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  • Cr13-1890-4156463 (Opening Brief Appellant Opening Brief - Transaction 4267066 - Approved by - Asmith - 01-21-2014!12!09 - 48)

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    NevadaGadfly
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    IN THE SUPREME COURT OF THE STATE OF NEVADA IN RE: ZACHARY BARKER COUGHLIN, ESQ. NEVADA BAR NO: 9473 ) ) ) ) ) ) ) ) Case 65587 REQUEST FOR PERMISSION TO FILE THIS SECOND SUPPLEMENTAL TO SCR 111(10) PETITION FOR REINSTATEMENT COMES NOW, ZACHARY BARKER COUGHLIN by and through his attorney, ZACHARY BARKER COUGHLIN, ESQ. and hereby submits this to whatever extent Coughlin’s incarcerations from 5/23/13-6/7/13 and 11/7/13-4/18/14 cast a pall over matters at issue herein. FACTS: I just became aware that the Reno Justice Court Bailiff whom I was convicted of resisting and sentenced to serve six months in connection therewith, was fired two weeks after he worked my sentencing hearing. The Supreme Court was apprised of this conviction and such may have contributed to its decision to have me evaluated in 60975 and such may be continuing to influence the state of the associated case in 62337, 65587, 62104, 61462, 64903 etc., etc .: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33092 I discovered this just yesterday via perusing the appeal of a particularly contentious divorce matter that went through trial involving such former bailiff John Reyes: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33475 http://caseinfo.nvsupremecourt.us/document/view.do?csNameID=33475&csIID=33475&deLinkID=464149&sireDocumentNumber=14-14712 http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33475 The Justice Court refused to allow me to subpoena either Bailiff Reyes employment/personnel file or his wife. In the SCR 117 Disability Petition of 5/31/12 in 60975 the NNDB attached two filings of mine that it (or the SBN) seemed to (at the time, though they abandoned any inquiry into such upon the arrival of my disciplinary hearing on 11/14/12 in 62337) believe indicated I was incompetent, engaging in some misconduct, or disabled in some way. One such filing is dated 2/21/12 and the other 3/5/12. RJC Bailiff Reyes had menacingly informed me he was going to put his foot up my ass in the court lobby on 11/10/11 or thereabouts incident to my having an animated discussion with my public defender. I believe the tone of those filings was influenced by such incident. I was denied my Sixth Amendment and ADKT 0411 right to counsel in the prosecution stemming from Reyes’ arrest, yet made to serve six months in jail incident thereto. Please see case 64804 COUGHLIN (ZACHARY) VS. GLASSON http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=32992 Tahoe Justice of the Peace Glasson showed upon the day of trial and announced he had been invited to preside over the trial because Bailiff Reyes was an RJC employee. However, all the pretrial rulings (such as the RJC refusing to allow Coughlin to subpoena Bailiff Reyes’s wife or his employment/personnel file) were made by RJC judges. Regardless, Bailiff Reyes worked the sentencing hearing as a bailiff on 11/7/13, then was fired by the RJC on 11/22/13. Judge Glasson/the RJC refused to include in the record on appeal of such conviction in CR13-1890 the majority of Coughlin’s filings, such as the following (not that APD Picker would dare attempt to have such omissions addressed (also, Picker, despite admitting he can’t imagine what the utility of NRS 169.163 is in light of his reading of Thompson as holding that all state, county, or city employees are public officers, probably would agree with refusing to give “public officer” Bailiff Reyes the hearing required under Nevada law before firing or removing a “public officer” from office): http://www.scribd.com/doc/232351427/11-4-13-Supplement-to-Emergency-Motion-for-Continaunce-72675-71437-607-3913-3914-With-Exhibit-1 http://www.scribd.com/doc/232351425/10-21-13-72675-Supplemental-Post-trial-Motions-and-Supporting-Declaration-Bw http://www539d9a1963a78.91kbw.com/doc/232351422/10-21-13-72675-7-Pages-Amended-Post-Trial-Motion-and-Declaration-in-Support-

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    Cr13-1890-4156463 (Opening Brief Appellant Opening Brief - Transaction 4267066 - Approved By_ Asmith _ 01-21-2014!12!09_48)

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    IN THE SUPREME COURT OF THE STATE OF NEVADA IN RE: ZACHARY BARKER COUGHLIN, ESQ. NEVADA BAR NO: 9473 ) ) ) ) ) ) ) ) Case 65587 REQUEST FOR PERMISSION TO FILE THIS SECOND SUPPLEMENTAL TO SCR 111(10) PETITION FOR REINSTATEMENT COMES NOW, ZACHARY BARKER COUGHLIN by and through his attorney, ZACHARY BARKER COUGHLIN, ESQ. and hereby submits this to whatever extent Coughlin’s incarcerations from 5/23/13-6/7/13 and 11/7/13-4/18/14 cast a pall over matters at issue herein. FACTS: I just became aware that the Reno Justice Court Bailiff whom I was convicted of resisting and sentenced to serve six months in connection therewith, was fired two weeks after he worked my sentencing hearing. The Supreme Court was apprised of this conviction and such may have contributed to its decision to have me evaluated in 60975 and such may be continuing to influence the state of the associated case in 62337, 65587, 62104, 61462, 64903 etc., etc .: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33092 I discovered this just yesterday via perusing the appeal of a particularly contentious divorce matter that went through trial involving such former bailiff John Reyes: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33475 http://caseinfo.nvsupremecourt.us/document/view.do?csNameID=33475&csIID=33475&deLinkID=464149&sireDocumentNumber=14-14712 http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33475 The Justice Court refused to allow me to subpoena either Bailiff Reyes employment/personnel file or his wife. In the SCR 117 Disability Petition of 5/31/12 in 60975 the NNDB attached two filings of mine that it (or the SBN) seemed to (at the time, though they abandoned any inquiry into such upon the arrival of my disciplinary hearing on 11/14/12 in 62337) believe indicated I was incompetent, engaging in some misconduct, or disabled in some way. One such filing is dated 2/21/12 and the other 3/5/12. RJC Bailiff Reyes had menacingly informed me he was going to put his foot up my ass in the court lobby on 11/10/11 or thereabouts incident to my having an animated discussion with my public defender. I believe the tone of those filings was influenced by such incident. I was denied my Sixth Amendment and ADKT 0411 right to counsel in the prosecution stemming from Reyes’ arrest, yet made to serve six months in jail incident thereto. Please see case 64804 COUGHLIN (ZACHARY) VS. GLASSON http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=32992 Tahoe Justice of the Peace Glasson showed upon the day of trial and announced he had been invited to preside over the trial because Bailiff Reyes was an RJC employee. However, all the pretrial rulings (such as the RJC refusing to allow Coughlin to subpoena Bailiff Reyes’s wife or his employment/personnel file) were made by RJC judges. Regardless, Bailiff Reyes worked the sentencing hearing as a bailiff on 11/7/13, then was fired by the RJC on 11/22/13. Judge Glasson/the RJC refused to include in the record on appeal of such conviction in CR13-1890 the majority of Coughlin’s filings, such as the following (not that APD Picker would dare attempt to have such omissions addressed (also, Picker, despite admitting he can’t imagine what the utility of NRS 169.163 is in light of his reading of Thompson as holding that all state, county, or city employees are public officers, probably would agree with refusing to give “public officer” Bailiff Reyes the hearing required under Nevada law before firing or removing a “public officer” from office): http://www.scribd.com/doc/232351427/11-4-13-Supplement-to-Emergency-Motion-for-Continaunce-72675-71437-607-3913-3914-With-Exhibit-1 http://www.scribd.com/doc/232351425/10-21-13-72675-Supplemental-Post-trial-Motions-and-Supporting-Declaration-Bw http://www539d9a1963a78.91kbw.com/doc/232351422/10-21-13-72675-7-Pages-Amended-Post-Trial-Motion-and-Declaration-in-Support-

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    Cr13-1890-4156463 (Opening Brief Appellant Opening Brief - Transaction 4267066 - Approved by - Asmith - 01-21-2014!12!09 - 48)

    Încărcat de

    NevadaGadfly
    IN THE SUPREME COURT OF THE STATE OF NEVADA IN RE: ZACHARY BARKER COUGHLIN, ESQ. NEVADA BAR NO: 9473 ) ) ) ) ) ) ) ) Case 65587 REQUEST FOR PERMISSION TO FILE THIS SECOND SUPPLEMENTAL TO SCR 111(10) PETITION FOR REINSTATEMENT COMES NOW, ZACHARY BARKER COUGHLIN by and through his attorney, ZACHARY BARKER COUGHLIN, ESQ. and hereby submits this to whatever extent Coughlin’s incarcerations from 5/23/13-6/7/13 and 11/7/13-4/18/14 cast a pall over matters at issue herein. FACTS: I just became aware that the Reno Justice Court Bailiff whom I was convicted of resisting and sentenced to serve six months in connection therewith, was fired two weeks after he worked my sentencing hearing. The Supreme Court was apprised of this conviction and such may have contributed to its decision to have me evaluated in 60975 and such may be continuing to influence the state of the associated case in 62337, 65587, 62104, 61462, 64903 etc., etc .: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33092 I discovered this just yesterday via perusing the appeal of a particularly contentious divorce matter that went through trial involving such former bailiff John Reyes: http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33475 http://caseinfo.nvsupremecourt.us/document/view.do?csNameID=33475&csIID=33475&deLinkID=464149&sireDocumentNumber=14-14712 http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=33475 The Justice Court refused to allow me to subpoena either Bailiff Reyes employment/personnel file or his wife. In the SCR 117 Disability Petition of 5/31/12 in 60975 the NNDB attached two filings of mine that it (or the SBN) seemed to (at the time, though they abandoned any inquiry into such upon the arrival of my disciplinary hearing on 11/14/12 in 62337) believe indicated I was incompetent, engaging in some misconduct, or disabled in some way. One such filing is dated 2/21/12 and the other 3/5/12. RJC Bailiff Reyes had menacingly informed me he was going to put his foot up my ass in the court lobby on 11/10/11 or thereabouts incident to my having an animated discussion with my public defender. I believe the tone of those filings was influenced by such incident. I was denied my Sixth Amendment and ADKT 0411 right to counsel in the prosecution stemming from Reyes’ arrest, yet made to serve six months in jail incident thereto. Please see case 64804 COUGHLIN (ZACHARY) VS. GLASSON http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=32992 Tahoe Justice of the Peace Glasson showed upon the day of trial and announced he had been invited to preside over the trial because Bailiff Reyes was an RJC employee. However, all the pretrial rulings (such as the RJC refusing to allow Coughlin to subpoena Bailiff Reyes’s wife or his employment/personnel file) were made by RJC judges. Regardless, Bailiff Reyes worked the sentencing hearing as a bailiff on 11/7/13, then was fired by the RJC on 11/22/13. Judge Glasson/the RJC refused to include in the record on appeal of such conviction in CR13-1890 the majority of Coughlin’s filings, such as the following (not that APD Picker would dare attempt to have such omissions addressed (also, Picker, despite admitting he can’t imagine what the utility of NRS 169.163 is in light of his reading of Thompson as holding that all state, county, or city employees are public officers, probably would agree with refusing to give “public officer” Bailiff Reyes the hearing required under Nevada law before firing or removing a “public officer” from office): http://www.scribd.com/doc/232351427/11-4-13-Supplement-to-Emergency-Motion-for-Continaunce-72675-71437-607-3913-3914-With-Exhibit-1 http://www.scribd.com/doc/232351425/10-21-13-72675-Supplemental-Post-trial-Motions-and-Supporting-Declaration-Bw http://www539d9a1963a78.91kbw.com/doc/232351422/10-21-13-72675-7-Pages-Amended-Post-Trial-Motion-and-Declaration-in-Support-

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    din 17

    F I L E D

    Electronically
    2014-01-21 11:11:46
    Joey Orduna Hastings
    Clerk of the Court
    Transaction # 4267066 : asmith

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