with you on SkyDrive. To view them, click the links below.
12 1 12 ex 1 to notice to that laura peters is 0204 screen print bz.pdf
12 1 12 ex 1 to notice that laura peters affidavit is whopper chocked 0204 bate stamped.pdf
12 1 30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs
attachment.pdf
6 7 12 email to gammick and @nvbar.org four hours before 60838 suspension order 0204.htm
6 9 12 Petty theft conviction leads to Reno lawyer's suspension - News - ReviewJournal.com.pdf
6 11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process 60838 0204.pdf
6 18 12 12-18962 60838 in re coughlin scr 111 filed stamped.pdf
6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf
6 25 12 SCR 115 Affidavit Coughlin 12-19902 0204 60838.pdf
6 25 12 stamped Coughlin's motion for extensio nto file brief and exhibit 60302.pdf
6 25 12 stamped 60302 MOTION FOR PERMISSION TO FILE OPENING BRIEF AFTER DEADLINE HAS RUN.pdf
8 13 12 61426 stamped Coughlins PETITION SCR 102(4)(D) AND SCR 111(7) IN RE COUGHLIN 8 13 12.pdf
000106
8 27 12 stamped 60331 APPELLANT'S Motion IFP with attached proposed Opening Brief.pdf
8 28 12 stamped 60302 coughlin v wls appellant's opening brief[1].pdf
8 28 12 stamped 60302 Coughlin's Opening Brief wls 60302 12-27202 0204.pdf
10 5 12 60838 file stamped proof of service of Petition In Re Coughlin.pdf
10 5 12 file stamped proof of service of Petition In Re Coughlin Petiton for Dissolution.pdf
10 5 12 filestamped 60838 Motion to Show Cause contempt scr 119(2) in re coughlin 60838 Coughlin.pdf
10 15 12 stamped 61901 Kings SCR 111(4) petition for 26405 trespass conviction.pdf
10 22 12 60203 garin's respondent's brief back from tiff.pdf
Download all
From: zachcoughlin@hotmail.com
To: patrickk@nvbar.org; davidc@nvbar.org; tsusich@nvdetr.org; je@eloreno.com; mike@tahoelawyer.com;
complaints@nvbar.org; eifert.nta@att.net; cvellis@bhfs.com; skent@skentlaw.com
Subject: RE: Mr Coughlin
Date: Wed, 21 Nov 2012 21:22:16 -0800
Dear SBN and Panel
The Disciplinary Hearing File that Pat King purported to have copied and provided to
me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
not being filestamped...). Echeverria's very ruling on filing he was not mailed (to
the extent that was the case, and perhaps it was a test) concedes at least the
approval of filign by fax (express indication of the permissibility thereof in
accordance with SCR 105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
Please confirm that my filings, all of them, including the Motion to Show Cause of
10/2/12, starting on bate stamp 02849 have been provided to all Panel members as
the SBN has repeatedly indicated they would be (included the copying of all
attachments, including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a
file stamp (and it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs
indicates...which means the SBN failed to Oppose the Motion to Dismiss, and the
Complaint was dismissed prior to any other purported proof of service being
effected (or spurious assertions of Coughlin dodging service given his numerous
000107
written correspondences and calls offering to meet Reno Carson or the SBN...until
Coughlin finally just gave the SBN his physical address on 10/23/12, despite safety
concerns....)
Who gave you this order that you attached in the email of your's included below (the
8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
of these grievances? Did Mr. Susich disclose that conflict incident to the problems
Maureen Cole had in carrying out the duties of her job as an attorney for the NV
DETR and NERC?
Please copy me on anything proving Chairman Susich so disclosed that conflict.
Additionally, more and more frequently, when I question Laura Peters on some
misstatement or attempt to mislead that she makes, she starts talking about getting a
"protection order" or otherwise seeking to abuse process. Speaking of abusing
process, due process namely, Peters was caught signing Certificates of Mailing for
10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes
system that Peters knew would not be picked up by the SBN's mail carrier the day the
certificate of mailing indicated the would be, or at least were placed...Please explain
how your office's certified mailing procedures work and comply with federal law.
Additionally, I have review the materials you had Sierra Legal Duplicating provide
and there is no indication of where materials such as the 8 28 12 Order sanctioning
Coughlin generated from or whom transmitted them to the SBN. I had a discussion
with Bar Counsel Clark over a year ago about whether there was some centralized
method of keeping track of Orders sanctioning attorneys. He indicated there was not.
Please indicate then, who provided you the various different Orders sanctioning
Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial
Family Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of
Court for Department 3" (ie, of the Municipal Court's Department 3, which you fail to
specify in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you
000108
that day about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even
talkin' 'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out
and about.) Pat, you are going to look like such an unbelievably compromised,
crooked, and inept Bar Counsel when it is displayed what a tenuous thread each and
every aspect of all these half baked grievances hang from.
Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
Panel is now in possession of the certified audio of the following transcripts:
April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
minute mark wherein the following exchange took place:
Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
April 2009 grievance onto the State Bar in the last two weeks
Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
will continue to be your attorney today."
At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River
Rock Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction
where the nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any
eviction notice or even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a
case wherein Coughlin was representing a single father in a custody dispute based upon a judicial canon (see
atached).

King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
000109
grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434,
and ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82
worth of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see
60838 and 61426:
60838 Walmart case with Court's June 7th, 2012 Order suspending
Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
S
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
0204 Coughlin Disciplinary Hearing File.pdf
10 31 12 Order by Echeverria 0204.pdf
12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
12 15 11 22176 2064 Order by Howard on transcript costs.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
Download all
> From: PatrickK@nvbar.org
> To: zachcoughlin@hotmail.com
> Subject: FW: Mr Coughlin
> Date: Thu, 30 Aug 2012 20:48:18 +0000
>
> Good Afternoon Mr. Coughlin,
>
> Attached is an Order that pertains to you.
>
> I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
expect to file an Answer?
000110
>
> Thank you.
>
> Patrick King
PLEASE DIGITALLY TRANSMIT MY ENTIRE FILE TO ME
IMMEDIATELY
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 11/30/12 3:12 AM
To: jbosler@washoecounty.us (jbosler@washoecounty.us); bdogan@washoecounty.us
(bdogan@washoecounty.us); complaints@nvbar.org (complaints@nvbar.org)
just an hour and a half before Dogan's retaliatory "clandestine status conference" with
DDA Young on 2/27/12 wherein he obtained an Order for Competency Evaluation from
Judge Clifton. Please indicate whom Judge Nash Holmes is referring to from your
office in her March 14th, 2012 letter to the SBN. Please email me my entire file and
or fax it to me immediately, I have the trial in less than 14 days.
Dear SBN, please file this as a formal grievance against Mr. Dogan including his utter
failure to communicate with me as his client, beyond just generally doing absolutely
nothing to defend the case, appearing in court, lying about whether he served or had
served his Motion to Quash of 11/7/12 on me in rcr2011-063341, then smirking at me,
and failing to display candor to the tribunal despite having any opportunity to
afterwards, in addition to cackling from the peanut gallery with Jim Leslie during my
Trial.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.com
To: bdogan@washoecounty.us
000111
Subject: RE: arraignment
Date: Mon, 27 Feb 2012 12:04:46 -0800
Dear Mr. Dogan,
Was it abnormal for my case to be assigned to you on January 17th, 2012, prior to any
arraignment? You and I discussed Chris Fortier calling and writing me ahead of
the February 14th, 2012 arraignment as well. Is there some reason you were docketed
as attorney of record well in advance of the arraignment, which, apparently, is contrary
to the established practice in the RJC vis a vis WCPD's being assigned to cases?
It is my understanding, from your email late last Friday, that the status conference that
was set for today at 1:30 pm has been cancelled, though it has yet to be rescheduled.
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
Subject: RE: arraignment
Date: Fri, 24 Feb 2012 16:29:04 -0800
From: BDogan@washoecounty.us
To: zachcoughlin@hotmail.com
Your case has been continued. I will send the new court date by mail.
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Wednesday, February 22, 2012 6:36 AM
To: Dogan, Biray
Subject: arraignment
'Sup Biray,
I went and got the arraignment done today....Judge Pearson informed me we have a
mandatory 2/27 1:30 STATUS Conference RJC with in rcr12-065630
However, I already had a "Trial" set in bench trial 11 tr 26800 RMC (ticket number 544281) 1pm feb 27th Judge
Holmes (talk to cashiers) right of way stop sign, can you get a continuanc brokered on the status conference.
Judge Pearson said you are my attorney of record in this matter, though you haven't been communicating with me
much far as I can tell and you guys hung up on me last we spoke.
Hope to hear from you, amigo,
000112
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
000113
Print Close
11 23 12 AMENDED SUPPLEMENTAL TO RESPONDENT'S
EMERGENCY MOTION TO SET ASIDE, ALTER OR AMEND ALL
ORDERS SO FAR BY NNDB, SBN, PANEL, OR BOARD, AND
NOTICE OF IRREGULARITIES OF PROCEEDINGS THUS FAR
and SUPPLEMENT TO VERIFIED ANSWER OR RESPONSE TO
WHATEVER EX
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 11/23/12 5:32 PM
To: (je@eloreno.com) (e@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com); (davidc@nvbar.org)
(davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org); (eifert.nta@att.net)
(eifert.nta@att.net); (mike@tahoelawyer.com) (mike@tahoelawyer.com); (patrickk@nvbar.org)
(patrickk@nvbar.org); (skent@skentlaw.com) (skent@skentlaw.com); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org
(tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org)
Please find attached and let me know if you want yours faxed as well
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
11 23 12 0204 RESPONDENT'S AMENDED SUPPLEMENTAL WITH EX 1 ATTACHED ALL 2025 BATE STAMPED PAGES OF
IT.pdf

Chief Marshal Roper and Marshal Harley on setting the record straight
in NG12-0435
000114
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 11/23/12 4:09 PM
To: roperj@reno.gov (roperj@reno.gov); harleyj@reno.gov (harleyj@reno.gov); je@eloreno.com
(je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com (cvellis@bhfs.com);
eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
patrickk@nvbar.org (patrickk@nvbar.org); christensend@reno.gov (christensend@reno.gov);
mike@tahoelawyer.com (mike@tahoelawyer.com); davidc@nvbar.org (davidc@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com); stuttle@washoecounty.us (stuttle@washoecounty.us); wongd@reno.gov
(wongd@reno.gov); ormaasa@reno.gov (ormaasa@reno.gov); mkandaras@da.washoecounty.us
(mkandaras@da.washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us); jleslie@washoecounty.us
(jleslie@washoecounty.us); holmesd@reno.gov (holmesd@reno.gov)
Dear Panel, Judge Nash Holmes, Chief Roper, Marshal Harley, Bar Counsel, et al,
I apologize for using email to communicate here, but my current indigency and time
constraints so require it. Further, I in no way wish to violate any Orders by any of the
RMC Judges respecting emailing or contacting the RMC in connection with specific
cases, and submit this limited correspondence in the hopes that my interpretation of any
such Orders is in line with reality and will forgive at least this limited use of email
outside of any attempt to file anything in any of the matters in which I am a party
before the RMC. The exigency involved here relates primarily to the enormous
deference that will be given to the Panel's decision in the SBN v. Coughlin disciplinary
matter, and my desire to have the Panel afforded every opportunity to have all essential
information necessary to arrive at a just decision at its disposal. What follows is in part
a request and in part a recognition of the extent to which Judge Nash Holmes's action
during the 2/27/12 Trial in 11 TR 26800 may likely have been the best thing to have
had done, owing to her vast experience in these and a great deal many other matters,
and, hopefully, will have an upbeat result stemming therefrom.
At the Double R Blvd. Northern Office of the State Bar of Nevada, RMC Judge Nash
Holmes, on 11/14/12, testified under oath and indicated something along the lines of
the following:
During the 11 TR 26800 "simple traffic citation Trial" on 2/27/12, starting at about 3
pm, Judge Holmes interrogated Coughlin as various points throughout the Trial as to
whether he was recording the proceedings (without permission), and or whether he had
a "recording device" (whether every laptop anyone brings to Court would be
considered a "recording device" to Judge Holmes is not exactly clear).
000115
Judge Holmes then testified that after an initial round of interrogation of Coughlin as to
whether he was recording the proceedings and or had a "recording device" that
Coughlin got "all sneakity" and said he was not, but then "quote, 'took the Fifth' then
immediately asked to be allowed to use the restroom...and I ordered Marshal Joel
Harley to accompany him there...and it was reported to me that while in the restroom
Coughlin disassembled a recording device and hid some part of it in the restroom..."
(Coughlin recounts this testimony from memory, and admittedly, it is far from
verbatim).
It is categorically false (though not necessarily maliciously so) for Judge Nash Holmes to
assert, in the audio record on 3/12/12 the order of events and when she asked Coughlin her
questions about recording, considering when a restroom break took place and exactly what it
is she asked Coughlin and when, and what his responses were, and when some allegations by
"the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio
transcript reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering
from some extreme form of mental illness. during the trial I asked the defendant attorney
repeatedly if he was recording the proceedings he denied that vehemently a few times and
then he quote took the fifth a few other times and then he requested to be excused to go
to the bathroom and the Marshal later reported to me that while the gentleman was in the
bathroom he disassembled a recording device in his pocket and took the memory out of it
and it was later found in that, uh, by the Marshal no one else had gone into the bathroom
and that was retrieved and it was put into his possession at the Sheriff's office and when
they booked him into jail for the contempt charge that was booked into evidence and I
asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme
Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
Perhaps NRS 178.405 in the context of NRS 5.073 should have some baring on anything said or done
or Ordered by Judge Nash Holmes following her statement at the 7 minute mark that "It appears to me
in this case that the defendant is suffering from some extreme form of mental illness." To the extent
000116
any question of Coughlin's competency was communicated to or brought to Judge Nash Holmes
attention prior to the 2/27/12 3:00pm start of the Trial in 11 TR 26800, that proceeding should have
been stayed or suspended, especially if the WCPD's Office made such communnications in close
temporal proximity to the 1:31 pm 2/27/12 Order for Competency Evaluation by Judge Clifton in
RCR2011-065630. And arguably, given the same office (in a broad sense) in which DDA Z. Young and
DDA Kandaras work, it is arguably a basis for conflicting out the WCDA's Office from any one of the
three prosecutions is has maintained against Coughlin this year (especially considering the issues related
to whether the WCSO's timely effected the lockout of 11/1/11 in the eviction from Coughlin's former
home law office, which, given the recent admissions by the locksmith there that day, and the Reno
Carson Messenger receipt from the day prior, and Casey Baker, Esq's testimony related to his
interactions with the WCSO on October 28th, 2012 during his sworn testimony at the criminal trespass
trial before RMC Judge Garder on 6/18/12, and the RJC's failure to even move to Quash Coughlin's
subpoenaing records related to the fax logs and confrimation of transmission or receipt incident to the
RJC's "usual custom and practice" of faxing eviction Orders to the WCSO for service (like those in the
Richard Hill/Casey Baker Summary Eviction "Trial" involving Coughlin's former home law office, and the
"within 24 hours of receipt" language found within NRS 40.253 (the Order is void or invalid after that
point, in which case, it would mean Hill and or Baker were the trespassers, not Coughlin, regardless, its
inappropriate for RMC court appointed defender Loomis to categorically refuse to assert any claim of
right defense that such a criminal trespass defendant may wish to assert for, say, Richard Hill admits to
charging the same rent under a "storage of personal property" that was previously charged for "full use
and occupancy". Nonetheless, posting an Eviction Order that does not contain stay away language
(much less the fact that is does not have the required "within 24 hours" language called for by the
statute) is not tantamount to posting a no trespassing sign, further, Hazlett-Stevens making arguments
in his closing as to matters not in evidence (allegations of living in the residence) is reversible error, and
for Judge Gardner to do as Judge Howard did, an prevent the City Attorney from even having to Oppose
Coughlin's Motion for New Trial, is further indication of the extent to which Coughlin's reactions during
the 2/27/12 Trial, however offputting, are not totally unfounded. Further, that which Judge Nash
Holmes had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be
testified to under oath, rather than have Bar Counsel assert to half baked "can't ask the judge about her
mental processes" loophole, as he has done. But, actually, a review of the Hardesty/Mirch dynamic
may dictate that Coughlin would have been fairly limited in that regard anyways, nonetheless, Judge
Nash Holmes appeared, to her credit, and answered some questions. The answers revealed an
opportunity put forward now to clear some things up, though the constraints of the Disciplinary Hearing
format, some disagreements over what the SBN communicated to Coughlin with respect to the rules
that would be applied to him vis a vis NRCP 45 subpoenas (whether, he, as a suspended attorney could
issues a subpoena (Coughlin maintains the Bar/Panel/Board did give him such authority) and whether
any witness fee or subpoena decus tecum fee must be paid by Coughlin (Coughlin maintains he was
provided indications upon which he reasonably relied that he would not be so required in additions to
the rules or practicies attached to the service thereof), and other factors severely limited the extent to
which the opportunity created by Judge Nash Holmes testimony was realized to its full potential. That
necessitated this correspondence. Coughlin recalls the first time he saw opposing counsel allege he
was lying in a filing, it was one of the early one's by Richard Hill's former associate Casey Baker, alleging
"outright lies". It was upsetting, especially considering how unfair and baseless the allegations
seemed...and Coughlin nows wishes he would have done and said some things differently incident to
000117
his testimony relative to RPD Sargent Tarter and Judge Nash Holmes's own testimony, and intends to
address the extent to which objectionable conduct by opposing counsel can often times become a sort
of learned characteristic perpetuating a race to, if not the ethical gutter, at least a preponderance of
Rambo litigating. To some extent the incidents with Marshal Harley and RCA Ormaas may be fallout
from that. Important too, however, is to consider whether the "courthouse sanctuary" doctrine has
some application, however confusing it may be, where the WCSO may be hired by private parties to
conduct service, and the Marshals are only extending intra-governmental courtesies in assisting in the
manner in which Marshal Harley did on 2/27/12. Richard Hill gets the "oopsies" a lot. Oppsie, I
asked for $20K in attorney's fee incident to a summary eviction at the trial court level, despite that not
being supportable under NRS 69.020, Hill says. Oopsie, I left the window unit air conditioner in the
exposed to the street by the Lakemill lodge window at your former home law office, which was then
robbed, but for which I still managed to charge you full rental value at full use and occupancy rates,
though I had you subject to an arrest for custodial trespass anyways, Hill and Baker say.
(at the 9 minute 48 second mark of the first audio file attached from 2/27/12)
"Judge: Sir, I would like you to raise your hand to be sworn, because its my experience that people who
represent themselves tend to testify a whole lot when they are asking other people questions, so let's
just start that way and then we won't have to do it later, so swear him in and then we'll get going
Marshal: Testimony (inaudible)...you are about to (inaudible) understand (inaudible) truth, whole truth,
nothing but truth, solemnly?
Coughlin: Yes, Sir?"
However, from there, throughout the Trial Judge Nash Holmes interrupts Coughlin during his
questioning of Tarter to indicate to Coughlin that he is asking questions and not testifying, or that he
will have an opportunity to make some point when its his turn to testify, if he chooses to testify, etc.,
etc, and eventually Judge Nash Holmes asks Coughlin, after the restroom break, if he intends to testify
on his own behalf..."Nor does the trial judge's speculation that Appellant might use his closing
argument to present unsworn testimony." Soto, 139 S.W.3d at 857.
The transcript from the 2/27/12 certified audio recording of the traffic citation Trial
at the 1 hour and 6 minute 18 second mark of the running time (yes the certified audio transcript is
provided in a FTR format that necessitates installing TheRecord Player, but for the ease of the
receipients of this correspondnece, Coughlin convereted the audio therein exactly as it was into a more
workable format, .mp3 files, split into two files for 2/27/12 (before and after the one restroom break)
and one file for the continuation fo the trial on 3/12/12) of file one:
000118
Judge Nash Holmes (Judge): Sir, Mr. Coughln, sit down, I am done with you.
Coughlin: Just to preserve for the record, Your Honor.
Judge: Sit down, sit down, your're done. For the record the defendant is looking in his pockets and
behind his back and turning around and clowning around and showing utter disprespect for this court
and if you say another word or do another little antic like that you are going out of this Court in
handcuffs. Do you have any other witnesses? Prosecutor?
Prosecutor Ormaas: No, Your Honor, the City rests.
Judge: Sir, do you wish to testify?
Coughlin: Can I call Officer Tarter as my own witness?
Judge: you can call anyone you wish to testify.
Coughlin: I am sorry, Your Honor, but I really need to use the restroom.
Judge: You have two minutes. Marshal (Harley), you will escort him to the restroom, don't take
anything with you, Sir...
Coughlin: Can I take my notes with me?
Judge:No, turn them upside down.
Coughlin: Can I take the one page?
Judge: No, turn them upside down.
Coughlin: Really?
Judge: Turn them upside down. Marshal you will go with him to the restroom.
Coughlin: Will I be able to go into the stall alone? Just checking.
Judge: You have two minutes. You have two minutes.
Coughlin: Okay.
(that ends the first audio file attached for 2/27/12, which represents the entirety of the proceeding
prior to the ONLY restroom break during that Trial)
(Start of the second audio file of 2/27/12, which represents the entirety of the proceedings of that day
following the ONLY restroom break of the day).
Coughlin: (re-enters courtroom): Thank you, Your Honor.
000119
Judge: Okay, we are back on the record in 11 TR 26800. Mr. Coughlin, are you recording these
proceedings?
Coughlin: No, Your Honor.
Judge: Do you have any sort of devices in your pocket?
Coughlin: I believe what is in my pocket is private, Your Honor.
Judge: I want to know if you have any sort of recording devices in your pocket!
Coughlin: I believe that is a Fourth Amendment issue, Your Honor.
Judge: I am asking you, are you are recording anything from these proceedings in your pocket without
Court permission?
Coughlin: I believe that is a Fourth Amendment issue.
Judge: Sir?
Coughlin: And, no, I'm not.
Judge: Okay, proceed, do you have any questions for this witness (RPD Sargent John Tarter) that are
different from the area that we gave gone over already.
Coughlin: Well, I would like to ask a follow up on the rolling stop citation..." (thereafter Judge Nash
Holmes does not ask any other questions of Coughlin in any way related to recording or recording
devices, nor did Judge Nash Holmes ask any questions of anyone related to recording or recording
devices besides. Judge Nash Holmes did ask, before the restroom break, of Coughlin, if Coughlin had
any evidence or proof to support his contention that he attempted to provide to either Reno City
Attorney Wong or Ormaas discovery or information related to the statement to Coughlin, incident to
the November 13th, 2011 custodial criminal trespass arrest of Coughlin at his former law office incident
to an impermissible summary eviction of a commercial tenant not based on the non-payment of rent
(ie, a No Cause Eviction Notice was posted and a Landlord's Affidavit alleged a No Cause basis for
proceeding).
On the second audio file from 2/27/12, at the 5 minute mark, the follow occurs on the record:
"Coughlin: was I there? Do I remember the name of the other officer who was there with him who
went into Richard Hill's law office for twenty minutes with him and hung out?
Judge: If you mention the name Richard Hill again I am going to hold you in contempt because I have
told you repeatedly to stick to the relevant issues about the boulevard stop."
000120
(At the 11:17 minute mark of the second audio from 2/27/12 the following occurs on the record):
Judge: Officer (RPD Sargent Tarter), you are excused. Sir, do you intend to testify?
Coughlin: Yes, Your Honor.
Judge: Then testify, you don't need to take the stand, you can testify right there, you don't have to ask
yourself questions, just give me a short narrative version of what happened, and don't refer to yourself
in the third person, he was sworn in at the beginning of the case, don't refer to yourself in the third
person, just tell me what happened.
Coughlin: Yes, your honor, I reported a bribe to Sargent Tarter, then he retaliated against me.
Judge: Sir! Sir! Keep it relevant!
Reno City Attorney Ormaas: Objection, move to strike!
Judge: Keep it relevant about whether or not the boulevard stop occurred and what happened:
Coughlin: Sargent Tarter perjured his testimony today
Judge: Sir, Sir, answer about the boulevard stop.
Coughlin: Yes, Your Honor, this incident occurred when I went over to Richard Hill's office.
Judge: Sir.
Coughlin: I can't get into that? Okay.
Judge: Sir, boulevard stop.
Coughlin: Sargent Tarter lied today when he...
Judge: All right, Sir!
Coughlin: about the boulevard stop, I am saying...I disagree
Judge: take him into custody, you are in contempt of court, you will spend the next five days in jail, this
court is finished, this matter is continued
Coughlin: Your Honor I move for a stay, I have a trial..and I have clients who need me
Judge: that is your problem, Sir. For the record you are in contempt of court because you have been
insubordinate, you have disregarded all of my requests, directions, orders, cajoling, my efforts to get
you to follow the instructions of the court, to act like a lawyer, or even to act like a defendant
representing himself in this court, you have made faces, belittled, you have argued, you have played,
you have been ridiculous in this courtroom and brought up issues that are irrelevant and immaterial
and to disrupt this proceeding, and there are only five or six people here that you could disrupt, you
have done everything you can to divert from the matter at question and to keep us from resolving the
000121
issue of whether or not you have committed the traffic violation of the boulevard stop, and you are in
utter contempt of this court and have done nothing to deal with the facts of this case...you are being an
obstinate jackass, I am having a hard time believing you are a lawyer, you obviously missed the class on
on evidence, courtroom decorum and on criminal law..."
Coughlin was taken into custody whereupon a search incident to arrest was performed in the holding
area/back room of the RMC by Marshal Joel Harley with Marshal Scott Coppa assisting, and Marshal
Coppa was one of two Marshals transporting Coughlin to the Washoe County Detention Facility where
he served the 5 days in jail Judge Nash Holmes ordered (and the RMC refused to return the $100 that
Coughlin's mother paid into the RMC when counter clerk "Tom" promised her the Court would issue an
Order resulting in Coughlin being released from jail one day early...however, aside from the WCDC
walking Coughlin down in handcuffs from his cell to the booking desk and back, there was no release
from custody and Coughlin's mother was not returned her $100 payment in exchange for an early
release by either the RMC or the WCDC.
While conducting the search incident to arrest, RMC Marshal Harley went through Coughlin's pockets
and took out a simple flip style cell phone, a smart phone, a micro sd card, and an electronic shaver.
Upon taking possession of the micro sd card Marshal Harley immediately began interrogating
Coughlin as to whether it would work with the smartphone, then directed another Marshal to "go tell
the Judge that Coughlin was recording!" without any other support for such an accusation. None of
this occurred in the restroom and Chief Marshal Roper has indicated to Coughlin that Marshal Harley, in
carrying out Judge Nash Holmes Order to escort Coughlin to the restroom, did not actually go in the
restroom, but rather waited outside its door.
I ask that Chief Marshal Roper, Marshal Harley, and Marshal Coppa correct the misrepresentations
made by Judge Nash Holmes (whether or not they were purposeful or where something was lost in
translation and the affidavit requirement of NRS 22.030 for "contempt not in the immediate presence
of the Court" was not followed by Judge Nash Holmes incident to her 2/28/12 Order, wherein Judge
Nash Holmes writes, on page 2 of her 2/28/12 Order Finding the Defendnat in Contempt of Court and
Imposing Sanctions: "The matter was called at apprxoimately 3:00p.m. and concluded withoua verdict
about 4:30 p.m. after the court held the defendnat in criminal contempt of court for his behavior and
activites committed in the direct presence of this court during the trial. The court finds that
defendant's contemptuous conduct conside of his ....deceitful...behavior during trial, all of which
appeard to be done to vex an annoy the court, the witness, and the opposing party, and to disrupt the
trial process. The court finds that the following occurred, and constitute contempt...."9) defendant's
lying to the court in response to direct questions posed by the court with regard to his recording the
proceedings...(page 3)...The court finds that the defendnat's actions were intentional and done in utter
disregard and contempt for the court, an in the presence of the cour, for purposes of disrupting and
delaying the proceedins and dishonoring the rule of law and this court, and constitute the misdemeanor
of criminal contempt, a violation of NRS 22.010. Good cause appearing therefore, the following
000122
sanctions are imposed: IT IS ORDERED, pursuant to NRS 22.100, that the defendant be incarcerated at
the Wahoe County Regional Detnetion Facility for the term of five (5) days, from the time he was taken
into custody on this court's order on February 27, 2012, and that sentence shall not be reduced for any
reason..." The time stamping on that 2/28/12 Order Finding the Defendant in Contempt of Court
and Imposing Sanctions indicate "3:47". Washoe County Sheriff's Office personnel Deputy Hodge,
Patricia Beckman, RMC
Somehow, in her 2/28/12 Order (and during the Trial) Judge Nash Holmes found it relevant that,
allegedly, the RPD "gave Coughlin a break" over his driver's license being expired (actually, Coughlin's
then valid, current, driver's license was being withheld by Richard G. Hill, Esq., as Coughlin reported to
Sargent Tarter...and it was likely an old DL that the RPD is referring to as "expired" when mentioning
the "break", which, again, was somehow relevant enough to find its way into the Order, but the
withholding of Coughlin's then current, valid DL by Hill was sustained as irrelevant during the Trial (and
in fact seems to have been one of a myriad of vague basis for issuing a summary criminal contempt
Order requiring then licensed attorney with client's depending upon him, Coughlin, immediately being
taken to the WCDC for 5 days in jail...).
Coughlin hereby requests the RMC, WCDA, and WCDC to indicate the extent to which his property was
booked into his personal property at the WCDC, only to have the WCDC and or WCDA release the
property to the City of Reno Marshals the following day, well after any timeframe to conduct a search
incident to arrest (NNDB Member Mary Kandaras was involved in this matter, and in fact, despite Judge
Nash Holmes ordering the property released on 3/30/12, it took until 4/7/12 and approval by Mary
Kandaras before the property was so released. wcso12-1805 c-47951.
With local attorney Pam Wilmore standing, watching, and or hearing/participating in the conversations,
on or about March 21st, 2012 WCSO's P. Beckman handed Coughlin a note that read "Per Judges
Orders, call Marshal Deighton" and provided a phone number for Coughlin to seek further explanation
as to the admission that the City of Reno Marshals had returned to the jail on 2/28/12 and retrieved
items of Coughlin's personal property, including his "flip" phone, his smart phone, and his micro sd
card. Deputy Hodge's admission that, contrary to the indications by WCSO Cummings and Campbell
that the micro sd card was released to Coughlin's agent on 2/29/12, but rather, was not so release,
combined with his statement that the smartphone, micro sd card, etc. were released to the Marshals
because it would be easier for Coughlin to get his property back through them, reveal that a search not
incident to arrest occurred here by the RMC on 2/28/12 and or the City of Reno Marshals, or, to be fair,
at least some sort of "seizure" did (especially considering that upon the smartphone and micro sd card
finally being returned to Coughlin on or about 4/7/12 by WCSO Deputy Iver, Brandi Berriman, and
Patricia Beckman (and only after "Maddy" got approval from DDA Kandaras, and after Coughlin was
threatened with abuse of process by Deputy Beatson). The RMC's Marilyn Tognoni also made some
indications respecting the smartphone and micro sd card to Coughlin. Perhaps, the allusion
000123
to wcso12-1805 c-47951 in Judge Nash Holmes 3/30/12 Order Releasing Coughlin's property indicates
whether a warrant or some other lawful Order allowed for the Marshals to retrieve those items a day
after they were booked into Coughlin's personal property at the jail...but Coughlin has not been
provided any such Warrant or Order and hereby requests that he be so provided a copy of it now, and
that, given important data was lost to Coughlin upon his discovery the micro sd card and smartphone
had been wiped, that any copies of the data then stored therein be provided to Coughlin (the Diaz case
in the Ninth Circuit seems to provided a great deal of latitude to law enforcement to search digital data
within the reach of one whom is subject to a custodial arrest, and perhaps even copy it...in which
case....is would be appreciate if a copy thereof could be provided to Coughlin, and some compensation
for the extent to which his 32 GB micro sd card was rendered useless upon its return, as was his HTC
G2 cell phone (which never quite worked the same from then on and was rendered totally inoperative
a short time thereafter...the 32 GB micro sd card having an approximate value of $85 and the HTC G2
smartphone a used value of around $175.00).
I know I write in the third person sometimes (its tough representing yourself, especially when time
requires lots of copying and pasting, etc., etc) and that it can appear awkward.
I would appreciate the parties receiving this correspondence who have any knowledge of the events
detailed herein (especially with respect to the false accusations related to recordings, disassembling,
and hiding component parts of devices in the RMC restroom as detailed on the record on 3/12/12 in 11
TR 26800 and again in Judge Nash Holmes testimony at the 11/14/12 Disciplinary Hearing for NG12-
0434 (and NG12-0204, and NG12-0435) to set the record straight.
For a verbatim or close to it transcription of what Judge Nash Holmes testified to at the Disciplinary
Hearing on 11/14/12 (including those matters she purported to repeat details related to what variosu
RMC Marshals told her regarding Coughlin, on would likely need get the transcript or any recordings
from the CCR assigned to that Hearing, Carol Hummel, and given Coughlin's current indigency, any
requirement that Coughlin pay up front for the transcript would make review prohibitive, and Coughlin
hereby requests of the Panel a fee waiver or deferment of such costs in that regard):
Linda Shaw, Owner, Sunshine Reporting Services - Reno
1895 Plumas St,
Reno, NV 89509,
(775) 323-3411
000124
Sunshine Reporting Services
Eric Nelson
CCR Longoni
(775) 323-3411
fax (775) 323-2749
151 Country Estates Circle
Reno, Nevada 89511
Carol Hummel
(775) 827-9120/
fax (775) 827-9120
chummel@charter.net
In her 3/12/12 Order in 11 TR 26800, a transmogrification of sorts appears to occur, turning a "simple
traffic citation trial" into a Disciplinary Hearing, albeit one of a summary nature, with an absent
Respondent. That Order read, in relevant part:
"Based upon the total circumstances of this case, the in-court performance of the
defendant, as observed by this court, the written documents faxed to the court for filing by
this defendant, the statements and behavior of this defendant and his overall conduct herein,
this court finds, by clear and convincing evidence, that Zachary Barker Coughlin, an attorney
licensed to practice law in the State of Nevada, has committed numerous acts of attorney
misconduct, including, but not limited to, violating the following Rules of Professional
Conduct:
000125
8.4(c}-engaging in dishonesty, fraud, deceit or misrepresentation;
8.4 (d)-engaging in conduct that is prejudicial to the administration of justice;
3.3 (a)-lack of candor to the court by knowingly making false statements to a tribunal;
3 .l-defending in a proceeding by asserting or controverting an issue without a basis in
fact and with matters that are known to be frivolous;
3.2-failure to make reasonable efforts to expedite litigation. and, in fact, taking
extreme measures to delay litigation;
3.4(c)-being unfair to opposing counsel by continually alluding to matters the lawyer
does not reasonably believe are relevant or supported by admissible evidence;
1.3-failing to act with reasonable diligence and promptness; and
1. I-lack of competence in his practice and appearances before this court.
In addition, Zachary Barker Coughlin, likely also violated Nevada Supreme Court Rule
229, section 2(b), as amended by ADKT 449 on August 1, 2011, by surreptitiously recording
the traffic citation trial of February 27,2012 without the advance permission of this court and
then lying to this court when questioned about it and denying that he had done so.
Whether or not there are medical reasons to explain Mr. Coughlin's actions is not for
this court to decide. He has become nothing less than a vexatious litigant to Reno Municipal
Court due to his unorthodox, disruptive, bizarre and irrational methods and practices that go
beyond the pale of anything that is civil, ethical. professional or competent. Good cause
appearing therefore, the court orders as follows:
IT IS ORDERED that this matter is continued, and all proceedings relating thereto are
tolled, until further order of this court, while the matter of attorney Zachary Barker Coughlin
is referred to the State Bar of Nevada;
IT IS ORDERED that no further action shall be taken by the Reno City Attorney's
000126
Office, or the clerks or staff of Reno Municipal Court, in the above-entitled case, pending
further order of this court;
IT IS ORDERED that Zachary Barker Coughlin is barred and forbidden from faxing,
emailing, delivering. having delivered, serving. presenting for filing. personally or otherwise,
any motion or document to Reno Municipal Court, in the above-entitled case, pending further
order of this court."
One, Coughlin is not emailing this correspondence in that "above titled case (11 TR 26800) but in
connection with matters outside that case. Three, it is really not at all clear how Judge Nash Holmes
could make all those rulings, and only after having done that, decide to suspend the proceedings for a
Competency Evaluation, given the import of NRS 178.405:
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of
defendant; notice of suspension to be provided to other departments.
NRS 178.405 Suspension of trial or pronouncement of judgment when doubt arises as to competence of
defendant; notice of suspension to be provided to other departments.
1. Any time after the arrest of a defendant, including, without limitation, proceedings before trial, during trial,
when upon conviction the defendant is brought up for judgment or when a defendant who has been placed on
probation or whose sentence has been suspended is brought before the court, if doubt arises as to the
competence of the defendant, the court shall suspend the proceedings, the trial or the pronouncing of the
judgment, as the case may be, until the question of competence is determined.
2. If the proceedings, the trial or the pronouncing of the judgment are suspended, the court must notify any
other departments of the court of the suspension in writing. Upon receiving such notice, the other departments
of the court shall suspend any other proceedings relating to the defendant until the defendant is determined to
be competent.
NRS 189.030 Transmission of transcript, other papers, sound recording and copy of docket to district court.
000127
1. The justice shall, within 10 days after the notice of appeal is filed, transmit to the clerk of the district court
the transcript of the case, all other papers relating to the case and a certified copy of the docket.
2. The justice shall give notice to the appellant or the appellants attorney that the transcript and all other
papers relating to the case have been filed with the clerk of the district court.
3. If the district judge so requests, before or after receiving the record, the justice of the peace shall transmit
to the district judge the sound recording of the case.
NRS 5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and
collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the
practice and proceedings of justice courts in similar cases. An appeal perfected transfers the action to the
district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS
5.010. The municipal court must be treated and considered as a justice court whenever the proceedings
thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the
jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS 5.075 Form of docket and records. The Court Administrator shall prescribe the form of the
docket and of any other appropriate records to be kept by the municipal court, which form may vary from
court to court according to the number and kind of cases customarily heard and whether the court is
designated as a court of record pursuant to NRS 5.010.
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether
the citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right
at it and given what she said in court. Also, the whispering with Marshal Harley, and the bits about
Coughlin reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's
responses thereto on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
000128
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording
anything or whether he possessed a "recording device" until AFTER the one and only restroom break Judge
Nash Holmes mentions on the audio record. Judge Nash Holmes did ask Coughlin if he had any proof that City
Attorney's Wong and Ormaas failed, in some way, to received or follow up on some offer by Coughlin to
provide materials related to Coughlin's contentions respecting the statement madAnd that sua sponte
interrogation of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH
HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED
AFTER COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S
EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME
OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF TIME
WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT
STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is odd,
considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630
and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and prosecutors
and public defenders were non too happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12
status conference between young and dogan that neither YOung nor Dogan wish to testify about...but which
seems to have been held anyways after a written communication of its being reset was transmitted to Coughlin
by Dogan, wherein, during the time Judge Nash Holmes couldn't be found (maybe she was at one of the group
meetings amongst Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the
record in 11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan
got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for
Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin of approximately
11/28/12, which resultd in Young promptly amending his complaint in rcr2011-063341 to add a charge that was
duplicative, even where YOung failure to allege theft or possessing/receiving "from another' under Staab makes
his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently. That,
and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive
document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on
2/27/12...never mind Young tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin
competent in cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in
RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010)
here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt Order in 11 tr 26800 until July 2012...but did file a Notice of
Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash Holmes
continues to refuse to follow NRS 189.010-050
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily
by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a
contempt committed in his immediate presence in open court cannot be likened to the proceedings here. For
we held in the Oliver case that a person charged with contempt before a "one-man grand jury" could not be
000129
summarily tried. [349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his
immediate presence in open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin
violated in both 11 cr 22176 and 11 tr 26800, also orders no sufficiently detailed or capable of being known
how to comply with, not sufficient warning, violat Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the
"immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is
entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe
she is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate,
particulary where she not only purports to issue a "summary criminal contempt" conviction against an
attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic
citation trial" into a full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That
Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something
on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge
Nash HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some
musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts
of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to
Quash the Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge
Nash HOlmes, Judge William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite
find the NOtice of Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR
26405 (the appeal was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal
of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which
was denied based upon a civil preparation of transcript down payment rule, in that criminal appeal, where the
RMC has a thing in place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the
audio cd of the trial for some time, insisting only Longoni would be allowed to transcribe it, and that the
transcript's preparation would absolutely not start until a down payment was made. Plus, even where Coughlin
caved to the payment demands..Longoni repeatedly hung up the phone on him and otherwise ignored his
communications (there may be an issue of the email Longoni holding out to the public issuing a
"bounceback"...but she needs to sign an affidavit as to whether she put Coughlin on a blocked list, and upon
information and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf too...
In her March 14th, 2012 grievance against Coughlin to the SBN Judge Nash Holmes details some concerns she
has with Coughlin's work as a self representing attorney defending a traffic citation (now NG12-0434, and
perhaps, NG12-0435, depending upon whom you ask and what King means by "Clerk of Court"...because in
King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would need
to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King
now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009
Order was not filed by the RMC Judges?
000130
AS to the application of the "courthouse sanctuary" doctrine to RMC Marshal Harley serving the Order to Show
Cause upon Coughlin at approximately 1:25 pm in one of the conference rooms right outside the interior of
Courtroom B at the RMC:
http://caselaw.findlaw.com/ny-district-court/1372465.html
"THE LAW
(COURTHOUSE SANCTUARY)
Despite antagonistic dicta to the contrary; most modern era precedent dealing with the issue of
Courthouse Sanctuary from service of process have held that New York State residents receive no such
immunity protections. Baumgartner v. Baumgartner, 273 A.D. 411, 77 N.Y.S.2d 668 (1st Dept.1948);
Department of Housing Preservation, City of New York v. Koenigsberg, 133 Misc.2d 893, 509 N.Y.S.2d 270
(N.Y. Civ.Ct.1986); Ford Motor Credit Co. v. Bobo, N.Y.L.J., 1 Misc.3d 901(A), 2003 WL 22928513 (Dec. 17,
2003, J. Miller, Nassau Co. Dist. Ct.) These cases hold that the Courthouse Sanctuary is only available to
foreign state residents who come into New York's Courts to contest jurisdiction. This doctrine has been
slightly expanded to include New York residents who enter the jurisdiction of a New York Court of limited
territorial jurisdiction to contest jurisdiction. See Palazzo v. Conforti, 50 N.Y.S.2d 706 (N.Y. Civ.Ct.1944);
Singer v. Reising, 154 Misc. 239, 276 N.Y.S. 714 (Queens County 1935).
The Baumgartner Appellate Division panel also acknowledges a limited Courthouse Sanctuary rule for
New York residents if such service would constitute a disturbance directly tending to interrupt the
proceedings of the Court or to impair the respect due its authority. This rule by itself would not be
applicable to the instant case as service of process was effected in the Courtroom but outside the Court's
presence and in between calendar calls.
STATE RESIDENCY IMMUNITY DISTINCTION?
The English Common Law made no New York State residency distinction. The doctrine of immunity from
arrest of a litigant attending a trial of an action to which he is a party found early recognition and dates back to
the book of 13 Henry IV, J.B. Sampson v. Graves, 208 A.D. 522, 203 N.Y.S. 729 (1st Dept.1924). This is for
the obvious reason that England had no sovereign states. The privilege is not a creature of statute, but was
created and deemed necessary for the due administration of justice. See Matthews v. Tufts, 87 N.Y. 568
(1882); citing to Van Lien v. Johnson (N.Y. Ct. Appeals, unreported 1871).
The logical question now arises, exactly when did New York's Appellate Court's recognize a residency distinction
for application of the Courthouse Sanctuary? The answer is that the Court of Appeals never
established such a rule. In contra point of fact, the Court of Appeals has opined that:
It is the policy of the law to protect suitors and witnesses from arrests upon civil process while coming to
and attending the court and while returning home. Upon principle as well as upon authority their
immunity from the service of process for the commencement of civil actions against them is absolute eundo,
morando et redeundo. Person v. Grier, 66 N.Y. 124 (1876). Emphasis Added.
In this unanimous opinion, the Court of Appeals expressly addressed the New York State resident immunity
distinction and established in its dicta that whether any distinction should or does in fact exist, is at least
doubtful. This immunity is one of the necessities of the Administration of Justice, and Court's would often
be embarrassed if suitors or witnesses, while attending Court, could be molested with process. It is noted
that Person involved a foreign state resident. In establishing the sanctuary doctrine, the Court stated that

Appeals is also applying the protective rule to New York residents.
000131
The basis of the Courthouse Sanctuary rule is that parties should be allowed to contest jurisdiction
Z
essentially allows the plaintiff to use a defective default judgment as a weapon to compel the defendant to
submit to the service of process. Ford Motor Credit Co. v. Bobo; cite supra. The location of an
individual's residence does little to legitimize such a mockery. Absent the compulsion of clear controlling
precedent; this Court will not condone such a situation..."
NRS 266.595 Appeals. Appeals to the district court may be taken from any final judgment of the municipal
court in accordance with the provisions of NRS 5.073.
NRS 5.073 Conformity of practice and proceedings to those of justice courts; exception; imposition and
collection of fees.
1.The practice and proceedings in the municipal court must conform, as nearly as practicable, to the
practice and proceedings of justice courts in similar cases. An appeal perfected transfers the action to the
district court for trial anew, unless the municipal court is designated as a court of record as provided in NRS
5.010. The municipal court must be treated and considered as a justice court whenever the proceedings
thereof are called into question.
2.Each municipal judge shall charge and collect such fees prescribed in NRS 4.060 that are within the
jurisdictional limits of the municipal court.
(Added to NRS by 1989, 903; A 1991, 455; 1997, 115)
NRS 5.075 Form of docket and records. The Court Administrator shall prescribe the form of the
docket and of any other appropriate records to be kept by the municipal court, which form may vary from
court to court according to the number and kind of cases customarily heard and whether the court is
designated as a court of record pursuant to NRS 5.010.
NRS 5.010 General requirements for court; designation as court of record. There must be in each
city a municipal court presided over by a municipal judge. The municipal court:
1.Must be held at such place in the city within which it is established as the governing body of that city
may by ordinance direct.
2.May by ordinance be designated as a court of record.
000132
The personal service by Marshal Harley of the Order to Show Cause in the appeal of the summary eviction
matter from Coughlin's former home law office at 121 River Rock St, with Richard G. Hill, Esq. as opposing
counsel in CV11-03628, occurred while Coughlin was speaking to RCA Ormaas in attempts to resolve the matter
(11 TR 26800 a traffic citation matter wherein RPD Sargent Tarter and other officers responded to Richard G.
Hill, Esq.'s office on 11/15/12 (its possible both Hill and Coughlin called the police and or 911...can't remember)
when Coughlin appeared there after being released from 3 days in jail incident to the 11/13/12 criminal
trespass arrest (now a conviction and discussed in that attached materials, some of which appear on the
Nevada Supreme Court's site under case 61901, the conviction stemming from 11 CR 26405 before RMC
Administrative Judge W. Gardner, the brother of District Court Judge Linda Gardner whose April 2009 Order
sanctioning Coughlin was cited by Washoe Legal Services at the cause for his firing, and led to 60302, now on
appeal...
I would really just like to move on from all of this, but this is a time of exigent circumstances, and if the RMC
and the City of Reno Marshals do not take affirmative steps to disavow the unsworn hearsay Judge Nash
Holmes attributed in her supposedly sworn testimony at Coughlin's 11/14/12 Disciplinary Hearing, it may be
that a negligent hiring, training, or supervision cause of action may acrue against various Marshals, even
personally (and its not so clear Mr. Christensen and the City of Reno would extend any purported
representation to such personal liability, for, say, slander or libel).
NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court, or engaged in judicial duties
at chambers, or toward masters or arbitrators while sitting on a reference or arbitration, or other judicial proceeding.
2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or in its immediate vicinity,
tending to interrupt the due course of the trial or other judicial proceeding.
3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge at chambers.
4. Disobedience of a subpoena duly served, or refusing to be sworn or answer as a witness.
5. Rescuing any person or property in the custody of an officer by virtue of an order or process of such court or judge at
chambers.
6. Disobedience of the order or direction of the court made pending the trial of an action, in speaking to or in the presence of a
juror concerning an action in which the juror has been impaneled to determine, or in any manner approaching or interfering with such juror
with the intent to influence the verdict.
7. Abusing the process or proceedings of the court or falsely pretending to act under the authority of an order or process of the
court.
[1911 CPA 452; RL 5394; NCL 8941](NRS A 1983, 843)

NRS 22.030 Summary punishment of contempt committed in immediate view and presence of court; affidavit or
statement to be filed when contempt committed outside immediate view and presence of court; disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at chambers, the contempt may be
punished summarily. If the court or judge summarily punishes a person for a contempt pursuant to this subsection, the court or judge shall
enter an order that:
(a) Recites the facts constituting the contempt in the immediate view and presence of the court or judge;
000133
(b) Finds the person guilty of the contempt; and
(c) Prescribes the punishment for the contempt.
2. If a contempt is not committed in the immediate view and presence of the court or judge at chambers, an affidavit must be
presented to the court or judge of the facts constituting the contempt, or a statement of the facts by the masters or arbitrators.
3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate view and presence of the
court, the judge of the court in whose contempt the person is alleged to be shall not preside at the trial of the contempt over the objection of
the person. The provisions of this subsection do not apply in:
(a) Any case where a final judgment or decree of the court is drawn in question and such judgment or decree was entered in such
court by a predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings for the violation of the judgment or
decree.
(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been established in the judicial
district.
NRS 22.100 Penalty for contempt.
1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall determine whether the person
proceeded against is guilty of the contempt charged.
2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine may be imposed on the person
not exceeding $500 or the person may be imprisoned not exceeding 25 days, or both.
3. In addition to the penalties provided in subsection 2, if a person is found guilty of contempt pursuant to subsection 3
of NRS 22.010, the court may require the person to pay to the party seeking to enforce the writ, order, rule or process the reasonable
expenses, including, without limitation, attorneys fees, incurred by the party as a result of the contempt.
NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one of the following kinds shall be
guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its immediate view and presence,
and directly tending to interrupt its proceedings or to impair the respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or hearing pursuant to an order of
court, or in the presence of a jury while actually sitting in the trial of a cause or upon an inquest or other proceeding authorized by law;
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of a court, jury or referee;
4. Willful disobedience to the lawful process or mandate of a court;
5. Resistance, willfully offered, to its lawful process or mandate;
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer any legal and proper
interrogatory;
7. Publication of a false or grossly inaccurate report of its proceedings; or
8. Assuming to be an attorney or officer of a court or acting as such without authority.
ARTICLE IV - Judicial Department
Sec.4.010Municipal Court. The Municipal Court must include one department and may include
additional departments in the discretion of the City Council. If the City Council determines to create additional
departments, it shall do so by resolution and may appoint additional municipal judges to serve until the next
election.
000134
(Ch. 662, Stats. 1971 p. 1976; ACh. 553, Stats. 1973 p. 881; Ch. 373, Stats. 1979 p. 645; Ch. 208, Stats. 1985
p. 675; Ch. 9, Stats. 1993 p. 21)
Sec.4.020Municipal Court: Qualifications of Municipal Judge; salary.
1.A Municipal Judge must be:
(a)An attorney licensed to practice law in the State of Nevada.
(b)A qualified elector within the City.
2.A Municipal Judge shall not engage in the private practice of law.
3.The salary of a Municipal Judge must be:
(a)Fixed by resolution of the City Council.
(b)Uniform for all judges in the Municipal Court.
(Ch. 662, Stats. 1971 p. 1976; ACh. 343, Stats. 1973 p. 422; Ch. 553, Stats. 1973 p. 881; Ch. 98, Stats. 1977
p. 211; Ch. 561, Stats. 1977 p. 1395; Ch. 208, Stats. 1985 p. 675; Ch. 599, Stats. 1993 p. 2501; Ch. 327, Stats.
1999 p. 1369)
Sec.4.030Disposition of fines. All fines and forfeitures for the violation of ordinances shall be
paid to the City Clerk in the manner to be prescribed by ordinance.
(Ch. 662, Stats. 1971 p. 1977)
Sec.4.040Procedure, additional judges. The practice and proceedings in the Court must conform
as nearly as practicable to that of justices courts in similar cases. Upon the written request of the City
Manager an additional temporary Municipal Judge may be provided for so long as the City Council authorizes
additional compensation for such a Judge. Whenever a person is sentenced to pay a fine, the Court may
adjudge and enter upon the docket a supplemental order that the offender may, if he or she desires, work on
the streets or public works of the City at the rate of $25 for each day. The money so earned must be applied
against the fine until it is satisfied.
CONTEMPT
Acts or omissions constituting, generally, 22.010
Affidavit of facts constituting, 22.030
Affidavits presented in bad faith, NRCP 56(g), JCRCP 56(g)
Appearance, failure of defendant to make, 22.130
Arrest
000135
Bond, 22.070
Excuses for not bringing arrested person before court, 22.140
Illness of defendant, effect, 22.140
Attorneys at law
Bar examination, early release of results, SCR 68
Discharged, failure to deliver certain materials to client, 7.055
Bail
Violation of conditions deemed contempt, 178.484
Commercial premises, violations of writ of restitution, 118C.210
Commission in presence of court or judge, 22.030
Compelling performance, imprisonment, 22.110
Court order, violation, 1.250, 22.010
Court reporters, 656.240
Criminal, 193.110, 193.300, 199.340
Custodial parent, failure to comply with visitation orders, 125C.030, 125C.040
Discharge from arrest, 22.070
Disqualification of judge or justice, making of charge not punished as contempt, 1.225, 1.230
Documents, refusal to permit inspection, NRCP 37(b)(2), JCRCP 37(b)(2)
Failure to perform specific acts directed by judgment, 22.010, NRCP 70, JCRCP 70
Imprisonment, 22.100, 22.110
Indictment for contemptuous conduct, 22.120
Justice courts, civil proceedings, 74.040
Material witness granted immunity, failure to testify, 178.576
Misconduct by defendant during criminal trial, 175.387
Municipal court may punish for, 266.570
000136
Punishment, 22.030, 22.100, 22.120
Reentry on real property after ejectment, 22.020
Refusal to answer or be sworn, 22.010, 50.195, NRCP 37(b)(1), JCRCP 37(b)(1)
Sheriffs duties, 22.060, 50.205
Subpoenas, failure to obey
Deemed contempt, 22.010, 174.385
Witnesses, forfeitures and damages, 50.195
Summary punishment, 22.030
Trials for contempt
By court or jury, 22.100
Disqualification of judge, 22.030
Investigating charge, 22.090
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-
Mart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
all the information necessary to issue a citation" explanations (including Crawfords
lying under oath that Coughlin didn't provide his driver's license to him on September
9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
chance to explain how she prosecutes cases based upon arrests by tribal officers for
misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the 11/14/12
Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.
000137
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police
officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of
Indian Affairs or a person employed as a police officer by an Indian tribe may make an
arrest in obedience to a warrant delivered to him or her, or may, without a warrant,
arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not
in the officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or
agent has reasonable cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross
misdemeanor by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or
described person for a public offense, and the officer or agent has reasonable cause to
believe that the person arrested is the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested
has committed a battery upon that persons spouse and the peace officer finds
evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense
committed on that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or
agent is in fresh pursuit of a person who is reasonably believed by the officer or agent
to have committed a felony within the boundaries of the reservation or colony or has
committed, or attempted to commit, any criminal offense within those boundaries in
the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to
000138
it in NRS 171.156.
Please see the photograph in the attached materials of the RSIC Officer taking
Coughlin's driver's license from him, thereby vitiating his assertion that an arrest was
an available option due to Couglin not providing his driver's license to the Officers.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 9 files to share with you on SkyDrive. To view them, click the links below.
11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 1 of 2.pdf
11 22 12 final collection for Chief Marshal Roper's review 0204 26800 part 2 of 2.pdf
11TR26800 031412 RMC continuation of trial Nash Ormaas Hill traffic citation 031412_20120312-
1033_01cd003b8f0851d0.mp3
11TR26800 RMC 022712 part 2 of 2 from 2 27 12 031412_20120227-1621_01ccf56bce224540.mp3
11TR26800 RMC 022712 part 1 of 2 from 2 27 12 031412_20120227-1507_01ccf5618f76c460 (2).mp3
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
NG12-0204.pdf
CR12-1262 appeal.pdf
11 2 12 file stamped complete notice of errata and revised supplemental 26405 1708 0204.pdf
11 15 11 rpd tarter redacted 0204 0434 26800 police report ormaas retaliation.pdf
Download all

please indicate some response to my subpoena and discovery requests
From: Zach Coughlin (zachcoughlin@hotmail.com)
000139
Sent: Thu 11/22/12 1:18 PM
To: bdogan@washoecounty.us (bdogan@washoecounty.us); zyoung@da.washoecounty.us
(zyoung@da.washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us);
complaints@nvbar.org (complaints@nvbar.org)
3 attachments
exhibit 1 to 61901 10 24 12 filing opposition.pdf (9.4 MB) , 10 24 12 stamped motion for leave to file
opposition 61901 0204 12-33724.pdf (228.4 KB) , 11 2 12 file stamped complete w 195 ex and dvd
notice of errata and revised supplemental 26405 1708 0204.pdf (979.7 KB)
Dear Mr. Dogan and DDA Young,
Please find attached updated discovery relevant to the RCR2012-065630 matter, especially considering Sargent
Paul Sifre's ordering both the 1/12/12 custodial jaywalking arrest and the 1/14/12 "misuse of 911" arrest (though
Sargent Kim Bradshaw appears to have a connection to those in addition to the July 3, 2012 "disturbing the peace"
arrest in 12 CR 12420.
Mr. Dogan, I am formally requesting that you send the Reno Police Department Custodian of Records (Doreen and
Harriet Neumann et al) and the ECOMM (Kelley Odom, Kariann Beechler
a subpoena and supboena duces tecum for all police reports, documentations, recordings of any kind, etc., etc.
related to the 10 incarcerations of Zachary B. Coughlin (dob 9/27/76) since 8/19/11, including the dispatch tapes
of communications between the RPD and Ecomm dispatchers.
Please note that the "possible fight" report that the RPD alludes to in its arrest report of 1/12/12 is similar to the
now debunked arguments in court and in pleadings on file and questions asked eliciting testimony thereto by DDA
Young and RPD Officer Duralde in RCR2011-063341.
It is my understanding the Richard Hill and or one of his contractors (possibly Phil Stewart of Nevada Building
Industries) called RPD Dispatch or 911 (or possibly just called a Sargent or Officer of their choosing directly) and
that what was communicated therein resulted in RPD response appropriate to reports of a "possible fight".
Please include in the discovery materials the calls that RPD Officer Hollingsworth alludes to in the videos from
that day that Coughlin can authenticate and verify as he filmed them (which show Hill lying to Officer
Hollingsworth where he alleges Coughlin, on 1/12/12, had already "lost his appeal" in that appeal of the summary
eviction from his law office (not true, as the Order denying the appeal was entered 3/30/12)...
This is also a formal complaint/police report of the extortionate threats made by Hill and apparent filing of false
police reports where Hill lies to the RPD (like he did in the 11/13/12 custodial arrest that is now detailed in 61901
and that attached filing in 11 CR 26405) to effect a false arrest of Coughlin.
Please respond in some way, Mr. Dogan as to whether you have complied with my requests that you subpoena
Sargent Sifre, Sarget Zach Thew (relevant to a claim of right defense that may arise given Sargent Thews
directions to Coughlin in the days prior to the arrest of 1/14/12) and Sargent Marcia Lopez and Officer Chris
Carter...Sargent Lopez's testimony will be particulary important given the motive she and the RPD had to harass
and retaliate against Coughlin arising from Coughlin, on 1/13/12, getting Sargent Lopez to admit on video that she
and Carter committed misconduct and fraud incident to teh 11/13/12 arrest of Coughlin fro criminal trespass in 11
CR 26405.
Further, please subpoena RPD Officer Travis Look (one of the "arresting officers" in 065630 whom utilized
excessive force, along with then trainee Wesley Leedy, at the direction of Sargent Paul Sifre, despite Officer
Hollingsworth indicated to Coughlin on video that Coughlin was not violating the law, and therefore, no lawful
warning or order having been given to Coughlin). Additionally, please subpoena Richard Hill, Casey Baker,
and Phi Stewart, Christopher Allaback, and Laura Foreshee to testify regarding the arrest.
000140
Further, Mr. Dogan and Mr. Young, the RPD had a multitude of recordings device out and recording that night,
yet none have been propounded to me....I am hereby reiterating my request to be provided that mandatory
discovery, regardless of the extent to which the DA's Office does not feel it excuplatory in nature or where,
predictably, Mr. Dogan and the WCPD don't see it's utility. Speaking of not seeing any utility...Mr. Dogan, what
is it you have done, in any way, to advocate on my behalf in this matter?
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.com
To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org;
fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com;
cvellis@bhfs.com; eifert.nta@att.net; rhrc@laketahoelaw.com; stuttle@washoecounty.us; kadlicj@reno.gov;
wongd@reno.gov; schornsby@nvdetr.org
Subject: new Discovery finally produced by Reno City attorney on 1/12/12 Jaywalking arrest in SCR 105
Complaint
Date: Wed, 14 Nov 2012 06:46:53 -0800
Dear Panel and Bar Counsel,
Please find the attach additional discovery the Reno City Attorney's Office gave me
today related to the custodial jaywalking arrest of 1/12/12, at which time Richard Hill
applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD
Officer Look took a special trip to the jail to attempt to serve the TPO for Hill).
Please see attached the video of the arrest and interactions prior thereto, and consider
the lack of accuracy in Hill and Baker's Second Motion to Show Cause, Judge
Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause
Hearing (which WCSO Deputy Machen, the same one who filed a false affidavit
incident to the summary eviction order posting and lockout on 11/1/11 in the Richard
Hill eviction cases rev2011-001708 served on Coughlin, by way of violating the
"courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that
case Coughlin did not require personal service anyways...this was hazing by Hill and
the RMC Marshals and WCSO Deputies, plain and simple, at the 2/27/12 Trial in 11
TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD
Sargent Tarter telling Coughlin to leave Hill's office upon going there after being
released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12
000141
resulting in a wrongful arrest for criminal trespass of Coughlin by RPD Officer Chris
Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer
Hollingsworth in seeking to abuse process and have Coughlin arrested. Then trainee
Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest
report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for
"misuse of 911" which DDA Young nows seeks to amend to a crime that will leverage
the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable
cause basis for doing so. Further, both Hill and Officer Leedy substantially
misrepresent what Officer Hollingsworth said. Additionally, should Officer
Hollingsworth had indeed told Coughlin that what he was doing was legal but that the
Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve
cooperation, that would violate Soldal v. Cook County, which is essentially what RPD
Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which
les to 11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes
a lot of people to help Board member Richard G. Hill, Esq. and his fled-to-Kentucky
associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half-
way believing RPD Officer Carter's statement on 11/15/11 that "Richard G. Hill pays
me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's
merely attributing the statement that RPD Carter said to Carter is not misconduct.
Hill's making up things about a "crack pipe and bag of weed" and "large quantity of
pills" (see the video "Zach's arrest 014 that Hill and Merliss themselves filmed to see
that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that
mentions this "large quantity of pills"). If you knew all the Thursday nights I spent
since 2003 with Coe, and now deceased Judge Bob, and so many others, you would
realize how infinitely tacky Hill's conduct is.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 14 files to share with you on SkyDrive. To view them, click the links below.
1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204
25 page discovery northwind ncs krebs reduced size.pdf
000142
1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-
000018 0204 Leed.pdf
SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
SAM_0189_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
11 9 12 61901 amendment to opposition.pdf
11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder
ptthoa 0204.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
bifurcate atty client severe hearing trialotjl.pdf
bifurcate atty client severe hearing trial.pdf
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
NG12-0204 BF.pdf
Download all

000143
Print Close
Formal request for names of those on my Screening Panel`
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 11/22/12 12:39 PM
To: tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org);
patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net
(eifert.nta@att.net); skent@skentlaw.com (skent@skentlaw.com); davidc@nvbar.org
(davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com
(fflaherty@dyerlawrence.com)
I am writing to formally request the names of those who were on the Screening Panel
incident to the current SCR 105 SBN v. Coughlin Complaint in ng12-0204, etc.
Rule 105. Procedure on receipt of complaint.
1. Investigation.
(a)
Investigation and screening panel review. Investigations shall be initiated and conducted by bar counsel or
bar counsel's staff or other investigative personnel at bar counsel's direction prior or pursuant to the
opening of a grievance file. At the conclusion of an investigation of a grievance file, bar counselshall
recommend in writing dismissal with or without prejudice, referral to diversion or mentoring pursuant to
Rule 105.5, a letter of caution, a private reprimand, or the filing of a written complaint for formal hearing.
The recommendation shall be promptly reviewed by a screening panel. A screening panel shall consist of
three members of the disciplinary board, appointed by the chair in accordance with Rule 103(6). Two of the
three reviewers must be members of the bar. By majority vote they shall approve, reject, or modify the
recommendation, or continue the matter for review by another screening panel
Given the Board's inclusion of numerous individuals with patent conflicts (DDA Kandaras (intimately
involved in the opposition's causes in a number of matters, including the apparent search and seizure of my
smart phone and micro sd card incident to summary "misdemeanor of criminal contempt" Order (that
cited to a non summary civil contempt statue in NRS 22.010, yet attempted to utilized the summary nature
of NRS 22.030 (only without complying with the Affidavit requirement for conduct not in the "immediate
presence" of Judge Nash Holmes, all while purporting to be a criminal misdemeanor charge a la NRS
199.340 (very creative, and very, very duplicitous to boot coming from a Judge...and add to that an attempt
to further Bar Counsels SCR 111(5) aims by including the "find by clear and convincing evidence" burden
of proof standard necessary to prove an ethical violations of the RPD in a disciplinary hearing setting....
Then there is Richard Hill's best friend, David Hamilton being on the Board (and SBN King has curiously
redacted nearly any mention of Hill in his 8/23/12 Complaint (for which there remains no return of service
filed in the Disciplinary File (and any attempt by the SBN to assert that the certified mailing of 8/23/12 is
sufficient is fraudulent, see Coughlin's recent sworn Affidavit or Declaration under penalty of perjury as to
000144
the SBN, Panel, and NNDB's representations in that regard, especially in light of SCR 105(4). Further is
is fraudulent and displays a lack of candor to assert that SCR 106 provides insulation from subpoena where
it speaks merely to causes of action, and any immunity therein surely has its limits, otherwise Pat King
would probably go biting Respondent's in their jugular's like the vampire he is.
Also, please formally provide me a copy of any rules of procedure or other applicable policies, practices,
rules, procedures, or dictates adopted by the Panel and or the NNDB or SBN that attach to these
disciplinary proceedings, such as the one of 11/14/12 (and the 45 days from the Panel's designation will run
real soon, so to get a non-void for lack of jurisdiction Disciplinary Hearing set and noticed, the SBN, Panel,
and NNDB is hereby advised to take note of that fact and proceed accordingly. Further, Coughlin objects
to the SBN, Panel, and Board's depriving him of his Sixth Amendment right to confront his accuser in this
quasi-criminal setting, particularly where the SBN still refuses to divulge the complainant in the NG12-0435
grievance, or which Clerk of Court or whoever it was that forwarded that April 2009 Order to the SBN.

And to the extent the Complaint has been curiously disinfected to redact mention of Richard G. Hill, Esq.,
allegations in Hill's 1/14/12 unsigned grievance letter to the SBN (while they waited to hear back on their
Milsner v Carstarphen case from the Nevada Supreme Court) attached to the SBN's 2/14/12 letter to
Coughlin (which King fraudulently attempted to assert at the 11/14/12 Hearing that Coughlin somehow
failed to respond to, or to respond timely, particularly where the bate stamped Disciplinary File as late
provided by King on 11/8/12 (in violation of SCR 105(2)(c)) is a textbook case of fraudulent ommission and
obfuscation....see the "Folders" for each grievance (the folder listing Linda Gardner as the grievance filer is
particularly interesting considering is consists only of a online blog entry about prosecutorial misconduct,
and given that Linda Gardner and her brother, the one who refused to recuse himself from the criminal
trespass matter where Richard G. Hill signed the Complaint and the RPD has admitted to fraud incident
thereto on tape, 11 CR 26405, are both lifelong prosecutors.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Judge Howard and Cassandra Jackson want to explain
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 11/22/12 12:56 AM
To: je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); davidc@nvbar.org
(davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
(eifert.nta@att.net); mike@tahoelawyer.com (mike@tahoelawyer.com); patrickk@nvbar.org
(patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); skauc@reno.gov (skauc@reno.gov);
000145
robertsp@reno.gov (robertsp@reno.gov); hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov);
wongd@reno.gov (wongd@reno.gov)
6 attachments
DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) , 12 16 11 email to
plongoni@charter.net longoni and 12 21 11 email to ballardd@reno.gov regarding longoni 22176
26800 0204 0435.pdf (22.7 KB) , 10 9 12 Affidavit of Laura Peters 0204 never sent to Coughlin no
proof of service, yet file stamped.pdf (1516.8 KB) , 12 15 11 22176 2064 Order by Howard on
transcript costs.pdf (92.8 KB) , 12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
(110.8 KB) , 11 16 12 skau grievance materials combined 0204 063341.pdf (1943.8 KB)

How RMC handouts and agreements with Pam Longoni are not violating NRS 189.030
and NRS 4.14(a)

RCA Skau wants to explain his lies about the judge authorize service by email for an
unnoticed hearing where Skau sought to argue email service was insufficient when it
came to his people...Then RCA Hazlett-Stevens want to explain his mysterious claims
to have not received the Notice of Appeal in cr12-1262 or why he puts on perjured
testimony by Richard G. Hill, Esq., RCA Pam Roberts would like to explain the same
for 11 cr 22176. RCA Allison Ormaas wants to explain what she was whispering in
RMC Marshal Harley's ears on 2/27/12 and whether it was about the same failure to
chart follow up on, or report RPD Chris Carter's admission that "Richard Hill pays me a
lot of money, so I arrest who he says to and do what he says to do...", just like Reno
City Attorney Chief Criminal Deputy Dan Wong explained he was surely not going to
do to when Coughlin made the same report to him on 1/19/12....

SBN Clerk of Court Laura Peters wants to explain how she approved fax filing for
Coughlin on 9/11/12, and how her Affidavit of 10/9/12 wound up in the Disciplinary
file only made available to Coughlin 5 days before the hearing (with thousands of pages
of filler and duplicates to hide the little it contained...which in the case of Linda
Gardner's grievance, was a mysterious printout from a blog and no more...no cover
letter, no nothing...and Kings email where he purports that the "Clerk of Court" sent
him the Order still has not been clarified, though Joey Orduna Hastings, Clerk of Court
of the Second Judicial District Court wants to indicate whether she sent it to the SBN,
or, more likely, the Clerk of Court of one of the Muni Court Departments (probably
Judge Nash Holmes' in D3, considering her 3/23/12 email to the SBN about Coughlin's
clothing choices to check on a traffic citation at a munic court filing office window...)
who got ahold of District Court Judge Linda Gardners April 2009 Order when Judge
L. Gardner passed it to her brother, RMC William Gardner, who refused to recuse
himself from Coughlin's criminal trespass case based upon Richard Hill's Complaint,
000146
but did manage to pass his sister's Order around to his fellow Judges and hold meetings
with them about how to get back at Coughlin for pointing out things they do that violate
due process rights and other laws. Like those requiring a stay of proceedings when a
defendants competency is brought into question. DDA Young is great at violating
those laws, and bossing Judge Sferrazza around in court, demanding he take into
custody anyone who doesn't do just exactly what DDA Young wants and or give just
exactly the answer he is looking for....

Pat King, Laura Peters and David Clark want to explain how their statements and
corresponence with Coughlin respecting his right to issue subpoenas and waiver of
witness fees of fees for subpoena duces tecums departed remarkably from the sudden
about face on that issue when the Motions to Quash started coming in, though the
Disciplinary Hearing of 11/14/12 went on just they same, right....


Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper,
and Marshal Joel Harley,
Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment
violation if the person was guilty of the crime you suspected him of committing when
you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy
Sleazy, WCPD Jim Leslie by muscling over indigent criminal defendants for him when
Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to
Jimmy's rescue and tells Coughlin, Leslie at his side, that "I'm going to put my foot up
your ass..." Reyes watches defendants get put in jail for months day in day out for doing
less than that....
Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for
information on the transmission of the Eviction Order in rjc 2011-001708 to the
Washoe County Sheriff's Office.
Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits
of service he files, and Maureen and Roxy's assertions that the "receipt" of the eviction
Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must
effect the lockout "within 24 hours of receipt of the Order"...and Casey Baker, Esq.
wants to explain his testimony of 6/18/12 when he explained what he did with the
Sheriff's Office on October 28th, 2011...and Reno Carson Messenger service want to
explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
000147
pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple
minutes to 5 pm, and definitely not sooner than 4:48 pm, despite Machens 11/1/11
Affidavit of Service (that his supervisor Stuchell had to admit was false in that it alleged
"personal service" where the WCSO admits no one was home (and the locksmith totally
refutes Hill's testimony of 6/18/12 "they tried to serve it to you but you ran away..."
(really, Rich, becaue Casey didn't testify to that, but he did say that you weren't even
there that day, so what do you base that sworn allegations on Rich, besides your desire
to mitigate your liability for all your misdeeds there?).
Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash
Holmes got "confused" on in her "sworn testimony"...which is shaping up to look at lot
like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a
disbarment, which in Nevada, are irrevocable as of 2008. To be clear, Judge Nash
Holmes testified falsely at the 11/14/12 Disciplinary Hearing in a number of ways. The
attached audio from the Hearing and Judges Nash Holmes various Orders (which reveal
a disturbing attempt to mix and match various civil and criminal contempt statutes,
some plenary, some summary, and add the transmogrification of a "simple traffic
citation Trial" into some sort of Summary Disciplinary Hearing...which SBN Bar
Counsel Pat King is only too happy to sign on to, eager to kick back and rely on SCR
111(5) after having fed Judge Nash Holmes the instruction to make sure to copy and
paste as many sections of the Rules of Professional Conduct into an "Order" that is sure
to point out the burden of proof necessary for a "ethical violation" finding in a
Disciplinary Hearing setting. The only thing less transparent than this awkward attempt
by Bar Counsel and Judge Nash Holmes to get 'r done was the brother and sister act by
Judge William Gardner and his sister Judge Linda Gardner, complimented, of course,
by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge L.
Gardner's April 2009 Order sanctioning Coughlin, which Washoe Legal Services's Paul
Elcano cited as the sole reason for Coughlin's firing (and which begat the Mandamus
Petition against L. Gardner in 54844, the wrongful termination suit against WLS in
60302, the criminal trespass conviction in 11 CR 26405 that Judge W. Gardner refused
to recuse himself from, etc., etc.
WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS
178.405 and the communications with RMC Judge Nash Holmes regarding the 2/27/12
Order for Competency Evaluation that should have prevented her from even holding the
Trial (the one that occurred right after RMC Marshal Harley served a civil eviction
appeal document on behalf of the process server Richard G. Hill, Esq. hired to serve
000148
Coughlin the Order to Show Cause in cv11-03628 that Coughlin had already received
in connection with his being the attorney of record and an e-filer on that matter...see
Caplow).
RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about
their misconduct in 11 CR 26405 and the extent to which Richard Hill and his client,
Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405
and 61901.
Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v.
Wells Fargo, LLC. Officers Wesley and Look wanted to weigh in on that too..
RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who
was working that night of the 8/20/11 arrest that started a year in which Coughlin was
arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one
for "misuse of 911" even though Coughlin received two protection orders in FV12-
00187, and -00188), with Officer Duralde pulling Couglin over in the middle of the
night upon his walking to his car after being released from jail on a 15 degree night on
1/13/12, where five other RPD Officers helped Officer Duralde with the pressing matter
of the sudden disappearance of Coughlin's license plate...), (all suspiciously close in
time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12 with the
RPD) wanted to weigh in on the misconduct attendant to Duralde's testifying that
dispatch reported to himself and RPD Officer's Alaksa and Rosa that night about "a
possible fight" thus supporting their reponse and the associated Terry Stop weapons
check frisk pat down and custodial arrest for a misdemeanor allegedly occuring outside
their presence after 7 pm:
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or arrest the person for another
alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense is
committed;
000149
(e) When the offense charged is battery that constitutes domestic violence pursuant toNRS 33.018 and the arrest is made in the manner
provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued pursuant to NRS
33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-
Mart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
all the information necessary to issue a citation" explanations (including Crawfords
lying under oath that Coughlin didn't provide his driver's license to him on September
9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
chance to explain how she prosecutes cases based upon arrests by tribal officers for
misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the 11/14/12
Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.
NRS 171.1255Arrest by officer or agent of Bureau of Indian Affairs or police
officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person
employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant delivered to him or
her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agent
s presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable cause
for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
offense, and the officer or agent has reasonable cause to believe that the person arrested is the person so named or
000150
described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery
upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation
or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a
person who is reasonably believed by the officer or agent to have committed a felony within the boundaries of the
reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in
the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts
with my father, Palmer v. Pioneer, etc.
So, this is the Elcano approach...he gets an email on 4/19/12 that is a written
employment law centered complaint from an employee...and he has the employee
suspended within days thereafter...then claims to have not received the email, then
adopts some Duluth Model "Power and Control" wheel co-opting or leveraging of
"treatment" or armchair psychiatry...
Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79. Stephen
Kent, McGeorge '80. RMC Judge Howard (Wal-Mart conviction resulting in 6/7/12
temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82 (twice
Coughlin's RMC court appointed counsel, allowed to withdraw with pay both times,
refused to advocate in any way). Gammick, McGeorge '82. Springgate, McGeorge '85
(opposing consel in ng12-0435 asking for sanctions in divorce case closing argument).
Kandaras, McGeorge '91 (Deputy District Attorney involved in warrantless seizure of
Coughlin's smart phone. DDA Z. Young, McGeorge '04. Hazlett-Stevens, McGeorge,
'06.
What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned
Coughlin about "recording devices" and or whether he was recording BEFORE the one
restroom break, purposefully changing the order of the questioning and the restroom
break to suggest some furtive activity on Coughlin's part, which Judge Nash Holmes
then further attempted to amplify in her assertion that Marshal Joel Harley was ordered
to follow Coughlin into the restroom and that a Marshal asserted to her that Coughlin
000151
"disassembled a recording device" in the restroom and "hid a part or portion of it in the
restroom"
Fraud on the court Conduct of counsel in omitting portion of deposition when
deposition is read into record, and giving impression that entire document is being
proffered, resulting in buttressing of his party's position is fraud on the court warranting
the imposition of sanctions. Sup.Ct.Rules, Rules 172, 172, subd. 1(a, d). Sierra Glass &
Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119, rehearing denied.
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events
and when she asked Coughlin her questions about recording, considering when a restroom break took place
an exactly what it is she asked Couglin and when, and what his responses were, and when some allegations
by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio transcript
reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some
extreme form of mental illness. during the trial I asked the defendant attorney repeatedly if he was
recording the proceedings he denied that vehemently a few times and then he quote took the fifth a
few other times and then he requested to be excused to go to the bathroom and the Marshal later
reported to me that while the gentleman was in the bathroom he disassembled a recording device in
his pocket and took the memory out of it and it was later found in that, uh, by the Marshal no one
else had gone into the bathroom and that was retrieved and it was put into his possession at the
Sheriff's office and when they booked him into jail for the contempt charge that was booked into
evidence and I asked the Sheriff's office to hold that into evidence. I believe he has violated Supreme
Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her statement
at the 7 minute mark that "It appears to me in this case that the defendant is suffering from some extreme
form of mental illness." Further, that which Judge Nash Holmes had communicated to her prior to the start
of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have Bar Counsel assert
to half baked "can't ask the judge about her mental processes" loophole, as he has done.
Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12 "simple
traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office to get his driver's
license, wallet, keys, and client's files following a custodial arrest for trespass (see RPD Sargent Lopez and
Officer Carter's explanations thereof in 11 CR 26405 and 61901) and three days spent in jail, upon being
released therefrom on 11/15/12...and at the Trial on that traffic citation issued by RPD Sargent John Tarter,
RMC Marshal Joel Harley, just before Trial (when Judge Nash Holmes couldn't be found and WCPD
000152
Biray Dogan and DDA Zach Young were getting an Order for Competency Evaluation of Coughlin in
rcr2012-065630 at 1:31 pm...and the 11 TR 26800 Trial starting late, not at 1 pm as noticed, but at 3
pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges wherein they
brainstormed ways of combating Coughlin's championing of due process rights for the disenfranchised...
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the
citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right at it and
given what she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin
reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's responses thereto
on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was
recording anything or whether he possessed a "recording device" until AFTER the one and only
restroom break Judge Nash Holmes mentions on the audio record. And that sua sponte interrogation
of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A BREAK IN WHICH
JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS YELLOW LEGAL
PAD WITH HIM AND WHICH OCCURED AFTER COUGHLIN MADE A VERBAL
PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY
CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT
UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY
BEFORE THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S
ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT
STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that
was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr
26800, and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that
local law enforcement and prosecutors and public defenders were non too happy with Coughlin...and
consider the 2/24/12 email vacating the 2/27/12 status conference between young and dogan that
neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the
time Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst
Judges about Coughlin that RMC Administrative Judge William Gardner referenced on the record in
11 CR 26405? Interesting the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan
got his ORder for Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation
for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by Coughlin
of approximately 11/28/12, which resultd in Young promptly amending his complaint in rcr2011-
063341 to add a charge that was duplicative, even where YOung failure to allege theft or
possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case
a RPC 3.8 violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which
YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an
Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind
YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in
cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC
000153
11 cr 26405, the criminal trespass case. NOt much respect for nrs 178.405 (including within NRs
5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a
Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge
Nash HOlmes continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript,
yay....
It is true that contempt committed in a trial courtroom can under some circumstances be punished
summarily by the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a
trial judge of a contempt committed in his immediate presence in open court cannot be likened to the
proceedings here. For we held in the Oliver case that a person charged with contempt before a "one-
man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a trial judge to
punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S. 257.
Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800, also
orders no sufficiently detailed or capable of being known how to comply with, not sufficient warning,
violate Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur
" in the "immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have
misled Judge Nash HOlmes, or maybe something worse is going on here....but what Judge Nash
HOlmes said on the recording is entirely misleading an inaccurate, if not an outright lie (again,
maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but regardless her reliance on
unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to issue a
"summary criminal contempt" conviction against an attorney, but also where Judge Nash Holmes
appears to try to transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR
105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to sign an
affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record,
under oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash
HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just some
musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing
evidence" all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar
Counsel has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on
Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge
Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin
faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was
dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11
cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which
was denied based upon a civilpreparation of transcript down payment rule, in that criminal appeal,
where the RMC has a thing in place with this Pam Longoni that violates Nevada law in that it
000154
refused to give Coughlin the audio cd of the trial for some time, insisting only Longoni would be
allowed to transcribe it, and that the transcript's preparation would absolutely not start until a down
payment was made. Plus, even where Coughlin caved to the payment demands..Longoni repeatedly
hung up the phone on him and otherwise ignored his communications (there may be an issue of the
email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit as
to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his
request to the number the RMC held out for her on her behalf too...
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps,
NG12-0435 (stamped as "received" by the SBN from the "Clerk of Court" of some still unnamed
Court (I'd bet its from the RMC Clerk of Court, whom King purported to have certified documents
from a Court she doesn't even work for at the 11/14/12 Disciplinary Hearing...but then again, Panel
Chair Echeverria allow WLS's Elcano to certify documents just because he claimed to have watched
a tape of a hearing, where Elcano is neither a licensed attorney, nor does he work for any Court....),
depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12
email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department
3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that
would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to
the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting
of Judge L. Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court
Orduna Hastings? Do you have anything to say about this? Judge Nash Holme's 3/14/12 grievance to
bar counsel reads:
"
Re: Zachary Barker Coughlin, Nevada Bar No. 9473
Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker
Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of this attorney being
experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what should be
a simple traffic citation case are self-explanatory and are included, together with copies of massive documents Me.
Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also included.
He failed to appear for the second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge
being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him between cases very
easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9
th
St. #2
Reno NY 89512), although I heard today he may be living in his vehicle somewhere. We do have an address for his
mother, however, as she recently posted part of a fine for him.
000155
Judge Ken Howard, Department 4, had a case on Mr.Coughlin late last year that is now on appeal to the Second
Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently pending in his court with Mr.
Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order, simply
because they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made you
some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him and
him and him and him and him in Departments 2 and 4 so you can hear for yourself how this attorney acts in court. You
can see his behavior in my traffic citation case does not appear to bean isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant
was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed for Contempt of Court and
they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your
pursuit of this matter. Mr.Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the staff and
even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a caseof some urgency,
and I apologize for taking two days to get this package to you; our IT person was ill and could not make the copies of
the audios of Mr.Coughlin's hearings until today, and I felt it was important that the audios be included in the materials
to be considered by the State Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had
appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of
law in Northern Nevada and could be jeopardizing someone's freedom or property interests. "
Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is easily proven
to be patently false at Disciplinary Hearings (to the extent one is allowed to offer such proof, which Panel
Chair Echeverria invariably rules is "not relevent" and King smugly basks in his SCR 111(5) vacation with
his "Clerk of Court" Laura Peters...whose lies about SCR 105(4) resulted in Panel Chair Echeverria
quashing all subpoenas Coughlin issued, including those to which SBN Bar Counsel Pat King filed on behalf
of his former co-worker at the AG's Office, Reno City Attorney Dan Wong...While the other Reno City
Attorney, Creig Skau, kept Coughlin busy with his lies about "the judge authorized me to serve you by
email"...
Sincerely
000156
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe
Swobe's contacts with my family
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 11/22/12 12:37 AM
To: skent@skentlaw.com (skent@skentlaw.com); eifert.nta@att.net (eifert.nta@att.net);
complaints@nvbar.org (complaints@nvbar.org); cvellis@bhfs.com (cvellis@bhfs.com);
davidc@nvbar.org (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); jgarin@lipsonneilson.com (jgarin@lipsonneilson.com);
snordstrom@lipsonneilson.com (snordstrom@lipsonneilson.com); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); roperj@reno.gov
(roperj@reno.gov); duralden@reno.gov (duralden@reno.gov); duraldej@reno.gov (duraldej@reno.gov);
lopezm@reno.gov (lopezm@reno.gov); carterc@reno.gov (carterc@reno.gov); tarterj@reno.gov
(tarterj@reno.gov); leedyw@reno.gov (leedyw@reno.gov); lookt@reno.gov (lookt@reno.gov);
sifrep@reno.gov (sifrep@reno.gov); weavera@reno.gov (weavera@reno.gov); millero@reno.gov
(millero@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us); voldenburg@rsic.org (voldenburg@rsic.org);
kcrawford@rsic.org (kcrawford@rsic.org); dbraunworth@rsic.org (dbraunworth@rsic.org);
jreyes@washoecounty.us (jreyes@washoecounty.us); stuttle@washoecounty.us
(stuttle@washoecounty.us)
8 attachments
10 25 12 61901 opposition (Filed Motion Motion for leave to file opposition or opposition to scr
111(4) petition)_001 - Copy.pdf (225.1 KB) , 11 2 12 file stamped complete notice of errata and
revised supplemental 26405 1708 0204.pdf (884.6 KB) , contempt scr 119(2) in re coughlin 60838
(Filed Motion Motion for Order to Show Cause or Contempt Order Against Bar Counsel and
NNDB)_001.pdf (294.3 KB) , 6 18 12 60630 coughlin v city of reno 0204 12-18956.pdf (2.2 MB) , 6
11 12 de minimis 37 cfr 11.25(3)(a) not a serious offense support and 11.25(3)(c) lacking due process
60838 0204.pdf (129.1 KB) , 11 9 12 stamped 60302 Notice of Lack of Access with both parts of
exhibit 1.pdf (5.0 MB) , 10 31 11 receipt 1708 lockout wcso 26405 03628 60331 within 24 hours hill
tried to get at 5 01pm versus baker oct 28th testimony from Memo of Costs - EX 1 (4-3-12).pdf (19.7
KB) , 11 1 11 locksmith receipt wcso lockout from Memo of Costs - EX 1 (4-3-12)-2 compare 6 18
testimony when the locksmith finally got there.pdf (79.3 KB)
Dear Panel, SBN, and Mr. Garin, and Ms. Nordstrom and RMC Chief Marshal Roper,
000157
and Marshal Joel Harley,

Bailiff John Reyes wants to explain his views on how "its not a Fourth Amendment
violation if the person was guilty of the crime you suspected him of committing when
you did the search" and how its acceptable "subterfuge" for Reyes to help ol Jimmy
Sleazy, WCPD Jim Leslie by muscling over indigent criminal defendants for him when
Leslie can't be bothered upholding the Sixth Amendment, whereupon Reyes comes to
Jimmy's rescue and tells Coughlin, Leslie at his side, that "I'm going to put my foot up
your ass..." Reyes watches defendants get put in jail for months day in day out for
doing less than that....

Steve Tuttle wants to explain why the RJC didn't respond to Coughlin's requests for
information on the transmission of the Eviction Order in rjc 2011-001708 to the
Washoe County Sheriff's Office.

Liz Stuchell and Deputy Machen, and Roxy Silva want to explain all the false affidavits
of service he files, and Maureen and Roxy's assertions that the "receipt" of the eviction
Order in NRS 40.253 was at 8:05 am on 11/1/11 in rjc Rev2011-001708 (Sheriff must
effect the lockout "within 24 hours of receipt of the Order"...and Casey Baker, Esq.
wants to explain his testimony of 6/18/12 when he explained what he did with the
Sheriff's Office on October 28th, 2011...and Reno Carson Messenger service want to
explain why their receipt shows they delivered the lockout order to the WCSO at 4:45
pm on 10/31/12, while the locksmith swears the lockout was not effected until a couple
minutes to 5 pm, and definitely not sooner than 4:48 pm, despite Machens 11/1/11
Affidavit of Service (that his supervisor Stuchell had to admit was false in that it
alleged "personal service" where the WCSO admits no one was home (and the
locksmith totally refutes Hill's testimony of 6/18/12 "they tried to serve it to you but
you ran away..." (really, Rich, becaue Casey didn't testify to that, but he did say that
you weren't even there that day, so what do you base that sworn allegations on Rich,
besides your desire to mitigate your liability for all your misdeeds there?).
Chief Marshal Roper and Joel Harley wanted to explain some of the things Judge Nash
Holmes got "confused" on in her "sworn testimony"...which is shaping up to look at lot
like the unsworn hearsay testimony of a Judge in the In Re Mirch case that resulted in a
disbarment, which in Nevada, are irrevocable as of 2008. To be clear, Judge Nash
Holmes testified falsely at the 11/14/12 Disciplinary Hearing in a number of ways.
The attached audio from the Hearing and Judges Nash Holmes various Orders
(which reveal a disturbing attempt to mix and match various civil and criminal
000158
contempt statutes, some plenary, some summary, and add the transmogrification of a
"simple traffic citation Trial" into some sort of Summary Disciplinary Hearing...which
SBN Bar Counsel Pat King is only too happy to sign on to, eager to kick back and rely
on SCR 111(5) after having fed Judge Nash Holmes the instruction to make sure to
copy and paste as many sections of the Rules of Professional Conduct into an "Order"
that is sure to point out the burden of proof necessary for a "ethical violation" finding
in a Disciplinary Hearing setting. The only thing less transparent than this awkward
attempt by Bar Counsel and Judge Nash Holmes to get 'r done was the brother and
sister act by Judge William Gardner and his sister Judge Linda Gardner, complimented,
of course, by that oh so suspicious looking "5" in the SBN's "received" stamp of Judge
L. Gardner's April 2009 Order sanctioning Coughlin, which Washoe Legal Services's
Paul Elcano cited as the sole reason for Coughlin's firing (and which begat the
Mandamus Petition against L. Gardner in 54844, the wrongful termination suit against
WLS in 60302, the criminal trespass conviction in 11 CR 26405 that Judge W. Gardner
refused to recuse himself from, etc., etc.
WCPD Biray Dogan and DDA Zach Young wanted to explain their violations of NRS
178.405 and the communications with RMC Judge Nash Holmes regarding the 2/27/12
Order for Competency Evaluation that should have prevented her from even holding
the Trial (the one that occurred right after RMC Marshal Harley served a civil eviction
appeal document on behalf of the process server Richard G. Hill, Esq. hired to serve
Coughlin the Order to Show Cause in cv11-03628 that Coughlin had already received
in connection with his being the attorney of record and an e-filer on that matter...see
Caplow).
RPD Sargent Marcia Lopez and Officer Chris Carter wish to address the panel about
their misconduct in 11 CR 26405 and the extent to which Richard Hill and his client,
Dr. Matt Merliss misled them, especially vis a vis the attached filings in 11 CR 26405
and 61901.
Sargent Paul Sifre had some thoughts on the custodial jaywalking arrest and Sifre v.
Wells Fargo, LLC. Officers Wesley and Look wanted to weigh in on that too..
RPD Officer Nick Duralde and his wife, ECOMM/911 dispatcher Jessica Duralde (who
was working that night of the 8/20/11 arrest that started a year in which Coughlin was
arrest 10 times, including a custodial arrest for jaywalking on 1/12/12 then another one
for "misuse of 911" even though Coughlin received two protection orders in FV12-
000159
00187, and -00188), with Officer Duralde pulling Couglin over in the middle of the
night upon his walking to his car after being released from jail on a 15 degree night on
1/13/12, where five other RPD Officers helped Officer Duralde with the pressing
matter of the sudden disappearance of Coughlin's license plate...), (all suspiciously
close in time to Coughlin filing a complaint against Duralde and the RPD on 1/7/12
with the RPD) wanted to weigh in on the misconduct attendant to Duralde's testifying
that dispatch reported to himself and RPD Officer's Alaksa and Rosa that night about "a
possible fight" thus supporting their reponse and the associated Terry Stop weapons
check frisk pat down and custodial arrest for a misdemeanor allegedly occuring outside
their presence after 7 pm:
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain or
arrest the person for another alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest immediately after the offense
is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant toNRS 33.018 and the arrest is made in the
manner provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against domestic violence issued
pursuant to NRS 33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
The RSIC Victoria Oldenburg wants to talk to the Panel about how the RSIC and Wal-
Mart are in a long term business partnership where the 2nd St. Wal-Mart is on tribal
land rented out by the RSIC and patrolled by its tribal officers, who admit to routinely
making misdemeanor petty theft/shoplifting custodial arrest (Officer Kameron
Crawford and Donnie Braunworth have been trained in all the neato "he didn't give me
all the information necessary to issue a citation" explanations (including Crawfords
lying under oath that Coughlin didn't provide his driver's license to him on September
9th, 2011, especially where Wal-Mart's Frontino admits he did not make a citizen's
arrest, nor did any Wal-Mart employee) even where such misdemeanor arrests by tribal
officers are forbidden under NRS 171.1255.. Reno City Attorney too would like a
000160
chance to explain how she prosecutes cases based upon arrests by tribal officers for
misdemeanor where Nevada law expressly prevents misdemeanor arrests by tribal
officers under NRS 171.1255.
I was forced to cross examine/interact with a represented party at the 11/14/12
Disciplinary Hearing, and the SBN and Panel's violations of SCR 105 contributed
greatly to my failure to alert Mr. Garin prior to that. I think out of fairness I and Mr.
Garin/Ms. Nordstrom should be provided transcripts from the 11/14/12 Hearing.

NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police


officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person
employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant delivered to him or
her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agent
s presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable
cause for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
offense, and the officer or agent has reasonable cause to believe that the person arrested is the person so named or
described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery
upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation
or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a
person who is reasonably believed by the officer or agent to have committed a felony within the boundaries of the
reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in
the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
Washoe Legal Services Paul Elcano and State Bar of Nevada's Coe Swobe's contacts
with my father, Palmer v. Pioneer, etc.
000161
So, this is the Elcano approach...he gets an email on 4/19/12 that is a written
employment law centered complaint from an employee...and he has the employee
suspended within days thereafter...then claims to have not received the email, then
adopts some Duluth Model "Power and Control" wheel co-opting or leveraging of
"treatment" or armchair psychiatry...
Elcano, McGeorge '78. Nash Holmes, McGeorge '79. Beesley, McGeorge '79.
Stephen Kent, McGeorge '80. RMC Judge Howard (Wal-Mart conviction resulting
in 6/7/12 temporary suspension in 60838), McGeorge '81. Loomis, McGeorge '82
(twice Coughlin's RMC court appointed counsel, allowed to withdraw with pay both
times, refused to advocate in any way). Gammick, McGeorge '82. Springgate,
McGeorge '85 (opposing consel in ng12-0435 asking for sanctions in divorce case
closing argument). Kandaras, McGeorge '91 (Deputy District Attorney involved in
warrantless seizure of Coughlin's smart phone. DDA Z. Young, McGeorge '04.
Hazlett-Stevens, McGeorge, '06.
What do you call it when Judge Nash Holmes testifies, on 11/14/12 that she questioned
Coughlin about "recording devices" and or whether he was recording BEFORE the one
restroom break, purposefully changing the order of the questioning and the restroom
break to suggest some furtive activity on Coughlin's part, which Judge Nash Holmes
then further attempted to amplify in her assertion that Marshal Joel Harley was ordered
to follow Coughlin into the restroom and that a Marshal asserted to her that Coughlin
"disassembled a recording device" in the restroom and "hid a part or portion of it in the
restroom"
Fraud on the court Conduct of counsel in omitting portion of deposition when
deposition is read into record, and giving impression that entire document is being
proffered, resulting in buttressing of his party's position is fraud on the court
warranting the imposition of sanctions. Sup.Ct.Rules, Rules 172, 172, subd. 1(a, d).
Sierra Glass & Mirror v. Viking Industries, Inc., 1991, 808 P.2d 512, 107 Nev. 119,
rehearing denied.
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events
and when she asked Coughlin her questions about recording, considering when a restroom break took
000162
place an exactly what it is she asked Couglin and when, and what his responses were, and when some
allegations by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio
transcript reads 7 minutes into the audio record the RMC provided the SBN:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some
extreme form of mental illness. during the trial I asked the defendant attorney repeatedly if he was
recording the proceedings he denied that vehemently a few times and then he quote took the fifth a
few other times and then he requested to be excused to go to the bathroom and the Marshal later
reported to me that while the gentleman was in the bathroom he disassembled a recording device in
his pocket and took the memory out of it and it was later found in that, uh, by the Marshal no one
else had gone into the bathroom and that was retrieved and it was put into his possession at the
Sheriff's office and when they booked him into jail for the contempt charge that was booked into
evidence and I asked the Sheriff's office to hold that into evidence. I believe he has violated
Supreme Court Rule 229(2)(B) which was amended by ADKT 440, August 1st, 2011...."
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed
hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her
statement at the 7 minute mark that "It appears to me in this case that the defendant is suffering from
some extreme form of mental illness." Further, that which Judge Nash Holmes had communicated to her
prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have
Bar Counsel assert to half baked "can't ask the judge about her mental processes" loophole, as he has
done.
Here is the actual statements made, verbatim, from the certified audio transcript of the 2/27/12 "simple
traffic citation Trial" stemming from Coughlin going to Richard G. Hill, Esq.'s office to get his driver's
license, wallet, keys, and client's files following a custodial arrest for trespass (see RPD Sargent Lopez
and Officer Carter's explanations thereof in 11 CR 26405 and 61901) and three days spent in jail, upon
being released therefrom on 11/15/12...and at the Trial on that traffic citation issued by RPD Sargent John
Tarter, RMC Marshal Joel Harley, just before Trial (when Judge Nash Holmes couldn't be found and
WCPD Biray Dogan and DDA Zach Young were getting an Order for Competency Evaluation of
Coughlin in rcr2012-065630 at 1:31 pm...and the 11 TR 26800 Trial starting late, not at 1 pm as noticed,
but at 3 pm....with RMC W. Gardner admitting to meetings being held amongst the RMC Judges wherein
they brainstormed ways of combating Coughlin's championing of due process rights for the
disenfranchised...
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the
citation or report in 11 tr 26800 contained any mention of retaliation, given she was looking right at it and
given what she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin
reporting to Ormaas what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's responses thereto
on 2/27/12, and Dan Wong, ditto at an earlier hearing on that matter...
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording anything
or whether he possessed a "recording device" until AFTER the one and only restroom break Judge Nash Holmes
000163
mentions on the audio record. And that sua sponte interrogation of Couglin occured IMMEDIATELY AFTER
THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW
COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER
COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH
OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A
BIT UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE
THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT
INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT STACKED DOCKET, THAT
Judge Nash Holmes just couldn't be found, and how odd that was...which is odd, considering what was going on
in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time
(lots of reasons for and indications that local law enforcement and prosecutors and public defenders were non too
happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and
dogan that neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time Judge
Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about Coughlin that
RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of
Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for Competency Evaluation of
Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was
still smarting from a filing by Coughlin of approximately 11/28/12, which resultd in Young promptly amending
his complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure to allege theft
or possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8
violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which YOung did by filing in
rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an Opposition to Coughlin's or the
WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that
case despite the Order finding Coughlin competent in cr12-0376 didn't even get signed and entered until
5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for nrs
178.405 (including within NRs 5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of
Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes
continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by
the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a contempt
committed in his immediate presence in open court cannot be likened to the proceedings here. For we held in the
Oliver case that a person charged with contempt before a "one-man grand jury" could not be summarily tried.
[349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his immediate presence in
open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176
and 11 tr 26800, also orders no sufficiently detailed or capable of being known how to comply with, not sufficient
warning, violate Houston v Eighth Judicial District (Nev.).
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the
"immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is
entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe she
is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary
where she not only purports to issue a "summary criminal contempt" conviction against an attorney, but also
where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic citation trial" into a
000164
full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to
sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record, under
oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash HOlmes phone in
her testimony, and it probably won't even be sworn testimony, but rather just some musings by Judge Nash
Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts of things outside her
jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to Quash the Subpoenas
Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge
William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of
Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal
was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176
conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was denied based
upon a civil preparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in
place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the trial
for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's preparation would
absolutely not start until a down payment was made. Plus, even where Coughlin caved to the payment
demands..Longoni repeatedly hung up the phone on him and otherwise ignored his communications (there may be
an issue of the email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit
as to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his request to
the number the RMC held out for her on her behalf too...
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps, NG12-0435
(stamped as "received" by the SBN from the "Clerk of Court" of some still unnamed Court (I'd bet its from the
RMC Clerk of Court, whom King purported to have certified documents from a Court she doesn't even work for
at the 11/14/12 Disciplinary Hearing...but then again, Panel Chair Echeverria allow WLS's Elcano to certify
documents just because he claimed to have watched a tape of a hearing, where Elcano is neither a licensed
attorney, nor does he work for any Court....), depending upon whom you ask and what King means by "Clerk of
Court"...because in King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of
Court of Department 3"...whoever, wouldn't it be Second Judicial District Court Clerk of Court Joey Orduna
Hastings that would need to send Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin to
the SBN's King for King now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L.
Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have
anything to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
"
Re: Zachary Barker Coughlin, Nevada Bar No. 9473
Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary Barker
Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of this attorney
being experienced by myself and the other three judges in Reno Municipal Court. My two most recent Orders in what
should be a simple traffic citation case are self-explanatory and are included, together with copies of massive documents
Me. Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in this matter are also
included. He failed to appear for the second one this past Monday.
I have another traffic case pending trial with him that was re-assigned to me based on our Department I judge
000165
being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him between cases very
easily. We are setting that case for trial and attempting to serve him at the most recent address we have (1422 E. 9
th
St.
#2 Reno NY 89512), although I heard today he may be living in his vehicle somewhere. We do have an address for his
mother, however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on appeal to the
Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently pending in his court with
Mr. Coughlin as the defendant. I have enclosed some copies of documents from those matters, in chronological order,
simply because they appear to demonstrate that he is quickly decompensating in his mental status. Our staff also made
you some audio tapes of Coughlin in the him and him and him and him and him and him and him him and I will him
and him and him and him and him in Departments 2 and 4 so you can hear for yourself how this attorney acts in court.
You can see his behavior in my traffic citation case does not appear to be an isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial Assistant
was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed for Contempt of Court and
they stated that they represent him in a Gross Misdemeanor matter in RJC. I have no other information on that.
You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in your
pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the staff and
even our pro temp judges on the most simple traffic and misdemeanor matters. I do think this is a case of some urgency,
and I apologize for taking two days to get this package to you; our IT person was ill and could not make the copies of
the audios of Mr. Coughlin's hearings until today, and I felt it was important that the audios be included in the materials
to be considered by the State Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had
appointments with clients. [ do not know if that was true, but if so, he could be causing serious harm to the practice of
law in Northern Nevada and could be jeopardizing someone's freedom or property interests. "
Maybe it would be best if the RMC focused less on offering unsworn hearsay testimony that is easily
proven to be patently false at Disciplinary Hearings (to the extent one is allowed to offer such proof, which
Panel Chair Echeverria invariably rules is "not relevent" and King smugly basks in his SCR 111(5)
vacation with his "Clerk of Court" Laura Peters...whose lies about SCR 105(4) resulted in Panel Chair
Echeverria quashing all subpoenas Coughlin issued, including those to which SBN Bar Counsel Pat King
filed on behalf of his former co-worker at the AG's Office, Reno City Attorney Dan Wong...While the other
Reno City Attorney, Creig Skau, kept Coughlin busy with his lies about "the judge authorized me to serve
you by email"...
000166

Sincerely
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 35 files to share with you on SkyDrive. To view them, click the links below.
11 16 11 voicemail from Tim regarding Washoe Legal Service's Elcano's attempt to settle lawsuit with treatment routine
60302 ng12-0204.mp3
3 8 11 voice mail from Tim Coughlin to Zach Coughlin regarding SBN's Coe Swobe's contacting him for WLS's Elcano
ng12-0204.mp3
4 27 09 email from WLS's Elcano to Coughlin to call SBN's Swobe ng12-0204.pdf
June_2008_Nevada_Lawyer In re Mirch compare to ng12-0204.pdf
11 16 12 skau grievance materials combined 0204 063341.pdf
2 27 12 and 3 8 12 Affidavits of Service by WCSO Machen in 1708 and 03628 26800 00696 marshal harley.pdf
2 27 12 Order For Competency Evaluation Judge Clifton RCR2012-065630 1 31 pm file stamp rjc rmc schroeder nash
holmes young dogan 26800 26405 loomis - Copy.pdf
3 7 12 rmc 11 cr 26405 loomis gardner 178.405 Coughlin Trial Setting 26800 00696 063341 065630.pdf
3 8 12 26800 nash barker denial return of bail $100 wcso rmc 0204 00696.pdf
3 8 12 Coughlin Trial Setting 11 cr 26405 april 10 8 am trial loomis gardner 650630 26800 0032 0376.pdf
3 9 12 needs stamped 11 tr 26800 0204 MOTION TO RETURN CELL PHONES; MOTION TO SET ASIDE SUMMARY.pdf
3 12 12 rmc 11 tr 26800 order judge nash holme suspending case and referring to the SBN enhanc.pdf
3 13 12 158 pm 26800 Nash rmc SUA SPONTE ORDER DENYING RELIEF SOUGHT IN IMPROPER DOCUMENT.pdf
3 13 12 1238pm 11 TR 26800 SUA SPONTE ORDER DENYING RELlEF SOUGHT IN IMPROPER DOCUMENT RPD WCSO
RMC RJC NASH KING CLARK SBN check.pdf
3 13 1238 pm 26800 SUA SPONTE ORDER DENYING RELlEF SOUGHT IN IMPROPER DOCUMENT 0204 0434.pdf
3 16 12 sbn grievance king with ng12-0434 nash 26800 of 3 14 12 and ng12-0434 4 10 09 linda gardner sanction
order 00696 26405.pdf
3 30 12 nash order releasing property 26800 0204 0434 cleaned up-3.pdf
5 4 12 goodnight email 063341 26405 26800 regarding mhc loomis hazlett-stevens 0204 0434.pdf
5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844 dd.pdf
5 6 09 email from wls ed elcano 26405 60302 garnder 01955 10896 60302 26800 60317 54844.pdf
Download all

000167
RE: Mr Coughlin
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/21/12 9:22 PM
To: Patrick King (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
(eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com)
Dear SBN and Panel
The Disciplinary Hearing File that Pat King purported to have copied and provided to
me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
not being filestamped...). Echeverria's very ruling on filing he was not mailed (to the
extent that was the case, and perhaps it was a test) concedes at least the approval of
filign by fax (express indication of the permissibility thereof in accordance with SCR
105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
Please confirm that my filings, all of them, including the Motion to Show Cause of
10/2/12, starting on bate stamp 02849 have been provided to all Panel members as the
SBN has repeatedly indicated they would be (included the copying of all attachments,
including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a file stamp (and
it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs indicates...which
means the SBN failed to Oppose the Motion to Dismiss, and the Complaint was
dismissed prior to any other purported proof of service being effected (or spurious
assertions of Coughlin dodging service given his numerous written correspondences
and calls offering to meet Reno Carson or the SBN...until Coughlin finally just gave
the SBN his physical address on 10/23/12, despite safety concerns....)
Who gave you this order that you attached in the email of your's included below (the
8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
000168
2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
of these grievances? Did Mr. Susich disclose that conflict incident to the problems
Maureen Cole had in carrying out the duties of her job as an attorney for the NV DETR
and NERC?
Please copy me on anything proving Chairman Susich so disclosed that conflict.
Additionally, more and more frequently, when I question Laura Peters on some
misstatement or attempt to mislead that she makes, she starts talking about getting a
"protection order" or otherwise seeking to abuse process. Speaking of abusing
process, due process namely, Peters was caught signing Certificates of Mailing for
10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes system
that Peters knew would not be picked up by the SBN's mail carrier the day the
certificate of mailing indicated the would be, or at least were placed...Please explain
how your office's certified mailing procedures work and comply with federal law.
Additionally, I have review the materials you had Sierra Legal Duplicating provide and
there is no indication of where materials such as the 8 28 12 Order sanctioning
Coughlin generated from or whom transmitted them to the SBN. I had a discussion
with Bar Counsel Clark over a year ago about whether there was some centralized
method of keeping track of Orders sanctioning attorneys. He indicated there was not.
Please indicate then, who provided you the various different Orders sanctioning
Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial Family
Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of Court
for Department 3" (ie, of the Municipal Court's Department 3, which you fail to specify
in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you that day
about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even talkin'
'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out and
about.) Pat, you are going to look like such an unbelievably compromised, crooked,
and inept Bar Counsel when it is displayed what a tenuous thread each and every
aspect of all these half baked grievances hang from.
Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
000169
Panel is now in possession of the certified audio of the following transcripts:
April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
minute mark wherein the following exchange took place:
Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
April 2009 grievance onto the State Bar in the last two weeks
Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
will continue to be your attorney today."
At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River Rock
Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction where the
nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any eviction notice or
even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a case wherein Coughlin
was representing a single father in a custody dispute based upon a judicial canon (see atached).

King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434, and
ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82 worth
of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see 60838 and
61426:
60838 Walmart case with Court's June 7th, 2012 Order suspending
Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
S
000170
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
0204 Coughlin Disciplinary Hearing File.pdf
10 31 12 Order by Echeverria 0204.pdf
12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
12 15 11 22176 2064 Order by Howard on transcript costs.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
Download all
> From: PatrickK@nvbar.org
> To: zachcoughlin@hotmail.com
> Subject: FW: Mr Coughlin
> Date: Thu, 30 Aug 2012 20:48:18 +0000
>
> Good Afternoon Mr. Coughlin,
>
> Attached is an Order that pertains to you.
>
> I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
expect to file an Answer?
>
> Thank you.
>
> Patrick King
RE: Mr Coughlin
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/21/12 8:58 PM
To: Patrick King (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); complaints@nvbar.org (complaints@nvbar.org); eifert.nta@att.net
(eifert.nta@att.net); cvellis@bhfs.com (cvellis@bhfs.com); skent@skentlaw.com (skent@skentlaw.com)
000171
Dear SBN and Panel
Please be sure to listen to the attached voice mails from my Dad, Tim Coughlin, MD,
talking about Washoe Legal Services Paul Elcano and the State Bar of Nevada's Paul
Elcano running their hustle on our family.
The Disciplinary Hearing File that Pat King purported to have copied and provided to
me contains numerous instances of my filings (as ruled on by Panel Chair Echeverria,
not being filestamped...). Echeverria's very ruling on filing he was not mailed (to the
extent that was the case, and perhaps it was a test) concedes at least the approval of
filign by fax (express indication of the permissibility thereof in accordance with SCR
105(4) was provided by SBN Clerk of Court Peters on 9/11/12.
Please confirm that my filings, all of them, including the Motion to Show Cause of
10/2/12, starting on bate stamp 02849 have been provided to all Panel members as the
SBN has repeatedly indicated they would be (included the copying of all attachments,
including cd/dvds). Further, the Motion to Dismiss of 9/17/12 lacks a file stamp (and
it should be filestamped 9/17/12, not 10/16/12 as the Panel Chairs indicates...which
means the SBN failed to Oppose the Motion to Dismiss, and the Complaint was
dismissed prior to any other purported proof of service being effected (or spurious
assertions of Coughlin dodging service given his numerous written correspondences
and calls offering to meet Reno Carson or the SBN...until Coughlin finally just gave
the SBN his physical address on 10/23/12, despite safety concerns....)
Who gave you this order that you attached in the email of your's included below (the
8/28/12 Order by Judge Flanagan in the Carpentier foreclosure defense case in SBN
King's 8/30/12 email below)? And who gave you the April 2009 Order sanctioning
Coughlin, which Washoe Legal Service's ED Elcano cited as the sole reason for firing
Coughlin, now on appeal in 60302, a wrongful termination lawsuit that worked its way
through NERC and Maureen Cole, Esq. and therefore, Chairman Susich in 2009 and
2010. Does that not conflict Mr. Susich out of the screening panel and other aspects
of these grievances? Did Mr. Susich disclose that conflict incident to the problems
Maureen Cole had in carrying out the duties of her job as an attorney for the NV DETR
and NERC?
000172
Please copy me on anything proving Chairman Susich so disclosed that conflict.
Additionally, more and more frequently, when I question Laura Peters on some
misstatement or attempt to mislead that she makes, she starts talking about getting a
"protection order" or otherwise seeking to abuse process. Speaking of abusing
process, due process namely, Peters was caught signing Certificates of Mailing for
10/31/12 certified mailings created in conjunction with the SBN's Pitney Bowes system
that Peters knew would not be picked up by the SBN's mail carrier the day the
certificate of mailing indicated the would be, or at least were placed...Please explain
how your office's certified mailing procedures work and comply with federal law.
Additionally, I have review the materials you had Sierra Legal Duplicating provide and
there is no indication of where materials such as the 8 28 12 Order sanctioning
Coughlin generated from or whom transmitted them to the SBN. I had a discussion
with Bar Counsel Clark over a year ago about whether there was some centralized
method of keeping track of Orders sanctioning attorneys. He indicated there was not.
Please indicate then, who provided you the various different Orders sanctioning
Coughlin. Let me guess, you refuse to, right? Or you want to say "the Clerk of
Court" provided the April 2009 Order Sanctioning Coughlin by Second Judicial Family
Court Judge Gardner...which means what, Pat? Does that mean "the Clerk of Court
for Department 3" (ie, of the Municipal Court's Department 3, which you fail to specify
in your 3/23/12 email reporting such an identified "Clerk of Court" wrote you that day
about pajamas (we talkin' 'bout pajamas, Pat. Pajamas? What are we even talkin'
'bout? Pajamas? Seriously, not even wearing pajamas in court, but just out and
about.) Pat, you are going to look like such an unbelievably compromised, crooked,
and inept Bar Counsel when it is displayed what a tenuous thread each and every
aspect of all these half baked grievances hang from.
Literally every sentence of the RMC hearings that you were provided Pat, and that you finally provided to me,
that I transcribe makes the appearance of impropriety disclosed herein look worse and worse for the RMC, the
SBN, the City Attorney, etc., etc. And that is not even getting started on any other forums or players.
Its really nice how upon transmission of this email I can prove, via a means that is digitally verifiable that this
Panel is now in possession of the certified audio of the following transcripts:
April 10th, 2012 Trial in criminal trespass matter before RMC W. Gardner in 11 CR 26405 (check out especially
the conflict analysis vis a vis his sister's April 2009 Order sanctioning Coughlin becoming the third grievance in
SBN King's August 23rd, 2012 SCR 105 Complaint). You have a duty to review this, paying especially close
attention to the statements on the record by Hon. W. Garder between the 4:45 minute mark to the 9:30 mark
000173
and then again from the 10:32 mark to the (the matter of whether recusal is appropriate for W. Gardner in
light of his sister being Family Court Judge L. Gardner (see Mandamus Petition Coughlin filed against W.
Gardner's sister L. Gardner in 54844 and, between 7:20-8:00 minute mark whether the filing of a bar grievance
based upon his sister's April 2009 Order then becoming the ng12-0435 bar grievance would further require
recusal, beyond the fact that Coughlin has anticipated litigations against the City of Reno, RMC, and City
Attorney's Office, and W. Gardner worked as a criminal prosecutor for the City of Reno Attorney's Office from
1987 to 1997, short stint in Arizona, then from 1997-2000, then again from 2007-
2010): http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746
You will need to take a long hard look and listen to the material betwen the 14:20 minute mark and the 15:30
minute mark wherein the following exchange took place:
Coughlin: I asked Loomis to inform the Court of the fact that your sister, or someone forwarding your sister's
April 2009 grievance onto the State Bar in the last two weeks
Judge Gardner: Forwarding? That I was unaware of...that is the first I have heard of that, today.
Coughlin: I asked Mr. Loomis to inform you of that and he failed to.
Gardner: Now, I am aware of that. Unless Mr. Loomis has made a Motion to Withdraw as your counsel, he
will continue to be your attorney today."
At that point, Judge W. Gardner might have done well to take a page out of his sister's book when she recused
herself from the Bell v. Greer case FV11-02864 (which also proves Coughlin was holding out the 121 River Rock
Address as a law office, and therefore a commercial tenancy precluding No Cause Summary Eviction where the
nonpayment of rent is not plead or alleged in the Hill eviction case prior to the service of any eviction notice or
even any hint of an oncoming eviction) wherein Judge L. Gardner recused herself from a case wherein Coughlin
was representing a single father in a custody dispute based upon a judicial canon (see atached).

King's unlawful attempt to combine the hearing required by the Court's June 7th, 2012 Order with these three
grievances (which comprise the instant SCR 105 Complaint in SBN v. Zach Coughlin (ng12-0204, ng12-0434, and
ng12-0435) violates SCR 111(7)-(8) and the express terms of the Court's June 7th, 2012 Order in 60838 in
failing to have a proceeding (singular) addressing the "sole issue" of determining the punishment of Coughlin
for the conviction in RMC 11 CR 22176 for petty larceny of $14.00 comprised of "a candy bar and some cough
drops" where Wal-mart alleges Coughlin consumed those items while shopping for and paying for $83.82 worth
of groceries. Coughlin categorically disputes that legitimacy of every aspect of that conviction, see 60838 and
61426:
60838 Walmart case with Court's June 7th, 2012 Order suspending
Coughlin: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29004
61426: Coughlin's Petition to Dissolve the Temporary Suspension of June 7th, 2012, which Bar Counsel admits
entitles Coughlin to an "immediate hearing" under SCR 102(4)(d)
S
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000174
ZachCoughlin@hotmail.com
Zach has 6 files to share with you on SkyDrive. To view them, click the links below.
10 31 12 Order by Echeverria 0204.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
12 15 11 22176 2064 Order by Howard on transcript costs.pdf
12 15 11 22176 ROBERTS NOTICE OF DENIAL OF SERVICE.pdf
031709 3 of 5 dv08-01168 54844 26405 NG12-0435 wls 08h24m39s contempt warning sidebar.wmv
3 8 11 voice mail from Tim Coughlin to Zach Coughlin regarding SBN's Coe Swobe's hustle for WLS's Elcano ng12-
0204.mp3
Download all
> From: PatrickK@nvbar.org
> To: zachcoughlin@hotmail.com
> Subject: FW: Mr Coughlin
> Date: Thu, 30 Aug 2012 20:48:18 +0000
>
> Good Afternoon Mr. Coughlin,
>
> Attached is an Order that pertains to you.
>
> I have not yet received an answer to the Complaint that I filed against you. Could you let me know when you
expect to file an Answer?
>
> Thank you.
>
> Patrick King
FW: Bar Admission and employment
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/20/12 7:46 AM
To: fflaherty@dlpfd.com (fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org);
je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); schornsby@nvdetr.org
(schornsby@nvdetr.org); tsusich@nvdetr.org (tsusich@nvdetr.org); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
(nevtelassn@sbcglobal.net); eifert.nta@att.net (eifert.nta@att.net); (davidc@nvbar.org)
(davidc@nvbar.org); (complaints@nvbar.org) (complaints@nvbar.org)
1 attachment
ed collection of materials for State Bar of Nevada Grievance against Peter Christiansen, Kevin Kelly,
Michael Sanft, Patrice Eichman, etc adobe 4 and later grey.pdf (17.1 MB)
000175

Subject: RE: Bar Admission and employment
Date: Fri, 5 Nov 2004 21:26:35 -0800
From: bobarker@barkermartin.com
To: zachcoughlin@hotmail.com
Zach- This seems unusual. If there was an agreement for a flat fee representation it should be supported by a written fee
agreement. You, Tim and I should have a conference call. I am surprised by what appears to be inattentiveness on
Christiansen's part. For not we need to focus on getting you admitted and deal with Christiansen after your admission.
Please arrange a conference call with you, Tim and me. Thanks. Bo
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Fri 11/5/2004 5:16 PM
To: Bo Barker
Subject: RE: Bar Admission and employment
Bo,
Here is Christiansen's offices most recent email. I will also forward
emails from the state bar's director of admissions.
\
Zach,
1. I will attempt to mail you another copy of your file.
Please
confirm you mailing address to me in an e-mail. We have tried
to mail
your file to you on two occasions the last of which was October
2003 to
the address you provided of 631 Humboldt Frt, Reno, NV 89509.
Our mail
was returned. As to your request for "complete" copy of your
file, we
always send complete copies of files upon the request of a
client.
2. There is no itemization for the services rendered to you.
Mr.
Christiansen charged you a flat fee to handle your hearings with
the
State Bar which fee was paid by your father. Mr. Christiansen
continued
to monitor your case as a courtesy and no such itemized records
were
kept for time we did not charge you.
3. On September 10, 2003, after my conversation with Ms.
Eichman's
000176
assistant, I set forth in my e-mail to you the specific
procedure for
which to have your admittance to the Stat Bar reconsidered. You
were to
prepare a letter of intent and forward it to our office. No
such letter
was ever received from you. The letter was due to the State bar
on or
before October 1, 2003.
4. Other than an invoice from our office, I do not see a signed
fee
agreement in your file. I will send you any billing records I
have
along with a copy of your file when you send me confirmation of
your
billing address.
Kelley Huff
Christiansen Law Offices
520 South Fourth Street
Las Vegas, Nevada 89101
(702) 384-5563
khuff@christiansenlaw.com
-----Original Message-----
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Sunday, October 31, 2004 2:02 PM
To: Kelly Huff
Subject: Re: File: State Bar Admittance
Dear Miss Huff,
I would like another copy of my file. Please send Mr. Barker
one as
well.
Please send me a thorough status report
and do not to send my file to storage. Also, I am requesting
a complete copy of my file (including all materials that your
office has
recently submitted to the State Bar) and an itemization of the
services your office has rendered in regard to this matter.
This is the
second time I have made such a request for an itemized
statement.
I would like a response to my request of last month that your
office
indicate whether it ever submitted anything to further this
matter along
to
the State Bar or Supreme Court on or around the October 2003
000177
expiration
of
the deferral order issued in December of 2002. My records
indicate that
I
made repeated requests that your office do so. If no request
was sent,
please indicate what, if any actions your office took to further
this
matter
along between December of 2002 and the present. Please don't
forget the
itemized statement of the services you have rendered at this
point.
Please send me a copy of any fee agreement in your possession.
Sincerely,
Zach Coughlin
>From: "Kelly Huff" <khuff@christiansenlaw.com>
>To: "Zach Coughlin" <zachcoughlin@hotmail.com>
>Subject: Re: File: State Bar Admittance
>Date: Wed, 27 Oct 2004 15:24:44 -0700
>MIME-Version: 1.0
>Received: from lawserver.christiansenlaw.com ([24.234.45.95])
by
>mc7-f18.hotmail.com with Microsoft SMTPSVC(5.0.2195.6824); Wed,
27 Oct
2004
>15:28:04 -0700
>X-Message-Info: JGTYoYF78jGhpAquzv3dzm/M2o+Bg2I5
>Message-ID:
><F44EE6CE7264924B9F92F6844D350DAE8FAA@lawserver.christiansenlaw.com>
>X-MimeOLE: Produced By Microsoft Exchange V6.0.4417.0
>content-class: urn:content-classes:message
>X-MS-Has-Attach: X-MS-TNEF-Correlator: Thread-Topic: Re: File:
State
Bar
>Admittance
>Thread-Index: AcS8c8KjeND+3BnuS1u7pXCaabj6Iw==
>Return-Path: khuff@christiansenlaw.com
>X-OriginalArrivalTime: 27 Oct 2004 22:28:04.0264 (UTC)
>FILETIME=[39A63A80:01C4BC74]
>
>Zach,
>
>We received a letter yesterday from Bo Barker inquiring into
the status
>of your file with our office. Mr. Christiansen has also
reviewed the
000178
>various e-mails sent to Mike and me with regard to your file.
Per Mr.
>Christiansen, all the documentation you have submitted to our
office
>along with the Stipulation you signed has been submitted to the
State
>Bar of Nevada. As such, Mr. Christiansen has concluded his
>representation of your interests and will now be closing out
your file
>with our office. Therefore, there is nothing to communicate to
Mr.
>Barker. Although one has already been provided to you, if you
would
>like another copy of your file, please contact me within the
next 10
>days before your file is sent to storage. All other questions
you may
>have with regard to your admittance to practice in Nevada may
be
>directed to the State Bar office.
>
>If you have any further questions, please feel free to contact
our
>office.
>
>Kelley Huff
>Christiansen Law Offices
>520 South Fourth Street
>Las Vegas, Nevada 89101
>(702) 384-5563
>khuff@christiansenlaw.com
>
>From: "Bo Barker" <bobarker@barkermartin.com>
>To: <zachcoughlin@hotmail.com>
>Subject: RE: Bar Admission and employment
>Date: Thu, 4 Nov 2004 13:38:22 -0800
>MIME-Version: 1.0
>Received: from exchange.lawoffice.barkermartin.com ([207.225.248.213]) by
>mc9-f5.hotmail.com with Microsoft SMTPSVC(5.0.2195.6824); Thu, 4 Nov 2004
>13:38:23 -0800
>X-Message-Info: JGTYoYF78jE7aK1HQZaqWDI/9/uD8ns9
>X-MimeOLE: Produced By Microsoft Exchange V6.5.7226.0
>Content-class: urn:content-classes:message
>Message-ID:
><A09D62B72306C94ABF2385B7C2069B6C2E2679@exchange.lawoffice.barkermartin.com>
>X-MS-Has-Attach: X-MS-TNEF-Correlator: Thread-Topic: Bar Admission and
>employment
>Thread-Index: AcS/k0yXO3hkWRcBQsu32m0Me1fYJADIs7/A
>Return-Path: bobarker@barkermartin.com
>X-OriginalArrivalTime: 04 Nov 2004 21:38:23.0554 (UTC)
000179
>FILETIME=[9C4FFA20:01C4C2B6]
>
>Zach- I think that the best thing to be done is for either you or me,
>perhaps me, ask for a complete copy of your file from Christiansen.
>This should be done immediately, certainly before the passage of 14
>days. Please track me down on my cell phone and lets talk and decide
>who asks for the file. Then, I think that you should retain a well
>qualified attorney to represent you in getting your bar status approved.
>Please call me as soon as possible. (206)718-5757. Best regards,
>
>
>Bo Barker
>Barker Martin, P.S.
>Construction Defect and
>Homeowner Association Attorneys
>720 Seventh Avenue, Suite 300
>Seattle, WA 98104-1960
>Direct: (206) 381-9806 x100
>Fax: (206) 381-9807
>www.barkermartin.com
>
>-----Original Message-----
>From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
>Sent: Sunday, October 31, 2004 1:48 PM
>To: Bo Barker
>Subject: RE: Bar Admission and employment
>
>HI Bo,
>
>I have no idea what is going on. THis is pretty much in line with their
>representation of me so far. Its just be a nightmare with these guys.
>Originally I went to me first hearing with the NV bar and didn't have
>representation. It went on for three and a half hours then I started
>crying. so the stopped the hearing and said they were going to give me
>a referral to three different lawyers who would represent me on a pro
>bono basis. then this lawyer coe swobe, from in reno calls me and
>refers me to christiansen. the guy who was at the hearing and said he
>would refer me to a pro bono lawyer is name Kevin Kelly, and if you do a
>google search for him in las vegas it will reveal an article about how
>he owns this strip club, the spearmint rhino. Apparently he is the one
>who suggested christiansen.
>christiansen sent me to a psychologist who revealed that he is one of
>kevin kelly's best friends, the psychologist that is. this seemed like
>a rather big conflict of interest. Christiansen revealed that he would
>not do my case pro bono, but would for 5K, which my dad paid him. I
>felt kind of required to use him as my attorney, but it was stupid and
>lazy of me not to check this out more, but I trusted Coe Swobe and the
>bar committee. It seems that when the october 2003 date came, marking
>the end of the supreme courts deferral period, that christiansen's
>office didn't do anything to get the process moving along. So a year
>passed. I have written christiansen's office requesting them to answer
>whether they ever mailed a letter to the bar or court requesting
>consideration of my case. Around october 2003 I was calling everyone
>involved, christiansen, the bar, the supreme court, etc, to try to
000180
>figure out how to get the process moving. I got conflicting answers but
>made sure to request that christiansen submit the request for
>consideration. I passed the July 2001 bar exam. It seems like
>christiansen's never submitted the request, so my case just sat there.
>This seems like malpractice to me. Also, there were times were I made 5
>or 6 phone calls over a 8 week period and never got a response from
>Christiansen's office. I'll email them the requests you suggested.
>I'll call you soon. In the meantime I have pulled all the nevada case
>law in regard to character and fitness applications and am writing a
>brief in favor of my admission. My aa sponsor, who is an attorney of
>some stature in reno, finally signed off the letter of recommendation I
>drafted for myself.
>Also, I am getting proof of some community service I have done and
>attendance at aa meetings and have requested that several lawyers in AA
>write me letters of recommendation.
>One really frustrating person is Coe Swobe. He is an old lawyer who
>runs the bar's "lawyers concerned for lawyers" section, a substance
>abuse prevention entity. He is really lazy and pretty oblivious of how
>long this ordeal has gone on and how very little I did to deserve this
>treatment.
>Perhaps a call from you or my sponsor Kelly will help get his
>recommendation, which appears to be fairly important. He is the one who
>recommended this lawyer, and it wouldn't surprise me if he made the
>recommendation with hardly any knowledge of the guy. Kelly often
>remarks on Coe's laziness and incompetence. I would like to request a
>refund from Christiansen, but I am not doing anything right now in that
>regard.
>
>Thanks,
>zach
>
>
> >From: "Bo Barker" <bobarker@barkermartin.com>
> >To: <zachcoughlin@hotmail.com>
> >Subject: RE: Bar Admission and employment
> >Date: Sat, 30 Oct 2004 13:55:49 -0700
> >MIME-Version: 1.0
> >Received: from exchange.lawoffice.barkermartin.com ([207.225.248.213])
> >by mc8-f23.hotmail.com with Microsoft SMTPSVC(5.0.2195.6824); Sat, 30
> >Oct 2004
> >13:56:11 -0700
> >X-Message-Info: JGTYoYF78jG9ZXbx0t2orsERNDwBpif/
> >X-MimeOLE: Produced By Microsoft Exchange V6.5.7226.0
> >Content-class: urn:content-classes:message
> >Message-ID:
> ><A09D62B72306C94ABF2385B7C2069B6C053DB7@exchange.lawoffice.barkermartin
> >.com>
> >X-MS-Has-Attach: X-MS-TNEF-Correlator:
> ><A09D62B72306C94ABF2385B7C2069B6C053DB7@exchange.lawoffice.barkermartin
> >.com>
> >Thread-Topic: Bar Admission and employment
> >Thread-Index: AcS+QPH57EnxkswMTuehm8oP9HEp1wAf8/gr
> >Return-Path: bobarker@barkermartin.com
> >X-OriginalArrivalTime: 30 Oct 2004 20:56:11.0796 (UTC)
000181
> >FILETIME=[E3339D40:01C4BEC2]
> >
> >Zach- Do you understand what is going on? Is Mr. Christiansen
>withdrawing?
> > If so, why? What was Tim's relationship with Christiansen? You
>should
> >tell them not to send your file to storage and to provide you with a
> >status report. Their statement: "Although one has already been
> >provided to you, if you would like another copy of your file, please
> >contact me within the next 10 days before your file is sent to
> >storage." is confusing. Tell them you want a copy of what ever was
> >referred to by the word "one." Also tell them you want a status report
>
> >and not to send your file to storage. Finally, tell them you want a
> >complete copy of your file and an itemization of the
> >services they have rendered for you. By their statement: "All other
> >questions you may have with regard to your admittance to practice in
> >Nevada may be directed to the State Bar office." it would appear that
> >they are refusing to represent you further. I think that he is not
> >treating you well. Have you had problems with this office? Please
> >give me a call to discuss. Bo
> >
> >________________________________
> >
> >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
> >Sent: Fri 10/29/2004 10:25 PM
> >To: Bo Barker
> >Subject: RE: Bar Admission and employment
> >
> >
> >
> >HI Bo,
> >
> >I just got this email from Christiansen's secretary.
> >i have pulled about 30 NV Supreme Court Cases pertaining to Character
> >and Fitness issues and bar applicant's admissions and am working on a
> >brief in favor of my admission at present. Perhaps you could read over
>
> >it before I send it in.
> >
> >
> >THanks,
> >
> >
> >Zach
> >
> >ps, I pasted the email below
> >
> >Zach,
> >
> >We received a letter yesterday from Bo Barker inquiring into the status
>
> >of your file with our office. Mr. Christiansen has also reviewed the
> >various e-mails sent to Mike and me with regard to your file.
000182
> >Per Mr.
> >Christiansen, all the documentation you have submitted to our office
> >along with the Stipulation you signed has been submitted to the State
> >Bar of Nevada. As such, Mr. Christiansen has concluded his
> >representation of your interests and will now be closing out your file
> >with our office. Therefore, there is nothing to communicate to Mr.
> >Barker. Although one has already been provided to you, if you would
> >like another copy of your file, please contact me within the next 10
> >days before your file is sent to storage. All other questions you may
> >have with regard to your admittance to practice in Nevada may be
> >directed to the State Bar office.
> >
> >If you have any further questions, please feel free to contact our
> >office.
> >
> >Kelley Huff
> >Christiansen Law Offices
> >520 South Fourth Street
> >Las Vegas, Nevada 89101
> >(702) 384-5563
> >khuff@christiansenlaw.com
> >
> >
> >
> >
> > >From: "Bo Barker" <bobarker@barkermartin.com>
> > >To: <zachcoughlin@hotmail.com>
> > >Subject: RE: Bar Admission and employment
> > >Date: Thu, 21 Oct 2004 12:40:05 -0700
> > >MIME-Version: 1.0
> > >Received: from exchange.lawoffice.barkermartin.com
> > >([207.225.248.213]) by mc5-f8.hotmail.com with Microsoft
> > >SMTPSVC(5.0.2195.6824); Thu, 21 Oct
> >2004
> > >12:40:07 -0700
> > >X-Message-Info: JGTYoYF78jHCcITVD+zs6qbFmOAlmrcH
> > >Content-class: urn:content-classes:message
> > >Message-ID:
> > ><A09D62B72306C94ABF2385B7C2069B6C2E2379@exchange.lawoffice.barkermart
> > >in.com>
> > >X-MS-Has-Attach: X-MimeOLE: Produced By Microsoft Exchange
> > >V6.5.7226.0
> > >X-MS-TNEF-Correlator: Thread-Topic: Bar Admission and employment
> > >Thread-Index: AcS3A/1iQw5I3vTATe6Dyu594Y+ICAAoZF0g
> > >Return-Path: bobarker@barkermartin.com
> > >X-OriginalArrivalTime: 21 Oct 2004 19:40:07.0224 (UTC)
> > >FILETIME=[C4C97380:01C4B7A5]
> > >
> > >Zach-
> > >Good news from you. Be persistent and patient. Keep me posted as to
>
> > >what I can do to help. I think of you often and am wishing the best
> > >for you.
> > >
000183
> > >
> > >Bo Barker
> > >Barker Martin, P.S.
> > >Construction Defect and
> > >Homeowner Association Attorneys
> > >720 Seventh Avenue, Suite 300
> > >Seattle, WA 98104-1960
> > >Direct: (206) 381-9806 x100
> > >Fax: (206) 381-9807
> > >www.barkermartin.com
> > >
> > >-----Original Message-----
> > >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
> > >Sent: Wednesday, October 20, 2004 5:21 PM
> > >To: Bo Barker
> > >Subject: RE: Bar Admission and employment
> > >
> > >Hi Bo,
> > >Thanks for the letter, I appreciate it. Also, thanks for the letter
> > >to Christiansen's office, I think it is really good and will help. I
>
> > >am sorry if I sent you the wrong address. I am applying to firms and
>
> > >knocking on doors. I have done everything that the emails you
> > >mentioned requested.
> > >I'll keep you informed.
> > >
> > >Thanks,
> > >Zach
> > >ps. My resume is attached.
> > >
> > > >From: "Bo Barker" <bobarker@barkermartin.com>
> > > >To: <zachcoughlin@hotmail.com>
> > > >Subject: Bar Admission and employment
> > > >Date: Wed, 20 Oct 2004 13:15:14 -0700
> > > >MIME-Version: 1.0
> > > >Received: from exchange.lawoffice.barkermartin.com
> > > >([207.225.248.213]) by mc7-f24.hotmail.com with Microsoft
> > > >SMTPSVC(5.0.2195.6824); Wed, 20 Oct 2004
> > > >13:15:16 -0700
> > > >X-Message-Info: JGTYoYF78jGQL0qHRj71gv2EbGDzBZ0+
> > > >Content-class: urn:content-classes:message
> > > >X-MimeOLE: Produced By Microsoft Exchange V6.5.7226.0
> > > >Message-ID:
> > > ><A09D62B72306C94ABF2385B7C2069B6C2E233D@exchange.lawoffice.barkerma
> > > >rtin
> > > >.com>
> > > >X-MS-Has-Attach: yes
> > > >X-MS-TNEF-Correlator: Thread-Topic: Bar Admission and employment
> > > >Thread-Index: AcSyEIi4MBQu8XTbTx+lK/BWoB3W8AEzBdIQ
> > > >Return-Path: bobarker@barkermartin.com
> > > >X-OriginalArrivalTime: 20 Oct 2004 20:15:16.0835 (UTC)
> > > >FILETIME=[83CCCB30:01C4B6E1]
> > > >
000184
> > > >Zach-
> > > >The letter I sent to Christiansen was returned for an incorrect
> > >address.
> > > >I had it spelled Christianson and at 520 S. 5th Street. It should
> > > >have
> > >
> > > >been Christiansen on 4th Street. Attached find a revised copy of
> > > >my revised letter as signed and sent today.
> > > >
> > > >I note in reviewing the emails you sent me that there were certain
> > > >steps you were advised to take. Have you taken all steps advised
> > > >in Pat Eichman's email to you of Monday, March 8, 2004 nad in
> > > >Michael Sanft's email to you of Monday, July 5, 2004? If not, I
> > > >advise you to
> > >do so.
> > > >
> > > >You faxed me a resume that was smudged and unreadable. If you will
>
> > > >email me or mail me a ledgible copy I will make what suggestions
> > > >for revision that I think might be helpful for you.
> > > >
> > > >I continue to believe that the best possible thing that you could
> > > >do for yourself is to knock on door after door after door until you
>
> > > >get a job in Reno clerking for a lawfirm. This will give you some
> > > >experience
> > >
> > > >and history in the law and it will set you up for some good
> > > >reference letters to the Suproeme Court. In your interviewing
> > > >process, I would tell the prospective employer that you really need
>
> > > >and want a job and that you would be willing to do an assignment
> > > >for free just to demonstrate your capability and tenacity. Be
> > > >candid and tell them about your admission problems. Tell them that
>
> > > >you are committed to making some life changes. The longer that you
>
> > > >put off finding employment, the harder it will be to break the
> > > >cycle. Zach, I would close the bed business imediately. It will
> > > >not serve your best
> > >interests.
> > > >
> > > >I know from first hand experience how hard it can be to get a job.
> > > >When I interviewed during spring break of my third year in law
> > > >school, I knocked on at least 50 doors, calling cold trying to find
>a job.
> > > >This effort produced not a single offer and not even a single
> > > >exptression of interest in me as a possible employee. I was very
> > > >discouraged. Later in life after practicing for 8 years I was
> > > >fired from my firm after I had earned a partnership. I tried again
>
> > > >to find a
> > >
> > > >job. For a long time I had no success in this 1978 effort. This
000185
> > > >was particularly embarassing to me as I had gotten married only a
> > > >month before. I felt terrible. I found that I had to be very
>persistent.
> > > >
> > > >I know you must be feeling discouragement among other things. I am
>
> > > >sure that with your brains and talent things will work out for you
> > > >if you are persistent and keep focused.
> > > >
> > > >Let me know what I can do to help. Good luck, Zach.
> > > >
> > > >Bo Barker
> > > >Barker Martin, P.S.
> > > >Construction Defect and
> > > >Homeowner Association Attorneys
> > > >720 Seventh Avenue, Suite 300
> > > >Seattle, WA 98104-1960
> > > >Direct: (206) 381-9806 x100
> > > >Fax: (206) 381-9807
> > > >www.barkermartin.com
> > > >
> > > >-----Original Message-----
> > > >From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
> > > >Sent: Thursday, October 14, 2004 10:08 AM
> > > >To: Bo Barker
> > > >Subject: Hello, the smudged fax
> > > >
> > > >Hi Bo,
> > > >Sorry for the smudged fax. I am mailing you the documents and some
>
> > > >email correspondence between christiansen's office and myself.
> > > >Please be aware that they likely think the delays were caused by
> > > >me, and this may be true.
> > > >I read your introductory letter and it looks great.
> > > >I am mailing this stuff today.
> > > >Thanks,
> > > >Zach
> > > >
> > > >_________________________________________________________________
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grievance against Creig Skau, Esq., Reno City Attorney's Office
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 11/19/12 6:49 AM
To: complaints@nvbar.org (complaints@nvbar.org)
Dear SBN OBC,
I believe Pat King is conflicted off of handling this grievance, but please check with the
Boss..
Please write back immediately with the grievance number, and provide the grievance
numbers for all the previous grievances that I have filed, yet Bar Counsel has failed to
respond to. All grievances filed by Zach Coughlin have been mailed to the State Bar
of Nevada by certified mail as well. Please divulge the conflicts of interest before I
bring them up. Pat sure can cook up a good Panel...He chooses Smiley Kent because
of Mike Smiley Rowe, Esq. and Ken'ts 1980 McGeorge School of law pedigree
(providing a nice connection to Judge Nash Holmes, class of '77, Judge Kenneth
Howard, class of '81...anyways, this is a formal grievance against Reno City Attorney
Creig Skau, Esq. to the extent he seems to have violated RPC's related to candor to the
tribunal and fairness to opposing counsel (even a suspended attorney like myself) in
securing my attendance at an impromptu 11/13/12 Hearing the day before my
Disciplinary Hearing (which just happens to be when the District Attorney's Office
decided to respond, however, deficiently, to my subpoenas...
000187
Anyways, the attached materials demonstrate ex parte extra judicial contacts with the
court and the judge, and apparent lying to get me to the hearing by asserting that Judge
Sferrazza had authorized service via email of Skau's ex parte motion to quash my
subpoenas, which he sought to quash based upon alleged service insufficiencies...go
figure. In fairnes to Mr. Skau, however, it can be a real moving target trying to
figure out what Judge Sferrazza's Orders are at any one given time (sometimes a court
date is noticed in writing as a "Trial" and continually referred to on the record as a
"Trial" after Judge Sferrazza has ruled that the tenant has "established a genuine issue
of material fact" sufficient to meet the summary judgment standard as applicable to
summary eviction proceedings under the Anvui decision (as he did both at the 10/13/11
summary eviction proceeding in RJC 2011-0001708, and again at the 10/25/11 Trial (it
was noticed in writing as a Trial, etc., etc.) on the unlawful detainer matter (where
Coughlin still was precluded from bringing third party claims or conducting discovery,
or granted the 20 days to respond to a Complaint under JCRCP 109, etc., etc..in some
summary plenary souffle' pastiche, kinda like...well, kind of like the SBN's Pat
King...you go the last minute shift of the 11/14/12 Disciplinary Hearing in NG12-0204
to a McGeorge SOL 1977-79 reunion of sorts, with most of the witnesses or exhibits
not even being served in the DowSoE or any Supplemental DoW until after the
hearing.
Oh, that reminds me, as for the 11/14/12 Hearing, beyond the fact that I was having
severe aching in my hands hands preventing me from taking notes as I would have
normally, Chair Echeverria issued an Order which he did not appear to have
jurisdiction to enter refusing to allow me to audio record the proceeding...and given my
ADHD and MDD, I ask that sufficient accommodations be made under the ADA to
ameliorate that discrimination and disparate impact/disparate treatment I was seemingly
maliciously subjected to, given Chair Echeverria's constant haranguing of me regarding
my conditions. PLEASE HAVE ALL RECORDINGS, RECORDS, AND OR
DOCUMENTATION (INCLUDING EVEN THE ROUGHEST DRAFTS OF THE
TRANSCRIPT SUNSHINE REPORTING SERVICES'S CAROL HUMMEL (AND
THAT FIRM REALLY WAS CONLICTED OUT OF PARTICIPATING GIVEN ITS
ASSOCIATION WITH THE RMC'S PAM LONGONI AND MS. LONGONI'S
FRAUDULENT CONDUCT IN CONNECTION WITH THE DUE PROCESS
CHALLENGED CONVICTION AND SUBSEQUENT APPEAL (DISMISSED DUE
TO MS. LONGONI, THE RMC'S EXCLUSIVE TRANSCRIPTIONIST THAT THEY
FORCE ON DEFENDANT'S, FRAUDULENT FAILURE TO PREPARE AND
000188
TRANSMIT THE THE TRANSCRIPT IN 11 CR 22176...WHICH PROVIDED A
NICE COUNTERPOINT TO RENO CITY ATTORNEY PAMELA ROBERTS
VIOLATING THE RPD, INCLUDIG RPC 3.9 AND NRS 171.1255 IN
PROSECUTING ME INCIDENT TO A MISDEMEANOR ARREST BY A TRIBAL
POLICE OFFICER WHERE WAL-MART AND THE CITY ATTORNEY ADMIT
THAT NO ONE WITH WAL-MART EFFECTED A CITIZEN'S ARREST (THAT
WOULD EXPOSE THE DEEP POCKETS TO TOO MUCH LIABILITY....WHY DO
THAT WHEN THEY KNOW ITS SO HARD TO FIGHT CITY HALL
PARTICULARLY FOR THOSE THAT DON'T OWN THEIR VERY OWN PIECE
OF IT, some might say....).
Please email me those transcripts, recordings, and associate materials right away AND
REALIZE THIS CORRESPONDENCE PLACES THE STATE BAR OF NEVADA
OFFICE OF BAR COUNSEL ON A LITIGATION HOLD NOTICE WITH RESPECT
TO ALL MATERIALS CONNECTED TO THE MATTERS SET FORTH IN THIS
WRITING.
Also, I am very, very uncomfortable with something Pat King, Esq. did at the 11/14/12
Disciplinary Hearing in NG12-0204. While I was peacefully using a urinal in the
restroom, a lecherous, leering Bar Counsel King sauntered right up to the very next
urinal beside mine and stated "pretty good grub, huh, Zach?" He said this as we both
had our penises in our hands. Needless to say it was entirely inappropriate,
unwelcomed, and requiring Mr. King's immediate removal from this matter, in addition
to a multitude of other basis for such an action that I have previously set forth.
Beyond that, Mr. King continues in his lame "push me pull me" thing were he
alternatively bemoans me not coming into the Bar's Office to meet and allegedly have
an opportunity to review the materials submitted in connection with the always murkily
attributed grievances only to threaten some abuse of process in a manner similar to
Laura Peters has done should I appear... (that's the nice thing about scanning and
OCR'ing the entire "big box" he only had delivered on 11/8/12...it shows so much
about King's approach, so very much...which, when combined with King's practice of
gleefully announcing that SCR 106 has given him a license to lie, cheat, and commit
other transgressions...its a wonder why the other attorney's in the Office of Bar
Counsel even bother trying to keep up the fine work they have done for so very long to
make the image of the State Bar of Nevada what it is...
000189
Sincerely,
`
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
11 14 12 email dda young and 0204 panel regarding skau and update dispatch discovery.htm
11 8 12 city attorney skau and homer email with 3 motion to ex parte quash attachments.htm
11 8 12 emails to dogan, kandaras and skau 0204.htm
11 8 12 homer and 11 9 12 skau reno city attorney's office emails 063341.htm
11 9 12 email from skau 063341 purporting that Judge authorized service of notice of hearing by email.htm
Download all

000190
RE: does Richard Hill have standing to file a grievance
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/18/12 8:48 AM
To: davidc@nvbar.org (davidc@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com)
Mr. King admits in his email below that he is departing from the SBN's stated policy of according every
grievance received a case number. Further, Justice Hardesty made some comments about a Constitutional
requirement in Nevada at a luncheon earlier this year respecting the fact that the Nevada Supreme Court must
review every grievance received...which would be hard to do given Mr. King, the filter/attack dog for the rich,
powerful, and influential in Northern Nevada/Social Climber Extraordinaire. Further, Mr. King was sued by a
close personal friend of mine, Geof Giles, Esq., and, aside from King's overt love of big banking and obvious
hatred of homeowners (which is notated on the record in hearings before the legislature and elsewhere) it is
inappropriate for King to have remained on my disciplinary matter...and I informed you of this long ago...
Now, this situation is a disaster for all involved in some respects. I am worried about Pat. I think we need
to get him some help. Being Bar Counsel is a tough deal, all that power can really go to one's head, and I
would like to be part of the intervention (what? No, I won't lead the damn thing, I couldn't possibly do that...I
don't have the training or time or inclin...Oh, alright! Fine, I'll do it) so we can get our Patty back. I know for a
fact his spouse is on board, and I have arranged for a bag to be packed for him and a plane ticket to
Biloxi...there's a great facility there, and when Pat comes back and its the old Patty Ice we all know and love, he
will be just as welcome as the flowers in May. Who's with me? Otherwise, you are left in the rather
untenable situation of trying to explain why Pat is violating SCR 121 with the Eastman in CV11-00820 prior to
the filing of any Petition, why he is feeding Judge Nash Holmes the "clear and convincing evidence" ethical
violation standard of proof language and instructions that she should improperly transmogrify a traffic citation
trial into some newfangled "summary disciplinary hearing" scenario (and she can't even cite to the right
statute when she wants to splash out with a criminal contempt conviction or, in her terms "the misdemeanor of
criminal contempt" (we all know being a prosecutor isn't exactly the best training ground for building up one's
aptitude for specificity or factual support, now, is it?).
It just hurts to see Pat like this...He's such a great guy "when he's right", you know? But when Dave's not
there, its like "Risky Business" up here...Patty gets out the Bob Seager out, takes them old records off the
shelf... and the dress shirt/boxer shorts/white tube socks/dark lensed Ray-Bans come out too, and the next
thing you know he's got some sort of dog-horse hybrid crapping all over the floors of the Northern Office of the
State Bar of Nevada, he's wearin' cargo pants to Disciplinary Hearings, he's booking Judge Linda Gardner's
courtroom deputy for the same hearing that involves Judge L. Gardner's ghost grievance in NG12-0435, he
booking the same court reporting firm (Sunshine and Pam Longoni, and Senator Grassley would find that dba so
rich, would he not?) that hung up on the phone on Coughlin and got his appeal dismissed for lack of a transcript
cited to in the matter that resulted in the SCR 111(6) Petition that is the basis for the current temporary
suspension of Coughlin's law license. It one thing to run this hustle on some sad 25 year old...But, why would
you want to get in a throwin' stars competition with a ninja? You wouldn't. He's failing to send out Laura's
000191
10/9/12 Affidavit, despite it being file-stamped. He's making the SBN look like lying clowns considering the
announcing of the applicable SCR 105(4) procedural rules by "Clerk of Court Peters" on 9/11/12 (vis a vis
deadlines not running for materials requiring service by certified mailing until the signature tag is signed by the
recipient, and barring that, a remailing of such a certified mailing, and failing the requisition of a signed
signature tag there, the certified mailing of a Notice of Intent to Take Default (and King and Peters, by
admission on their own certificate of mailing to the file stamped 10/9/12 NOITD only sent it by certified mail, ie,
they departed from their stated and established procedural practice of sending everything two different ways
(ie, certified and first class)...regardless, HERES THE KICKER...that 10/9/12 certified mailing of the NOITD was
returned to the SBN and signed for by the SBN on 11/8/12, and the envelope (a large manila one with the SBN's
in house red Pitney Bowes postage printing affixed to it indicating an under postage was mistakenly applied
given te large manila envelope with a certified mail certificate and return receipt requested card (at least $5.50
in postage) had only $1.25 in postage affixed to it, which Tim, a 20 year employee of the Downtown Reno (I
might have previously said Vassar, for some reason my brain was stuck on that...but it was definitely, definitely
the Downtown Reno 89505 postal station) where upon a previous attempt to collect the certified mailing Tim
failed to find it (who knows why, might be due to my handing him an Official Change of Address on October
5th, 2012 for my PO Box 3961 89505 address..from which I forward mail to my current 1471 E. 9th St. 89512
address) or due to his looking in "the small box" whereas that mailing was in an 8.5 x 11 inch envelope...but
when I returned again on a later date, the same counter attendant, Tim, did find the 10/9/12 certified mailing
of the NOITD (and Chair Echeverria doesn't seem to get this...I didn't get the NOITD until November 8th, 2012,
and I only got it then in the bate stamped form is come in with the other thousands of pages of documents in
the Sierra Document Processing "big box" that Chair Echeverria's 10/30/12 Order required the SBN to provide
me as a consolation, apparently, to actually following the rule in SCR 105(2)(c) and allowing me inspect the
materials "up to 3 days prior" to the 11/14/12 Hearing (that is a huge deal, for a variety of reasons, not least of
which is the act that King continued to attempt to Supplement the Designation of Witnesses and Summary of
Evidence as late as 11/7/12 (and the certified mailing signature card for that Supplemental was only signed for
today, 11/16/12, and you know if Joe Garin is going to pull the old "actual notice of is not a substitute for
technical compliance with service rules" card on me in 60302, that I am going there with the SBN), to wit, from
SBN Ethics Committee member Joe Garin's 10/22/12 Respondent's Brief in 60302 (where Coughlin sued Washoe
Legal Services, and involving NNDB member Kathleen Breckenridge, whose mess Coughlin cleaned up quite
nicely on the i-864 Affidavit of Support for battered immigrant spouse issue (Breckenridge got the $3K award of
attorney's fees...I clean up what she failed to spot, and am fired shortly thereafter....). So, really, given the
return receipt card was only signed for the Notice of Hearing on 10/27/12 (and the earliest it was in my box,
according to USPS track and confirm was 10/22/12, despite a certificate of mailing by Peters indicating she
sent it out 10/12/12...which is odd given the USPS Track & Confirm shows it was first scanned into USPS custody
on 10/16/12...not so odd when you consider that upon my arriving at the SBN's Northern Office on 10/31/12 at
about 4:45 pm I spoke with Peters and noticed that in the "outbox" at the front desk were a lot of letters
with the green certified mail/return receipt requested placards affixed to them...and I queried Peters about
them. She admitted the mail had been picked up that day at the SBN already, so those items would not go
out that day, despite what the certifcate of mailing attached thereto might swear to under penalty of perjury
(you are playing with people's livelihood's and Fourteenth Amendment property rights, here...)...So, it would
appear that Peters signed the certificate of mailing for the Notice of Hearing (and I believe a Designation of
Witnesses and Summary of Evidence requires its own file stamping and its own certificate of mailing...and the
bate stamped version of the "Disciplinary File for Zach Coughlin" indicates, in the 10/12/12 certifcate of mailing,
that only a Notice of Hearing was sent out (ie, not a DoWSoE along with it...regardless, SCR 105(2)(c) requires
000192
the Panel send it out and serve it in compliance with SCR 109 (as altered by SCR 105(4), which includes Peter's
attestations of 9/11/12...). None of that was done correctly. Rather, King persisted in his established
practice of going back on the SBN's word to cheat and gain an advantage, and in his habit of taking on the roles
of the Panel or the Clerk of Court (or the Municipal Court Judge where he tells Judge Nash Holmes to be sure to
put the "I find by clear and convincing evidence violations of (insert copy and pasting with zero specificity as to
any factual support for such a summary ethical violation order incident to a "simple traffic citation matter" (do
you get the picture, here? Its amateur hour, and he's doing it with your good name, or what's left of it by
now...) various Rules of Professional Conduct so Pat can ignore Claiborne some more and rest on his laurels
and SCR 111(5)....which Chair Echeverria likes himself quite a bit...only problem is that they both like to go with
a lot of Richard HIll testimony about pajamas and slippers and livin' in the former home law office after eviction
and "breaking and entering" some crawlspace/glorified basement under the house that never had a lock at any
time...not to much SCR 111(5), not relevant, puffing going on there, though, huh, Pat? Chair Echeverria?
SCR 105(2)(c) a/k/a that which Patrick O. King and Chair Echeverria used as a guide for "things to make sure we
avoid providing to Respondent Coughlin so our hit piece goes off smoothly and we both get a bunch of attaboys
by the McGeorge Mafia and other power brokers..." along with the ol' Bar Counsel as debt collector for Richard
G. Hill,Esq. and Casey Baker, Esq. meme of "if the Panel won't sign on to my ridiculous disbarment of Coughlin
request, then please be sure to require Coughlin to pay Richard G. Hill, Esq. the attorney's fees award that
Coughlin's former co-worker Judge Flanagan entered against Coughlin after refusing to recuse himself, and
shortly after Pat King's 3/23/12 email to Coughlin attempting to mislead Coughlin about the Department 3
"Clerk of Court' throwing a sewing circle of gossip :
"...(c) Time to conduct hearing; notice of hearing; discovery of evidence against attorney. The hearing panel
shall conduct a hearing within 45 days of assignment and give the attorney at least 30 days' written notice of
its time and place. The notice shall be served in the same manner as the complaint, and shall inform the
attorney that he or she is entitled to be represented by counsel, to cross-examine witnesses, and to present
evidence. The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the
attorney, and the names of the witnesses bar counsel intends to call for other than impeachment, together with
a brief statement of the facts to which each will testify, all of which may be inspected up to 3 days prior to the
hearing. Witnesses or evidence, other than for impeachment, which became known to bar counsel thereafter,
and which bar counsel intends to use at the hearing, shall be promptly disclosed to the attorney. For good cause
shown, the chair may allow additional time, not to exceed 90 days, to conduct the hearing."

The thing is, since the Panel was not even created or named by NNDB Chairman Susich until October
Here's Joe "Joey Detroit" Garin's take on why the SBN did a very bad think in pushing through with that
Disciplinary Hearing on 11/14/12, by analogy to 60302, of course:
"b. The District Court properly dismissed Torvinen, Breckenridge, and Sabo from the case because Plaintiff failed
to provide them proper process.
A claim of insufficiency of process is a challenge to the content and form of a summons and complaint. See e.g.,
Musgrave v. Squaw Creek Coal Co., 964 N.E.2d 891 (Ind. Ct. App. 2012). A defendant has an absolute right to
000193
demand that process be issued in a manner prescribed by law. See MJS Enterprises, Inc. v. Superior Court, 153
Cal.App.3d 555,557,200 Cal.Rptr. 286 (1984). Additionally, Nevada Rule of Civil Procedure 4( d) provides,plaintiff
furnish person making copies necessary.
"The summons and complaint shall be served together. The shall the service with such as are Service shall be
made by delivering a f!2J2l!. of the summons attached to a f!2J2l!. of the complaint ... " (Emphasis added). In
this case, Plaintiff failed to effectuate proper process against Torvinen, Sabo, and Breckenridge because process
did not comply with NRCP 4(d). With respect to Torvinen, on October 27, 2011, Plaintiff served Torvinen with 35
pages worth of documents related to the case. (Record Vol. II, 201-248). Nearly every page comprised of 9
pages scaled onto one page. Id. Accordingly, on November 15, 2011 Torvinen filed a Motion to Dismiss on the
grounds that Plaintiffs service of process was untimely and insufficient under NRCP 4. Id. Torvinen argued that a
copy is a reproduction of an original and that Plaintiff provided modified versions of the original that were
illegible and improper. Id. On November 30, 2011, Plaintiff responded with a three sentence Opposition that
stated that service was sufficient and sidestepped the issue regarding process. (Record Vol. II, 394-396). The
District Court subsequently dismissed Torvinen from the case for lack of service of process. (Record Vol. IV,
1174-1160). The Court later clarified its order and found that Torvinen was dismissed for lack of process.
(Record Vol. IV, 1475-1480). It adopted Torvinen's arguments that the papers provided were not a "copy" within
the meaning of NRCP 4 and found Plaintiff did not effectuate proper process. Id. Likewise, Plaintiff served
Breckenridge in a similar fashion. Breckenridge received a total of 89 pages worth of documents some of which
related to the case and others which did not. (Record Vol. II, 286-387). The documents were also scaled down in
size. Id. Some pages comprised of 9 pages to a page, while others fit 2 pages to a page. Id. On November 28,
2011, Breckenridge filed a Motion to Dismiss based on non-service of process and insufficient process. Id. Much
like
Torvinen, Breckenridge argued that 89 pages of condensed documents did not
constitute a "copy" of a summons and complaint within the meaning of NRCP 4.
Id.
In response, Plaintiff filed two perplexing oppositions presumably against her Motion, the latter of which was
untimely. (Record Vol. II, 416-468; Vol. III 569-671). In the first opposition, Plaintiff dedicated two sentences to
opposing Breckenridge's Motion. (Record Vol. II, 416-468). Per the first opposition's title-Opposition to all
Defendant's Motions to Dismiss and all Defendant's Motions to Quash Service, Motion for Extension of Time to
Respond/Continuance; Opposition to Motion to Tax Costs Simultaneously Seeking Extensions of Time or
Continuance to Respond-Plaintiff sought to do various things in two sentences. Id. In reality, Plaintiff failed to
do anything more than make a conclusory statement that he opposed the then filed motions to dismiss.
Plaintiff's second opposition while more than two sentences in length, sought to raise tangential issues that
were not before the Court. (Record Vol. III, 569-671). In effect, the District Court dismissed Breckenridge from
the case. (Record Vol. III, 723-725).
The District Court also dismissed Sabo from the case after she filed a motion to dismiss on the grounds of
insufficient process. Id. Specifically, Plaintiff served Sabo with only a copy of the summons, once again ignoring
NRCP 4's requirements. (Record Vol. II, 250-261).
Based on all the above, it is clear that the District Court properly dismissed Torvinen, Breckenridge, and Sabo
from this case. Plaintiff did not truly oppose the various motions to dismiss and failed to effectuate process on
the parties.
It was only after the District Court dismissed Torvinen, Breckenridge, and Sabo, that Plaintiff found a case, which
he now relies on, to argue that the District Court erred in dismissing these parties (Record Vol III. 767-869).
Plaintiff relies on the New York case, McKenzie v. Amtrak M of E, 777 F.Supp. 1119 (S.D.N.Y.
000194
forma
1990). In McKenzie, a New York court denied a Motion to Dismiss for defects in process because they were
attributable to court personnel. Id. at 112l. Specifically, the court acknowledged that generally there is a strong
argument for ineffective service of process "unless a legible copy of both the summons and the Complaint are
received by the defendant." Id. (citing Village of Wellsville v. At!. Richfield Co., 608 F.Supp. 497 (W.D.N.Y.1985);
Parker v. Mack, 61 N.Y.2d 114, 472 N.Y.S.2d 882, 460 N.E.2d 1316 (Ct.App.1984)). The Court determined that
because court personnel in this particular jurisdiction were required to make copies for in forma pauperis
litigants, and a faint copy of the complaint was made and served on the defendants, dismissal was not
warranted. Id.
The McKenzie decision is not controlling and inapplicable to this case. In citing to the McKenzie decision,
Plaintiff seeks to carve an exception into NRCP 4(a), which specifically places the responsibility to effectuate
proper service of process on a plaintiff. Moreover, the circumstances in McKenzie were unique because that
particular jurisdiction required court personnel to make copies for in
pauperis litigants and serve such copies on their behalf. Plaintiff has failed
to establish that court personnel in the Second Judicial District Court are required to makes copies of service
papers for in form pauperis applicants. That is because there is no such requirement or practice and NRCP 4(d)
specifically imputes that responsibility on a plaintiff. Furthermore, Plaintiff never argued that the modifications
to the service papers were the fault of court personnel. Rather, the modifications were admittedly Plaintiff's
own doing. (Record Vol. III, 816). Thus, McKenzie is not only a non-binding decision, but it is inapposite to the
rules and
overall circumstances of this case.
Overall, the District Court did not abuse its discretion in dismissing Torvinen, Breckenridge, and Sabo from the
case seeing as Plaintiff provided insufficient process."
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: PatrickK@nvbar.org
To: zachcoughlin@hotmail.com
Subject: RE: does Richard Hill have standing to file a grievance
Date: Fri, 23 Mar 2012 17:57:26 +0000
Dear Mr. Coughlin,

Please come to see me and I will show you the letter and documents from the Court.

000195
Patrick King

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Friday, March 23, 2012 10:39 AM
To: Patrick King
Subject: RE: does Richard Hill have standing to file a grievance

Mr. King,
This is the very first time you allege anyone other than Mr. King filed or alleged a
grievance. Please provide any documentation or proof related to these apparent
communications from judges that you are only now bringing up.
Sincerely,
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada
Bar No: 9473
From: PatrickK@nvbar.org
To: zachcoughlin@hotmail.com
Subject: RE: does Richard Hill have standing to file a grievance
Date: Fri, 23 Mar 2012 17:18:34 +0000
Dear Mr. Coughlin,

I have repeatedly expressed my interest in having a meeting with you to discuss the
grievances against you. You claim to be too busy to meet with me, yet you have time to write lengthy e-mails and
apparently to do legal research.

You asked if Mr. Hill has standing to file a grievance against you. Not only does he have
standing to file a grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As I
have explained to you, the grievances against you came not only from Mr. Hill but also from Judges from different
Courts. These grievances, and the evidence attached with them, rather clearly puts into question your competence to
practice law. As I have explained to you, I will make the evidence and exhibits available to you when you come to
inspect them at my office. I will not send you reports or document, especially since you claim your mail is being
compromised.

As for the grievances you have made, nothing that you have submitted appears to show an
000196
ethical violation that could be proved by clear and convincing evidence, which is the standard of proof required in
disciplinary matters. As such, at this time we have not opened any files based on the information you have
submitted.

Sincerely,

Patrick King

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Friday, March 23, 2012 9:12 AM
To: Patrick King; cdbaker@richardhillaw.com
Subject: does Richard Hill have standing to file a grievance

American Jurisprudence Trials


Database updated April 2011
Defending Lawyers in Disciplinary Proceedings
31 Am. Jur. Trials 633 (Originally published in 1984)
III Attorney-Client Grievances
10 In general
11 Sources of complaints and grievances; checklist
12 Former criminal clients
13 Particular problem clients
14 Fee disputes; checklist of factors of reasonableness
15 Arbitration; forms
16 Fee dispute committee hearings; illustrative testimony

Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining


professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or
misrepresentation
000197
and engaging in conduct prejudicial to administration of justice, where attorney, acting in
bad faith,
filed documents which he or someone in his office generated to falsely certify debtors'
completion of
required credit counseling course and which he knew, or should have known, that debtors
did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11
U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev.
2010).

Mr. King, could you please update me on that status and progress of the various grievances
I filed recently in addition to providing a detailed summary of the content of all of your
correspondences, written or otherwise, and telephone communciatiosn with Richard Hill or
anyone with his office. Further, please state whether Casey Baker is part of the grievance,
as Hill asserts he is filing it on Mr. Baker's behalf.

Sincerely,

Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy
work" for opposing counsel?
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
new Discovery finally produced by Reno City attorney on 1/12/12
Jaywalking arrest in SCR 105 Complaint
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/14/12 6:46 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
(nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org);
(fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org);
(complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org);
(je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com) (cvellis@bhfs.com); (eifert.nta@att.net)
(eifert.nta@att.net); (consult@laketahoelaw.com) (rhrc@laketahoelaw.com); (stuttle@washoecounty.us)
(stuttle@washoecounty.us); (kadlicj@reno.gov) (kadlicj@reno.gov); (wongd@reno.gov)
000198
(wongd@reno.gov); (schornsby@nvdetr.org) (schornsby@nvdetr.org)
Dear Panel and Bar Counsel,
Please find the attach additional discovery the Reno City Attorney's Office gave me
today related to the custodial jaywalking arrest of 1/12/12, at which time Richard Hill
applied for an received a TPO from RJC Judge Schroeder in 40 minutes (and RPD
Officer Look took a special trip to the jail to attempt to serve the TPO for Hill).
Please see attached the video of the arrest and interactions prior thereto, and consider
the lack of accuracy in Hill and Baker's Second Motion to Show Cause, Judge
Flanagans denying that Motion incident to a 3/23/12 and 3/29/12 Order to Show Cause
Hearing (which WCSO Deputy Machen, the same one who filed a false affidavit
incident to the summary eviction order posting and lockout on 11/1/11 in the Richard
Hill eviction cases rev2011-001708 served on Coughlin, by way of violating the
"courthouse sanctuary" doctrine, and Caplow holds attorney of record and efiler on that
case Coughlin did not require personal service anyways...this was hazing by Hill and
the RMC Marshals and WCSO Deputies, plain and simple, at the 2/27/12 Trial in 11
TR 26800, the traffic citation trial that NG12-0204 stems from, which stems from RPD
Sargent Tarter telling Coughlin to leave Hill's office upon going there after being
released from a 3 day custodial arrest incident to Hill and Merliss's lies on 11/13/12
resulting in a wrongful arrest for criminal trespass of Coughlin by RPD Officer Chris
Carter and Sargent Marcia Lopez). In the video Hill is see and heard lying to Officer
Hollingsworth in seeking to abuse process and have Coughlin arrested. Then trainee
Officer Leedy then proceeds to adopt Hill's approach nearly verbatim in his arrest
report. Sargent Sifre (whom arrested Coughlin again two days later on 1/14/12 for
"misuse of 911" which DDA Young nows seeks to amend to a crime that will leverage
the "serious offense" dictates of SCR 111, even though he lacks an RPC 3.8 probable
cause basis for doing so. Further, both Hill and Officer Leedy substantially
misrepresent what Officer Hollingsworth said. Additionally, should Officer
Hollingsworth had indeed told Coughlin that what he was doing was legal but that the
Officer was ordering Coughlin not to do it, or threatening Coughlin in order to achieve
cooperation, that would violate Soldal v. Cook County, which is essentially what RPD
Sargent Tarter did on 11/15/11 in his three traffic citations outside Hill's office, which
les to 11 tr 26800, which begat ng12-0434, and, arguably ng12-0435. I guess it takes
a lot of people to help Board member Richard G. Hill, Esq. and his fled-to-Kentucky
associate Casey Baker, Esq. make money...One can hardly blame Coughlin for half-
way believing RPD Officer Carter's statement on 11/15/11 that "Richard G. Hill pays
me a lot of money so I do what he says to and I arrest who he says to...". Coughlin's
000199
merely attributing the statement that RPD Carter said to Carter is not misconduct.
Hill's making up things about a "crack pipe and bag of weed" and "large quantity of
pills" (see the video "Zach's arrest 014 that Hill and Merliss themselves filmed to see
that the "pills" are vitamins...and Hill's contractor Phil Stewart, signed an affidavit that
mentions this "large quantity of pills"). If you knew all the Thursday nights I spent
since 2003 with Coe, and now deceased Judge Bob, and so many others, you would
realize how infinitely tacky Hill's conduct is.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 14 files to share with you on SkyDrive. To view them, click the links below.
1 12 12 audio of RPD Officer Leedy 12 cr 00696 rmc jaywalking arrest 1708 26405 03628 000018.cda
7 3 12 redacted disturbing the peace arrest 12 cr 12420 rmc loomis sotelo mauser weaver dye 00696 26800 sbn 0204
25 page discovery northwind ncs krebs reduced size.pdf
1 14 12 bf additional discovery 12 cr 00696 jaywalking arrest Richard Hill's lies led to RPD RMC RJC TPO rcp2012-
000018 0204 Leed.pdf
SAM_0190_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
SAM_0189_mpeg4 rpd hill sifre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4
rcp 2012-000018 D3 Hill v Coughlin Protection Order smaller nuanced.pdf
1 20 12 WDC APPEAL RICHARD HILL 2ND MOTION TO SHOW CAUSE.pdf
4 20 12 1708 0204 exhibits 1 to 4 of Hills motion for attorney's fees cv11-03628.pdf
11 9 12 61901 amendment to opposition.pdf
11 5 12 000374 notice that noa was not file stamped motion for new trial or to set aside order kern king schroeder
ptthoa 0204.pdf
10 29 12 notice of errata and SUPPLEMENTAL MOTION FOR NEW TRIAL 26405 1708 26800 0650630.pdf
bifurcate atty client severe hearing trialotjl.pdf
bifurcate atty client severe hearing trial.pdf
CV11-03628 ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800
NG12-0204 BF.pdf
Download all

000200
City Attorney Skau, updated discovery in iPhone case, dispatch
recordings, don't seem to reveal basis for "a possible fight" assertions in
office testimony and prosecutors's filings and argument
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 11/14/12 2:09 AM
To: zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); skent@skentlaw.com
(skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com); nevtelassn@sbcglobal.net
(nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org
(complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); je@eloreno.com (je@eloreno.com);
cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net (eifert.nta@att.net); rhrc@laketahoelaw.com
(consult@laketahoelaw.com); stuttle@washoecounty.us (stuttle@washoecounty.us); kadlicj@reno.gov
(kadlicj@reno.gov); wongd@reno.gov (wongd@reno.gov); schornsby@nvdetr.org
(schornsby@nvdetr.org); jleslie@washoecounty.us (jleslie@washoecounty.us);
jgoodnight@washoecounty.us (jgoodnight@washoecounty.us); jbosler@washoecounty.us
(jbosler@washoecounty.us)
Dear DDA Young and Bar Counsel and Panel Members,
The prosecution in RCR2011-063341 and the associated arrest on 8/20/11 is what
started all this off (by "all this" I mean the 46 days in jail, the 10 different trips to jail,
the five to six different evictions, all summary, the competency evaluations, and all the
associated grievances. This arrest and prosecution have largely been based on and
the office and prosecutor have cited to, their contention that the information from
ECOMM or dispatch told the RPD Officers (and the arresting Officer Nick Duralde is
married to a dispatcher working that night and perhaps whose voice is on these files,
finally given to me only today, by Reno City Attorney's Office Creighton Skau, after he
secured my attendance at a hearing that I do not believe was noticed in a legal since by
sending me an email saying Judge Sferrazza authorized service of the notice of the
hearing by email...which Judge Sferrazza denies (in fairness to Mr. Skau...its possible
the Judge did say that...Mr. Young could maybe shed some light on that, as apparently
their was a sort of group meeting with he, the Reno City Attorney and the WCPD on or
about November 8th, 2012 in rCR2012-063342, that I was not noticed on and, of
course did not attend).
Anyways, DDA Young and Officer Duralde have constantly harped on how dispatch
reported a "possible fight" and how that somehow justified the rash approach taken
by Officer Duralde, the overcharging of "oooh, that's a felony" Felony Grand
Larceny (7 days in jail, the eviction notice in the Richard Hills summary eviction from
000201
my former home law office was served during the interim in RJC Rev2011-001708) for
a three year old iphone that the alleged owner, Cory Goble, testified was worth about
$80 at the time....(and the overcharging of a felony enabled Officer Duralde to conduct
a search incident to arrest for a misdemeanor not committed in his presence, after 7
pm...which Nevada law prohibits, particularly where, as here, there was no citizen's
arrest (Coughlin himself called 911 and there is a video of the time prior to arrest
where Coughlin is heard imploring the skater youths to stay peaceful and wait for law
enforcement to arrive so a civil resolution of the dispute could be garnered).
I am writing now and providing this new production of ECOMM/911 dispatch
recordings that would seem to be the State's last hope of proving that the Officers were
told of, by dispatch, "a possible fight" and therein provide some factual basis for that
which Officer Duralde and DDA Young have testified to, and filed pleadings in that
matter arguing that reports of "a possible fight" justified the subsequent terry stop
weapons check pat down, and search incident to arrest (remember, Officer Duralde
announced 20 seconds into arriving on scene that he was going to arrest Coughlin and
do a search of Coughlin's pockets prior to conducting any of the pretexutal
"investigation" that he later testified to...its just that Officer Duralde did not realize he
was being recorded when he said that....no matter how he "remixed" things in his
Supplementary Declaration (filed within 48 hours of arrest) or his Narrative (by all
indications, the Narrative was only filed some three months after the arrest and
apparently after the RPD and City Attorneys Office became aware that the video of the
arrest was publicly available).
I have listened closely to these dispatch recordings and hear nothing about "a possible
fight". Does that make the Officer's Testimony perjury and DDA Young's conduct
misconduct? DDA Young, I have a Hearing in a few hours on 11/14/12 at the SBN's
Office on Double R. Blvd. I ask that you attend and explain these matters as this
arrest is pled in Bar Counsel Kings SCR 105 Complaint.
Mr. Leslie and Mr. Goodnight, I ask that you attend and explain your failure to
subpoena the dispatch recordings until October 3, 2012 (despite the Trial occuring on
May 7th, 2012 (in violation of NRS 178.405, no less), and again on July 16th,
2012....and, again on August 29th, and September 5th, 2012....and then please explain
why you feigned inability to personally serve subpoenas as a basis for failing to get
Nicole Watson (easily found and or served via a certified mailing under NRS 174.345,
at the addresses your investigator refused to turn over to me until November 2012 upon
000202
a court order (you guys are supposed to help defend the accused, not the County or
local law enforcement against their potential civil liability for ego driven foolish
arrests) as a student at McQueen High School along with Lucy Byington, both
percipient witnesses, and where Watson was captured on tape admitting to the "man
with a six-pack" holding the phone aloft and offering it up, and announcing, very
loudly, that he woud "throw it in the river" if it was not immediately claimed (therein
presenting yet another claim of right defense and further vitiating the legitimacy of
DDA Young's retaliatory, deficiently pled, amending of the Complaint on December
5th, 2012 to included "possessing or receiving stolen property from another".
I ask that in inquiry into the propriety of Mr. Skau's email attached (wherein the City
Attorney's gained an advantage and prejudiced my ability to defend in both NG12-
0204, etc. (the Bar Hearing) and the petty larceny Trial (in RCR2011-063341). I will
note that at least Joe Goodnight gathered the three 911 calls.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 66 files to share with you on SkyDrive. To view them, click the links below.
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-45 PM Source_ID = 44.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 1.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-49 PM Source_ID = 31.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-00 PM Source_ID = 36.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-06 PM Source_ID = 38.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21.wav
000203
Start_Time = Saturday, August 20, 2011 11-23-55 PM Source_ID = 34.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17.wav
Download all

SBN and or Panel will be breaking the law by holding a hearing
tomorrow in violation of SCR 105(2)(c) proof attached
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/13/12 3:22 PM
To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org);
complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); eifert.nta@att.net
(eifert.nta@att.net); rosec@nvbar.org (rosec@nvbar.org)
You will be criminals as of tomorrow if you hold that hearing.
SCR 105(2)(c), SBN"s Index for Hearing is holding out certificates of mailing and or
proofs of service on the most materials documents incident to a due process analysis
(10 9 12 Notice of Intent to Take Default was recieved as returned due to insufficient
postage by the SBN on 11 8 12, I declare under penalty of perjury...nrs 53.045...further,
SBN only sent one envelope of that document, that returned for insufficient postage
certified mail mailing on 10 9 12.
Additionally, SBN is holding out 10 12 2012 certified mailing of Notice of Hearing and
Designation of Witnesses and Summary of Evidence as having a date of 10/12/12 for a
constructive notice analysis, despite the USPS proof indicating the first scan in a USPS
system occurred on 10/16/12.
Additionaly, the SBN and Peters formally declared that the 8/23/12 mailing was
000204
returned to the SBN and that another certified mailing of the Complaint would
immediately be sent out, and that the 8/23/12 certified mailing would never be offered
to prove proof of service under SCR 109 or in any other manner offered as proof of
service of the Complaint. Yet that is just what King has done by his Index putting
that forward.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
11 13 14 attachment proving 0204 sbn and panel fraud scr 105(2)(c).pdf
From: zachcoughlin@hotmail.com
To: skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; patrickk@nvbar.org;
fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org; je@eloreno.com;
cvellis@bhfs.com
Subject: FW:
Date: Sun, 11 Nov 2012 07:50:13 -0800
Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR
116 appeal rights...
Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN
Laura Peters signed a waiver of service or similar
and the 10 31 12 Pre Hearing Motion to Dismiss Summary Judgment/Memorandum of Law
(Response)

Date: Mon, 13 Aug 2012 11:28:12 -0700


From: silverman@silverman-decaria.com
To: zachcoughlin@hotmail.com
Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final
000205
judgment in the crim case and point out that your temporary suspension is akin to a permanent death of your
practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now
have access to your meds and are ok. I can't think this pleading is going to help you much...it is too long,
repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't make
your case in 3-5 pp, you can't make your case in 35. You do seem to be a good lawyer, however. At bottom, Steve
Harris took hundreds of thousands of dollars and had no temp suspension; you stole a candy bar (at worst). WTF.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com

SCR Rule 104(3) Complaint filed against Bar Counsel King and Clerk
of Court Peters
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 11/12/12 9:51 PM
To: Frank Flaherty (fflaherty@dyerlawrence.com); rosec@nvbar.org (rosec@nvbar.org);
schornsby@nvdetr.org (schornsby@nvdetr.org); glennm@nvbar.org (glennm@nvbar.org)
President Flaherty,
I have filed my SCR 104(3) Complaint with you already. I reserve my right to supplement it at a later date, but
it is filed. Whether you choose to abide by the duties of your Office is not something I can control. However,
I do understand that there is a Constitutional requirement that the Nevada Supreme Court review your
determination. Please provide me the case number for this Complaint, and the case numbers for every grievance
I have filed this year. Just want my file stamp and case number, Sir. I understand you may feel my Complaint
is jibberish...but I don't believe Clerk's of Court, under NRCP 5(e) are permitted to refuse to file Complaints (or
anything for that matter, so...please just stamp it in and give 'er a case number.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: FFlaherty@dyerlawrence.com
To: zachcoughlin@hotmail.com
CC: DavidC@nvbar.org; PatrickK@nvbar.org; KimberlyF@nvbar.org
Subject: RE: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman
Date: Wed, 31 Oct 2012 21:02:36 +0000
000206
Mr. Coughlin:

Regarding your numerous complaints and allegations below, I have no case


numbers, I have no authority over attorneys who are not employees of the
Office of Bar Counsel, and I certainly have no authority over judges.

If you think you really need to file a complaint against an attorney in the
Office of Bar Counsel, please review SCR 104(3) and send me a succinct and
organized written document, along with only relevant exhibits, setting forth
your allegations that said attorney has violated the Nevada Rules of
Professional Conduct.

Thank you.

Francis C. Flaherty
Dyer-Lawrence
2805 Mountain Street
Carson City, Nevada 89703
(775) 885-1896
FAX: (775) 885-8728

This e-mail may contain legally privileged and/or confidential information. If you are not the intended
recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you
are hereby notified that any dissemination, distribution or copying of this e-mail message is strictly prohibited.
If you have received this message in error, please immediately notify the sender and delete this message from
your computer.

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]


Sent: Wednesday, October 31, 2012 12:57 PM
To: Frank Flaherty
Subject: FW: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman

000207
Dear President Flaherty,

Can I get a case number for this matter, I have not heard anything about it in forever. I also, I would like to
file a grievance or Complaint against Bar Counsel Pat King and NNDB Chairman Susich for failing to follow the
June 7th, 2012 Order of the Nevada Supreme Court and SCR 111(7)-(8), in addition to SCR 102(4)(d). Under
the Ching or Chang decision, the SBN is the "complainant" and wit respect to these matters, wherein I allege
misconduct by Peter Christiansen, Character and Fitness Chairman Kevin Kelly, Esq. and others, the SBN has not
known about these matters for more than 4 years. Further, King refuses to undertake any investigation
against Richard G. Hill, Esq., Judge Nash Holmes, Casey Baker, any of the RMC "court appointed defenders" (like
Loomis, Puentes, Taitel, Sotelo) or WCPD's Leslie, Goodnight, Dogan, or Bosler. Now, King is trying to jam me
into a combo hearing on November 14th, 2012 in his ng12-0205 ng12-0434, and ng12-0434 scr 105 complaint,
which impermissilby seeks to skirt scr 111(7)-(8) vis a vis King's SCR 111 petition in 60838 (please see my filings
in that regard).


Furhter, the "courthouse sanctuary" rule makes the RMC Marshal Harley's conduct in personally serving me
notice of an Order to Show Cause Hearing in the appeal of the eviction matter in cv11-03628 (Richard HIll got
me evicted from my former home law office) on behalf of WCSO Deputy Machen (whom HIll hired to serve it
despit the Caplow decision making clear that is not even required...basically, its wrong to have the RMC Marshal
barge in to my plea bargaining session with city attorney ormaas on february 27th, 2012 incident to the traffic
citations in 11 tr 26800 that the rpd gave me at hill's office when I went to get my wallet, key's, drivers license,
and client's files from hill after being released from a fraudulent custodial arrest for criminal trespass at my
former home law office in a criminal complaint signed by hill, judge nash holmes held that 11 tr 26800 trial later
that day, despite her apparent admission that she was made aware by the wcpd and or wcpd biray dogan that
an order for competency evaluation had been entered respecting me on 2/27/12 at 1:31 pm and nrs 178.405
and nrs 5.010 shoudl have prevented judge nash holmes from holding that trial, and In re Oliver (us supreme
court case requiring sixth amendment right to council in cases like 11 tr 26800 where Judge Nash Holmes
convicted me of "summary criminal contempt" despite her order resting upon alleged conduct outside her
presence, in a bathroom stall that she alleged in her 3/ 12/12 hearing in that matter an RMC Marshall
witnessed by peering through a bathroom stall I was in where "dissassemblign a smartphone" or some
nonsense like that peeping tom crap...RMC Harley was serving an Order to Show Cause on behalf of WCSO
Deputy Machen (who didn't want to wait around to serve me it....just like on 11/1/11 when machen didn't want
to follow the law in serving me the eviction order, and instead filed a false affidavit attesting to personal service,
then conducted a lockout using a stale or invalid eviction order when I was not present, only to attest to having
"personally served" me..

This is a mess, the SBN doesn't have jack on me (give me my hearing under the court's 6/7/12 order for the
"sole purpose" of determingin my punishment over the "walmart candy bar" petty larceny conviction, which I
000208
completely showed to lack due process (dismissing appeals for failure to cite to a transcript where the rmc is
breaking the law in not preparing the transcript? i proved perjury by all the city's witnesses, and prosecutorial
misconduct, clearly)....then the criminal trespass conviction is so flawed its unbelievably. the judge was the
brother of the family court judge garnder who got me fired from washoe legal services, and the brother passed
her sanction order to judge nash holmes who passes it to the sbn, and it becomes ng12-0435, but sbn king
doesn't want to admit that that is how he got it? and the brother judge gardner refuses to recuse himself
from that criminal trespass case rmc 11 cr 26405, despit my filing mandamus against his sister's order in 54844
and despite his sister's order being a bar grievance against me, submitted by judge holmes, on behalf of the
brother judge gardner and all the other rmc judges? and the rmc "loses" my n otice of appeal an it gets
dismissed in cr12-1262 by the same judge elliot of d10 whom put me in jail between 4/19 and 4/26/12
impermissibly based upon lies by the competency evaluators and a motion by dda young that violated nrs
178.405's mandatory stay? and during that incarceration richard hill's $40k attorneys fees motion against me
in the eviction cv11-03628 is filed, which flanagan ultimately awarded?

the sbn is gambling a large chunk of yours and its reputation on a bunch of asinine arrest by the rpd, and
extremely suspect co-signing of richard hill's bullshit this year by people who should know better.


Sincerely,


Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin@hotmail.com

From: zachcoughlin@hotmail.com
To: patrickk@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
Subject: Character and Fitness, Kevin Kelly, Pete Christiansen, Patrice Eichman
Date: Fri, 16 Mar 2012 13:48:17 -0700
000209
Dear Bar Counsel,
I write respectfully asking an inquiry be conducted into whether Kevin Kelly indicated
at my June 2002 hearing that 3 pro bono attorney's name would be provided to me, but
that only one was, Peter S. Christiansen, and that, despite Christiansen saying he was
doing my case on a pro bono basis, he was paid at least $5,000, and pretty much the
only work he or his office did was attend the June 2002 hearing, and that Christiansen
and Kelly are very, very close, and that they sent me to a psychologist who specializes
in gambling addictions (I have never really even gambled) who cost approximately
another $2,000....Then Ms. Eichman failed to submit my application for admission or
my Request For Reconsideration (sent to her and Christiansen's office on September
15th, 2003, as confirmed by my fax records, in additional to being mailed to them) to
the Nevada Supreme Court. There are numerous other issues that deserve a grievance
there, including whether Christiansen supervised the newly licensed Sanft in any way,
whether a writing wherein I addressed alcoholism was forward to the Bar despite the
express dictate that it not be, whether second Consent Agreement sent to the
Christiasens on 9/27/04 was ever forwarded to the Bar. Additionally, Mike Rowe
wrote very stern letters to me basically telling me not to follow up on things, whereupon
my attorney's and Ms. Eichman failed to follow up on things, essentially tying my hands
in the matter. I intend to supplement this grievance with additional matters soon, but
wish it to begin now.
Sincerely,
Zach Coughlin
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
LITIGATION HOLD NOTICE PLEASE RETAIN ALL EVIDENCE
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 11/12/12 6:52 AM
To: schornsby@nvdetr.org (schornsby@nvdetr.org); patrick@nvbar.org (patrick@nvbar.org);
davidc@nvbar.org (davidc@nvbar.org); skent@skentlaw.com (skent@skentlaw.com);
mike@tahoelawyer.com (mike@tahoelawyer.com); cvellis@bhfs.com (cvellis@bhfs.com);
je@eloreno.com (je@eloreno.com); tsusich@nvdetr.org (tsusich@nvdetr.org); nevtelassn@sbcglobal.net
000210
(nevtelassn@sbcglobal.net)
RELATED TO THE MAILING OF, THE CERTIFIED MAILING NUMBER OF,
AND THE ENVELOPE AND DOCUMENTS RETURNED TO THE STATE BAR OF
NEVADA, ESPECIALY THE ONLY COPY OF THE NOTICE OF INTENT TO
TAKE DEFAULT THAT COUGHLIN EVER RECEIVED UNTIL GETTING A
COPY OF THE FILE ON 11 7 12 FINALLY DELIVERED TO HIS PHYSICAL
ADDRESS AT 1471 E. 9TH, ST. Simply put, the SBN only mailed a certified
version of the Notice of Intent To Take Default. That 10/9/12 mailing was not given
to Coughlin by "Tim" at the Vassar Station due to the postage thereon being
insufficient. However, the copy of the file provided to Coughlin lacks any indication
of what the certified mail track and confirm number is for that Notice of Intent to take
default.
Coughlin requests that the SBN notify the panel of its error, the fact that Coughlin's
Notice of Hearing and DowSoE was not even scanned into the USPS certified mail
until 10/16/12, despite the certificate of mailing indicating 10/12/12, and that that
mailing, with purports to have included the DowSoE, was not even available to
Coughlin until 10/22/12, at the po box Coughlin then utilized (3961
Its more than inaccurate for Mr. King to suggest I have dodged service. See my
email to Reno Carson below...I know I called and left at least once voice mail there,
etc. Plus, despite still being afraid of local law enforcement and others, and just
getting used to my new place (and I have already received threats), against my better
judgment and preferences, on October 23rd, 2012, I alerted the sbn of my new physical
adderss.
The Disciplinary File provided to Coughlin lacks a return of or proof of service of the
Complaint and for the Notice of Intent to take Default. Please proof of service
thereof of proof of attempts at service, including the certified mailing numbers. Give
the primacy of such documents to the due process of these matters, it would seem
holding the 11/14/12 Hearing would be reversible error and imprudent.
"The Rhino" is Johnno Lazetich, http://www.facebook.com/public/Johnno-Lazetich-the-Rhino
000211
we were on the Reno High School basketball team together in 1994-=95... Johnno ran the ball for Kansas State.

Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
9 24 12 10 3 12 10 23 12 physical address service issues ex 0204 rhino.pdf
"From: zachcoughlin@hotmail.com
To: process@renocarson.com
Subject: checking in
Date: Wed, 3 Oct 2012 23:09:50 -0700
Dear Reno Carson,

Hi, I think the Rhino called for me, new phone number below, same as my fax. Please let me
know what I can do for you.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
ZachCoughlin@hotmail.com"
my new address
000212
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 10/23/12 11:29 AM
To: patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org; complaints@nvbar.org
Dear Bar Counsel,
I am still very afraid of retaliation by local law enforcement, and due to my status as a domestic violence victim. In
the past, I have offered to assistn you in getting me served appropriately, but have received no follow up. Further,
the SBN, via Investigator/Clerk Peters and otherwise have made representations that I have relied upon to the extent
that another certified mail SCR 105 Complaint would be sent out shortly after my communications with Peters on
September 11th, 2012 or so where she admitted to receiving in the mail the one she said she sent on August 23rd,
2012. Whatever the SCR 109 implications, the SBN's promises made by Peters are binding in that regard...
Nonetheless, I now feel forced to provide you my address and expose myself to even greater danger, particularly
where, some might say, the SBN has a vested interest in discrediting me now, a motive, a bias, some might say (I take
no position in that regard at the current time). Please note my new phone number as well. While Mr. King has
referred to some upcoming SCR 105 hearing (a "combo hearing" akin to the one's, including a Trial that DDA Young
and his crew of Washoe County Public Defenders have been trying to run on me this year, including attempting to
hold a Trial on May 7th, 2012 in RCR2011-0063341 where the Order finding me competent and remanding
jurisdiction to the Justice Court in CR12-0376 was only signed, entered, and file stamped on May 9th, 2012...A big no-
no under NRS 178.405 and NRS 5.010, and something Keith Loomis, Esq. needs to answer for given his
communications with DDA Young, the WCPD and his "work" on RMC 11 CR 26405 and 12 CR 12420. This could be
your Waterloo, so I hope you will investigate this properly. Especially considering the Order granting Loomis'
withdraw in the criminal trespass case Mr. King just filed an SCR 111 petition in occurred during the pendency of such
an evaluation on May 8th, 2011 (lots going on between May 7th-May 9th, 2012, here!) and the fact that Loomis and
or the RMC ramrodded a Trial setting of June 18th, 2012 on May 8th, 2012 as well, well before Coughlin's
competency was determined...and to the extent King indicates NG12-0204 and NG12-0435 rely on "Orders" entered
or rendered during periods in which NRS 178.405 and NRS 5.010 lawfully prevented their being made...well...that's no
good. Please don't make my address public yet or disseminate it in any way.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, 89512
Tel and Fax 949 667 7402
ZachCoughlin@hotmail.com
000213
"From: zachcoughlin@hotmail.com
To: process@renocarson.com
Subject: checking in
Date: Wed, 3 Oct 2012 23:09:50 -0700
Dear Reno Carson,

Hi, I think the Rhino called for me, new phone number below, same as my fax. Please let me
know what I can do for you.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
ZachCoughlin@hotmail.com"
my physical address
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 10/03/12 9:31 AM
To: patrickk@nvbar.org; laurap@nvbar.org
Dear Bar Counsel King and Court Clerk Peters,

I would prefer not to give my physical address given that I am a victim of domestic violence and
have also been subject to quite a few attacks by law enforcement this year. I will provide it if
you write back demanding it, as I want to cooperate, but could we arrange for me to accept
service by certified mail of anything you wish to serve me? Or I could meet your process server
somewhere?
Zach Coughlin
000214
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin@hotmail.com
citation to legal authority?
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 9/24/12 5:13 PM
To: patrickk@nvbar.org
Mr. King, this is the first I have heard of you wanting a physical address for me. Can you indicate, in writing, when, if
ever the SBN has requested as much and whether it was in writing or verbal? Do you have an legal citation for
your contentions.

Thanks,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin@hotmail.com
000215
Tribal Police not allowed to arrest for misdemeanors FW: Case No.
RCR2011-063341
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/11/12 8:40 AM
To: homerj@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); hazlett-
stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov (robertsp@reno.gov);
kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com (fflaherty@dlpfd.com); patrickk@nvbar.org
(patrickk@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org); wongd@reno.gov (wongd@reno.gov);
ormaasa@reno.gov (ormaasa@reno.gov); bonyr@reno.gov (bonyr@reno.gov); skauc@reno.gov
(skauc@reno.gov); davidc@nvbar.org (davidc@nvbar.org); drakej@reno.gov (drakej@reno.gov);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); skent@skentlaw.com
(skent@skentlaw.com)
How exactly is it that both City Attorney Pamela Roberts, Esq. and Chris Hazlett-
Stevens, Esq. did not violate RPC 3.8 or otherwise prosecute for arrests that were not
lawful
in RMC 11 CR 22176 (Indian Tribe police custodial arrest for misdemeanor? Not
lawful under NRS 171.1255, and even if they were RPD, which they are not, its not like
they charge Coughlin with something other than petty larceny a la NRS 171.136(2)...
Further, can you provide me an indication of how it was lawful for RSIC Officer's
Kameron Crawford or Donnie Braunworth to arrest me on 9/9/11 (and Wal-Mart's
Thomas Frontino made explicitly clear in his testimony at trial on 11/30/11 that neither
he nor any of Wal-Mart's staff in any way effected a custodial arrest of Coughlin on that
date) for a misdemeanor given the following:
NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a person
employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant delivered to him or
her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer or agent
s presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has reasonable cause
for believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
000216
person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
offense, and the officer or agent has reasonable cause to believe that the person arrested is the person so named or
described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed a battery
upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that reservation
or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh pursuit of a
person who is reasonably believed by the officer or agent to have committed a felony within the boundaries of the
reservation or colony or has committed, or attempted to commit, any criminal offense within those boundaries in
the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
(Added to NRS by 1985, 452)
While Ormaas made sure to get judicial notice taken of jurisdiction in 11 TR 26800, it doesn't seem Pamela
Roberts, Esq. did in the Indian Colony Wal-Mart matter...Why is that, Pam? Tribal land? Never determined
if Coughlin had even an ounce of tribal blood? RSIC Officers not entitled to make custodial arrests for
misdemeanors, even, apparently, one's committed right in their presence? So, even if Coughlin did refuse to
provide his driver's license (which has been proven to be a lie, and perjury suborned by Pam Roberts as to the
testimony of Wal-Mart's Frontino and the RSIC Officer's Crawford and Braunworth via police reports, dispatch
recordings (AND PLEASE BE ADIVSED, AS ITS WITHIN THE 2 YEARS, THAT THE CITY OF RENO, THE
SOUTH DISPATCH CENTER FOR ECOMM OR WASHOE COUNTY, OR WHOEVER IT IS THAT
HANDLES THE RSIC DISPATCH CALLS, IT ON A LITIGATION HOLD NOTICE. COUGHLIN
DEMANDS (AND THE DISPATCH/ECOMM SOUTH DISPATCH CENTER WILL GET ITS NRS 174.345
SUBPOENA IN THE MAIL FOR A MISDEMEANOR SOON ENOUGH) THAT THE CUSTODIAN OF
RECORDS MAINTAIN ANY AND ALL RECORDINGS, LOGS, OR OTHER DOCUMENTATION OR
MEDIA IN ANY WAY CONNECTED TO ZACHARY B. COUGHLIN IN ANY WAY WHATSOEVER,
ESPECIALLY WITH REGARD TO THE ARREST OF 9/9/11 AT THE RSIC WAL-MART IN RENO
NEVADA NEAR GLENDALE AND W. 2ND ST.
So, all these arrests by the RSIC police of alleged shoplifters at Wal-Mart...Sling Bla...er, Officer Braunworth
testified that there was lots of them (sounds like Wal-Mart and the RSIC have the whole "find a way to get a
search incident to arrest" thing down part, while avoiding any wrongful arrest liability against the deep pocket
tenant Wal-Mart by avoiding any "shopkeeper's privilege" type citizen's arrests (or trying to use just as much
intimidation and coercion as Frontino and the gang can muster, while seeking to claim not to have effected a
citizen's arrest later in court, given setting the RSIC up to handle those types of lawsuits is arguably a better long
term loss mitigation approach for these long term business partners, Wal-Mart and their partner/landlord the RSIC.
So, please enlighten me. How is it these RSIC Officers are making all these custodial arrests for simple
misdemeanors? And just where in the audio transcript of the Trial (you might want to have RMC house
000217
transcriptionist Pam Longoni finally get around to making a transcript and providing it to Coughlin, as the
handouts the RMC itself provides defendants baring Longoni's and the RMC's "down payment"/transcript hostage
rules are tantamount to extortion in violation of NRS 189.030. Then there is the bit about the RMC and or other
discovering over $700K was "missing", and the attempts to chalk it up to "data entry" errors. Please get that
transcript to me right away, and transcripts of every other hearing I have ever had in the RMC, including the one
on or around February 2nd, 2012 or so where RMC court appointed defender Roberto Puentes successfully argued
for an Order Granting His Withdrawal (five Withdrawals by court appointed counsel of Coughlin, four via an
Order Granting a duly filed Motion (though these guy's Motions wouldn't pass my 7th grade English Class's bi-
weekly writing assignment in my days at Swope Middle School) and Hon. W. Gardner starts to divulge, only after
Coughlin's prompting, bit by bit some of the patent conflicts that should have prevented him from ever ruling on a
single motion in that case 11 CR 26405. With such lack of vigor from the RMC's court appointed defense
counsel, could a class action lawsuit agains them, the RMC, and or the City of Reno be a possibility someday?
Certainly is a nice lil side gig $7K a month those guys get...and all these prosecutions and trips to jail this year
certainly have afforded an opportunity to see the "operation" up close.
Also, you know, as to lots of these arrests, like say the July 3rd, 2012 arrest by RPD Officer Alan Weaver and
now Sargent Brian Dye in 12 CR 12420 (wherein two RMC court appointed counsel have already sought and
obtained Orders Granting Their Withdrawal, one, by Keith Loomis, one by Henry Sotelo, the latter in violation of
the stay in NRS 178.405) the legitimacy of effecting a custodial arrest is completely suspect considering:
ARREST: BY WHOM AND HOW MADE
NRS 171.124 Arrest by peace officer or officer of Drug Enforcement Administration.
1. Except as otherwise provided in subsection 3 and NRS 33.070 and 33.320, a peace officer or an officer of the
Drug Enforcement Administration designated by the Attorney General of the United States for that purpose may
make an arrest in obedience to a warrant delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officers presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officers
presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer has reasonable cause for
believing the person arrested to have committed it.
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor by the
person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person for a public
offense, and the officer has reasonable cause to believe that the person arrested is the person so named or
described.
2. A peace officer or an officer of the Drug Enforcement Administration designated by the Attorney General of the
United States for that purpose may also, at night, without a warrant, arrest any person whom the officer has
reasonable cause for believing to have committed a felony or gross misdemeanor, and is justified in making the
arrest, though it afterward appears that a felony or gross misdemeanor has not been committed.

000218
So back to the Wal-Mart RSIC arrest...the charge sheet doesn't say Coughlin was arrested for anything other than
petty larceny....but:
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at any time of
day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting officer to stop, detain
or arrest the person for another alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person makes an arrest
immediately after the offense is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and the arrest
is made in the manner provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against domestic
violence issued pursuant to NRS 33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of arrest.
So, on exactly what basis was the July 3rd, 2012 arrest made by the RPD? The police report says the arrest was
made for "disturbing the peace", yet the only allegation of anything remotely in the "officer's presence" relates to
the minor traffic citation the City of Reno is clinging to in attempts to mitigate the Sec. 1983 damages here.
However, the RPD admits at least one vehicle was between their's and Coughlin's and Sooudi et al (besides
making an incomprehensibly stupid decision to briefly file an amended complaint for trespassing where even the
RPD was smart enough to realize that was a poor choice given Coughlin still had lease at Northwind, and thus a
pat claim of right defense to any trespass allegation absent something like the manufactured protection order that
RPD Officer Weaver coerced Milan Krebs into obtaining, just like Weaver attempted to get Superior Storage's
Matt Grant to do, shortly after Weaver, in full view of Welch, Sargent Miller, and other RPD Officer's, on
September 21st, 2012, threatened to come up with yet another fraudulent "failure to secure a load on one's vehicle"
arrest of Coughlin). So, even though Weaver and Dye are stuck with their statements in the written reports,
wherein they allege to have arrest Coughlin for "disturbing the peace" only to then tack on "citations" for the two
traffic offenses (and the "proof of insurance" citation, even after Officer Weaver admits to being provided a high
000219
definition pdf picture on a 5 inch smart phone screen with a policy number, etc., only to be amplified by the July
5th, 2012 bail hearing racket tearing (a tennis reference for Jill Drake, Esq.,... for shame, really Jill, really, really
unimpressed).
Please remit a certified check for $450,000 in satisfaction of these torts committed upon Coughlin, under color of
law.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.com
To: homerj@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov;
fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Subject: RE: Case No. RCR2011-063341
Date: Thu, 8 Nov 2012 20:36:27 -0800
couldn't open them, and I don't accept service of anything form you... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
the RMC Rules to the extent there is not difference technologically anymore between
an email and a fax:
Rule 5: Motions/Pleadings by Facsimile
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address,
fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
the receiving party is a governmental agency, an attorney, or with the consent of the receiving party. If service of the
motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
Rule 6: Continuances
000220
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
state the reason therefore and whether or not any continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
becuase he has lied numerous times, on the record about not being served where he has been. Take, for
instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405,
failed to follow RMC Rules in withdrawing from representation:
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
000221
Inbox x
utbound fax report
Voxox noreply@voxox.com Jun 27
to me
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 08:54:28 PM on 2012-06-27.
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox?
Get Voxox: http://download.voxox.com and adjust your Notifications in the Settings/Preferences window. Voxox
by TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
Voxox noreply@voxox.com Jun 27
to me
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 09:16:58 PM on 2012-06-27.
Voxox noreply@voxox.com Jun 28
to me
Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
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000222
000223
Print Close
FW:
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/11/12 7:50 AM
To: skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); patrickk@nvbar.org (patrickk@nvbar.org);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); davidc@nvbar.org (davidc@nvbar.org);
complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
3 attachments
10 31 12 0204 Pre Hearing Motion to Dismiss and for Summary Judgement and Memorandum of
Law (Responsive Pleading).pdf (10.4 MB) , 10 31 12 subpoena on peters and waiver of service.pdf
(541.5 KB) , ex x harris silverman coughlin garin 0204 11 11 12.pdf (9.8 MB)
Nice to see my friend Steve back in the game. And the SBN stipping to a dismissal of its SCR
116 appeal rights...
Please find attached the file stamped versions of the 10 31 12 subpoena duces tecum for which SBN
Laura Peters signed a waiver of service or similar
and the 10 31 12 Pre Hearing Motion to Dismiss Summary Judgment/Memorandum of Law
(Response)

Date: Mon, 13 Aug 2012 11:28:12 -0700


From: silverman@silverman-decaria.com
To: zachcoughlin@hotmail.com
Subject: re: FW: please find enclosed my Petition under SCR 102(4)(d) and SCR111(7)
I think this is waaaaay too complex and detailed. Give them a procedural history and whether there is a final
judgment in the crim case and point out that your temporary suspension is akin to a permanent death of your
practice. Or, if true, say you fucked up and/or were fucked up from lack of drugs and you are sorry and you now
have access to your meds and are ok. I can't think this pleading is going to help you much...it is too long,
repetitive and does not seem to deal with why the temp suspension is sijmply wrong or harsh. If you can't make
your case in 3-5 pp, you can't make your case in 35. You do seem to be a good lawyer, however. At bottom, Steve
Harris took hundreds of thousands of dollars and had no temp suspension; you stole a candy bar (at worst). WTF.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com

000224
Emergency Ex Parte Motion NG12-0204, 0434,0435
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/11/12 4:13 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
(nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org);
(fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org);
(complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org);
(je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com (cvellis@bhfs.com)
from:
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
tel and fax 949 667 7402
I do not consent to service or notice of anything electronically in this proceeding, but I do appreciate being
copied on such things via email and fax)
Emergency Ex Parte Motion NG12-0204, 0434,0435
please find attached 88 page Emergency Ex Parte Motion to Dismiss or Quash or Otherwise Challenge
Sufficiency of Service
and of Process, of Complaint and Notice of Intent to Take Default and DoWSoE; and Preserving for Appeal
Objection to All other Due Process Violations; and UNDER PROTEST...RESPONSE TO COMPLAINT
submitted for filing with the State Bar of Nevada on November 9th, 2012
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
11 9 12 response under protest 0204 and various motions and notices 0204 etc.pdf

RE: Case No. RCR2011-063341
000225
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 11/08/12 8:36 PM
To: HomerJ@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); hazlett-
stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov (robertsp@reno.gov);
kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com (fflaherty@dlpfd.com); patrickk@nvbar.org
(patrickk@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org)
couldn't open them, and I don't accept service of anything form you... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
the RMC Rules to the extent there is not difference technologically anymore between
an email and a fax:
Rule 5: Motions/Pleadings by Facsimile
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address,
fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
the receiving party is a governmental agency, an attorney, or with the consent of the receiving party. If service of the
motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
state the reason therefore and whether or not any continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
000226
becuase he has lied numerous times, on the record about not being served where he has been. Take, for
instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405,
failed to follow RMC Rules in withdrawing from representation:
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?

Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Inbox x
utbound fax report
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Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 09:16:58 PM on 2012-06-27.
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Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
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Hi zachcoughlin,
Your Fax was successfully sent to 14021bda-178b-448f-afcc-1af150604a18general693298 ( 17753344226).
Your Fax was delivered @ 09:04:24 AM on 2012-06-28.
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to me
Hi zachcoughlin,
Your Fax was successfully sent to 3ad3f15b-3a33-4863-a6cd-7934ec8f8b32general693298 ( 17753343859).
Your Fax was delivered @ 09:05:24 AM on 2012-06-28.
Date: Thu, 8 Nov 2012 14:48:18 -0800
From: HomerJ@reno.gov
To: zachcoughlin@hotmail.com
Subject: Case No. RCR2011-063341
Please see attached documents from Creig Skau, Deputy City Attorney:

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

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

Thank you.

Jeannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
000228
(775)334-2050
(775)334-2420/fax
homerj@reno.gov

ATTORNEY-CLIENT PRIVILEGE

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

"investigator" Peters putting the blindfold on herselfFW:


Undeliverable:
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/06/12 8:25 PM
To: complaints@nvbar.org (complaints@nvbar.org); davidc@nvbar.org (davidc@nvbar.org);
patrickk@nvbar.org (patrickk@nvbar.org)
This is ridiculous that Clerk of Court/Investigator Peters has admitted to adding me to her blocked senders list.
Why doesn't she add herself to the "blocked paycheck" list? Please forward this on to her. Plus, she added
me to that least WAY too late to excuse the lack of investigation and due diligence her, considering all the
materials I can proved she and the SBN received.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: postmaster@nvbar.org
To: zachcoughlin@hotmail.com
Date: Tue, 6 Nov 2012 19:45:32 -0800
Subject: Undeliverable:
Delivery has failed to these recipients or groups:
laurap@nvbar.org (laurap@nvbar.org)
This message was rejected by the recipient e-mail system. Please check the recipient's e-mail address and try resending this
message, or contact the recipient directly.
000229
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From: Zach Coughlin <zachcoughlin@hotmail.com>
To: "laurap@nvbar.org" <laurap@nvbar.org>, "patrickk@nvbar.org"
<patrickk@nvbar.org>
Subject:
Date: Tue, 6 Nov 2012 19:44:50 -0800
Importance: Normal
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x-doc: x-doc
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x-doc-filename2: supplemental to Coughlin's designation fo witnesses and
summary and production of evidence and notice of objection 0204 CORRECTED
CAPTION.pdf
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x-doc-filename3: 0204 notice of non service of purported notice of intent to
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--Forwarded Message Attachment--
From: zachcoughlin@hotmail.com
To: laurap@nvbar.org; patrickk@nvbar.org
Subject:
Date: Tue, 6 Nov 2012 19:44:50 -0800
Dear Bar Counsel King and Clerk of Court/Investigator Peters and Chairman
000230
Echeverria,
There is a big problem with respect to when the State Bar of Nevada actually sent the
Respondent, Coughlin the Designation of Witnesses and Summary of Evidence
(DoWSoE) (and Coughlin has yet to received a file stamped version of that DowSoE.
Further, Coughlin has never received any Notice of Intent to Take Default
(NoITD) from the SBN. As such, the notice and other procedural safeguards
attendant to the Hearing set for 11/14/12 are severely deficient. This is just the 13th
chime of the clock, and I have had as many "get right with Jesus" (or any other number
of nondenominational Saviors) talks with Bar Counsel King and Clerk Peters as anyone
deserves. Add to that this new thing where first Bar Counsel says, as required by
SCR 105(2)(c)'s:
"The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the attorney, and the names of the
witnesses bar counsel intends to call for other than impeachment, together with a brief statement of the facts to which each will testify, all of
which may be inspected up to 3 days prior to the hearing. "
See, it doesn't say, in SCR 105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out from under
Respondent's feet suddenly and claim to be "copying" only certain things, and refusing to allow inspection of others (even where the SCR
105 Complaint specifically invokes such non copied materials), and then cut short the time up to which Respondnet may inspect. Let's say
Bar Counsel did copy and provide those materials on October 31st, 2012. Okay, well SCR 105 allows Coughlin to go to the SBN and
inspect "up to 3 days prior"...so Coughlin may go to the SBN tomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is
a violation of SCR 105, right? Please advise in writing.
Please see Supreme Court Rule (SCR) 119(2), which holds that Bar Counsel and the
Panel's failure to follow these rules "may result in contempt of the appropriate disciplinary board or
hearing panel having jurisdiction..." Please note there has already been a Motion for Order to Show Cause
filed against Bar Counsel and or the Board or Panel in 60838 and 61426. Additionally, please be aware that
SCR 119(3) holds: 3. Other rules of procedure. Except as otherwise provided in these rules, the
Nevada Rules of Civil Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
In that regard, the decision on the motion to bifurcate dispalyed a clear lack of regard for procedural safeguards
in that it was issued prior to the expiration of five judicials days from the constructive service upon Coughlin,
under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged mailing. The term "alleged" is used do to a
recent visit to the SBN on October 31st, 2012 at around 4:45 pm when I saw in the SBN outgoing mail box two
certified letter to myself that Clerk of Court Peters admitted would not be picked up that day by the regular
postal carrier to the SBN, despite what they certificates of mailing therein might state. It is particularly
troubling to me that the Notice of Hearing did not have the Designation of Witnesses and Summary of Evidence
included with it, and therefore, my right to have the DoWSoE 30 days prior to the hearing, and to receive it
from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me up with less than
the required notice (and jam the Panel up to for the matter, though there has been little indication so far that
000231
the Panel cares or has much an intent to do anything more than let Bar Counsel King lead them down the same
primrose path that Clerk Peters can tell you about...). It is a path that Richard G. Hill, Esq. often takes people
down too...
I would be very interest to know who was on the screening Panel...which Bar Counsel King promised to tell me,
though, like most all of Pat's promises, he has broken...could it have been David Hamilton, Esq.? Richard G.
Hill's best friend, David Hamilton? Was it WCDA Mary Kandaras? The one included in the correspondences
about my smartphone and micro sd data card being searched and or seized illegally and or outside any lawful
search incident to arrest given the hand of an booking it into Coughlin's property on 2/27/12, only for the RMC
Marshals to return on 2/28/12 (at the soonest) to take it back to Judge Nash Holmes? What's next, Judges
showing up in our bedrooms reading our diaries out of the blue?
It is my understanding that Chief Bar Counsel David Clark gave me permission to issue subpoenas and granted
me indigent status as to witness fees...if this is not within the power of Bar Counsel or is otherwise against the
Orders of the Panel or Board, please let me know very soon. Please See SCR 110 and in that regard, I am
requesting a prehearing conference for the purpose of gathering admissions from Bar Counsel and narrowing
the issues, and in that regard, I recently sent Bar Counsel and at least Panel Chair Echeverria materials related
to what I see as a frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John
Gessin.

Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons that I have voiced to
President of the State Bar of Nevada Flaherty, in that light:
Rule120. Costs; bar counsel conflict or disqualification
2.If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of governors shall
appoint an attorney, ad hoc, to act in the place of bar counsel.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
11 6 12 0202 Objection and Notice.pdf
supplemental to Coughlin's designation fo witnesses and summary and production of evidence and notice of objection
0204 CORRECTED CAPTION.pdf
0204 notice of non service of purported notice of intent to take default.pdf
0204 SUBPOENA WITH DISCLAIMER.pdf
0204 subpoena all.pdf
000232
Download all

(No Subject)
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/06/12 7:44 PM
To: laurap@nvbar.org (laurap@nvbar.org); patrickk@nvbar.org (patrickk@nvbar.org)
Dear Bar Counsel King and Clerk of Court/Investigator Peters and Chairman
Echeverria,
There is a big problem with respect to when the State Bar of Nevada actually sent the
Respondent, Coughlin the Designation of Witnesses and Summary of Evidence
(DoWSoE) (and Coughlin has yet to received a file stamped version of that DowSoE.
Further, Coughlin has never received any Notice of Intent to Take Default
(NoITD) from the SBN. As such, the notice and other procedural safeguards
attendant to the Hearing set for 11/14/12 are severely deficient. This is just the 13th
chime of the clock, and I have had as many "get right with Jesus" (or any other number
of nondenominational Saviors) talks with Bar Counsel King and Clerk Peters as anyone
deserves. Add to that this new thing where first Bar Counsel says, as required by
SCR 105(2)(c)'s:
"The notice shall be accompanied by a summary prepared by bar counsel of the evidence against the attorney, and the names of the
witnesses bar counsel intends to call for other than impeachment, together with a brief statement of the facts to which each will testify, all of
which may be inspected up to 3 days prior to the hearing. "
See, it doesn't say, in SCR 105, Bar Counsel can puff on about the Respondent's right to inspect, then pull the carpet out from under
Respondent's feet suddenly and claim to be "copying" only certain things, and refusing to allow inspection of others (even where the SCR
105 Complaint specifically invokes such non copied materials), and then cut short the time up to which Respondnet may inspect. Let's say
Bar Counsel did copy and provide those materials on October 31st, 2012. Okay, well SCR 105 allows Coughlin to go to the SBN and
inspect "up to 3 days prior"...so Coughlin may go to the SBN tomorrow, October 7th, 2012 and inspect, no? And any refusal by the SBN is
a violation of SCR 105, right? Please advise in writing.
Please see Supreme Court Rule (SCR) 119(2), which holds that Bar Counsel and the
Panel's failure to follow these rules "may result in contempt of the appropriate disciplinary board or
hearing panel having jurisdiction..." Please note there has already been a Motion for Order to Show Cause
filed against Bar Counsel and or the Board or Panel in 60838 and 61426. Additionally, please be aware that
SCR 119(3) holds: 3. Other rules of procedure. Except as otherwise provided in these rules, the
000233
Nevada Rules of Civil Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
In that regard, the decision on the motion to bifurcate dispalyed a clear lack of regard for procedural safeguards
in that it was issued prior to the expiration of five judicials days from the constructive service upon Coughlin,
under NRCP 6(e) of Bar Counsels October 24th, 2012 alleged mailing. The term "alleged" is used do to a
recent visit to the SBN on October 31st, 2012 at around 4:45 pm when I saw in the SBN outgoing mail box two
certified letter to myself that Clerk of Court Peters admitted would not be picked up that day by the regular
postal carrier to the SBN, despite what they certificates of mailing therein might state. It is particularly
troubling to me that the Notice of Hearing did not have the Designation of Witnesses and Summary of Evidence
included with it, and therefore, my right to have the DoWSoE 30 days prior to the hearing, and to receive it
from the Panel, along with the Notice of Hearing, rather than have Bar Counsel try to jam me up with less than
the required notice (and jam the Panel up to for the matter, though there has been little indication so far that
the Panel cares or has much an intent to do anything more than let Bar Counsel King lead them down the same
primrose path that Clerk Peters can tell you about...). It is a path that Richard G. Hill, Esq. often takes people
down too...
I would be very interest to know who was on the screening Panel...which Bar Counsel King promised to tell me,
though, like most all of Pat's promises, he has broken...could it have been David Hamilton, Esq.? Richard G.
Hill's best friend, David Hamilton? Was it WCDA Mary Kandaras? The one included in the correspondences
about my smartphone and micro sd data card being searched and or seized illegally and or outside any lawful
search incident to arrest given the hand of an booking it into Coughlin's property on 2/27/12, only for the RMC
Marshals to return on 2/28/12 (at the soonest) to take it back to Judge Nash Holmes? What's next, Judges
showing up in our bedrooms reading our diaries out of the blue?
It is my understanding that Chief Bar Counsel David Clark gave me permission to issue subpoenas and granted
me indigent status as to witness fees...if this is not within the power of Bar Counsel or is otherwise against the
Orders of the Panel or Board, please let me know very soon. Please See SCR 110 and in that regard, I am
requesting a prehearing conference for the purpose of gathering admissions from Bar Counsel and narrowing
the issues, and in that regard, I recently sent Bar Counsel and at least Panel Chair Echeverria materials related
to what I see as a frivilous issue, the ghostwriting allegations vis a vis Board Member Shelly O'Neill's client, John
Gessin.

Further, I believe there is a conflict here with Bar Counsel King, for a variety of reasons that I have voiced to
President of the State Bar of Nevada Flaherty, in that light:
Rule120. Costs; bar counsel conflict or disqualification
2.If, for any reason, bar counsel is disqualified or has a conflict of interest, the board of governors shall
appoint an attorney, ad hoc, to act in the place of bar counsel.
Zach Coughlin
1471 E. 9th St.
000234
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has 5 files to share with you on SkyDrive. To view them, click the links below.
11 6 12 0202 Objection and Notice.pdf
supplemental to Coughlin's designation fo witnesses and summary and production of evidence and notice of objection
0204 CORRECTED CAPTION.pdf
0204 notice of non service of purported notice of intent to take default.pdf
0204 SUBPOENA WITH DISCLAIMER.pdf
0204 subpoena all.pdf
Download all

(No Subject)
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/06/12 9:46 AM
To: (skent@skentlaw.com) (skent@skentlaw.com); (mike@tahoelawyer.com) (mike@tahoelawyer.com);
(nevtelassn@sbcglobal.net) (nevtelassn@sbcglobal.net); (patrickk@nvbar.org) (patrickk@nvbar.org);
(fflaherty@dlpfd.com) (fflaherty@dlpfd.com); (davidc@nvbar.org) (davidc@nvbar.org);
(complaints@nvbar.org) (complaints@nvbar.org); (tsusich@nvdetr.org) (tsusich@nvdetr.org);
(je@eloreno.com) (je@eloreno.com); (cvellis@bhfs.com (cvellis@bhfs.com)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Zach has a file to share with you on SkyDrive. To view it, click the link below.
11 5 12 SUPPLMENTSAL TO 0204.pdf

000235
Print Close
Zach Coughlin has shared a folder with you
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/06/12 9:46 AM
To: patrickk@nvbar.org
Exhibit 1 to 11 3 12
Supplement to
Coughlin's List of
View photos
You are invited to view Zach's album. This album has
147 files.
031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 1 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 2 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 2 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h17m06s.wmv
from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 10h22m12s.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
Share your files with
000236
Zach Coughlin has shared a folder with you
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/06/12 9:46 AM
To: davidc@nvbar.org
Exhibit 1 to 11 3 12
Supplement to
Coughlin's List of
View photos
You are invited to view Zach's album. This album has
147 files.
031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 1 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 2 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 2 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h17m06s.wmv
from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 10h22m12s.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
Share your files with
Zach Coughlin has shared a folder with you
000237
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/06/12 9:46 AM
To: complaints@nvbar.org
Exhibit 1 to 11 3 12
Supplement to
Coughlin's List of
View photos
You are invited to view Zach's album. This album has
147 files.
031209 part 2 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
031209 part 1 of 2 dv08-01168 54844 01955 01896 60302 60317 ng12-0435 26405
0223121 PTTHOA 1 of 2 RJC Rev2012-000374.asf
0223121 PTTHOA 2 of 2 RJC rev2012-000374.asf
122011 rjc rev2011-001708 part 1 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 1 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 2 seg 2 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
122011 rjc rev2011-001708 part 2 seg 1 of 2 hearing on motion to contest personal property lien merliss v coughlin1.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h24m39s.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 08h17m06s.wmv
from blse 6 29 12 15 wcso machen and northwind moment of arrest and ncs.mp4
071612 rjc rcr2011-063341 rcr2012-065630 rcr2012-067980 dogan bosler leslie goodnight young rpd rmc wcso Trial continued coughlin.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
031709 dv08-01168 54844 cv11-01955 cv11-01896 60302 60317 Joshi divorce trial Judge L Gardner coughlin mandamus wls 10h22m12s.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
Share your files with
FW: NEF: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB): Subpoena Duces
Tecum: CV10-01341
000238
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 11/05/12 3:31 AM
To: patrickk@nvbar.org (patrickk@nvbar.org); je@eloreno.com (je@eloreno.com)
5 attachments
12 8 11 email to eflex regarding Gessin's efiler status and withdrawals 0204.htm (12.7 KB) , 11 25 11 email to John Gessin
jd.gman@yahoo.com explaining ghostwriting taboos and Notice of Appearance 0204.htm (12.7 KB) , 9 6 11 11-05078 Gessin 0204
26405 1708 03628 proof that Coughlin was commercial tenant 40.253 prohibits summary evict no cause.pdf (39.5 KB) , 9 6 11 11-
05078 NVB Gessin Coughlin not ghostwriting 0204.pdf (558.4 KB) , 9 7 11 Adversary Proceeding 11-05077-btb rissone gessin
0204.pdf (36.2 KB)
Dear Mr. King and Chairman Echeverria,
Is this ghostwriting allegation by Hill in 0204 still an issue? I am pretty sure Gessin paid for his own
electronic filing account at about the time we parted ways...and that Hill, Baker, and I were all listed as his
attorney at that time....Shelly O'Neill, Esq. (of the NNDB) is now or recently was Gessin's attorney in various
matters...Can we narrow down what is at issue in the hearing? I didn't do any ghostwriting and in fact kind of
went out of my way to prevent anything of the sort...I think I was halfway concerned about the appearance of
ghostwriting when I sent Gessin the 11/25/11 email and filing Notices of Appearances were, to some extent (not
soley) done to guard against anything like that... In the eflex notification below...I did not filed such a Subpoena
Duces Tecum and I am almost sure I didn't have anything to do with a subpoena and Gessin during the entire
time I worked on his matters. I believe I filed a few documents in the NVB on an "unbundled services" type
of arrangement, from which I learned that it is not really possible to do so, to the extent that one will still need
get an Order granting their Withdrawal as "counsel of record", even if the attorney notates "unbundled services"
on the information above the caption....
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Date: Fri, 9 Dec 2011 10:22:05 -0800
From: eflex@washoecourts.us
To: zachcoughlin@hotmail.com
Subject: NEF: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB): Subpoena Duces Tecum: CV10-01341
****** IMPORTANT NOTICE - READ THIS INFORMATION *****
PROOF OF SERVICE OF ELECTRONIC FILING
A filing has been submitted to the court RE: CV10-01341
Judge: PATRICK FLANAGAN
Official File Stamp: 12-09-2011:09:26:55
Clerk Accepted: 12-09-2011:10:17:49
Court: Second Judicial District Court - State of Nevada
Case Title: STACEY RISSONE VS. JOHN DAVID GESSIN (ARB)
Document(s) Submitted: Subpoena Duces Tecum
000239
- **Continuation
Filed By: JOHN GESSIN
You may review this filing by clicking on the following link to take you to your cases.
This notice was automatically generated by the courts auto-notification system.
If service is not required for this document (e.g., Minutes), please disregard the below language.
The following people were served electronically:
RICHARD HILL, ESQ. for JOHN GESSIN
ZACHARY COUGHLIN, ESQ. for JOHN GESSIN
CASEY BAKER, ESQ. for JOHN GESSIN
The following people have not been served electronically and must be served by traditional means (see Nevada electronic filing rules):
GLADE HALL, ESQ.
--Forwarded Message Attachment--
Print Close
John Gessin wishing to be able to file without rejections
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 12/08/11 3:08 PM
To: eflex@washoecourts.us; filing@washoecourts.us; cfranden@mail.co.washoe.nv.us; courttech@washoecourts.us
3 attachments
alternatively errate withdraw etc CV09-00710 - ALLISON TAITANO VS JOHN GESSIN NOTICE OF APPEARANCE.pdf (81.3 KB) , alternatively
errate withdraw etc ARB09-00710 - ALLISON TAITANO VS JOHN GESSIN NOTICE OF APPEARANCE.pdf (81.3 KB) , ERRATA TO NOTICE OF
APPEARANCE OR ALTERNATIVELY MTN TO WITHDRAWCV10-01341 - STACEY RISSONE VS. JOHN DAVID GESSIN (ARB) notice of
appearance hill baker.pdf (81.0 KB)
I am writing (I just filed the attached motions as well) due to exigent circumstances. Basically, John
Gessin (jd.gman@yahoo.com 775 376 3650), who is apparently an efiler pro se, wishes to be able to file things, but
is being told my attorney of record status is preventing that. In order to attempt to avoid prejudicing Mr.
Gessin's interests, I am writing to ask that you allow him to file what he wants, on his own behalf right
away, given that time may be of the essence.

Sincerely,
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you
are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney
work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this
message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
--Forwarded Message Attachment--
000240
Print Close
NOTICES OF APPEARANCES
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Fri 11/25/11 12:24 AM
To: jd.gman@yahoo.com
4 attachments
CV10-01341 RISSONE ARB BAKER HILL NOTICE OF APPEARANCE.pdf (60.4 KB) , CV09-00710 TAITANO MOORE STP NOTICE OF
APPEARANCE.pdf (60.6 KB) , CV10-03675 STACEY RISSONE ET VS JOHN DAVID GESSIN ET (D3) NOTICE OF APPEARANCE.pdf (60.4 KB) ,
ARB09-00710 taitano moore arb notice of appearance.pdf (61.1 KB)
John, Let me know whats going on, i got a new temporary address and phone number. theres is some
ghostwriting taboos, so...if you want me to withdraw thats fine, whatever, its all good
Zach Coughlin, Esq.
817 N. Virginia st. #2
Reno, NV 89501
775 229 6737
Licensed in Nevada
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you
are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney
work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this
message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
RE: convicting attorney of summary criminal contempt during pendency of Order for
Competency Evaluation
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/04/12 12:34 AM
To: togninim@reno.gov (togninim@reno.gov); joey.hastings@washoecounty.us (joey.hastings@washoecounty.us);
joey.orduna@washoecounty.us (joey.orduna@washoecounty.us); david.hardy@washoecounty.us (david.hardy@washoecounty.us);
patrickk@nvbar.org (patrickk@nvbar.org); skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org); tsusich@nvdetr.org (tsusich@nvdetr.org);
je@eloreno.com (je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com)
Dear SBN,
I have set my email to add to my blocked sender list any "bounce back" or error messages that might be sent me
in response to your antiquated email system having any sort of file size limitations resulting in a rejection of a
transmission that pretty much an old free gmail or hotmail account could accept. So, your on notice of that
and your apparent purposeful Luddite stance (reminds me of "Investigator" Peters mentioning how reluctant she
is to investigate anything) is not something I will be receiving any notice of so you might want to adjust your
email system accordingly.
I have an idea, how about you implement a "salary size limitation" on your paychecks until you cease pursuing
outdated and dubious plausible deniability constructs?
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
000241
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.com
To: togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org;
je@eloreno.com; cvellis@bhfs.com
Subject: convicting attorney of summary criminal contempt during pendency of Order for Competency Evaluation
Date: Sat, 3 Nov 2012 03:13:58 -0700
togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org;
tsusich@nvdetr.org; je@eloreno.com; cvellis@bhfs.com
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
RE: Mr. King's assertion in his 3/16/12 letter
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 11/04/12 12:33 AM
To: patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); complaints@nvbar.org (complaints@nvbar.org)
Dear SBN,
I have set my email to add to my blocked sender list any "bounce back" or error messages that might be sent me
in response to your antiquated email system having any sort of file size limitations resulting in a rejection of a
transmission that pretty much an old free gmail or hotmail account could accept. So, your on notice of that
and your apparent purposeful Luddite stance (reminds me of "Investigator" Peters mentioning how reluctant she
is to investigate anything) is not something I will be receiving any notice of so you might want to adjust your
email system accordingly.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.com
To: togninim@reno.gov; joey.hastings@washoecounty.us; joey.orduna@washoecounty.us; david.hardy@washoecounty.us; patrickk@nvbar.org;
skent@skentlaw.com; mike@tahoelawyer.com; nevtelassn@sbcglobal.net; fflaherty@dlpfd.com; davidc@nvbar.org; complaints@nvbar.org; tsusich@nvdetr.org;
je@eloreno.com; cvellis@bhfs.com
Subject: FW: Mr. King's assertion in his 3/16/12 letter
Date: Sat, 3 Nov 2012 03:00:11 -0700
Dear Judge Hardy, Chairman Susich, Clerk of Court Orduna Hastings, Bar Counsel, and Ms. Tognini, and Members of the Panel,

It is plain from my interactions with Patrick King that the irony of Richard G. Hill, Esq's allegations of my "ghostwriting" are
richest when considering the apparent "ghost-grievancing" going on here, especially with respect to the genesis of NG12-0435,
the grievance consisting of Family Court Judge Linda Gardner's April 2009 Order sanctioning a domestic violence attorney
$1,000, personally, where failed to follow Judge Linda Gardner's orders to seek to intimidate his battered spouse immigrant client
into accepting the marital settlement agreement offer of one John Springgate, Esq. (a chimera of sorts where Mr. Springgate's
client would agree to be responsilbe for a collection of third party credit card debt for which he was the sole signatory and for
which even under and extremely unlikely "doctrine of the neccessaires, assuing my client lost on a "waste of marital assets",
approach, my client, Ms. Joshi, would be very unlikely to ever face judgment or execution in connection with such third party
credits card debts. I failed to cave to Judge Linda Gardner's bullying demands, and even where she yelled at me and my client
000242
in the impromptu "settlement conference" she decided to hold 10 minutes before the Trial (Judge Linda Gardner yelled at me to
"shut up" in front of my client, then proceeded to tell Ms. Joshi "don't listen to your attorney!" in an angry, hostile, and
belligerent tone), and instead cited to an ALR article that presents the position I took as the majority viewpoint in American
jurisprudence with respect to the duty of a domestic obligation not being permissibly set off with a mere debt, particularly a third
party unsecured credit card debt, such as those for which Mr. Joshi was the sole signatory. Apparently Judge Gardner agreed
with John Springgate's whining about how he "needed to be able to know how much to charge for his time" or something along
those lines (Mr. Springgate indicated that Coughlin's failing to immediately accept Springgate's settlement offer was screwing up
Springgate's whole profit margin, and therefore contrary to the orderly administration of justice, or something along those lines,
at which point Springgate moved for sanctions (despite not having served a 21 day safe harbor filing ready NRCP 11 motion),
which, in John's words was tantamount to "sending a shot across your bow", a bloodsport sort of analogy one might expect from
a semi-professional fencer like Mr. Springgate. I was fired from Washoe Legal Services and told by its Executive Director
that the decision was based solely on Judge Linda Gardner's Order....which was odd given she and Master Edmondson and at
least one other judge had given Elcano positive reviews of my work less than two months prior to that. Elcano, though, did,
at the time of reporting those positive reviews mention that he goes "way back" with Linda Gardner, and that "she owes" him
because "he did her a big favor a long time ago", etc., etc.

Anyways, Bar Counsel King has recently indicated that he was completely unaware that Linda Gardner is the sister of the RMC
Judge William Gardner who refused to recuse himself from the criminal trespass conviction I sustained incident to a custodial
arrest at my former home law office, wherein the opposing counsel Richard G. Hill, Esq., has been caught lying on tape
regarding whether any warning was given to me to leave, and whether the RPD identified themselves as law enforcement and
issued a lawful order to leave the premises prior to the landlord kicking down a door to a "basement" that was, according to Hill's
associate, not even a part of the property (or included in the part of the property contained within any exterior doors to the
premises.

Despite the statements of RMC Judge Gardner in the audio cds that King himself finally admitted to me to possessing and
receiving from RMC Judge Nash Holmes (after several instances of King lying about his willingness to allowing me to review
the materials Judge Nash Holmes and others slipped to the SBN, King finally was forced to turn over at least a few of those
items. Included amongst them were the hearings before Judge William Gardner on 4/10/12 and 5/8/12 wherein RMC Judge
William Gardner admits that his sister is none other than Family Court Judge Linda Gardner, and that his sister passed him her
April 2009 Order sanctioning Coughlin (which Coughlin filed a Petition for Writ of Mandamus challenging in 54844,):
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=22746

Washoe Legal Services fired Coughlin, citing Judge Linda Gardner's Order sanctioning Coughlin as the sole reason for its doign
so. Couglin sued WLS for wrongful termination, and Judge Elliot dismissed Coughlin's lawsuit without reaching the merits of
the Complaint, but then decided to sanction Coughlin for his lawsuit allegedly lacking "merit" anyways...go figure. Judge
Elliot also incarcerated Coughlin from April 19th, 2012-April 26th, 2012 based upon some fraudulent letter by Lake's Crossing,
and some Motion for Revocation of Bail made by DDA Zach Young at a time when NRS 178.405 forbid his making any motions
given that all proceedings must be stayed during the pendency of an Order for Competency Evaluation. Amazingly, in her
3/16/12 letter to the SBN, Judge Nash Holmes is still mentioning how she and the RMC are furiosly trying to set for Trial the
case stemming from teh custodial "jaywalking" arrest of Coughlin on January 12th, 2012 incidnet to the lies by Richard G. Hill,
Esq. to the RPD on that date. It is curious that that matter 11 CR 00696 was all of the sudden transferred to Judge Nash
Holmes on February 27th, 2012, the same day Judge Nash Holmes was purportedly made aware of the 2/27/12 Order for
Competency Evaluation of Coughlin in RCR2011-063341 (relative, at the very least, to the communications between Tognini and
the WCPD, at the very least). Additionally, Second Judicial District Chief Appeals Clerk denied Coughlin's 2/27/12 filing of
a Motion for Extension of Time to effectuate service in the wrongful termination lawsuit by Coughlin against Elcano (whom
Judge Linda Garnder "owes a big favor", according to Elcano) in CV11-01955 (before Judge Elliot).

Further, to the extent Judge Elliot's remanding Coughlin into custody to coerce his consent to divulging extremely private
medical information is somehow a contempt Order, then the "letter" or "evaluation under seal" of 4/18/12 by Lakes Crossing Dr.
Bill Davis and Dr. Sally Farmer must be in the form of an affidavit. It was not. Further, Coughlin called Dr. Davis from the
booking room at the jail and Dr. Davis attempted to weasel out of the consequences of his professional misconduct, done under
color of law, by alleging that he "didn't write the 4/18/12 letter filed with the Court" but merely signed it and was not responsible
for it being filed with the court. To the extent the assertions in that 4/18/12 letter are outright lies (they are...the letter
indicates Coughlin outright refused to provide basic medical information, which is not true, Coughlin indicated he would "need
to check his records" in response to one initial question, and then mentioned that some professional, particularly physicians, face
an inability to obtain malpractice insurance if word gets out that they take anti-depressants. Somehow Dr. Davis and Dr.
Farmer interpreted such a statement to allow themselves to file a letter with the Court alleging that Coughlin "threatened one of
the evaluators with legal action". No wonder Lake's Crossing insists on doing a Terry Stop style "pat down" search on each
and everyone forced to go there by the Courts to get a Competency Evaluation (the RJC and WCPD have it set up so that one
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must utilize the services of Lake's Crossing for any such evaluation) and maintain a strick ban on any sort of smart phones or
cellular phones within their evaluation rooms (how difficult it would be for Dr. Davis and Dr. Farmer to lie with seeming
impunity, as they did in their 4/18/12 "evaluation" filed with the Court in CR12-0376, should their subjects be readily able to
reveal the dishonesty of these evaluators via some recording impeachign their credibility. To the extent Judge Elliot found
Coughlin in contempt of court (which he apparently did in response to Coughlin inquiring into the scope and extent of such a
Competency Evaluation rather than submitting to a blank check inquest into his mental health and medical records incident to a
retaliatory Motion for Competency Evaluation on 2/27/12 by a public defender upset that Coughlin had criticized his failing to
show up to a court date even after that attorney, Biray Dogan had filed a Notice of Appearance and met with the client to discuss
the case RCR2012-065630, for over an hour and a half just one week previous to that missed court appearance, and where DDA
Young was clearly retaliating against Coughlin for Coughlin filing a Motion for Sanctions against Young just days previous to
that in a different case.

Regardkess. Marilyn Tognini is now being listed as a witness Coughlin intends to call at his November 14th, 2012 NNDB
hearing at the State Bar of Nevada Offices at 9 am, and any other person whom Judge Nash Holmes may be referring to in her
attached grievance against Coughlin (wherein she manages to allude to some hearsay about Coughlin living in his car despite the
fact that Coughlin was clearly still living at 1422 E. 9th St. at the time Judge Nash Holmes letter to the SBN was written,
3/14/12, even where Judge Nash Holmes feigns an inability to readily make contact with Coughlin, depsite neither she nor the
RMC calling, emailing or faxing Coughlin, or managing to mail the 2/28/12 Order to the address all other RMC Departments
then had for Coughlin. Regardless, that 3/14/12 grievance goes on to demonstrate Judge Nash Holmes profound lack of respect
for or knowledge of the dictates of NRS 178.405, or the legal principles, in general, related to refraining from proceeding with
prosecutions where the competency of the accused is in doubt in the mind of the trier of fact. Further, the SBN's Bar Counsel
Patrick King (whom, again, managed to just in the last couple weeks indicate that he was unaware that Judge William Gardner
and Judge Linda Gardner are brother and sister, or even related, despite King receiving from the RMC's Judge Nash Holmes a
box of materials that included multiple hearings in the criminal trespass proseuction of Coughlin that Judge William Gardner
(then RMC Administrative Judge, whom admitted to "at least one meeting" wherein he and the other RMC Judges discussed
Coughlin, along with Chief Marshal Roper, only for Judge Gardner to then attempt to say with a straight face that he "was not
sure whether he was" aware of this or that, or had any knowledge of the grievance Judge Nash Holmes filed against Coughlin
with the SBN (despite that 3/14/12 letter to the SBN by Judge Nash Holmes expressly purporting to be written on behalf of
herself and ALL the other RMC Judges, whose "full cooperation" she assures she can deliver to the SBN in seeking to discredit
Coughlin and in so doing assist the City of Reno in addressing the multiple wrongful arrests of Coughlin in the preceding
months.

Regardless, the communications between the Washoe County Public Defender and the RMC, including Ms. Tongini and Judge
Nash Holmes, and what exactly Judge William Gardner was made aware of, and what he passed from his sister, Judge Linda
Gardner, on to Judge Nash Holmes, and what Judge Nash Holmes passed onto Bar Counsel King is now of material relevance,
and brings into play the issue of the level of candor with opposing counsel King exhibits in his 4/19/12 correspondenc with
Coughlin when he purports to only have recieved Judge Linda Gardner's April 2009 Order for Sanctions on 3/15/12 (and that
"5" in the "15" looks shaky, Pat), wherin King wrote: "It was sent to me by the clerk of the court at my request, pursuant to my
investigation." Which Clerk of Court, Mr. King? Clerk of Court Orduna Hastings? Then there is Judge Elliot dismissing Coughlin's
lawsuit against Washoe Legal Services, then incarcerating Coughlin between April 19th and April 26th, 2012 (during which time Richard G. Hill
and Casey Baker filed their Motion for Attorney's Fees of $40,050 incident to the appeal of a summary eviction in CV11-03628, which
Coughlin's former co-worker Judge Flanagan awarded Baker and Hill, after Judge Flanagan refused to recuse himself even where Coughlin
pointed out the necessity of his so doing. Then Judge Elliot denied Coughlin's appeal of RMC Judge Howard's conviction of Coughlin for
"petty larceny of a candy bar and some cough drops" in 11 CR 22176 (the sole basis for the current temporary suspension of Coughlin's law
license, incident to a trial where the Reno City Attorney Pamela Roberts offered perjured testimony from Wal-Mart's Thomas Frontino and
RSIC Officer Kameron Crawford that Crawford was justified in conducting a custodial arrest and search incident thereto for an alleged
misdemeanor offense, occurring after 7 pm, outside the presence of the officer, in light of Coughlin failure to provide the officer his driver's
license. City Attorney Roberts had been provided by the RSIC a video tape showing Coughlin providing Crawford his driver's license, and
Coughlin's booking inventory sheet lists his drivers license (despite Officer Crawfords sworn testimony that Coughlin did not have one on his
person at the time, even where Wal-Mart's video shows Crawford copying down Coughlin's information off the driver's license Coughlin
provided to Offier Crawford, and where Wal-Mart admits that it did not effect a citizen's arrest of Coughlin, and therefore NRS 178.1255
required an application of the exclusionary rule to any partial package of "cough drops" found in Coughlin's pockets upon a search incident to
arrest (and even that is not all that necessary to prove Coughlin's innocence given that the RSIC Officer and Wal-Mart's Frontino testified
incorrectly that the receipt for the $83.82 worth of groceries that Coughlin selected and paid after his allegely consuming a "candy bar and
some cough drops" while shopping, did, in fact have an entry for that exact UPC of Duract Cough Melts ("cough drops"), contrary to the sworn
testimony of both Wal-Mart's Frontino and the RSIC's Crawford). But none ofthat mattered much to Judge Elliot, as he denied Coughlin's
appeal based on some civil statute related to a litigant being required to pay for a transcript up front, even where, in criminal matters, the
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RMC is required to transmit the record on appeal and order the production fo the transcripts within 10 days of the filing of a Notice of Appeal,
pursuant to NRS 189.010-030, regardless of whether the criminal defendant pays for the transcript up front. See CR12-1018 for other
instances of teh RMC and its "exclusive trancriptionist" Pam Longoni perpetuating a fraud on the public (the RMC indicates Longoni is the only
transcriptionist they will allow, and demand that she be paid up front....Longoni hung up on Coughlin multiple times and otherwise prejudiced
Coughlin's appeal by refusing to prepare his transcript even where Coughlin would pay up front for the transcripts, in CR11-2064. Judge Elliot
then dismissed Coughlin's appeal of the criminal trespass conviction by Judge William Gardner in CR12-1262 where the RMC and Lisa Wagner
failed to file the 6/28/12 Notice of Appeal Coughlin has confirmation that the RMC and City Attorney Hazlett-Stevens recieved, though both
maintain a dubious position counter to such irrefutable proof.

Additionally, one of the aspects of Richard G. Hill's grievance with the SBN against Coughlin, memorialized in NG12-0204 (one of the three greivances forming
Mr. Kings SCR 105 SBN v. Couglin Petition) alleges some sort of "ghostwriting" on Coughlin's part for a former client of Coughlin's John Gessin. This is
plainly not true, though some confusion may have arisen given the fact that at about the time Gessin and Couglin parted ways, Gessin apparently paid for and
signed up for an E-flex account (apparently non-attorneys may do so?). Hill's allegations respecting Gessin are baseless and ironic given the fact that
Coughlin filed Notice of Appearance as Gessin's attorney in various matters, and even sent Gessin a correspondence wherein he warns Gessin that he will not
tolerate any appearance of ghostwriting (what can an attorney do when a client pays him money, drafts of NRCP 60(b) Motions are worked up extensively over a
period of time, then the client decides he wants to part ways, and takes with him those drafts? File a Notice of Appearance so there is at least some paper
trial?). It would be helpful to addressing Hill's allegations vis a vis "ghostwriting" for Gessin if the Second Judicial District Court would present or allow for
inspection anything it may have tending to shed light on such allegations.


Here is one correspondence Coughlin sent then client John Gessin refuting the allegations that Hill made to the SBN in his attached 1/14/12 grievance against
Coughlin (attached to the SBN King's 2/14/12 letter to Coughlin):

"Subject: NOTICES OF APPEARANCES

John, Let me know whats going on, i got a new temporary address and phone number. theres is some
ghostwriting taboos, so...if you want me to withdraw thats fine, whatever, its all good
Zach Coughlin, Esq."


Further, in her 10 4 12 order in 11 TR 26800, Judge Nash Holmes continues to refuse to allow Coughlin to appeal a final appealable order convicting
him of "summary criminal contempt", even though Judge Holme's Order specifically relies upon alleged conduct, and an essential element thereof, not
occuring in here "immediate presence", and where there is no Affidavit by her Marshal (Judge Nash Holmes states on the record in 11 TR 26800 that an
RMC Marshal (apparently Marshal Harley) followed Coughlin into the restroom during a break in the Trial Judge Nash Holmes begrudingly granted
Coughlin (though she ordered him to leave his yellow note pad in the courtroom?) whereupon Marshal Harley played Peeping Tom through a bathroom
stall and alleges to have spied Coughlin "dissassembling a smartphone", which Judge Nash Holmes took as an opportunity to find "by clear and
convicing" evidence that Coughlin "lied" "under oath" in response to her impromptu, sua sponte, interrogation of Coughlin immediately following that
bathroom break (and soon after RMC Marshal Harley (who violated the "courthouse sanctuary" dictates against serving Coughlin Judge Flanagan's
Order to Show Cause for a 3/23/12 Hearing on Richard G. Hill's Motion in the eviction appeal in CV11-03628 while Coughlin and City Attorney Ormaas
where haggling over plea details immediately prior to the traffic citation trial in 11 TR 26800 (incident to Coughlin being told to leave Hill's office
upon arriving their to retrieve his keys, wallet, and driver's license, and client's file upon being released from three days in jail incident to a criminal
trespass complaint Hill signed against Coughlin, which the RPD committed misconduct in subjecting Coughlin to a custodial arrest for, especially in
light of the video taped admission of Sargent Lopez and the matrials presented in Coughlin's recent filings in 61901 and 11 CR 26405). RMC Marshal
Harley took it upon himself to aid WCSO Deputy Machen in filing a false Affidavit of Service in Harley's handing Coughlin, on behalf of Hill, a
document Hill paid the WCSO to serve on Coughlin (an how unseemly and bullying to attempt to serve it at the traffic citation trial, appearance of
impartiality and impropriety be damned, Caplow, regardless.). And City Attorney Ormaas may have been whispering in Harley's ears given her
apparent concern or her responses to Coughlin asking her, shortly before the trial commenced, if she planned to follow up on or in any way document
the admissions to accepting bribes from Richard Hill made by the officer effecting the custodial criminal trespass arrest, RPD Officer Chris Carter, Jr.
(whom will apparently attest that he was jesting, though its not clear what is funny about arresting an attorney for trespass at his former home law
office where the WCSO admits it lied in filing an Affidavit of Service attesting to having "personally served" Coughlin such an Eviction Order.


I appreciate this opportunity to clarify my subpoena.

Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
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From: PatrickK@nvbar.org
To: zachcoughlin@hotmail.com
Subject: RE: Mr. King's assertion in his 3/16/12 letter
Date: Thu, 19 Apr 2012 21:29:10 +0000
April 19, 2012

Zach Coughlin

Dear Mr. Coughlin,

A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday April 10, 2011 to address the grievances filed
against you. The panel directed me to proceed to a formal disciplinary hearing. As such, I will be preparing a formal Complaint.

I understand from the e-mail below, that you do not believe you should have been found guilty of the theft at Wal-Mart and
that you should not have been found in contempt of Court. However, it must concern you that you were found in contempt of Court by more than one
Judge in two different trials. You wanted to know how I learned of or obtained a copy of Judge Gardners Order after trial that was filed in 2009.
It was sent to me by the clerk of the court at my request, pursuant to my investigation.

It would help me and perhaps yourself, if you would respond and explain why you were convicted of theft and why you were
held in contempt of Court. You may be well served to explain what remedial measures you are taking to make sure you do not repeat the conduct
complained about. I cannot give you legal advice. However I can suggest you cooperate with Bar counsels investigation and that you respond
specifically to the allegations contained in Judge Holmes and Richard Hills grievance letters to the office of Bar Counsel.


Patrick King
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Monday, April 16, 2012 5:41 PM
To: Patrick King; David Clark; Glenn Machado
Subject: Mr. King's assertion in his 3/16/12 letter

Dear Bar Counsel,


One thing that I am not sure I have ever pointed out, is that my then live in girlfriend of over 4 years stole about 2 months worth of my portion of our rent from
me (our arrangement was I would give her the money, she would forward it on to the landlord) in the period between May-July 2011. I sacrificed a great deal
and paid lots of her tuition, and she broke up with me and moved out on or around May 18th, 2011, about 3 days after we hosted her entire family for her
graduation from UNR. I did not know about her stea