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FW: LITIGATION HOLD NOTICE FOR VIDEO AT RJ C

INVOVLING WCSO COURT SECURITY UNIT RENO J USTICE
COURT
From: Kandaras, Mary (mkandaras@da.washoecounty.us) You moved this message to its current
location.
Sent: Tue 2/21/12 10:16 AM
To: zachcoughlin@hotmail.com
1 attachment
ex 1 CV11-03628-2658302 (Exhibit 2)_001.pdf (185.1 KB)
Dear Mr. Coughlin:

I have received your request to preserve video at Reno Justice Court. I am summarizing your request as follows: On
February 14, 2012, you sought to file a document shortly before 5:00 pm. However, you state that the court house doors
were locked prior to 5:00 p.m. on that day. You state that Court Administration stated that the Sheriff was the custodian
of records for this video.

I will attempt to discern who is the holder of this video. I am assuming that you want to see the officers locking the front
door or anything with you on it (although I do not know what you look like).

Please confirm that I am seeking the proper information. Also, if there is something else with respect to video recording,
please let me know so there wont be duplication of effort.

Mary Kandaras
Deputy District Attorney
Phone: (775) 337 - 5723
Fax: (775) 337 - 5732

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Thursday, February 16, 2012 5:37 PM
To: Kandaras, Mary
Subject: LITIGATION HOLD NOTICE FOR VIDEO AT RJ C INVOVLING WCSO COURT SECURITY UNIT RENO J USTICE COURT

Dear Ms. Kandaras,

Please find below and attached a LITIGATION HOLD NOTICE FOR VIDEO AT RJ C
INVOVLING WCSO COURT SECURITY UNIT RENO J USTICE COURT. Now, I suspect this
video will turn up "lost" pretty soon, but, I am sending this to you anyway.

Sincerely,

Zach Coughlin, Esq.

From: zachcoughlin@hotmail.com
To: stuttle@washoecounty.us
Subject: RE: cases being randomly assigned in RJ C FW: attempt to file prior to 5pm denied
Date: Thu, 16 Feb 2012 16:58:06 -0800

Dear Court Administrator Tuttle,

I feel that you have misunderstood my import. Please consider that you and others in the court are
only human, whereas Richard G. Hill, Esq. is clearly a lycan, who has also somehow managed to
fashion himself and his brethren into a sophisticated commercial law firm capable of distorting reality
in ways not commonly seen absent the administration of extremely potent psychotropic drugs. There
were no "assertions regarding "J udges Sferrazza, Clifton and the Court's integrity" in anything I
wrote you. There is a difference between an "appearance" and a "reality", however, I think you will
find that "appearances of impropriety" are given considerable attention in the Rules of Professional
Responsibility, the Code of J udicial Conduct, and the Model Code of Conduct for J udicial Employees
in the State of Nevada.

Further, I think you will find that, contrary to your retaliatory assertions, my duty to my client
includes making a reasonably diligent effort to attempt to access justice, and any subsequent
excusable neglect analysis may, in fact, call for making an attempt to inquire with court personnel or
Sheriff's Deputies in an attempt to address my concerns vis a vis the doors locking. While you
indicate the videos are the property of the Sheriff (quite a bit of power for the Sheriff alone to own
those videos) you do not make clear how it is that you are able to review them, while at the same
time, seemingly disclaiming any liability for the negligent hiring, training, or supervision of the
various Deputies you supervise and or work with at the RJ C, especially, vis a vis their propensity to
tell litigants that they will have objects forcibly inserted into their anuses should such litigants in any
way question the cold, hard, authority of these Sheriff's Deputie's jackboot.

What is not clear is why J udge Clifton would handle all the other cases on the stacked docket of
2/13/12, beginning at 8:30, but then, after Chief Bailiff Sexton came into the Court Room with
Bailiff Reyes (whom I have been forced to file for a Protection Order against just recently) and made
some phone calls, J udge Sferrazza replaced J udge Clifton. Further, while J udge Sferrazza explained
the non-appearance of J udge Lynch by indicating that J udge Lynch was instead scheduled to do
traffic court that day, Chief Civil Clerk Stancil indicated today that, in fact, J udge Lynch was hearing
matters on a criminal calendar.'

Regardless, I certainly have not impugned the credibility of any of the fine judges of the RJ C.
However, your jumping to being "insulted" and failing to ask me anything about these incidents
involving threats to insert objects inside of my anus leaves a bit to be desired, in my humble opinion,
from the perspective of a member of the public appearing in your court as a litigant.

You wrote: "You were not denied by this Court your right to file these documents yesterday. You
were, however, denied by Washoe County Sheriff Court Security Unit access to the building after
closing time; the same as anyone else would be denied. You were not here before 5:00pm and trying
to gain access into the facility by coming through an exit only door is not permissible."

I don't agree with your assessment, but I apologize for the annoyance this seems to have caused. I
hope you will consider that the date on which this occurred was the last day to file a pre-trial motion
(under NRS 174.125, such motions, including a "motion to suppress" the fruits of an unlawful search
by law enforcement) in a matter for which I am a criminal defendant, and for which a conviction
could result in me being disbarred as an attorney, in addition to fairly substantial criminal penalties,
including incarceration. There are a lot of things that can go wrong on the way to an innocent man
being convicted of a crime. One key area involves the failure to preserve for appeal important issues.
Such were the content of the documents I sought to filed on February 14th, 2012. Additionally, only
yesterday was I finally informed by the RJ C, criminal division, that I may file by fax. I have
previously been told that I may not file by fax. Further, today Ms. Stancil, Chief Civil Clerk,
informed me that I may also file by fax in the Civil Division. I am quite certain I have requested
permission to do this before in both the civil and criminal divisions and have been told I may not
every single time. This relates to your recent commentary on "favoritism" and applying the rules
evenly to all litigants. I am sure I have heretofore been disallowed from filing by fax. Indeed, I have
spent countless hours of my time travelling out of my way, down to the Reno J ustice Court, to file
each and every document that I have filed in the few cases I have had in your court (and most any
lawyer will tell you that their "time" is the only thing a lawyer is much able to sell to anyone for the
purpose of making a living, something which, I assure, has been an enormous struggle for me this
past few years). You are aware of just how enormous the file is in RJ C Rev2011-001708. I guess
some would say that is my fault, though I would counter that the law is rather clear that NRS
40.253's summary eviction proceedings are forbidden against commercial tenants where the non
payment of rent is neither alleged nor Notice of such is posted or served, as here.

Mr. Tuttle, you know as well as I do that there is a turnstile that only turns one way that would
obviously present any such attempt to gain access. Further, the door you are referring to is not
marked "exit only", and your assertions that I was "trying to gain access to the facility" is so
transparent that it is disturbing considering your position with the court. I clearly knocked on the
window and waived to Deputies in an attempt to ask them my questions. Surely, the video you
reference easily show this. Additionally, you do not mention exactly what time "after 5 pm" the video
showed, and I find that curious. Further, you do not mention any system in place to assure that the
time stamping on the video is in accord with the official United States time at www.time.gov. Indeed,
the RJ C or the Sheriff are not the only one's in the this world with cameras and clocks, and it might
be very interesting to see a documentary of several days worth of footage of just when exactly the
doors lock, synced to a visual time stamping verified to be accurate vis a vis www.time.gov. If such a
video did exist, you don't sound like you would be too interested in seeing it. Please correct me if I
am wrong.
You further wrote: "Because your actions could be consider trespassing is the reason why Reno
J ustice Court Chief Bailiff Michael Sexton again asked you to leave. Fair and equal access to justice
applies not only to discrimination, but also to favoritism. Allowing one party to file documents after
a deadline is unethical and without question unfair." Your interpretation of the crime of "trespassing"
is interesting. I guess, under your approach, Richard G. Hill, Esq. would be guilty of trespassing
where, at the 12/20/11 Hearin on Tenant's Motion to Contest Personal Property Lien, after the Tenant
invoked the Rule of Exclusion, and J udge Sferrazza ordered Hill and other prospective witnesses to
leave the court room, where Hill surreptiously snuck back in the court room, found time during a
recess to announce to myself Bailiff Reyes and Chief Bailiff Sexton that Hill too would like to "put
his boot up Coughlin's ass", and then manage to sneak back into the court room during the
proceeding, and have Bailiff Sexton pass post-it notes from behind the Bar to a struggling Casey
Baker, Esq., whom was attempting to apply and unlawful rent distraint under the guise of "reasonable
storage" expenses.

At $30 a day for "reasonable storage" expenses, J udge Sferrrazza's Order was more in line with what
one gets in a room at the Sand's for a day, complete with the full use and occupancy of the room,
heat, plubming, light, and premium cable television, and wi-fi access. $30.00 a day for "reasonable
storage" of that which could fit in a 10 by 30 foot storage shed (which typically cost $125 per month,
or about 1/8th of what J udge Sferrazza ruled would be a reasonable daily storage charge, in the great
Reno area). This $30.00 a day storage charge is made all the more questionable by the fact that the
locations where all these items were being "stored" (and for which a bill for $1,060 to "secure" this
"storage" was filed with the RJ C) was actually burglarized on December 12th, 2011, while under Hill
and Baker control, and many valuable were stolen, though neither Hill nor Baker ever provided
anything close to a reasonable detailed inventory of what was there prior to the burglary and what
remained after the burglary. The did manage to notice that a 62 inch Television was missing, though.

I agree with your assessment that it would be unethical and without question unfair for the criminal
division filing office to ask a "red headed step child" litigant "who is calling" on the phone when
they inquire with court personnel as to whether the court will, in fact, remain open, all the way up to
the posted 5pm closing time, and then for the door's to the court to, ever so curiously, be locked prior
to 5 pm when said redhead presents to access justice, and even more so where a court administrator
and Chief Bailiff then arrange a version of the facts to explain away their actions and decisions,
replete with menacing allusions to retaliatory prosecution, etc., etc. You are right about that, Sir.

You further wrote "Informing Chief Bailiff Sexton of your intention to wait outside for Reno J ustice
Court employees to leave so you could force them to take your filings is a form of harassment and
needs to stop immediately. If this aggressive behavior continues, the Court will consider a protective
order against you, which will result in your ability or privilege to access Reno J ustice Court." Well, it
does seem somewhat untoward that you are now threatening to file a protective order merely because
a litigant asked to speak with a supervisor regarding the court's doors locking prior to 5 pm. This is
particularly troublesome where you make accusations of such a litigant engaging in "aggressive
behavior" when, in fact, it is your own Chief Bailiff Sexton and Bailiff Reyes who have both
engaged in bullying behavior towards litigants, replete with the ever so professional threats to
forcibly insert objects into a litigants anus, and other menacing commentary related to a litigants
"ass", particularly where such commentary occurred while said litigant was attempting to access
justice in the most basic way (by presenting documents to be filed with the filing office, during hours
for which the court holds itself out as open for business).

You further wrote: "In addition, I have looked into your assertions of sexual assault by the Reno
J ustice Court Bailiffs and found these allegations to be without merit." However, in your "looking
into" these "assertions of sexual assault" you have neither met with me nor interviewed me or
otherwise conducted anything close to a reasonably diligent inquiry, something which you may have
a duty to perform with respect to any negligent hiring, training, or supervision claim or other 42 USC
Sec 1983 claim a member, or a class of members of the public may have. But you seem to suggest
that you do not bare any responsibility for the actions of the WCSO Court Security Unit's actions.
However, if that is the case, one must wonder why you would have "looked into your assertions of
sexual assault by the Reno J ustice Court Bailiff's" or why you refer to said Bailiff's alternatively as
"Reno J ustice Court Bailiffs", while elsewhere using the designation Washoe County Sheriff Court
Security Unit.


You went on to write in another recent correspondence: "1) The locking of the front doors to the
Courthouse is the responsibility of the Sheriffs Office, so all your questions regarding this issue will
need to be directed to them. However, I will state that the surveillance videos, which are dated and
time stamped, clearly shows that you were here after 5:00pm on 2/14/2012." Well, the videos may
technically show I was "here after 5 pm", but it is curious you do not write that the videos show that
I "did not arrive until after 5 pm"...or otherwise get very specific.

Please be aware that this correspondence places you on a LITIGATION HOLD NOTICE with respect
to any and all recordings made in conjunction with this matter, and further, with regard to any
recordings made concerning me whatsoever. PLEASE PROVIDE ME WITH A COPY OF THE
VIDEO YOU REFERENCE, COMPLETE WITH THE TIME STAMPING AND A WRITTEN
ATTESTATION AS TO THE PRACTICE IN PLACE TO ASSURE THE ACCURACY OF THE
TIMESTAMPING.

You go on to write: "3) I am not sure what your question is regarding your 11/16/11 filing - Motion
to Contest Personal Property." By all means, let me elucidate this matter for you more clearly. Please
see the attached 1/5/12 Reply to Opposition in the appeal from this matter, in CV11-03628 wherein
the RJ C's liability for failing to appropriately carry out the dictates of black letter Nevada law found
in NRS 40.253(7)-(8) is quite clearly pronounced. Further, I was never provided or served a copy of
(until the filing of the Record on Appeal, well after the 12/15 and 12/17/11 entries in the docket,
which preceded the 12/20/11 Hearing on Tenant's Motion to Contest Personal Property Lien) the two
statements the RJ C seemingly order Deputy Clerk J ocelyn J onas and Chief Civil Clerk Karen Stancil
to place in the file in RJ C REV2011-001708.

In that Reply, in page 7 of 24, one' finds the following: 4. Funny thing about the Reno J ustice Court: when
it comes to setting a hearing within 10 days of my filing Motion to Contest Personal Property Lien on November
16th, 2011, the RJ C is all "oh, we needed your permission, Mr. Coughlin, to set such a hearing, its your fault that
we couldn't get it on within the 10 days required by statute under NRS 40.253(7-8); however, when Coughlin went
in to file something on November 3, 2011 at 4:58pm, RJ C filing office Chief Clerk Karen Stancil didn't need no
permission to serve personally on Coughlin Notice of a Hearing to take place on Monday, November 7, 2011.
Well, actually, allegathetically, another clerk (Deputy Clerk Christine Erickson) had to sneak that Notice of the
Hearing on November 7, 2011 into a stack of papers she slipped Coughlin when she was pretending to be helpful
for a change, rather than sullen, and overly opinionated for someone who cares so little of the import of the
Whitman, Donoho, Byrant, and Sullivan decisions of the Nevada Supreme Court with respect to court employees
legislating from the filing office desk and refusing to accept filings because they just aren't feeling it that day....
You see, somebody at the RJ C figured out that it probably was not legal to hold on to Coughlin last $2,275 on
earth if it was not granting him a stay (especially where NRS 40.385 entitles Coughlin to one, for his posting a
bond as little as $250 (instead the RJ C kept Coughlin's $2,275, and if you believe Hill, did not grant a stay) as, in
J udge Sferrazza's words, that would be "conversion". So, how again is it Mr. Hill's outrageous allegations of
Coughlin living here or there during this or that period (something which Hill never bothers to support with
anything other than his own bluster, hot air, and conjecture, and apparent willingness to to incur NRCP Rule 11
sanctions if it means milking a willful neurosurgeon good and dry in the process) are reasonably based in fact or
law and therefore not worthy of NRCP 11 sanctions?

Regardless, the RJ C did set a Hearing on Tenant's Motion to Contest Personal Property Lien, and Tenant did show
up for it, in face, he checked in with Chief Bailiff Sexton prior to that Hearing, which was set for November 22,
2011. However, Tenant was the only one who showed up. Should that not yield a default victory?

However, more troubling is the RJ C's conduct in forcing two of its filing office personnel to sign unsworned
"statements", one month after some alleged conversation incident to a litigants visit to the filing office, and
further, where Deputy Clerk J ocelyn J onas was called to testify by J udge Sferrazza, would conducted a leading
examination of the Court's witness, in a matter where the Court was not even a party. Most troubling of all,
however, it the fact that Ms. J ones, on cross-examination had to admit matters that show here statement of
December 15th, 2011 to be misleading, at best, and wholly deficient in fulfilling the RJ C's duty to maintain an
appearance of impartiality towards all litigants. It is simply impermissible for the RJ C to have Ms. J onas sign and
unsworn "statement" (truly a new one to me, being neither a notarized Affidavit, nor a Declaration made under
"penalty of perjury" in lieu of an Affidavit. However, when Ms. J onas did get sworn in at the 12/20/11 Hearing, a
few unpleasant truths emerged. One, Ms. J onas was forced to admit that she did recall having a discussion with
Tenant Coughlin in RJ C REV2011-001708 about the requirement that the RJ C comply with NRS 40.253(8) which
reads:

"NRS 40.253(8): Upon the filing of a motion pursuant to subsection 7, the court shall
schedule a hearing on the motion. The hearing must be held within 10 days after
the filing of the motion. The court shall affix the date of the hearing to the motion
and order a copy served upon the landlord by the sheriff, constable or other process
server. At the hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460
or 118C.230 and any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment of the charges
determined to be due or if no charges are determined to be due.
One thing you may notice about the jurisdiction granted to the Court, above, in NRS 40.253(8), is that there is
decidedly not any language allowing for an Order "Resolving" Motion to Contest Personal Property Lien like that
J udge Sferrazza entered on 12/21/11, and for which the RJ C filing office has refused to allow me to file a Notice
of Appeal for, and has further refused to even mark as "received" my attempts at so filing Such a Notice Appeal
and Motion to Proceed on Appeal In Forma Pauperis (to the extent that would even be necessary considering the
previous IFP status given the Tenant in that matter, RJ C REV201-001708). That 12/21/11 Order is included
following this corrspondence.

Coughlin is also the Defendant in this criminal matter, which is also before J udge Sferrazza, RCR11-
063341....J udge Sferrazza is now seemingly being placed onto another landlord tenant matter where Coughlin is a
named party, despite J CRRT 2 calling for a random assignment of cases (J udge Lynch was randomly assigned to
the case originally, RJ C2012-074408, Coughlin v. Park Terrace HOA, and, also, J udge Sferrazza is now set to also
take jurisdiction over the unlawful detainer matter that shall soon be filed upon Coughlin filing a Tenant's
Affidavit upon the proper service of a 5 day Unlawful Detainer Notice to Quit). This is not about impugning J udge
Sferrazza as a jurist. Its about criticizing and seeking redress for the appearance of impropriety created where
WCSO Bailiff's engage in conduct that is impermissible (threatening to forcibly insert objects up a litigants anus)
and then create an unduly suspicious appearance of "judge shopping by Bailiff" (Why these Bailiff's seem to want
to insult an esteemed jurist like J udge Sferrazza, one who has an extraordinary depth and breadth of experience
throughout all three branches of government in Washoe County, is puzzling and unfortunate). It would not take
much for these Bailiff's to gather an opinion on which judges have which approach on landlord tenant matters. It
would be impermissible to allow Bailiff's go grudge based judge shopping to retaliate against litigants asserting
their consitutional rights, as Coughlin clearly does, much to their totalitarian dismay. J udge Sferrazza has an
approach to landlord tenants matters that is his own, as all judges invariably will. That does not make him and
impartial arbiter or imply any impropriety. However, to allow RJ C Bailiff's to "gerrymander" what is supposed to
be a random assigning of cases, would clearly be impermissible. Even if that is not what is occurring here, a
reasonable person could concluded that the appearance of such is evident. This is particularly true where J udge
Clifton was on the bench and heard every other case set for the 8:30 stacked docket in court room "B" on 2/13/12.
Mr. Tuttle did not get where he is by being foolish or dim. He must work day in day out with these Bailiffs. Mr.
Coughlin is but a minor occasional litigant/attorney in the Reno J ustice Court. Reasonable minds may feel it would
be foolish for Mr. Tuttle to take any action which would appear to undermine his belief in the reasonableness and
justness of these Bailiff's actions, particularly where these brave men are called to perform the heroic in truly
dangerous circumstances at times. That is where rules get to be the "bad guy" rather than judges or administrators.
J CRRT 2 is the bad guy here, and it is only appropriate for J udge Lynch to hear both this new Complaint for
Unlawful Interruption of Essential Services, in addition to any Summary Eviction and or Unlawful Detainer
matter that may arise between those parties and within a common nexus of circumstances and facts.

Also: "The justices' judgment obligation to pay attorneys' fees is based (1) on their having followed a
procedural rule (J CRCP 106) enacted by this court and (2) on their having made several erroneous
judicial decisions." Lippis v. Peters, 112 Nev. 1008, 921 P.2d 1248 (Nev. Aug 16, 1996); G.C.
Wallace, Inc. v. Eighth J udicial Dist. Court of State, ex rel. County of Clark, 262 P.3d 1135, 1140+,
127 Nev. Adv. Op. 64, 64+ (Nev. Oct 06, 2011) (NO. 56773) " HN: 2,3,4 (P.2d) 2 Schneider v. Elko
County Sheriff's Dept., 17 F.Supp.2d 1162, 1165 (D.Nev. Aug 06, 1998) (NO. CV-N-96-548-ECR)
Mentioned 3 Cheung v. Eighth J udicial Dist. Court ex rel. County of Clark, 124 P.3d 550, 552, 121
Nev. 867, 869 (Nev. Dec 15, 2005) (NO. 42212) HN: 1 (P.2d); "42 U.S.C. 1988 (1991). This
federal statute permits the state courts to award attorneys fees to successful civil rights litigants in
civil rights actions brought in the state courts under 1983. The cited code provision, section 1988,
allows for an award of fees to the prevailing party when that party has sued to enforce a provision
of ... 42 USCS 19811983. Even if we were to recognize the tenants as the prevailing party in
this litigation, it is more than clear that this action was in no way designed or pleaded to enforce a
provision of ... 42 USCS 19811983. In their points and authorities in support of their
application for *1015 attorney's fees the tenants agree that [i]n order to state a claim under 1983,
Plaintiffs must allege a person has deprived him or her of a federal right and the person so depriving
acted under color of state law. In no instance did plaintiff tenants ever allege [that] a person has
deprived him or her of a federal right. Lippis v. Peters 112 Nev. 1008, 921 P.2d 1248.

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

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Subject: RE: cases being randomly assigned in RJ C FW: attempt to file prior to 5pm denied
Date: Thu, 16 Feb 2012 09:46:45 -0800
From: stuttle@washoecounty.us
To: zachcoughlin@hotmail.com
CC: psferrazza@washoecounty.us
1) Questions regarding clocks asked and answered.
2) Assertions of a countywide conspiracy are unfound and insulting.
3) Case judge assignments are random, but hearing judge assignments are at the discretion of the court and
cases will be moved for a variety of reasons, mostly to ensure continuity and caseflow efficiency.
4) Statements regarding your ass asked and answered.
5) Assertions regarding Judges Sferrazza, Clifton and the Courts integrity are unfound and insulting.

Steve Tuttle

Court Administrator
Reno J ustice Court

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Wednesday, February 15, 2012 10:29 PM
To: Tuttle, Steve; Lynch, Patricia
Subject: cases being randomly assigned in RJ C FW: attempt to file prior to 5pm denied

Dear Mr. Tuttle,
Would you please confirm that the clocks in the court are accurate,
and indicate how the doors are locked, and how they were locked
yesterday. It is my position that I was there prior to 5 pm, further
the appearance given by the fact that the person I spoke with on the
telephone from the criminal division filing office (she made sure to
ask for my name, as though that would affect the content of her
answer to my questions-contrary to your a
ssertions, I am seeking no special privilege, but rather, seeking to
avoid any special prejudice) made sure to ask my name, and it was
provided is troubling when viewed in conjunction with the events
before my 2/ 13/ 11 Hearing in the RJ C in Coughlin V. Park Terrace
Townhomes HOA. As you know, J CRRT Rule 2 requires cases be
assigned randomly. However, though J udge Lynch was assigned to
hear my Complaint for Interruption of Essential Services, shortly
before the hearing, the court room was popuplate by two different
Deputies who have both made menacing statements to me involving
my "ass", one of which involved forcible putting an object up my
"ass". Chief Deputy Sexton entered the court room and made a few
calls, and he is one of the two Deputies to which I refer when
mentioning this "ass" situation. Next thing I know, J udge Sferrazza
is hearing the case, and now I am told J udge Sferrazza is "attached"
to the case instead of J udge Lynch. While hearing the case, before it
was continued, J udge Sferrazza apparently granted a license to
practice law to a property manager on behalf of another named party,
the Park Terrace Townhomes HOA. I feel this case should be heard
by J udge Lynch. This is not a statement against J udge Sferrazza, it is
a statement with respect to the appearance created by the above
facts. This, combined with the unexplained October 19th, 2011 fax
to J udge Clifton seeking an ex parte Order allowing inspection of my
law office by Casey Baker, Esq. of the Law Offices of Richard G. HIll,
Esq., despite J udge Clifton not being Chief J udge at that time in
consideration of J CRCP 84.
Sincerely,
Zach Coughlin, Esq.
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

From: zachcoughlin@hotmail.com
To: stuttle@washoecounty.us
Subject: RE: attempt to file prior to 5pm denied
Date: Wed, 15 Feb 2012 22:15:02 -0800
Dear Mr. Tuttle,
Your correspondence contains numerous inaccuracies that I am too pressed for
time to counter at this point. I appreciate your response though. Can you
confirm that the clocks in your court are correct? Deputy Sexton agreed to
get a supervisor and it was agreed I would wait outside to speak to one. You,
of course, have been informed numerous times previously of WCSO Court
Security efforts to deny the access to justice prior to the 5pm closing time. I
am still waiting for some response from you regarding the various statements
concerning my "ass" by those you have some supervisory position over.
Further, can you please indicate why I was, apparently, provided some
demand whereby I would perform the duty placed upon the WCSO incident to
my 11/16/11 filing of a Motion to Contest Personal Property Lien vis a vis the
service and scheduling dictates found in NRS 40.253(7)-(8), especially
considering the holding in Lippis and NRS 42.
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

** 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
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Subject: RE: attempt to file prior to 5pm denied
Date: Wed, 15 Feb 2012 15:57:32 -0800
From: stuttle@washoecounty.us
To: zachcoughlin@hotmail.com
CC: J Goodnight@washoecounty.us
Mr. Coughlin:

The documents that you emailed and faxed to Reno Justice Court at 6:40pm on February 14, 2012 were filed stamp with
todays date (February 15, 2012) and placed in the file for the Judges review. It will be noted that these documents were
received by the Court after normal business hours on February 14, 2012.

You were not denied by this Court your right to file these documents yesterday. You were, however, denied by Washoe
County Sherriff Court Security Unit access to the building after closing time; the same as anyone else would be denied.
You were not here before 5:00pm and trying to gain access into the facility by coming through an exit only door is not
permissible. Because your actions could be consider trespassing is the reason why Reno Justice Court Chief Bailiff
Michael Sexton again asked you to leave. Fair and equal access to justice applies not only to discrimination, but also to
favoritism. Allowing one party to file documents after a deadline is unethical and without question unfair.

Informing Chief Bailiff Sexton of your intention to wait outside for Reno Justice Court employees to leave so you could
force them to take your filings is a form of harassment and needs to stop immediately. If this aggressive behavior
continues, the Court will consider a protective order against you, which will result in your ability or privilege to access
Reno Justice Court.

In addition, I have looked into your assertions of sexual assault by the Reno Justice Court Bailiffs and found these
allegations to be without merit.

Lastly, your practice of filing hundreds of documents on multiple cases and then repeatedly asking for copies of the case
files free of charge will no longer be granted by the Court. Reno Justice Court will provide you one free copy of your
original case files and one free copy of any future filings , but you will be charged appropriately for all additional copies.

Steve Tuttle

Court Administrator
Reno J ustice Court

From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Tuesday, February 14, 2012 6:40 PM
To: Tuttle, Steve; Goodnight, J oseph W; Young, Zach; RJ CWEB
Subject: attempt to file prior to 5pm denied

Dear Reno J ustice Court Administration and Filing Office, DDA Young and DPD Goodnight,
Hello, I am emailing and faxing the document and one exhibit you will find herein as I was denied my right to file it today. I
presented to the court prior to 5pm today but was prevented from filing this document (and today is the last day to file these
pretrial motions absent receiving leave of court to do so prior to the February 29th, 2012 Trial in Department 2 before J udge
Sferrazza. J udge Sferrazza has, in the past, expressed displeasure with regard to any attempt to file by email, and I do not
wish to upset J udge Sferrazza here, and accordingly am not copying him on this correspondence. However, I believe the
"excusable neglect"/"deprivation of rights under color of law" analysis may dictate that I promptly attempt to make some record
of my attempt to file and in that regard I am submitting this to you now.
Incidentally, I did call the criminal division RJ C filing office today shortly before 5pm alerting them to my imminent attempt to
access justice and received confirmation that they would not close prior to 5pm. HOwver, the doors of the court house were
locked prior to 5pm. I have witness timers/clocks in the court to be set approximately 5 minutes fast in that past. I attempted
to ask a supervisor about this by alerting Chief Deputy Sexton, and while he initially refused to get a supervisor, he then finally
indicated he would, however, no supervisor ever appeared. Chief Deputy Sexton, along with another Deputy has sexually
assaulted me in that past, and as such, of course, the was a very unusual and uncomfortable situation.
Additionally, I had another landlord tenant hearing involving myself on Monday, 2/3/12. AS per J CRRT my case was randomly
assigned to J udge Lynch. However, just prior to my case being heard, Deputy Sexton entered the court room, made some
calls, and J udge Sferrazza appeared to hear my case. J udge Sferrazza then proceeded to grant a property manage a license to
practice law on behalf of Park Terrace Homeowners Associations (PTHOA). I, of course, am very uncomfortable having the
Deputy who sexually assaulted me appear in the court room at all my appeances, as Deputy Sexton seems to do (in fact, he
glowered over me at the 12/21/12 Hearing on my Motion to Contest Personal Property lien) in such a menacing fashion that I
was unable to think clearly, much to the detriment of my case. Further, I am uncomfortable at the appearance given off by the
curious changing of the J udge assigned to my hearing after Deputy Sexton entered the court room and made a few calls. It
may be inappropriate to give off the appearance that Deputy Sexton is able to control the assignment of J udges to certain
cases rather than having cases randomly assigned pursuant to J CRRT. I believe this filing and one exhibit you find herein
should be accorded a filing date for 2/14/12, as I was prevented from appropriately accessing justice, and in that regard, I
don't believe this is a request to "bend" the rules or allow a special exception, though I do believe one is able to file a motion
seeking such an exception for cause. Deputy SExton has sexually assaulted me in the past in similar situations where I attempt
to use all of the hours available to filing accorded to any other member of the public.
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

** 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.