11 7 12 0204 62337 Bates 2701 To 3,094 Formal Hearing File SBN v. Zachary B. Coughlin SBN Violates SCR 105 (2) (C) With Index Link

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Laura Peters
From:
Patrick King
Sent:
Thursday, April 19, 2012 2:35 PM
To:
Laura Peters
Subject:
FW: CORRECTION CHANGE OF ADDRESS ATIORNEY ZACH COUGHUN, ESQ.
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]

Sent: Monday, April 16, 2012 3:55 PM
To: Suzanne Walters; Patrick King; David Clark; Glenn Machado
Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHUN, ESQ.
Dear Suzanne,
I check the portal and notice that too, sorry I meant to write you back and
say "nevermind" .1 am sorry to have had to change my address so much recently, I
know it is probably more work for the Bar.
Thanks
..
Sincerely,
Zach Coughlin, Esq., PO BOX 3961, RENO, N V, 89505, tel: 775338 8118, fax: 949667 7402;
ZachCoughlin@hotmail.com
Nevada Bar No: 9473
From: SuzanneW@nvbar.org
To: zachcoughlin@hotmail.com
Subject: RE: CORRECTION CHANGE OF ADDRESS ATTORNEY ZACH COUGHUN, ESQ.
Date: Mon, 16 Apr 2012 21:44:47 +0000
That is what we have Zach
From: Zach Coughlin [mailto:zachcoughlin@hotmail.coml

sent: Monday, April 16, 2012 2:39 PM
To: Suzanne Walters; 5upport@baralliance.com; renodirect@reno.govi cQurtadmin@washoecourts.us;
courttech@washoecourtS.YSi joey.hastings@washoecoyrts.ys; joey.orduna@washoecourts.us;

craigJranden@washoecourts.us; kstancil@washoecounty.us; stuttle@washoecounty.us; rbaker@washoecounty.u5
Subject: CORRECTlON CHANGE OF A DDRESS ATTORNEY ZACH COUGHUN, ESQ.
Dear State Bar of Nevada, 2nd Judicial District Court, Reno Justice Court, et
ai,
Please let me clarify and or change my recent communication. In my last
correspondence I made a misstatement based upon my misreading of SCR

79.
Please allow me to correct that. My preferred mailing address and my

1
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""-'''''.
SCR 79 address shoula"Oe the same, as listed dire
""""',
dTy below:
Zach Coughlin, Esq.

PO BOX 3961
Reno, NV 89505
Tel: 775 338 8118
Fax: 949 667 7402
email: ZachCoughlin@hotmail.com
website: www.ZachCoughlinEsg.wordpress.com
please make all the above information my preferred mailing address and
publicly available.
As for any alternate mailing address, please change that to:
Zach Coughlin, Esq.
945 W. 12th St.
Reno, NV 89503
I will attempt to make these changes myself at the "portal" found at

www. nvbar.org in the member section, however, I am contacting you now
in an abundance of caution.
Sincerely,
Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118,
fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
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Laura Peters
Patrick King
Friday, April
From:
Sent:
To:
27, 2012 11:19 AM
Laura Peters
Subject:
FW:
Update and a Request
Sent: Friday, April 27,2012 12:13 AM

To: Patrick King; David Clark; Glenn Machado; coe@gbis.com; keith@leelawoffice.net
Subject: Update and a Request
Dear
Bar Counsel,
I was never afforded an informal meeting or an opportunity to view the materials
submitted in conjunction with the various grievances or other types of complaints
I given a deadline to respond for any such matters outside the

deadline related only to the Hill "grievance". I ask that the process be paused and
that those procedural safeguards be afforded me. Further, I have met with Coe
against me, nor was
Swobe recently and discussed this matter and ask that all avenues available to me
be held available, until
I have had a a legitimate chance to explore them. I
apologize for what may seem an overly adversarial tone so far on my behalf and
pledge to work with you from hereon in addressing these matters of concern.
Sincerely,
Zach Coughlin, Esq.
Zach Coughlin, Esq., PO BOX 3961,RENO, NV, 89505, tel: 775 33881 18, fax: 94966 7 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
From: PatrickK@nvbar.orq
Subject: RE: Mr. King's assertion in his 3/16/12 letter
Dat e : Thu, 19 Apr 201
221:29:10 +0000
April
19, 2012
Zach Coughlin
Dear Mr. Coughlin,
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A screening panel of the No
rtn Nevada Disciplinary Panel met on Tues April 10, 2011 to address the
grievances filed against you. The panel directed me to proceed to a formal disciplinary heari ng.
preparing a formal Complaint.
As such, I will be
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 Gardner's 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 counsel's investigation and that you respond specifically to the allegations contained in Judge
Holmes and Richard Hill's grievance letters to the office of Bar Counsel.
Pat rick King

To: Patrick Kingi David Clarki 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 stealing my portion of the rent or falling to pay her own portion until
August 2011, as the landlord was on an extended vacation and failed to communicate any deficiency in the rent until mid
August, 2011, and the eviction in RJC REV201 1-001708 from my former home law office ensued within less than a week
of his communicating this defiCiency. He and his counsel, Richard G. Hill, Esq. and casey Baker pursued a No cause
Notice of Eviction because there was a wealth of support for me contention that habitability issues, fix and deduct, and
the landlord's failure to cure, in addition to personal property damage done by the landlord's landscaping crew and a
provision in the lease holding the landlord liable for such, indicated it would "be the path of least resistance" to simply
seek a No Cause Eviction. The only problem in their attempt to circumvent the law (even though they still threatened to
seek back rent in another forum after getting their No Cause, summary eviction) was the fact that the Lease Agreement
specifically allowed for me to have a commercial law office there, and NRS 40.253 makes impermissible a summary
eviction against a commercial tenant unless the non-payment of rent is Notice, which, of course Baker and Hill chose not
to do....and it was about the time that Hill started to understand that his "wrong site surgery" for his neurosurgeon
landlord client might subject Hill and his firm to some malpractice liability, that Hill started writing letters to bar counsel
attempting to start some grievance on behalf of Gessin (whom Hill did not find so objectionable when Gessin was Hill's
client and Hill was milking over $20K from Gessin) for "ghostwriting" even though I was listed as Attorney of Record on
several different Gessin cases, etc., etc.
Anyway, I deny guilt on each an every allegation made against me by Hill, Judge Nash Holmes, and whoever else has
filed a grievance or complaint and also with respect to any criminal charge against me, including that which resulted in a
conviction in 11 CR 22176, which, I think will ultimately reveal was replete with prosecutorial misconduct, lying by the
Wal-Mart loss prevention aSSOCiate, and lying by the two RSIC police officers, in additional to abuse of discretion and
other errors by Judge Howard.
I am writing to report that I did not receive Mr. King's 3/16/12 letter until a substantial time after it was sent The
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postma
on that 3/16/12 letter from
stant Bar Counsel King (please see attach'Ei picture of the letter and envelope)
indicates it was mailed 3/16/12, and the letter indicates it was not faxed to me (despite my numerous written requests
that such a practice be done in consideration of the problems I have encountered in the USPS violations of the Federal
Torts Claims Act and incident to the domestic violence I have been subjected to, in FV12-00188 and FV12-00187, which
included interference with my mail).
I timely filed an Official Change of Address with the USPS. Additionally, I made numerous appearances at both the
Golden Valley USPS Station and the Downtown Reno Post Office in and attempt to make every diligent effort to receive
my mail.
I have been threatened by and lied to by the supervisors of the Golden Valley Station USPS Station. I had a
hearing related to a landlord tenant dispute on 3/15/12 (which makes Judge Nash Holmes assertion, in her 3/14/12 letter
that I was living in my car at that time rather suspect, given my home law office was located at the property which was
the subject of that hearing and which I was still located at on 3/14/12 ...of course, Judge Nash Holmes provides no
attribution for such hearsay in her extremely reckless assertion) in RJC REV2012-00374 (the matter for which Gayle Kern
sent a property manager who lacked even a law license to litigate on her behalf, or on that of the HOA which Kern has
now decided to appear for, despite her being listed a the PTlliO A Resident Agent for sometime and despite Kern being a
named party in the lawsuit in RJC Rev2012-000374.
My point is, I did not receive Mr. King's mailing of 3/16/12, in a timely manner, and as such, I am requesting more time
to respond to it. Additionally, I note that Mr. King, in that 3/16/12 letter, writes "I am enclosing with this letter copies of
a grievance letter, from the Municipal Court and a copy of an Order from District court. ..1 will make available for your
.
review and inspection the supporting documents and audio recordings."
However, as I have previously written, Mr. King has not made "available for (my) review and inspection the supporting
documents and audio recordings". 1 wish to have a copy of all such "supporting documents and audio recordings", and
failing a copy being provided, I wish to be allowed the access to conduct a "review and inspection" of "the supporting
documents and audio recordings" that Mr. King promised to afford me. At no time has Mr. King ever allowed me such
access. In addition, Mr. King now informs me that he has opened a grievance on behalf of Judge Linda M. Gardner,
incident to a Order for Sanctions she entered in April 2009. Mr. King has refused to indicate to me who submitted this
Order for Sanctions or otherwise provided it to Bar Counsel as a Complaint or Grievance or otherwise. I believe someone
necessarily must file the complaint or grievance. Further, I believe 1 am entitled to know whom that is, and when such
was filed. Additionally, Mr. King has, so failed to provide a copy or any access to any purported complaint by the City of
Reno Marshal's division incident to my accessing justice, or attempting to, on March 22nd, 2012. I am again requesting
that I be so provided as much.
I filed an Official USPS Change of Address on March 12, 2012, in anticipation of a change of address incident to a landlord
tenant hearing set for March 15th, 2012, and further, in response to hostility, retaliation, lies, and threats made by the
USPS Golden Valley Station supervisors Buck Hyde, Terri James, and a "Ms." Passot. Some mail, like Mr. King's 3/16/12
letter to me, was eventually forwarded to me (Mr. King's letter has 3 different yellow stickers affixed, one atop the other,
on it by the USPS), however, some mail, like several Orders of the Reno Municipal Court, were not forwarded on to me,
but rather, apparently, returned to the Reno Municipal Court. Nonesuch Orders were returned to the RMC in time for
Judge Nash Holmes 3/14/12 letter to Mr. King, as such, I have no idea what Judge Nash Holmes is referring to when she
describes difficulty contacting me (the attempts by Judge Nash Holmes and the RMC apparently did not included either
email or fax or a phone call, however .... ).
There has been little rhyme or reason as to what mailings the USPS simply returned to the sender (such as a mailing from
the RMC dated 3/14/12) and which mailings it ultimately forwarded on to me (at my then PO BOX 60952, please note, 1
have a new PO BOX, that 1 intened to keep for a substantial period of time, it is PO BOX 3961, Reno 89505... ), such as a
3/13/12 mailing from the Reno Justice Court, which was forwarded on to my then PO BOX 60952 (albeit that envelope
has 3 yellow stickers stacked atop each other as well, the farthest one down indicating a forwarding date of 3/21/12, then
next sticker indicating a hold, and the final sticker atop the stack indicating a forwarding date of 3/28/12 .... ).
I stayed in a weekly motel for an extended period of time following my November 2011 No cause eviction from my
former home law office, and there was difficulties in filing a Change of Address incident to that given that the Address
being changed from was permanently assigned to a bUSiness, a motor lodge. Further, some problem cause Bank of
America to temporarily deny my attempts to change my address on file online, and rather require that I mail Bank of
America a signed letter requesting as much, all the way to Florida. That resulted in delays in filing an online Change of
Address with the USPS, given the USPS demands the onli ne changes be made with one's own debit card, and that they
debit card bare the same billing address as the location one i s filing a change of address from, or else, the USPS, will
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Y-lO days to tohe processing time.
rocess such a request, but it will add
. ..."
. , -;.. .
"iat option given mailign a letter to
I chose
Bank of America in Florida would have taken just as long. IN the interim I went to the Golden Valley USPS Station and
explained these circumstances and the supervisor, beyond calling me a "squatter" in advance of the hearing in RJC
REv2011-000374 (and refusing to divulge whom had been providing information to them resulting in such a prejudicial
view of my tenancy at 1422 E. 9th St. #2, Reno 89512), informed me that while my Change of Address to my then PO
Box 60952 was being processed, my mail would be held at the Golden Valley Station and that I could retrieve it there for
the next 7-10 days. When I returned in the following days, a supervisor named Buck Hyde literally assaulted me, and he
and two other supervisors there, Terri James and "Ms. Passot" Informed me they were "Feds" and didn't have to put up
with any crap from an attorney related to state laws like NRS 118A.190, though they couldn't cite specifically to any
section of Title 39 of U.S. Code justifying their refusal to allow me a mailbox key to my former home law office at 1422 E.
9th St. #2.

Sincerely,
Zach Coughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel: 775 338 8118, fax: 949 667 7402;
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Patrick
g
Kin
From:
Zach Coughlin <zachcoughlin@hotmail.com>

Tuesday, May 22, 2012 11:31 P M
Patrick King; David Clark
update for In Re Coughlin SCR 111
Sent:
To.:
Subject:
Dear Bar Counsel,

I am sorry for how I conducted myself in my dealings with you over the last few
months. Below, please find some updates on my progress.

Sincerely,
Zach Coughlin, Esq.

PO:BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
From: zachcoughlin@hotmail.com
Tp: geofg iles@hotmail com; judgemcgee@aol.com; keith@leelawoffice.net; coe@gbis.com
Subject: RE: In Re Coug h lin SCR 111 petition to avoid temporary petition from practice of law FW
Date: Tue, 22 May 2012 23:26:14 -0700
.
Hi
Geof and Judge McGee,

Thanks for the note you wrote below. Somehow, I missed it until now. I was
moving everything I own and unpacking it from about 5/5112 until just a couple
days ago, so things have been difficult. I moved everything with a honda accord. I
am talking many trips, by myself, roping things to my roof, everything.
deaf, I am disappointed that I didn't get you something better for the Thursday
filing you wrote of last week vis a vis the foreclosure trustee actions as void due to
the lack of a debt collectors license . . . you deserved better, sorry. But, I did collect
and previously send you a lot of stuff on that issue, some scanned (rats) and some in
Cligital ocr ready format from the s ct law library . . .1 just need to distill it more, and
that didn't get done in time.
.
Judge McGee, sorry I missed the Thursday group last week.
I am amazed that I
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didn't go, but I just didn't. T'had a very emotional day an~week last week and 6pm
rolled around and I was just spent. 10 months off my antidepressants (not by
choice, but because I simply couldn't afford them), then starting back up on them on
4' 28 12 resulted in a flooding of emotions and grief over my divorce, family
problems, career dumpster fire, etc. I am exercising again daily after about 18
!n0nths of not doing so (I have always exercised to regulate my mood) and am
experiencing benefits from that.
1 don't know if all this can be undone, but I am making progress each day, and that
has always been the recipe for me to get back on track, ie, to eat the whale one
spoonful at a time, one day at a time, etc.
twant to get together some apology letters or something for Judges Nash Holmes
(though I did apologize at my last hearing before her), Judge Adams, Judge Elliot,
Judge Sferrazza (although he and I seem to have a pretty good rapport, I believe ... he
rha~e ajoke about me being part of the "roller derby" the case before me involved),
~iiH probably many others ....
" "' 1 1:
"
iihe 'thing about this Wal-Mart petit larceny ofa chocolate bar and some cough
mydication drops/melts is that I did not go into the store and grab those items and
h~aYe.. The Wal-Mart associate said I ate the chocolate bar (and that they saw me
take it off the shelf in the candy isle) while I was shopping for any paid for $90 of
oth; r groceries. However, the UPC of the chocolate bar shows it was an ice cream
e
bar, meaning it wouldn't have been in the candy isle, but rather the refrigerated
isle. Then, the Wal-Mart witness admitted he could not hear whether or not I told
the cashier ringing me up whether I had a quantity of 3 of the cough medication
drops/melts and the Walmart and Indian Colony Officer testified that on the receipt
for the items I did pay for, the UPC of the type of cough medication melts they say I
sible did not appear. Also, amazingly, the Wal-Mart loss prevention associate
t,estitied that he could glean, from 30 yeards away, each and every item the cashier
rung up for me and that those items did not include such a box of the cough
meclication melts.
~
'i.:.
However, I showed in court and in exhibits that the receipt for the items I purchased
~iclhave one item with the same UPC as the exact type of cough medication melts
(theyhave dextromethorphan in them and if you take enough of that stuff it will
make you forget about the effects of coming of antidepressants too rapidly,
processing a divorce from 4.5 year relationship, a father physician who can have
2
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"I'tt care and mental health

difficulties recognizing b6Undaries vis a vis his son's hea
care, and who can, at times, seem a bit of a saboteur to his son's life in the pursuit of
serving him the "incomprehensible demoralization" the he feels so necessary to the
process, etc .... plus getting fairly whacked out on cough syrup doesn't carry quite the
same shame of a relapse the street drugs and alcohol would to some... ). So the
Wal-Mart loss prevention associate admitted neither he nor anyone at Wal-Mart
could say that they could hear whether I told the cashier a quantity to ring up for the
cough medication melt box with the same UPC as the ones Wal-Mart alleges were
stolen or consumed while shopping ....
Further, the Indian Colony Officer testified that he only arrested me and conducted
a search incident to arrest because I didn't provide me driver's license to
Him. However, the video of the Wal-Mart interrogation room interview clearly
shbws me giving the officer my driver's license and him radioing it in to his
:',
dispatch and him taking down the DL number and other information off of
R Further, the receipt from the $90 of groceries I paid for contains an entry with
he!VPC of the exact type of cough medication melts that the officer found in my
pocket upon conducting the search incident to arrest. The Wal-Mart associate and
hl;di'an Colony Officer both testified that the receipt did not contain an entry for the
c,dugh drops, but the copy of the receipt in the police report and discovery and a
review of the UPC and subsequnetly looking up the item assigned that Universal
Parcel Code clearly shows that a box of those cough medication melts were, in fact,
included on that receipt.
f'
.:
<
('htn, all for owning up to things but this wasn't a "walked into the store, grabbed
Sbnie stuff, tucked under one's shirt, and dashed away" type situation. Plus Wal
Mart's loss prevention staff had told me just weeks before they would retaliate
itgairtst me by having me banned from all their stores for arguing with their
customer service personnel about a curious practice wherein Wal-mart staff and
managers seem to "forget" the terms of their store's return policy and or claim that
pdlicy is a "courtesy" rather than a bargained for term included in a contract for the
sale of goods:
ttp:/Iwww.enotes.com/consumer-issues-reference/purchases-and-returns
About a week ago I sent Ba r Cou nsel a pri ntout of all my prescription
tno ication history since February 2008 and it showed some i nteresting
th{ngs vis a vis ttiat Wal-Mart arrest and my firing from Washoe Lega l
ervices in May of 2009. At both times I was out of my antidepressant,

3
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lite
Wel lbutrin . I n May of }t)09 there was somethi ng l

a 21 day delay with
the pharmacy a nd my doctors office in getting my refill done. At the time
of'the September 20 1 1 Wa l-Mart petit larceny a rrest I had stopped taking
my a ntidepressant beca use I didn't have the money to pay for it o ut of
pocket. My dad wouldn't give me a ny samples of it or a loa n or whatever to
get a temporary supply. I get it, I am a grown man, need to pay for my
own stuff or figure somethi ng out. However, that same logic should
probably prevent my Dad from cal l i ng up State Bars a nd the Dea ns of law
cools and my girlfriends and seemingly trying to arra nge for some
"incom prehensible demoral ization" to be delivered to me, b ut it often
doesn't. I l ove my Dad to death and thin k the world of h im, but he and I
haVe a bit of obsessive compulsive disorder sometimes and he just has rea l
pnolems staying' out of my mental health care, particularly where it may
involve taking a medication he would prefer I not ta ke. Hopefu l ly, Bar
Counsel will appreCiate my forwarding my certified prescri ption history to
them, but I have no idea if they will or not.
.. .
..
Its fun ny, both my sisters have divorces from a lcoholics in the last 2 years
pnd everybody tells them they need AI-Anon. I have a divorce from a n
alcoholic type-1 diabetic who starts dri n king again right after leavi ng me
(after stea l i ng two months of rent from me by not forwarding my
contribution to the l a ndlord, i n addition to getting a g rand i n loans and gifts
from my mother, sisters, a nd other family members that she still hasn't
tatted to pay back, leaving just 2 days after finally graduating from UNR
\,MittJ a degree i n journal ism that I contributed
lots of money a nd sweat to. . . )

a..ndmy fam i l y decides I am a jerk off, won't loan me a d ime, my dad won 't
chip me off a box of Wel l butrin a ntidepressa nt sa m ples that he gets for free
and which he sta rted me on when I was 17. What, don't I need AIAnon? Ah ...s hoot, its th is type of com pa rison thi n king that got me s u i ng
Washoe Lega l Services. I am a whiny l ittle bitch sometimes.
"" ',0
.'
hldge McGee, I hope your hip is coming along and I will be there for sure Thursday
jght.
L!U upset about how this year has gone for me and disappointed in myself in many
)vays and know I have to do better and have to make amends.
.. .
. ....
".. ..,
':
... "
j;..:,i '"
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Sincen51y.
Z.ach Coughlin
From: geofgiles@hotmail.com
To:zchcoughlin@hotmail.com; judgemcgee@msn.com; judgemcgee@aol.com; keith@leelawoffice.net; coe@gbis.com
Subject: RE: In Re Coughlin SCR 111 petition to avoid temporary petition from practice of law FW
Date: Wed, 9 May 2012 02:01:17 +0000
am having trouble following this.
The assistant bar counsel filed a petition for a temporary suspension, and I assume
you wish to contest this. However you eMail says you want to do a 'show cause as to why you shouldn't be suspended',
is this a typo or are you offering to stipulate to that? If you wish to get things back on track, you need to speak with
someone who knows the 'ins and outs' of Supreme Court practice. That's not me, though I have managed to follow the
rules all these years. May I suggest David Hamilton who is tops in this, but pretty obnoxious, If he thinks you've gotten
a raw deal, he might help you out. I dont know, under his rough exterior he really does care about justice. Or you could
call cal Dunlap, who has represented many professionals before administrative agencies. I have a feeling that he will be
expensive. If you insist on doing this yourself, please call me in the morning as I am free until noon. I give you this
'9<lvi!?e' as a friend and not your counsel. I hope you can distance yourself from your problems, but the first step in that
9ir'ection is to acknowledge you have them. Geof Giles
From: zachcoughlin@hotmail.com
to:' geofgiles@hotmail.com; judgemcgee@msn.com; judgemcgee@aol.com; keith@leelawoffice.net; coe@gbis.com

5I:Jbject:In Re Coughlin SCR 111 petition to avoid temporary petition from practice of law FW: Adverse ruling on
foreclosure from Judge Kosach
Bate: Tue, 8 May 2012 15:31:31 -0700
Dear Judge McGee and Mr. Giles, Mr. Lee, and Mr. Swobe,
t',/
(hope yoru surgery goes well today, Judge Mcgee, best wishes for that and a speedy recuperation. Mr. Giles, I am
disappointed to see the result in LaBrosse, but know you did the best work anybody could have done, and that, hopefully,
cases like Meluzio and In re Johnson:
http://www.jdsupra.com!post!documentviewer.aspx?fid=0441f3d3-291e-427S-aafe-11e212f6fc97
nttp:/!law.justia .comlcases/north-carolina!court-of-appea Is/2009/081263-1.html
l hate to write either of you about this at this time, but time is of the essence. I am preparing a motion to Show cause
Winy I should not be temporarily suspended from the practice of law in light of the Petition of Bar Counsel for Temporary
$\Jsp'ension From The Practice of Law Pursuant to SCR 111 that is attached, and was filed on May 3, 2012. I feel I need
to,get something filed with the Nevada Supreme Court in the next 3 days or so to avoid a Situation where such an Order
u spending me from the practice of law is entered prior to me having a chance to say my peace. I feel I am innocent of
this charge, and that my going off my antidepressants suddently because I could not afford them because my girlfriend
stole two months of rent from me played a large role in this conviction. This was my live in girlfriend of 4 and half years
whom I helped finish her final 3 years of college. She had four years of sobrierty (we met in AA) before breaking up with
rrte two days after graduating from UNR and starting to drink again. The break up had a real divisive result in terms of
my relationship with my family, particularly my father, as much of my family seemed to really "side" with my girlfriend in
fhe:breakup (both of my sisters had divorces in the last 18 months and it seemed to create somewhat of an anti-male
sentiment in my extended family). I know I have my faults and a role in all of this, and am renewing my recovery
efforts. However, I feel that those who may be able to watch a condensed movie of the last, say, 10 months of my life
may be somewhat impressed at the dedication I have displayed to my clients and the practice of law and the resilience
and tenacity I have demonstrated in overcoming some tough obstacles, including a summary eviction from my former
home law office where the nonpayment of rent was not plead, something expressly prohibited by NRS 40.253, on top of a
027 1 3
02713
...........
ite"t
"rent escrow" deposit of $2,300 bein

manded by the Reno Justice Court, desp
he law of a corollary to Las Vegas
Justice Court Rule 44 in the Reno Justice Court, and the dictates of JCRCP 84 requiring that any such rule be published
and signed off on by the Nevada Supreme Court prior to its implentation. Rules like JCRCP Rule 44 exact quite a tole on
communities, and a re only warranted, if ever, i n the most unique of drcumstances (such as in a town like Las Vegas) and
really do not have a place in com munities like Reno, i n my opinion.
Further, I believe police and prosecutorial misconduct played some role and that the Reno M unicipal Court was remiss in
not contemplating mental health court in any way, or otherwise alerting me to the possibility thereof, especially where I
'Was denied my Sixth Amendment Right to Counsel, particularly where I feel I established my i ndigency, and was
wrongfully evicted from my former home law office less than one month prior to the trial date, for which my request for a
continuance was denied, despite my indicating to the court that opposing counsel in the eviction matter was applying a n
(jnlaful ren t distraint under NRS 1 18A.520 to exculpatory materials. Additionally, Judge Elliot's Order seems t o apply a
Civil standard to the issue of whether the RMC was to create transcripts of the Trial in my appeal (an bill me later, rather,
'jUdge Elliot's Order cites a civil statute that allows the court to not even begin making the transcripts until they have been
paid for, however, this is a criminal matter, and this, in conjunction with my being denied my right to counsel,
incarcerated for three days under a summary contempt ruling, and mental health court not being broached in any way,
'
may provide some avenue for arguing that a temporary suspension from the practice of law is not warranted).
peported this arrest to my psychiatrist, Dr. Vassar, of Ascent Neurobehavioral Insitute, and he confirmed that I called
and cancelled my August 2, 201 1 apPOintment and indicated I would not be filling my prescriptions (and I have pharmacy
records indicating that I did not so fill those prescriptions during this August-September period...the arrest was on
September 9, 201 1 for the conviction resulting from RMC 11 CR 22176... I filed a 60b motion for relief from judgement in
that matter at the trial court level, while the case was on appeal before Judge Elliot, on March 23, 2012 ... but I have not
filed a Request for Submission of that Motion yet... but should it be overturned by Judge Howard, that may help with
avoIding a suspension from the practice of law. I would appreciate any input as to how I might proceed with that 60(b)
?tion before Judge Howard and any other input you might offer).
1 have a diagnosis of Major Depressive Disorder on file with Dr. Vassar and the Mental Health Court has agreed to accept
'
me and I would like to see about getting the conviction in RMC 11 CR 22176 overturned and placed into Mental Health
Court in that regard. I do not know whether I am allowed to contact Judge Breen (he swore me in with Keith Lee and
Coe Swobe in attendance) about this and would appreciate your input. Hopefully, the fact that Judge Cherry was sworn
il1 as Chief Justice recently will help in managing to get the Cou rt to take a rehabilitative view towards this matter.
Ariyhelp you can offer is much appreciate, of course, though I know the work you are doing is so important that I am
'
hesitant to ask you to associate with this Situation, but I do feel I am innocent here, and further, I am not sure
consuming a chocolate bar and or cough drops while shopping for and payign for $90 of other merchandise is tantamount
to "theft" in the sense that word is used in SCR 1 1 1. Further, while paying for those items, items of the same UPC
hu mber were purchased, and at trial, the Wal-Mart witness did admit that it is an established practice at Wal-Mart, when
items a re being rung up, to indicate a quantity of one item to the cashier, whom would type that quantity in rather than
sdmhing, say, three boxes of cough drops.
dditionally, the Reno Sparks Indian Colony Officer testified that he made a custodial arrest, and conducted a search
frkident to arrest in light of my refusal to provide my driver's license ... however, the video from Wal-mart interrogation
rooniprovided by Reno City Attorney Pam Roberts clearly shows me giving my driver's license to the officer, and further
s,hows him radioing the number off of it in, thereby undermining his rationale for failing to issue a Citation, but rather
conduct a search incident to arrest, wherein a cough d rop was found in my pocket. The receipt from the $90 of items I
Rai d for has an entry for the UPC of that very type of cough drops.
Sincerely,
"
ZachCoughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel:
775 338 8118, fax: 949 66

77402;
. _-
. _ _ .
--------""----" "
. - ._ .
From: geofgiles@hotmail.com
To: attcbf@cox.neti mark@markmausertlaw.com; mcI3303@aol.com; zachcoughlin@hotmail.com; tahoephil@gmail.comi
t2@kqswproductions.com
027 1 4
02714
Yom Judge Kosach

Subje0:: Adverse ruling on foreclosure
221:11:07 +0000
Date: Tue, 8 May 201
Welt here is an order that just came down from Dept 8. It was a hard fought and well briefed case, I am considering a n
appeal but doubt that I will d o it, unless you see something glaring. I used a l l the latest techniques i n hopes that I could
get a better result than I am getting in federal court, but to no avail. It's a long case, so if you don't have time, I
understand. Geof
"::"".
027 1 5
02715
.>.
Laura Peters
Patrick King
Friday, May 11, 2012 10:54 AM
fieri. Hlitrl1Jtty (SCH"Jls,_"'*f1crg)
From:
Sent:
To:
Cc:
Subject:
Laura Peters
FW: lach Coughlin
FYI
\I!
F;:;;Bre:e;Fm'g:sai7e:.-
Sent: Thursday, May 10, 20125:23 PM
To: Patrick King
Subject:
lach Coughlin
Mr. King:
You recently filed a petition seeking the temporary suspension of attorney lach Coughlin (Supreme Court case No.
60838).
Mr. Coughlin's improprieties go way beyond just that theft conviction. He's been sanctioned or threatened with sanctions
by multiple Nevada courts. Nevada courts have warned him about filing frivilous pleadings and about using profanity in
his pleadings. He has had multiple attorney's fees awards entered against him, but he never pays them. The list goes
on.
I know this because I represent a client that had the bad luck of coming into Mr. Coughlin's line of fire. Both cases were
dismissed and Mr. Coughlin appealed both. I was planning on filing a complaint with the state bar about Mr. Coughlin
after the appeals were dismissed, but when I saw your petition, I thought I would mention this to you so you have a full
picture of exactly who Zach Coughlin is.

Feel free to contact me.
Brian A. Gonsalves, Esq.
530-386-6845
027 1 6
02716
IN THE SUPREME COURT OF THE STATE OF NEVADA
1
2
3
4
ORIGINAL
In Re: Matter of
)
)
ZACHARY B. CQUGHLlN, ESa. )
Nevada Bar No. 9473 )
Case No.
6tJ!3i
FILED
5
6
7
8
In accordance with the requirements set forth in Supreme Court Rule ("SCR") 111(4),
the State Bar of Nevada, by and through its Bar Counsel, David A. Clark, hereby notifies the
10
Supreme Court of the conviction of attorney ZACHARY B. COUGHLIN Nevada Bar No. 9473,
11
after a trial and an appeal on a charge of larceny (theft.)

STATEMENT OF FACTS
12
13
Mr. Coughlin is a member of the State Bar of Nevada. His Bar Number is 9473. Mr.
14
Coughlin was admitted to the Bar on March 25,2005. His date of birth is September 27,1976,
15
and he is 36 years old.
16
17
18
19
20
21
22
23
24
25
Mr. Coughlin was recently convicted of a crime involving theft. On November 30,2011,
Mr. Coughlin was found guilty, after a trial, of the offense of Petit Larceny, a violation of RMC
8.10.040, in Municipal Court for the City of Reno. See Exhibit 1.
On September 9, 2011, Mr. Coughlin had shoplifted a candy bar and cough drops from
a WfillMart store with a value of approximately fourteen dollars ($14.00). Mr. Coughlin
appealed the judgment of conviction. The judgment of conviction was affirmed on appeal. See
Exhibit 2.
As evidenced by the documentation submitted herein, Respondent has been conviCted
lI rting requirements of Bar Counsel under SCR 111(4).

<)
additicmA'P<8 loj7) and (8), state that upon receipt of a petition demonstrating that
of a crime
'. t9irt t
an attorne
asrsi'4fif'''wa d
W
DEPUTY CLERK
a " serious crime, the Court shall enter an order suspending
02717
02717
Patrick King
From:
Sent:
To:
Subject:
Attachments:
Townsend, Lo ri < LTownsend@washoecounty.u s >

Wednesday, April 11, 2012 1 1:34 A M
Patrick King
Zachary Coughlin
RCR201 1-065630.pdf; RCR2011-065630-Motion.pdf; RCR2011-063341.pdf
Hi PatrickH ere are the two outstanding criminal cases against M r. Coughlin in Reno J u stice Court. Case numbe r RCR
2011-063341 is set for trial on May
ih at 9:00 am;
Case RCR 2011-065630 is t h e one awaiting t h e results of
the com petency evaluation. I also included a notice/motion that he filed in the gross misdemeanor case. I did
not include a p l e ading entitled "Pre Trial Motions" he filed in t h e misde meanor case (it is in excess of 200
p ages), but if you wo uld like to see that, I can send you a copy.
He is also emailing staff mem bers with links to
his YouTube pages.
Please let me know if you need anything else.
RCR2011-065630.pdf RCR2011-065630-Motion.pdf RCR2011-063341. pdf

Lori
Lori cr'ownsena
Judges' Secretary
f\eno Justice Co u rt
P. O. Box 30083
Reno, NV 89520
775-325-6550
0271 8
02718
Patrick King
From:
Sent:
To:
Subject:
Attachments:
Townsend. Lori < LTownsend @washoecounty.us>

Wednesday, Ap ril 1 1, 2012 11:34 AM
Patrick King
Zachary Cough li n
RCR2011-065630.pdf; RCR2011-065630-Motion.pdf; RCR2011-063341.pdf
Hi Patrick Here a re the two outstanding cri m i n a l cases against Mr. Cough l i n i n Reno J u stice Court. Case n u mb e r RCR
2011-063341 is set for trial o n M ay
th at 9:00 am;
Case RCR 2011-065630 is the one awaiting the res u lts of
the competency eva l u ation. I a lso included a notice/motion that he fi led in t h e gross m isdemeanor case. I did
n ot i n c l u d e a pleading entitled "Pre Tri al Motions" he fi led in t h e misdemea n o r case ( it is i n excess of 200
pages), but if you wou l d like to see th at, I can send you a copy.
He is also e m a il i ng staff mem bers with l i n ks to
h i s YouTube pages.
P l ease let m e know if you need a n yt h i n g else.

R C R201 1 -065630. pdf R C R201 1 -065630-Motion. p df R C R201 1 -06334 1 . pdf
Lori
Lori rr
ownsena
J u dge s ' Secreta ry
Reno J u stice Court

P. O. Box 30083
Reno, NV 89520
775-325-6550
027 1 9
02719
Patrick
King
From:
Sent:
To:
Ken Howard < Howard K@reno.gov>

Wednesday, April 04, 2012 10:47 AM
Patrick King
Patrick
I don't know if you are interested in this or not but Mr. Coughlin has numerous po stings on V-Tube . Some
relate to his various court proceedings. A sampling: Events at Reno Municipal Court 3/1 2/ 1 2 ; City of Reno
Reno Marshal Harley DCA Allison Onnaas ; RMC bounced by Reno Marshals.
The moniker is 25TeddyJames
Ken Howard
Reno Municipal Court Judge
Department 4
(775) 3 26-6673
':; Vision without action is a daydream, action without vision is a nightmare. " Japanese Proverb
02720
02720
0 3 / 2 2 / 2 0 1 2 1 3 : 1 7 FAX
From:
To:
Cc:
Date:
MUN I C I PAL COURT DEPT 3
0002 /0003
Page 1 of 1
"cassa ndra Jackson" <JacksonC@reno.gov>

"Jay Dilworth" <DiIworth@reno.gov>,"Dorothy Nash Holmes" <HolmesD@reno.gov>,"William
Gardner" <GanerW@reno.go>, "Ken Howard" <HowardK@reno.gov>,uJustin Roper"
<RoperJ@reno.gov>,"Gregg DeIghton" < DelghtonG@reno.gov>
-Marilyn Tognoni" <TognonIM@reno.gov>, "Maya Shennan" <ShermanM@reno.gov>,"Usa Wagner"

<WagnerL@reno.gov>,"VeroniCa Lopez" <L.opezV@reno.gov>
03/22/2012 03:43 PM
Subject: Zach Coughlin
In case you are not aware, Mr. Coughlin appeared in the clerk's office this morning. He was
dressed in pajamas with street clothes underneath. He was demanding and argumentative and
was unhappy with the responses he was getting from Donna. He became more unreasonable
and argumentative so Donna called f a marshal. Marshals Coppa and Thompson arrived and
or
Mr. Coughlin was told to leave several times before he complied.
I have asked the marshals to provide written statements of the incident.
Please let me mow ifyou need any further information.
Cassandrn Jacbon
Court Admiaistrator
Reno Mamiaipal Court
JfU'!lc.sonC@reno.goy
Phone:7'75-334-2Jl95
F
ax: 77
5"334-126J
' .
;
0272 1
02721
Zach Coughlin, Esq.

Offense Date
RPD
RMC Case No.
I C l l -0627
1 1 CR 22 1 76
RMC
Status
Dept.
Case/Citation
09-09- 1 1
Offense(s)
Petit Larceny
at Walmart
- TD : 1 1 -3 0- 1 1 Convicted;
after conclusion of Trial, Def
held in Contempt of Court by
Judge Howard and taken into
custody for 3 -day WCJ
nd
- Conviction appealed to 2
,
JD Case No. CRI 1 -2064

- Appeal denied 03- 1 5- 1 2
- Def Mot for New Trial filed
03-26- 1 2
- City Mot to Strike filed
03-27- 1 2
1 1 -03 - 1 1
Parking Citation
020 1 45322
1 1 - 1 3-1 1
1 1 -22 1 85
1 1 CR 26405
Trespassing
- Legal Defemder Keith

Loomis, Esq. apptd
- Trial Date: 04- 1 0- 1 2 8A
1 1 - 1 5- 1 1
#54428 1
1 1 TR 26800
No Ins
- dism ' d b/c proof shown
No Veh Reg
- dism' d ble proof shown
Blvd Stop
- Trial began 02-27- 1 2; midTrial, Def held in contempt

by Judge Holmes and taken
into custody for 5-day WCJ;
hal of Trial eont' d to 03- 1 21 2;
- Def FTA'd Cont ' d Trial
Date of 03 - 1 2 - 1 2
1 2-03- 1 1
Parking Citation
020 1 46724
0 1 - 1 2- 1 2
1 2-808
1 2 CR 00696
Jaywalking
Trial Date: 04- 1 2- 1 2 I P
02722
02722
Patrick
King
Daniel Wong <wongd@ reno.gov>
From:
Sent:
To:
Subject:
T u e s day, Apri l
10, 2012 3:19 PM
Patrick King
RE: Cri m i na l History from Dept. of Public Safety . . .
It appears the State Bar will be unable to get Coughlin's criminal history.
Fro m : Pamela S. Sebring [mailto:p

sebring@dps.state. nv. us]
Sent: Tuesday,
April 10, 2012 3:09
To: Daniel Wong
PM
Cc:: : ' Penie Colter; p

atrickk@nvbar.or
g
S.ubject: RE:
. ( . :. . . .
.
Criminal History from Dept. of Public Safety . . .
Mr Wong,
The N evada Attorney/Defendant will need to get what they call a PID ( p e rsona l I d en tification ) wh ich is fing erprint based
criminal h istory. Then h e can sign a wavier to have the criminal history sent to you or choose to share it with you .
Without statutory authority you can not request this person's criminal h i story. If you refer this to law enforcement or the
Attorney General's office, and they open a case, they can get this person's criminal history.
Pam Sebring
NCJISfN C I C Compliance A d i to r
Records & Technology, DPS
33;W Nye Lane Ste 1 00

CarsOn City, Nv
..
"
89701
?'7.9-684-6244 Phone
.'
f75-684-6268
Fax
This communication, including attachments, is for exclusive use o addressee and may con tain proprie tary,
f
confidential and/or privileged information. If you are not the intended recipient, any use, copying,
Original Message---
disclosure,
dissemination or distribution is strictly prohibited.
-----
From:
Daniel Wong [ma ilto:wongd@reno.gov]
Sent: Tuesday, April 10, 2012 1 : 3 1 PM

To : Pamela S. Sebring
Cc: 'Penie Colter'; King, Pat patrickk@nvbar.or

g
Subject:
Criminal History from Dept. of Public Safety
Pamela,
This is not a situation of the Nevada attorney/Def
endant wanting to get his own criminal history.
02723
02723
It is a situation of the State'l'r of Nevada wanting to get the Nevada Attorney/Defendant's criminal
ar
history.
Would the State Bar of Nevada used the same procedure in the Attachment hereto? The State Bar of
Nevada would have to supply the fingerprint card of the Nevada Attorney/Defendant in order to request
a copy of the Nevada AttorneylDefendant's criminal history?
Daniel Wong
Chief Crim inal Deputy City Attorney
Office of the City Attorney

One East First Street,
P.O. Box 1 900
Third
Floor
Reno, NV 89505-1 900

(77 5 ) 334-2048
Fax: (775) 334-4226
wongd@reno.gov
Mon. - Thurs. 630A-5P
From: Penie Colter [mailto:colterp@reno.gov]
Sent: Tuesday, April

To: Daniel Wong
1 0, 2012 1 : 1 8 PM
Subject: Fwd: RE: [SPAM?] Criminal History
-----Original Message----From: "Pamela S. Sebring" <psebring@dps.state.nv.us>
To: <co1terp@reno.gov>
Date: Wed, 4 Apr 20 1 2 1 6 :03 :07 -0700

Subj ect:
RE:
[SPAM?] Criminal
History
H i Pene
You are correct. If he wants a copy of his criminal history he can get it him self. I attached a document with the
y.state. nv.us
instructions. More information may be found at: www . n vrepositor
Pam Sebring .
NCJIS/NCIC C om plia n ce Auditor
Records & Te c hn ology , D P S

333
W Nye Lane Ste 1 00
Carson City, Nv 89701

775-684-6244 Phone
775-684-6268 Fax
This communication, including attachments, is for exclusive use of addressee and may contain
/or privileged information. If you ore not the intended recipient, any use,
proprietary, confidential and
copying, disclosure, dissemination or distribution is strictly prohibited.
-----Original Message----From: Penie Colter [mailto:colterp@reno.gov]
Sent: Wednesday, April
04, 2012
3 :53 PM
02724
02724
TO: Pamela S. sebri~

Subject: [SPAM?] Criminal History
Importance: Low
The Nevada State Bar is investigating an attorney, who was and is a defendant In one or two (and
more) of our cases. The attorney at the Nevada State Bar asked us to supply a copy of his criminal
history. I said no because their investigation is a dvil matter, not criminal. Is this correct?
If they want a copy of his criminal history, they should contact DPS, shouldn't they?
Penie
,. ~
r---"- .
02725
02725
03/22/2012 13:17 FAX
Fo ;;~.
f
FILED
REND MUNICIPAL COURT
~0003/0003
MUNICIPAL COURT DEPT 3
Ra'7~6L
f~NO M~ItIVZ:-t!6tl~.~~/)Ifi
0(" / It (,,
A.vd
P.O s: 19011
Reao, NV .9501
t-
L
/ZP;..'t{'~
-t
(fi1 ({ V~
V.
/' /
/j
.
- t E-mail address: RenoMuniRecordS@reno.gov
.
, G ''S ' ~ '\
CL~t~THE~c-"'Ic~
RECORD REQUEST, ,,1 (( ~- ?:
,C~:
BY ~I<?NS: ' )' -f:(t~.-Ic,-r; .~Af!a~:'::'ij ~" k,1 Request Date: ?
Z 2 /-;
ZI12 HAl 22 AtI lOs itS
(775) 3J4..11!JO Fa (175) 334-3124
'[Cl
7.j
1. Pnnt out thIS request fonn. \::>~ c: ce5>$~ Cl,

J
. 2. Fill. the fonn out ~ompletely.
j..
k4Ei:, <" .
.
' .' I) " '
3. Mad, fax, oremad your request to the Court. 0 1-', c . '
i
t ej
/e;' f~
I r~
4, You will be notified when your records are ready. ~t to'
z ~/I '- 1 {;.~' ~"l _
If you do not indicate the year of the record, the case number, d"/ibe charge date you will be charged a record
search fee of $2.00 per year searched, per person searched (we will search 7 years prior per our record retention
schedule). This fee'is in addition to any copy fees incurred.
6. All fees mast be paid in full before record request is mled.
j:.
I!
lh
s.
va!
j" c.....
.f
J>. tit /fa Id~
Charge(s): _ _ _ _ _---:----r--.-'==+-''--t-1:+------'~___i~..L..Jol~-'--'-_=_''''''L.4-'~-~L_f_--='--'-_'7f
Charge Date:
~t~,
C'
~'
.. Ii'
Computer printout: This includes case history and disposition.

($8.30 per page + addithmal seareb fees if applicable, see 'Slaltructloa)
Certified computer priutout; This includes ~ history and disposition, all copies certified.
($3.00 per page + addldoDai SI!tU'eIa r_ If appUcable, _115 IutnIctioa)
I.N.S. Certified copies:
($3.00 per page + addldonalleareb fees if appIieable, ._
p-ilther
d~umeuts: (please ' p.

.
" ,
~ /j l.f ,,:'::1.
c
t..
(ou will 6e notified by

<1\ r
v~C {V~ I' "
l. t. \
CC ,
~.
1-1
II
.5 iDlIt-:ur-t '
{
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ify,
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tll:t.f:scic
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".''1;'
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l-'oJlr ~rdS are ~e." . .,'. ~ . ',
~rfo- ~'>1 i 1,/ ,,~., /.' ~-lil,.tlC.t.'\
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Oftb71e and ~b
(' .' )
L ' t. ll4 (,,"\ ., ' . / ' (,_ (.r:

. ;f\:c c " ,,,:'--l'((! '~'il ' ), Jcf,.' > : .
' (~y J :..t'pe.. t:f q. (::.-lc ,: t=.:
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.
02726
P. 2/4
No. 1009
17. 2012 4:46PM

IN THE MUNICIPAL COURT OF THE CITY OF RENO
COUNTY OF INASHOE, STATE OF NEVADA
CITY JF RENO (Plaintiff / Demandante) vs.
Zachary Barker Coughlin
Name (First. Middle, Lest) (Nombre Complelo)
1422 E. 9th. St. # 2
Dept. #1 0
Reno NV 89501
Case # 11 CR 26405
FLED
Dept. #2 0
Address (5rieccion)
City, Slate, Zip (Ciudad, Estado, Codigo Postal)
Home PFione Number (Telefono Casa) Work Phone Number (Telefono Trebe),
Dept. #3 0
Dept. #4
MOTION PET/C/ON A LA CORTE
eputy Clerk
Cornea now the undersigned Went end moves the court to grant the following (El SUsorfi0 S011cita a la code qua to sigulente sea otorgado)!
New Arraignment Date (Nueva Peen!, de Lecture de Cargos)

C:1 Time to Pay Extension (Extension pate pager)8Forfait Ball (Conl)sque Is llama)
Change of Plea(Camblo de Catelerscion)HDismIss Warrant (Descadar onion de arresto)
0 NOW Trial Date Nueva fiche de Alicia)
[.] Other (Otto): MOTION IFOR WITHDRAWAL. OF ATTORNEY
Thli relief Is sought for the following reasons gee remote as stokes.% parse stguiente maw 'scan en Espanol)
SEE ATTACHED EXHIBIT "A"
AFFIRMATION / ATESTACION
(nsme I ',corbel!) gtooseTO MIMICS

, hereby solemnly affirm and declare
that Ma above statements are true to the-beei of-my knowle7ge, bolter, endmade In good felth end not marshy for delay. (Yo, por
tor de me saber, credIblilded,
este medio sotemnemente erfrrno y deditro qua las declaraclones anterior,' son ventaderes
y /retries de buena re y no pars relnsser ml caso.)
APPIAN ra SICINATURE (FIRMA DEL DECLARANTE)
COURT USE ONLY / NO ESCRIBA NADA ABAJO

Continued From:
Defendant(Mall)
Continued To:
Dotandani(Hand) LI Defendant's Alty El City Attorney

Date:
Clark Signature:
ORDER ORDEN
GOOD CASE APPEARING, IT IS HEREBY ORDERED thel the motion be: 0 Granted (Otorgada)
(Heblendo psis razor), as waned qua la sollcitud sea)
0 Denied (flegsda)
Other (Oro):
DATED THIS
Cowl
day of
ay AIWA,
CS
Nunketsi tout
I here certify this u a true and oorreot oorsy of Yea Adair/ Jaw lir La Colt uuotior
In
of the Reno Murackard Court, Reno, Wise:
run%
Ronda, and that the Clerk of the Court la the
custodian el the
original record and th 't am autflOrlad to
make this
ICI
(k.ari) Clir..ju *MAN
By
02727
. _ . _'_'c.<._. .,:.-_, . . _ .-
J a n . 1 7, 2 0 1 2
. .
.
. ""r " ,.; ". . "'._'. ..... "
4 : 46 PM
No,
1 009
p, 3/4
The instant matter was set for trial on January 1 0, 201 2. However, a defense motion to
continue was fil ed on January 3, 201 2. not opposed, and granted. A new trial date is
pending.
Under Supreme Court Rule 46, the attorney 'n In aotl on may be ch a n ged at any time
before Judgment upon the consent of the attorney. approved by the client, or upon o rder
of the court or
the reof on the application of the attom ey or client. SCR 46.
judge
Further, undor NRPC 1 . 16(b), a lawyer may withdraw from representing a client If the
sama can b. accomplished without materIal adv,r.e effect on the Intere sts of the clie nt;
a c l ie nt Insists upon taking action t h e lawyer conl/ders re p u g n an t , or with which the
l awyer has fundamental disagreement: tho rtpresentatlon has been rendered
unreasonably difficu lt by the client: or other good cause for wlthdrawa. exists. See
NRPC 1 . 1 6(b)( 1 ), (4). (6). (7).
The undersigned regretfully makes this mot/on aa continued representation of the
defendant In this matter has been rendered unreasonably difficult and the defendant
will be better served by having an alternative lega' defender appoInted to represent hIm.
EXHIBIT A
i
02728
02728
.
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'
J a n , 1 7. 2 0 1 2
4 : 46 PM
No,
1 0 09
P.
1 14
Law Office of Roberto Puentes J r.

416 RIDGE STREET
RENO, NV 89501
Telephone (17S)18e 7676

FAX (71S)18S8720
P. O. BOX 242 1
RENO, NV89505
..
FAX TRANSMITTAL SHEET
January 1 7, 2012
DATE:
ATTN. :
Oepartment Two
TO:
Hon. William Gardner, Dept #2, Jill Drake, Deputy City Attorney &
Motions
Roberto Puentes Jr. , Esq.
FROM:
FAX NO. ;
334-3859 . 334w3859 & 3344226

The folloWing page6,L, Including thl. FAX pags, are being tefecopled
from the Law Offices of Roberto Puent,,, J r. , Reno, Nevada. Please call
(775 )786-7676 jf you do not receive the number of pages noted above.
Message
I RE:
Motion to Withdrawal
City of Reno va. Zachary Barker Coyghlln Case No.
1 1 CR
26405
Thlt Informellon 11'1 Ihf8 FAA, snd thai accompanying !hl. pag., Is attomey-cllenl ptlVll6ged.
conlldenl/al and work privileged. If you receIve thIs In 8rtOr, please oaU u. nghl away. We w"1 pay your
telephone expense or accept a collect call. If you 8re nol the Inlended recipient. plesse do nol read Ihls
malerlal and be aware that any dlstrlbutlon, dl.cu..lon 01 copying of lhl. matellal l. slr1c:t1y prohibited.
If you have rocctved this communlcallon In eftor, pilla ImmedIately notl(y us by (elaphone and telvm Ihe
.
orfglnal maNage to us at the above addre vi. U.S. Poala' Sorvlce.
Thank you.
..
02729
02729
l1 V .
.,.
I VV]
1 .
1 I 't
..:
" .
Law Office of Roberto Puentes J r.

41 6 RIDGE STREET
RENO, NV 89501
Telephone {115)7Se..7676
FIV< (77!5)18S8720
FAX TRANSMITTAL
DATE:
Hon. WillIam Gardner,

Motions
FROM:
Roberto
SHEET
Department Two
TO:
RENO, NV89505
January 1 7, 201 2
ATTN.:
P.O. SOX 242 1
Puentes Jr
Oopt #2, Jill Drake, Deputy City Attorney &
Esq.
FAX NO.:
334-3859 , 3343859 & 34226
The following pagea,L, lncludl"SJ thl. FAX page, are being terecopled
from the law Offices of Roberto Puent" Jr" Reno, Nevada. Please call
(775)786-7676 If you do not receive the number of pages noted above.
Mes ge l
RE:
Motion to Wlthdlllwal
City of Reno va, Zachary Backer Coughlin Case No. 1 1 CR 26405
Tho Informsl/on In thle FAX, and thal acaompanylng (hie page, I. attorney-client ptlVfltgod,
conlldenUai and work privileged. II you tecolve Ihls ln .rl'OI', pl.... caU U8 right away. We wfll pay your
telephone BlIPsn or accept 8 col/ect calt. If you .,. nol the Inlended recipient, plea do not read this
materl.1 and be aware that a ny dl" tfbutlon,
or copng of Ihf, material Is 'IrtcUy prohibited.
If u have recetved this communlcatlon In ertOr, plo... Immedlalely notify us by telephone and reMn Ihe
.
orfglnal mage to us at tho 9OOY8 addree. vt. U.S. po,1II Sel'Vles.
Thank you.
02730
02730
".
',.
.,"
No.
P. 2/3
0845
I N THE MUNICIPAL COURT OF TH E CITY OF RENO

COUNTY OF WASHOE, STATE OF N EVADA
CITY OF RENO (Plaintiff I Oemandante) vs.
Zachary Barker Coushll"
Name (Flrsl, Middle, LA!) (Nomble ComIJ/eto)
."reno e.a)
Numbl((t
MOTION
T1
ork
W Phone Number ( e 810110 TI'i1IijOJ
I PETICION A LA
Dept. #2
Reno NV 89501
,Iidii, CtJdfgo POi/II)
p
en." Sill., ZI IC/lJdiiJ;E
Hom. Phon.
#1
Dept.
1 422 e. 9th. St. 1# 2
)
Addrell (OIIeoolon
CORTE
F ,tER205
By
Dept. #3
20'2
Deputy CIeri;
Oapt. #4
Com.. now lila undetslgned a"'.nl .nd move. Ihe court to glllni lha (olle\l/Ino (EI 'UlM/O $OI/' , I, coIfe que 1o ./gll;"'l. JQ oIorgldo):
N.W
B
PIJQlI)I BFOIfel'
C1 nme fo P'y /:J(/em./orr (Elcl"r7slOl1 pare

(Z] N.w TrI/JI Oa', (Nueva FeCIt. d. Julclo)
[J o (a
81111 (COIIH.qu. II '.n,

Ch"fI of PIf.(C.mOlo fl. DlCllrIIOIon)
II,.,./g"mel'll 0.1. (Nil."" Fech. de Lee/ullI d" ClIrr/05)

DlMllsa W.tnIIII (OeIC."'" anle" dri rrg$lo)
__
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)
l
ThIs rell.lla souoht for Ihe Iollowlllo rOa lon. I/!". ft",.dlO 0IJtM,. II'" ./fv/ttl. /WlOII tJfbIJ .., E6p8ll d
see ATTACHED eXHIBIT "A"
A
AFFIRMATION / A TES T CION
'
I, (n ...... /"""'.'.) 1t01I'ItTO Ui!HT1!8JIl
hereby solemnly IMrm and dod.,.
Ihe' !h bow 11.l
amenta Ire lrul \0Gi. 6.a 01 my knoWledge, 6.11." Ind mla,ln goOdr Ind
auI\
merely lor delay. (Yo, por
I'sl. ffl8dlo
lfrmo y decl. qUI '" rJecltlfflc/on, .,I.rlO/'e,
fflflde,,,, 1 (0
d4I me '. etedlblllfl.fI.
y hlCltu de buena " r no fJUI "''''$lr ",1 so.J
solemnemlJlli
COURT USE ONLY 1 NO ESCRIBA NADA ABAJO

Conllnuld From:
ConUnued To; _ __ _
_
_
_
CletX SlgnaIUrl:_ _ _ __ __ __ __
_
_
_
_
__
o Deltndant(Ma") 0 oelendlnt(Hand) 0 Defendant'. Ally 0 City Allornoy
Dale: ------
ORDER I ORDEN
GOOD CASE APPEARI NG, IT IS HEREBY ORDERED

(Hllb/enrlo jus/II flIlM, 05 orrJonedo que Ie sollcltud sea)
o Olh., (OItr)):- - - - - - - - -
DATED
'MI: C O...
THIS
ttlrday
PinIt. <:if)' ""_
of
:j>f
,J%
4
CMOoy' "",. .. ...
0 DenIed
lhal lh. moUon bl
...,-_ --:. J-,L.

I"I r4, -I-
__
__
__
_
__
__
_
_
_
_
_
_
. 2 ()f;.;
e;;by . .. . Irve In
ttI
the feQOr<H 04 t Aono Court R
NI.,._ and ttI.t tht CIeItr of 1ft. eou,;
I,
ori"' __
(Ne(JIJdlJ)
__
__
_
_
_
_
: ....
.... - -
'U:' c 01 l1li
W
''
'''''I .;.,v........
02731
02731
" """j a n .
3. 2 0 1 2 1 0 : 0 2 A M
This matter is
continuance
No.
0845
P. 3/3
set for trial on January 1 0, 2011, at 1 :00 PM. The defendant moves for a
of the trial dato in this mattel' f iSi,ues related to discovery/further

or
investigation, including but limited

City Attomey's Office
to defense counsel having received
CD n:om the
on December 20, 20 1 1 , which contains a very la rge number of
documents and videos that need to be roviowed in

Deputy City Attorney Jill
anticipation of trial in this matter,
Drake has no objection to this motion.
r
EXHIBIT A
02732
02732
t.
, -_.....
FILED
Electronically
03-27-20 1 2:08:56:46 AM
Joey Orduna Hastings
Clerk of the Court
!.r nsa
a
tl9n_ # 2849823
3
4
5
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
IN AND FOR THE COUNTY OF WASHOE
7
8
9
10
MATT MERLISS,
Respondent.
14
15
Procedural History
17
20
21
22
23
24
25
26
27
28
/
ORDER
16
19
VS.
13
18
CVI I -03628
Dept. No.:
Appellant,
11
12
Case No. :
ZACHARY BARKER COUGHLIN,
On January 20, 20 1 2, Respondent, Matt Merliss [hereafter Merliss], filed his Second
Motion Jor Order to Show Cause, and the matter was submitted for decision on February 8,
20 1 2_ An
Order to Show Cause was entered February 8, 20 1 2, setting the hearing date for same
on March 23, 20 1 2 , to commence at 1 1 :00 a.m. On March 13, Appellant, Zachary Barker
Coughlin [hereafter Coughlin], filed his Supplement to Motion to Vacate or Stay Hearing on
Order to Show Cause.
The matter was heard on March 23, 2 0 1 2, and due to time constraints, the
hearing was continued and completed on March 26, 20 1 2 .
III
III
III
III
02733
02733
s
and apprised of the pleadings herein Order
This Court, having he ard evidence, argument
2
3
that Respondent Merliss's
or
Motion/ Order 10 Show Cause to hold Appellant Coug
hlin in
1 1 , 20 1 2, is DENIED.
contempt of this Court 's Order of January
DATED this
day of March, 20 1 2.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
02734
02734
CERTIFICATE OF SERVICE
2
3
Pursuant to NRCP 5(b), I hereby certify that I
am an employee of the S econd Judicial
District Court of the State of Nevada, County of Washoe; that on this
day of March,
20 1 2, I electronically filed the following with the Clerk of the Court by using the ECF system
which will send a notice of electronic filing to the following:
7
8
9
10
Zachary Coughlin, Esq for Zachary Barker Coughlin; and

.
Casey B aker, Esq. and Richard l Iill, Esq. for Matthew Merliss
I deposited in the County mailing system for postagc and mailing with the United States
Postal Service in Reno, Nevada, a true copy of the attached document addressed to:
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
02735
02735
. - .
COVER SH EET
Reno, Nevada
Case
No. : 1 1 TR 26800 2 1
4
5
CITY OF RENO,
Plai ntiff
7
8
9
vs.
ZACHARY BARKER COUGHLI N.
Defendant,
10
11
12
13
14
List of documents included in
1 . O rder Finding the
the attached
Defend ant
pleading by title and date.
in Contempt of Court and Imposing Sanctions -
3 pages filed by the Court on February 28, 2 0 1 2 ;

2 . Notice of Appeal of
Summary
Contempt Order; Motion to Return Personal
15
Property Confiscated by Reno M unicipal Court and Its Marshals: Motion For
16
New Trial and to Alter or Amend Summary Contempt Order
17
submitted by the
Defendant by fax and filed with the
224 pages
Court on March 7, 20 1 2;
18
3. Motion to Return Cell Phones: Motion to Set Aside Summary Contempt Order;
19
and Notice of Appeal of Summary Contempt Order - 2 1 8 pages submitted by
20
the Defendant by fax and filed
with
the Court on March 1 2 , 2 0 1 2 ;
21
4 . O rder - 5 pages filed by th e Court o n March 1 2 , 2 0 1 2 ;
22
5 . O rder Striking Fugitive Document Filed o n March 7, 1 020
23
six pages
(including Exhibit 1 ) filed by the Court on March 1 3 , 2 0 1 2 .
Reno MuniCipal Court
Dorothy Nasll Holmes,

Judge
P.O. Box 1900
Reno. NV 89505
(775) 3343822
02736
02736
." ".",'
. ...
the
I hereby certify that each docum ent included is a true and correct copy of
Washoe Cou nty,

original in the records of the Reno M unicipa l Court, Reno,
record and
Nevada , and that the Clerk of the Court is the custod ian of the original
that I am authorized to make this certification.
Dated: March 1 3, 20 1 2
6
7
RENO MUNICIPAL COURT
8
9
10
11
12
13
14
I nereby certily this as a true and carmCI copy of the original in

the records of the Reno M unicipal Court, Reno, Washoe County,
Nevada. and thaI the Clerk of the Court is the custodian of the
original record and that , !11 authorized 0 make this certification.
RENO MU ICIPAL QURT
15
16
17
18
19
20
21
22
23
24
Reno Municipal Court
Dorothy Nash Holmes,
Judge
P.O. Box 1900
Reno, NV 89505
(775) 334-3822
02737
02737
0 4 / 1 6 / 2 0 1 2 0 7 : 2 9 FAX
AItIIIBT .miD AND

-ua:r.o'TlOfU)I' ftOMU.It CAmB
'-"
- OFiGINAI.._
NASIOAD,
'JO<' IO
:
II
NOC
HUNI C I PAL COURT DBPT 2
DE /
8AI.
IlJc.I" ",;Messa
lION
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DEFBlDNfT OtCIERED tElUSED, MlE

s-aoe lREYI8ED MIG)
.....:...
_
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lWJISmAlE
02738
02738
MUN I C I PAL COURT DEPT 2
0 4 1 1 6 / 2 0 1 2 0 7 : 29 FAX
r I C:d bt;
--
IN 11IB MUNICIPAL COURT OPTIfB CITY OFRENO .

COUNI'Y OF WASHOB, STATH OFNBVADA
S!:?ARATE D'
.sPOS1TION
CRIMlNAL COMPLAINT
PIainIiff.
(GFNERAL
)
AArr 6. {3'11)J/aQ
9 A-:
9 -9
OOB
, 1,1
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SSN
sr, '
(;.A(
#A4M? &. illttJ
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r. .e
R NM.T_V
,t'iS' - L{BO
I.,, 1,...
1.
f.i-5f;:}G #'_
Dcfeadant
IAtI w/tiFJU
J,,4,eJ:3
has committed the crime of

__
__
to wit:
_ .m::;?:E .
_ __
.ntJ I?S"
1/
hereby complain aad say rhM
-aSP4Sr
Noif /3
. 2O.lL in tbc City of Reno.
State ofNeVlda.d I' A"d LfYA. - ntt:!" J)&..-r' WkS f&w(J
=nkr d&I Afn.;? MNCa EiVIG1k-D OrJ II - J - I I .
That said dcf
c:ndmt OD or about
All of w1licb is in Yiollaion of NRS

1.04.015 of the ReDo Mnnicipll Code.
__
_____
\)it- AIl ofwhich it in viollrion of . to ' 0 Ii)
Code.
as adopCcd by ICCIioa
of the Reno Mauicipal
) dIemfore teqQeIt !bat said Def

eadalll be dealt with ICCCII'diDg to law.
.
I heRby dcclarc upon inCmoation and belief UDder peuIty of pajury punuant MRS
I .
171.102, thai tbe foreaoios ia lme ad comet to the best ofmy bowJedge.
10)
02739
02739
Supplement No
1 1 -31 2
DRAFT
RENO MARS HAL DIVISION
0001
Reported 0..
12/14/2 0 11
1 SOUTH SIERRA ST
NIIIIn 01 C..
INCIDENT
Emp '
MOSER, JEAN-PIERRE
7 7 5-326-5125
775 -334-1260
LAW ENFORCEMENT PE RSO N N EL 1 : ; MOSE R,JP
LAW
Name
. Ji:roRCEMEN_ !':E:!.c?".
; MOSER JP
_ _
.L
.---.
_ .
J<:).;I.B
.
F I C
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...L"9"_. 1
of 2
I
i
02740
02740
",.:"
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I'
1 1 -3 1 2
DRAFT
RENO MA RSHAL D IVISION
Mod u s 0 era n d i
Supplement No
0001
On December 1 3, 20 1 1 at 1
rS, 1 was assI sting Marshal Menzel co nduct a
with after
secu n ty
the c o urt had closed. Marshal M enzel and I h ad noticed we had one more person in the lo bb y and as a standard
pr a ctice we both stood by the security bubble w a iting for the customer to conduct their business with the clerks
office and leave the building.
Marshal Menzel had recognized the customer at the clerks' window and told me his name was Zachary Caughli n .
Marshal Menzel went on t o exp l ain t o me C aug h l i n had been arrested for contempt o f court a couple o f weeks
prior during a trial in Department Four.
What made me pay attention to Caughlin was when he started ra is in g his voice at times and arguing with the
clerks in a sarcastic tone. He repeatedly asked the cle rk s the same questions in a manner that made me feel he
was attempting to twist what they were explaining to him in an attempt to get them to say someth i ng th ey didn't
mean.
At approximately 1 7 1 5hrs, Marshal Menzel wa l ke d from the security bubble to the clerks' area and placed himself
behind the clerks, Tom Bartoldo and Donn a Ballard. I h ea rd Caughlin acknowledge Menzel by sa yi ng "hello Sir".
Caughlin then began asking the same questions again of Donna Ballard and Tom. I saw Menzeli lean forward and
say something I did not clearly hear. Caughlin said to Menzell, "look. you almost pushed her (Donna) over, are
you in a roid rage"? I heard Menzell tell Caughlin "she (Donna) is going to answer your questions, and you will be
escorted out of the building ".
Caughlin asked a couple of questions of the cl e rk s and got up from his chair. He asked me which way he should
go, and I tol d him h e should go towards th e exit sign while pointing in the direction of the exit. Caughlin then
exited the building without any further contact.
Nothing further.
, .p.,n o
--
'_R109.90/l.'JOSER ,
_.
-- !
_
Priiit Aj - ed
-
12/1S /20.!l:. }C?. :. !.

02741
02741
Supplement Nc
ORIG
1 1 -3 1 2
D RAFT
RENO MARSHAL DIVISION
Reponed Date
1 2 / 14/2 0 1 1
1 SOUTH SXERRA ST
N.I... .., C..
I:NCXDENT
Emp '
MENZEL , JAMB S
7 7 5 - 32 6 -5125
7 7 5-334-1260
r...
..
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. -= :;-"'':':'-'- '
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TFrQji1 iii- D
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------ --
--
1
1 AU/ 13/2011- - 1, 1 7 -: -- 5 - 12 - --- - - 1thOr
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----- -
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Invl
In.I No
3
InvlNo
LEP 4
Invl
SUB
. Invt
laT
Invi '
. WIT
invl Nc
;' lnvI NO
i s
: Invl No '
6
Summa
Type
P
. Type
Type
. Name
: ; MOSER , JP
.
Name
; THOMPSON , MA":t:a:
Nam..
'-/;INI
. ...
tMNI
Race
DOB
09/2 7 / 1 9 7 6
M
; S.I
; RacCt
: 008
Sex
. - -- - , MNI
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' COUGHLrN .., ZACHARY

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Narrative
1 ncidenUlnformational:
Date: 1 2/1 3/1 1 at 1 700 hours
S u bject: Zachary Coughlin (DaB: 09/27/1 976)
Location: Reno Municipal Court (Clerks area) : 1 S. Sierra St. Reno, NV.
Subject Zachary COUGHLIN creating a verbal distUrbance at the Reno Municipal C o urt with court staff_
COUGHLIN left the building without further incident.
... --.--
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02742
02742
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Supplement No
ORIG
I ALL OTHERS
Na rrative
I N FORMATIONAL ONLY R EPORT:
On 1 211 3/1 1 , I (Marshal Menzel) was assigned to the Reno Municipal Court at 1 S. Sierra Street Reno, NV. At
about 1 700 hours Marshals Thompson, Mo se r and I were in the process of closing and conducting our floor
checks. During this tim e I left my work station and proceeded through the lobby area to the courtrooms on the first
noor. Th e lobby was empty when I walked through .
After completing the floor check I walked back toward s the lobby and noticed a white male sitting at a clerks
station (number 3). As I walked closer I i mm editely noticed the male was a past defendant I had dealt with as
Zach ary COUGHLIN and took note of the time, w h ic h was past 1 700 hours. At this time Marshals Thompson,
Moser and myself waited near the Central C o ntro l area, while COUGHLIN talked with the Sentence Compliance
Officer, Tom Bartoldo, While they were talking I could hear parts of the conversation. which COUGHLIN asked
several questions related to court m a tters. COUGHLIN also inquired about Judge Howard's email address, his
, RePOi! omee;;-" "

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02743
02743
1 1 ..31 2
DRA FT
RENO MARS HAL DIVISION

Na rrative
Supplemenl No
ORIG
assistant's na me, last name and email. At one pOint. COUGHLIN got Donna Ballard's a tte ntio n through the
window and asked her what her name was and then asked for her last name. Donna responded to the window
where COUGHLIN was to assist him and Tom. Ma rshals Thompson, Moser and I waited fo r over 1 5 mi n u tes , till
after 1 7 1 5 hours while COUGHLIN talked with the clerks. I co u ld hear parts of the converat ion between
COUGHLIN a nd the clerks, which COUGH L I N wo uld ask the same questions several times, or re- phrase the
questions, in a sarcastic tone of voice. COUGHLIN even made a comment that he knew that we (st aff) were here
afterhours and he was ca u si ng overtime and that the court was "secretive " with information when he asked for
staffs last names.
A little after 1 7 1 5 hours. I left the area and responded to Tom's desk, where Tom and Donna were. Tom informed
me that COUGHLIN a p peared at his window around a minute before closing or right at 1 700 h ou rs. While
COUGHLIN and Donna we re talking . COUGHLIN directed his attentio n at me a nd made a c ommen t, so met hi ng to
the effect of "Hi. how are you doing sir?" in a sarcastic tone . I am not sure if I responded to his comment, but
i mmeditately . COUGHLIN asked me my name, which I respond ed , "Marshal Men zel, with one "Ln. I informed him
that she, Donna, wa s answering his q uestions . in attempt to get his attention on Donna to answer h is q uestions so
that he would leave. COUGHLI N then stated so methi ng to the effect that we, him and I. had problems before in
court and asked if I was h avi ng a "raid-rage." I told COUGHLIN again, that Donna was answeri ng q uestions a nd
when she was done, he would be escorted out of the building. COUGHLIN then asked some more questions and
left the building without further incident.
Witness statements were given to Donna and Tom and are pending at the time of this report.
It should be noted that COUGHLI N's comment about him and I havi ng past prob lem s in court is an i ncident that
took place on 1 0/1 0/20 1 1 during aftemoon Arraignments. During this incident, COUGH L I N was very sarcastic
when he checked in with me for court a n d attempted to ask me legal q ue stio n s . He was i nfo rmed that he could
ask the J udge when his case was called. When his case was called he continued with his sarcastic to ne of voice
with Judge Gardner. COUGHLIN gave me th e impress io n that with all his q uestio ns he was attempting to dela y
the court proceedings and cause a disruption. Eventually he sat down and waited for me to give him his trial da te .
When I gave him the date , COUGHLIN j u st sat there rea ding his court paperwork. When I asked him if he had any
questions, he stated no and he was just reading. I noti ced that COUGHLIN was writing all over his paperwork. at
which time I informed him t hat was th e courts paperwork and his copy was the s a methi ng , which I showed him.
He tha n began to ask me legal question s and asked if he was making me mad. I told him that he could sit there
and read his paperwork as long as he wanted, but I w as not going to deal with his sarcatic tone of voice, answer
legal questions and have h im monopolize my time when I had a full room of peo ple and other duties to perfo rm .
COUGHLIN rem a ine d in the courtroom for a while longer, th en returned my papelWork, received his and left the
area without further incident.
Additionally, I have re ceive d information fro m the Chief B ai liff (Micheal Sexton) at Reno Justice Court (RJC) over
the past several wee ks about COUGHLIN's be havior at their faci l ity . SEXTON i nformed me t h at on at least two
o ccasions , COUGHLIN has walked into the Civil Division right at closing and at one time, noticed the Bailiff and
ran into the Civil Division after clOSing and had to be told several times to leave and/or be escorted out. I was also
told th at COUGHLIN has been excessively emai li ng the Judges' at RJC multipl e times and that the Judges' have
responded back to COUGHLIN. i n fo rm ing him that if he continues his actions, that they would report him the
Nevada Attorneys BAR ass oci ati o n .
NFl.
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02744
02744
.,.
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Incident Report
RENO MARSHAL'S U N IT
."
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"': '4 "
MARSHAL Thompson,
Matthew
Casillas,
WITNESS
Daniel
WITNESS
-_
._
(none)
Ballard,
(none)
Donna
WITN ESS
_-
CAS E
Garcia,
(none)
Vanessa
..
REPORT OFFICER
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PRINTED AT
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02745
02745
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March 22. 2012. approximately 1055 hrs. I (Marshal Scott Coppa) was notified by
central control to respond to Donna Ballard desk in reference to a Defendant Zachary
Coughlin.
On
Both Marshal Thompson and I met with M iss Bal lard at her desk. She informed us
Coughlin has been at Daniel Casillas window #8 for approximatle y 15 minutes and
was becoming argumentatlye with court staff. Miss Ballard further stated the Staff
has answered all his Questions as he was now becoming repetitive with his questions.
At one point Coughl in demanded to have Casillas read the docket to him word for
word and that he was goi ng to "depose" Miss Ballard.
Marshal Thompson and I approached Coughlin in the public hal lway. I informed
Coughlin all his Questions have been answered by court staff and it was time for h im
to leave. Coughlin asked me "did they tell you to tell me to 'eaye." Coughlin then
turned to Casillas and asked if he could talk to him. 80th Marshal T hompson and I
again asked Coughli n to leave, Cough l i n aske d for our names. gathered his items from
the counter and left the Coyrt.
Both Marshal Thompson and I made a recording of this event.

Nothing further to report.
REPORT OFFICER
at' ,4 I/ r
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PRINTED
AT
:.;l. 2,?,1;L
PAGE 2 OF
jt
02746
02746
i"",v
CAS E
':..
.
I
.
Incident Report
RE N O MARSHAL'S U N IT
PERSON S U M M ARY
TYPE
NAME
Coughlin,
SUBJECT
Zach
MARSHAL
WITNESS
WITNESS
WITNESS
DOB
09/27176
RACE
w
SEX
Male
HEIGHT
6 '4 "
WEIGHT
220
(none)
Thompson,
M
Ballard,
Donna
Casillas,
Daniel
Garcia,
Vanessa
(none)
(none)
(none)
PRINTED AT
PAGE 2 OF 3
02747
02747
t apprQxlmately
Os
,::te
1025 h
Zach CQughlin came i nto th
nQ Municipal CQurt, At
approximately 1055 hQurs DQnna Ballard cQntacted CQurt security asking fQr a
Marshal to respond tQ her IQcatiQn. Marshal CQPpa and I (Marshal ThQmpsQn) met
with Donna at her desk. DQnna stated Coughlin was becQming argumentative with
CQurt staff. Donna also stated tQ me that all Qf Coughlin's questiQns had been
answered and that there was nQthing further she could dQ tQ help Cough l in , DQnna
also stated CQughlin started to becQme repetitive with is QuestlQns then became
argumentative w ith DQnna and Dan iel Casillas. Donna stated CQugh lin said he was
gQing to "depose her and she would be found negligent". Donna stated Coughlin
wanted Daniel to read his paperwork to him and what the docket said on his case
wQrd fQr word. Marshal CQPpa and I then approached Coughlin at Daniel's windQw.
told Coughlin it was time for him to leaye. Marshal CQPpa stated to Coughlin. all his
questions had been answered and there was no more infQrmation the clerks CQuid
provide him. Coughlin stated to CQPpa "did they tell yQU to tell me to leaye" CQughl in
ignored Marshal Coppa's Qrder by turning his head away frQm Marshal CQPpa tQ ask
Daniel a auestiQn. Marshal Coppa and my self tQld CQughlin again he needed tQ leave.
Coughlin got his paperwork frQm the CQun ter asked what are nam es were and left the
building. I made a recQrd i ng Qn my recorder Qf t he co nversation Marshal Coppa a nd I
had with Coughlin.
None Further.
1:
RT OFF%CER
hrni)
PRINTeD AT
PAGE 2 OF ]
02748
02748
Patrick King
From:
Sent:
Zach
Subject:
RE:
To:
Coughlin <zachcoughlin @hotmail.co m >
Th u rsday, March 22, 2012 12:30 P M
King
hello from Zach Coughlin
Patrick
Thank Mr. King,

I will. Things are coming together quickly though I have faced many obstacles. I
may have mentioned this already, but I did file a Motion to Withdraw in the two
Gessin Adversary Proceedings in NVB. However, in the meantime, as I understand
it, I have a duty to represent Mr. Gessin, even despite his indications that he doesn't
necessarily want me to, that doing so is unnecessary (he apparently is in the process
or already has had his main BK case withdrawn, though I pointed out to him, that
does not necessarily make moot the adversary proceedings . . . ). It has been a good
lesson in how very important that attorney of record designation is. However, I did
learn a lot of lessons about that with Mr. Christiansen as my attorney in 2002-2004,
long with the extent to which a proper, detailed fee agreement setting forth in
explicit detail the scope of one's representation is very, very important.
Sincerely,
Zach Coughlin, Esq., 1 422 E. 9th St. #2, RENO, NV 895 1 2, tel: 775 338 8 1 1 8, fax : 949 667 7402;
From : PatrickK@nvbar.org
CC: DavidC@nvbar.org
Subject: RE : hello from Zach Coughlin
Pate: Thu, 22 Mar 2012 17:51 :20 +0000
Good Morning M r . Coughlin,
I s o rry to hear that you are having to deal with some extremely tough circumstances. Please come see me as soon as you carl.
Sincerely,
Patrick King

Sent: Thursday, March 22, 2012 2:31 AM
02749
02749
'To: Pafrick King

Subject: RE: hello from Zach Coughlin
Dea r M r. King,
I appreciate the seriousness of the process and want to show it the respectd it
deserves. I take what I do very, very seriously. If you can g ive me some time, it wou ld
help. Due to the recent eviction (and that is an a rea of law where I a m doing important
work that often goes neglected . . . the societal cost to Nevadans subject to this ultra fast
summary evictions, on top of the proced urally questionable manner in which they a re
carried out and served, is immense . . . sure it might hel p pay some RPD Sargents more tha n
District Court J udges, but its done o n the backs of real h u m a n beings suffering, etc . . . . ) .
I had a hearing today where I represented a client in a UIFSA matter. He needs m e . M y
rpresentation is very important to his life. He is a committed father who has been dea lt
some extremely tough circumstances. I think I have only received something l i ke $500
from this client so far, a nd have done enough work to make that less than minimum
wage, etc. .
do want to meet with you . It would be most prudent though, for my clients and myself,
ifVou and the State Bar cou ld afford me some time to tend to the immediate need to get
I
a new living space and office, attend and defend the "quadruple jeopa rdy" abuse of
process that Richard H i l l is orchestrating, and otherwise protect my client's interests. I
am not refusing to speak with you on the phone or meet in person. My two phones are
sti l l bei ng held by the Washoe Cou nty jail, under a n Order by RMC J udge Nash Holmes,
so . . . .The USPS Golden Valley Station has retaliated against me by i nterferring with my
mail, though I have ta ken a l l reasonable steps to cou nter that, including securing a new
O BOX, which I added as my public address on the Bar's onl i ne portal days ago, but for
which I stil l do not see a change reflected . The Federal Torts Claims act has likely been
violated by USPS Golden Valley Station su pervisors Terry Ja mes and Buck Hyde, whom
took it u pon themselves to play judge and j u ry incident to a complicated eviction process
that I have recently been l itigating against Park Terrace Town homes HOA and Western
Nevada Ma nagement and Gayle Kern, LTD. It involves respondeat superior l iabil ity, etc.,
etc. Western Nevada Management knew of and orchestrated, a nd received approval
from the Pa rk Terrace HOA to have the two individuals who I rented from live at the 1422
E. 9th St. 89512 location. This involved a Robyn Badalato, then a property manager at
Park Terrace. For some reason, when her boss fou nd out a bout this, she started crying,
$aying she was going to be fired, etc., etc. . Then she appa rently resig ned . This was
l itigated in a n interruption of essential services (electricity) com plaint I filed recently. The
HOA a nd Sue King admitted these things, yet they want to turn right a round a nd discla i m
an responsibil ity for anythi ng, pursue a summary eviction despite the facts not l ining up
with the G lazier case sufficient to a l low such, etc., etc.
Lcan sit down and tal k with you whenever you want. However, I am writing to explain
why this week or the i mmediate future would prevent a hardship for me with regard to
2
02750
02750
up
.Scheduling such a meeting.

ase no that is not a reflection
on my respect for you,
the State Bar, you r office, or this process, but rather indicative of the real ities faced by
businesses subject to summary evictions where the non payment of rent is NOT a lleged,
something which the law is supposed to forbid under N RS 40.253, but for which the Reno
J ustice Cou rt has now subjected me to TWICE in three or fou r months . . . .
I hope you can u ndersta nd though, that deadlines are running, Richard H i l l has me facing
quadruple jeopardy via his a buse of processes, etc. I have a hearing on that this
week. But I am not some young punk who is going to come in a nd let Jon Bailey blow a
lot of intimidation and hot air at him for his millionaire buddy Mark Tratos (whom had to
admit under oath, that he had previously "lost" other student's papers i n his i l l ustrious
career as an adj unct professor. And that was a lso confirmed by Anderson and Morishita,
two former patent attorney associates for Mr. Tratos. Also, M r. Tratos lost or "fa iled to
re(:eive" Jessica Wolfs paper in that 2002 Cyber Law course, but I don't recal l the State
Bar of Nevada raping her. Further, Tratos wrote me asking for "another copy of your
Aper", which i mplies he received one. Then he went on to ask for detail about the
papr, what it was about etc., clearly implying he did have possession of the one I turned
in with only my "blind grading" social secu rity number, etc. (he had a student in the class
who worked for his fi rm, he probably i nterpreted my adherence to the "bl ind grading"
setu p that was util ized in every other course I took at Boyd as a personal affront, etc . . . . To
me it is disturbing that the State Ba r of Nevada had allowed Mark Tratos to so leverage
the resources of the State Bar to wreck shop on my life, while, appa rentlYI no rea l inquiry
has ever been made as to whether Tratos did so inappropriately. He was "on vacation i n
Europe" according to m y "pro bono" attorney Pete Christiansen (and so d i d not appear at
the J une 2002 conclusion of the hea ring before the C&F Committtee, whom was referred
by Character a nd Fitness Committee member Kevin KellYI whom owns the strip club, The
Spearmint Rhinol or did at the time. I bel ieve i n Senator Grassley's "sunshine and
transpa rency" i n government, and in this grievance process too.
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel : 775 338 81 18, fax: 949 667 7402;
From: PatrickK@nvbar.org
Subject: RE: hello from Zach Coughlin
bate: Wed, 21 Mar 2012 18:36:13 +0000
Dear Mr.
Coughlin,
The al legations aga i nst you are serious and put into question your competence to practice law. I would like to meet with you so that
I can talk with you a b o ut the allegations and se e if there is a way

to assist you.
0275 1
02751
-,"".
rf you' do not meet with me, t h en t h e
sit down and talk with you.
Offif Bar Counsel will be forced to make deciSion thout the benefit of actually getting to
Patrick King, Assistant Bar Counsel.

Sent: Wednesday, March 21, 2012 8:31 AM
To: Patrick King
Subject:
hello from Zach Coughlin
Dear Mr. King,
IBye, hey jack is packing. How are you doing. My assistant Bar Council and we've been
sharing some emails. I would like to hear from you, so we can tal k on the phone if you
could please call me at (775) 328-1384 Thanks a lot. Bye. "
[J,ntil then, could we com m u nicate i n writing please. I provided you a g reat deal of
material in response to H i l l 's grievance, a nd I feel that should take you more than one
hour to appropriately review, so . . . .
Also, I have filed a motion to withdraw i n Gessi n's Ba nkruptcy AP cases and a Reply to
Opposition, though I don't real ly know what i n the hell that matters or why Richard Hill is
able to leverage your office to ma ke busy work for me by making com pletely unsupported
II ghostwriti ng accusations, etc., etc.
ll
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 81 18, fax: 949 667 7402;
lachCoughlin@hotmail.com Nevada Bar No: 9473
02752
02752
Patrick King
From:
Sent:
To:
SUbject:
Zach Coug hlin <zachcoughlin@hotmai l.com >

Monday, April 02, 2012 4:10 P M
Patrick King; David Clark; G lenn Machado
RE: my attempt to be provided access t o the g rievances filed today
Mr. King,
Could you please provide a copy of whatever it was the Marshals sent
you? Further, please indicate whether Judge Gardner filed a grievance herself, or
whom it was who is so filing a grievance based upon a three year old Order by
Judge Gardner. For, if that Order was just something Judge Nash Holmes included
.with her submission (which also purports to speak for various other RMC Judges),
that. is further indication of the extent to which you have confused or misrepresented
material facts throughout this matter, if, indeed, your statement that "other different
judges" have submitted complaints against me, when, in fact, only Judge Nash
Holmes has. Please indicate, in writing, who submitted the materials upon which
you have opened a case incident to the Judge Gardner matter. I have asked you to
do this at 1east four times now, several of which have been in writing, and yet you
have not done so. You may be interested to see that I filed a Mandamus action in
relation to that grievance by Judge Gardner:
http://caseinfo . nvsupremecourt . us/pu blic/caseView,do?csIID= 22746
Given that I have been u nable to get the RMC to g ive me a copy of the
court proceedings i n RMC 1 1 TR 26800 (the traffic case before J udge Nash
Holmes), wou ld you m i nd if I got one from you ?
You i nd icated that you r investigation revealed a condition
admissio n .
Where exactly did you glean such materials from? Further,
please confirm with Ba r Cou nsel that any conditiona l admission is relevant
to the extent the conditions of which have long si nce passed. I know
Character a nd Fitness Committee Chairman Rowe has made express
promises to applicants in the past that such would not be the case.
Sincerely,
1
02753
02753
A .:.
Zach Coughlin, Esq.,
PO BOX 60952, RENO, NV, 89506,
'.
tel: 775 338 8 1 1 8, fax: 949 667 7402;
ZachCoughli nfalhotmail.com Nevada Bar No: 9473
To : zachcoughlin@hotmail.com
Subject: RE: my attempt to be provided access to the grieva nces filed today
bate: Man, 2 Apr 2012 22:59:08 +0000
Dea r M r. Cough l i n ,
I have o pe n e d 3 d isci p l i n a ry f i l e s aga i n st yo u . They a re i d e ntified b y n u m be r below :
N G 12-0204 Zacha ry B . Coug h l i n , Esq . Ba r N o . 9473 ( 2005 ) M r. H i l l
N G 1 2-0435 Zacha ry B . Co ugh l i n, Esq . Ba r N o . 9473 ( 2005 ) J udge H o l m es
G 1 2-0434 Z a c h a ry B . Coug h l i n , Esq . Ba r N o . 9473 ( 2005 ) J udge G a rd ne r
You have received the grieva n ce from M r. H i l l a n d a lso the g rieva n ce fro m J u dge H o l m es . The
G ri eva n ce fro m J u dge G a rd n e r re lates to her "Ord e r After Tri a l " in the ca s e of As h w i n J o s h i v
Ba rti J o s h i, Case N u m b e r DV08-01168, w h e r e i n s he d escribes yo u r co n d u ct at pages 12 a n d
1 3 . I have received ce rtified co pies of t h e co nte m pt orde rs, a ce rtifie d copy o f the co nvictio n
at Wa l- M a rt, a n d a n i n c i d e n t re port from M a rs h a l s Thom pson a nd Co ppa rega rd i n g yo u r
c o n d u ct o n M a rch 2 2, 2 0 1 2 . I a l so have t h e reco rd i ngs o f the co u rt p roce e d i ngs a t i s s u e .

At t h i s ti me, I do n ot expect t o be p rovi d i n g you with a n y a d d it i o n a l i n fo rm ation.
I f you have
a d d itiona l i nfo rmation that you w a nt m e to b e m a d e awa re of i n resp o n s e to the grieva n ces
id e n tifi e d a bove p l ease fee l free to ma i l them to me.
S i n ce re ly,
Patrick Ki ng, Assista nt B a r Cou nsel
To: Patrick King

SubjeCt: RE: my attempt to be provided access to the grievances filed today
02754
02754
Mr. Ki n g,
I need for basic procedural due process protections to be afforded before
any consideration of any a rra ngement you have i n mind wou ld be

appropriate. It is my u ndersta nding that we a re still in the stage of the
process where you are providing me indication of the allegations a gainst me
and documentation in support and explanation thereof, a nd that there is
still additional materials and complaints wh ich you have so fa r chosen not to
al low me access to, even to view upon my responding to your stipulation
that I cou ld only so view such mate rials upon visiting the Reno office of the
State Bar of Nevada in person. Such as, please a nswer the q uestions I
have posed you i n my recent ema ils, especia lly with rega rd to providing
copies of a nd i nformation related to these "other d ifferent j u dges"
su pposed ly submitting written complaints a bout me to you . Further, please
explain whether you requested materia ls from J udge Nash Holmes, as her
letter to you appears to indicate, in her statements that she "apolog izes for
taking two days to get these materials to you " that you requested such
materials rather tha n she sending them to you on her own accord? Please
explai n .
Sincerely,
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel : 775 338 81 18, fax: 949 667 7402;
02755
02755
..
Patrick King
Laura Peters
Monday, March 26,
Patrick King
FW: FOIA REQU EST
From:
Sent:
To:
Subject:
2012 5:30
PM

Sent: Monday, March 26, 2012 5 :27 PM
To: Laura P eters
Subject: ForA REQUEST
Q,ear Mr. Peters,

.
. .
. '
I' have faced attacks by domestic abusers recently, as adj udged in FVI2-0 1 87, and
rtV1 2-00 1 88 and my mail has apparently been tampered with. Please resend me
anything you have mailed me since 1 2/ 1 51 1 1 to the new address below and update
my address on file.
Mr. King showed me a signed letter today that indicated he email me a copy of it on
31 1 6/ 1 2 . My records do not indicate any such email was received. Please correct
your records and my file in this matter to reflect any misstatement in Mr. King's
ietter of 31 1 61 1 2 . This is a FOIA Request as well, I would like a copy of all the
documentation, tapes, cds, letters, media, reports, in this and any other matters
Ihvqlving me (preferably fax or email it, and failing that, please mail it to the
fldress below) .
. .. :
S ihe.rely,
Za\=h Coughlin, Esq. ,
PO BOX 60952, RENO, NV, 89506,
ZachCoug
hlinfalhotmail.com Nevada Bar No: 9473
.
'
. -.
""
i'
, !
-.
tel: 775 3 3 8 8 1 18, fax : 949 667 7402;
.
:
" .1
'
02756
02756
Patrick King
From:
Zac h C o ug hl i n <zachcoughlin@ hotmail.co m >

Monday, March 26, 2012 5:35 P M
Se'nt:
To:
Patrick
King; Glenn Machado; David Clark

be p rovi d ed access to the g rievances filed today
my attempt t o
Subject:
Dear Mr. King,

This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and
attempted to be provided access the the various "other different judges" grievances that I, p rior to last Friday, was
completely unaware of. I have sent you several written correspondences detailing the tampering and other problems
with my USPS ma i l incident to the two domestic abuser attacks I have been subject to since a pproximately 1/1/12, and
.k: at you copy my on all correspondences or document production via email a nd fax. Today, yau showed me a two
page letter from Judge Nash Holmes. Did you i nterpret it to be a "grievance"? How is that designation arrived at? You
refused to identify the names of any other judges from whom you have received any other similar such materials and
further refused to a ll ow me ta view and such items. I asked for a copy of the large box of documents, and other FOIA
request materials and you refused. Further, you told me you didn't care I received anything you sent me and stated that
I did not have a right to review such complaint letters, grievances, or other materials, prior to being questioned by you
and before any such meeting. I informed you that I am considering different attorneys to represent me right now, and
indicated I need these materials to prepare for any future meeting with you. My records incidate that your letter of
3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let me know
if you received any sort af "return to sender" letter for that mailing.
Sincerely,
Zacn Coughlin, Esq.,
PO
BOX 60952, RENO, NV, 89506,
.
', : .
tel: 775 3 3 8 8 1 1 8, fax: 949 667 7402;
Nevada Bar No: 9473
" , ' _.,
' ;'
. . ; 1
02757
02757
-""
......,
Zach Coughlin, Esq ., PO BOX 60952, RENO, NV, 89506, tel : 775 338 8 1 18, fax: 949 667 7402;
Subject: RE: my attempt to be provided access to the grievances filed today
Date: Fri, 30 Mar 2012 15:58 : 14 +0000
Dea r M r . Coughl in,
ask t hat I be more careful with the facts and yet you will not respond or d iscuss the facts with me. Please explain
hat extre me ly im portant facts we have wrong. I was awa re that you r phone a nd cel l phone had been ta ke n as
You
evidence.
From : Zach Coughlin [mailto:zachcoughlin@hotmail .com]

Sent:: Thursday, March 29, 2012 6 : 53 PM
To: Patrick King; Glenn Machado; David Clark
Mr. King,
only know of one conviction for a crime, which I reported. Please explain your statement with respect to more than one
conviction.
Please try to be more careful with the facts, you have misstated several extremely important facts so far, and It Is very
alarming. Further, do you make every attorney who is found in contempt of court explain such a finding? Is there any
duty to? Does a summary contempt finding come within the purview of SCR 1 1 1? Doesn't Mr. Machado have jurisdiction
over the criminal conviction which I reported to him months ago? Are you not somewhat alarmed that J udge Nash
Holmes' complaint/letter to you fails to mention her seizure of the attorney's smart phone, other cell phone, and other
personal property? Or the fact that she makes extremely prejudicial assertions based u pon u nattributed hearsay?
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel : 77S 338 8 1 18, fax: 949 667 7402;
Zach Cough l i n@h otma i l .com Nevada Bar No: 9473
To: zacbcougblin@hotmail,com

Date: Thu, 29 Mar 20 12 23 : 1 1 :41 +0000
Dear
Mr. Coughlin,
My info rmation rega rd ing the crimina l convictions a n d the contempt orders agai nst you is limited.
I und ersta n d
of court. I a lso u n d e rstand that you were

convicted of a crime on mo re tha n one occasio n . You a re obv i o u sly awa re of these convictions a nd contempt
orders. Please provide me with a n expla nation of each conviction and of each contempt order.
you were sentenced to jail o n more than o ne occasion for conte m pt
Tha n k
you .
Patrick King, Assistant Ba r Counsel

7
02758
02758

Sent: Thursday, March 29, 2012 1 :46 AM
Subject: RE: my attempt to be provided accessto the grievances filed today
(
......'-
M r. Ki ng,
I recal l you making no request for a written response to anything incident to my

appearing at the Double R location of the State Bar of Nevada to view the g rievances
from the "other different judges". The only one you a l lowed me to view was the two
page letter from J udge Nash Holmes. You did not indicate if J udge Nash Holmes attached
the copy of the 2009 Order for Sanctions by J udge Gardner to Judge Holmes' letter, or
whether that was a separate complaint, and if so, by whom was it submitted . Please do
so in writing a nd provide a date by which I m ust submit a response. Please a lso copy me
via email and or fax on any other materia ls submitted with those Complaints, grievances,
qr letters (it seems patently unfair for you to say those a re confidential and of limits to
me, real ly). You know as wel l as I do that I was not hostile or i ntimidating to you and
that we did not have a "meeti ng". I indicated to you at the outset of my a ppearing at
you r offices that I was only there to view the g rievances or complaints, and that I would
not be able to u nderta ke any meeting with you that day. I am 6 foot 4 i nches tal l and
50 pou nds. If you think this is the first time somebody has tried to play the old "oh you
were trying to intimidate me" card on me, you a re mistaken . I have been socialized to be
doci le and cal m given my size, and real ly, the idea that my size has a ny real effecdt on
any legal proceeding is just silly, but, nonetheless, I have always gone out of my way to
avoid the appearance of being "the big bullying guy". Ma ny, many people who have
known me for the 30 some odd years I have l ived i n this comm u nity attest to that, in and
out of legal Circles. I real ize you wa nted to get more accompl ished then and therer and
that you have previously expressed disatisfaetion at the idea that I would have actually
(:lone any research in preparation for a ny future meeting with you, but I assure you, I
don't su bscribe to the coerced confession approach that is so favored by so many
prosecutors and Bar Cou nsel . I will be l itigating this ful ly. And I wi l l not be forced into
9 iring for $5,000 a "lawyer Kevorkian " hand picked by a strip club owning Character and
Fitness Committee bully, whom appears at the hearing and brags about how he is doing it
'.pro bono".
Sincerely,
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel : 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotma il.com Nevada Bar No: 9473
B
02759
02759
Subject:
my attempt to be provid
ccess to the grievances filed today
Date: Tue, 27 Mar 2012 16:26 : 1 1 +0000
M a rch 2 7} 2 0 1 2
Dea r M r. Cough l i n}
Perh a ps you a re not fu l ly awa re of yo u r behavior. At o u r brief m eeti ng yeste rday I perce ived
you a s ve ry host i l e a n d eve n th reate n i ng. U nd e r those ci rcu m sta n ces I fe lt it better to
term i n a te the m eeting.
I f it was n ot you r intent to a p pear h osti l e o r to atte m pt to i n t i m i d ate m e then yo u m ight
consider h ow I p e rce ived yo u r co n d u ct . I had i nte n d e d to try to l iste n to you a n d
cJ ete rm i n e
h o w m y office cou l d best
h e l p you a d d ress the g r i eva n ces that I h a ve received .
You s a i d you d i d n ot have ti m e a n d
si m p l y wa nted t o a rgue a bout yo u r rece ipt o f e-m a i l o r m a i l . l d i d n ot s a y t h a t I d id n o t ca re if

you received the
i,nformation I s e nt to yo u , I s a i d I did not care how yo u r received it, so long as yo u received
it. I do ca re that you receive the i nformati o n t h at I s e n d to y ou . As I attem pted to e xp l a i n, I
wi l l be meeting with a pa n e l
to h a ve t h e m ma ke a d eterm i n ation a bo ut t h e grieva n ce s that have bee n m a d e a ga i nst you by

M r. H il l a n d the J u d ge fro m Depa rtment 3 that you rea d at my office .
I h a ve a s ked fo r a
writt e n respo nse to those

grieva nces. In res po n se I
re ce ived m a ny e-m a i l s with atta c h m e nts. I will soon be s h a ri ng the
grieva n ces with a d isci p l i n a ry pa n e l a nd w i l l advise th e m of yo u r res p o n s e s to date.

I w i l l kee p you advised of the p a n e l's d ete r m i n atio n .
Si ncere ly,
Patrick K i n g
From: Zach Coughlin [mailto:zachcoughlin@hotmail,coml
Sent: Monday, March 26, 2012 5 : 35 PM

SUbject: my attempt to be provided access to the grievances filed today
Dear Mr. King,
02760
02760
..
.'-'
" " " ""'
This correspondence is sent to confirm that I visited the Double R Blvd. offices of the State Bar of Nevada today and
attempted to be provided access the the various "other different judges" grievances that I, prior to last Friday, was
completely u naware of. I have sent you several written correspondences detailing the tampering and other problems
with my USPS mail incident to the two domestic abuser attacks I have been subject to since approximately 1/1/12, and
ask that you copy my on all correspondences or document production via email a nd fax. Today, you showed me a two
page letter from Judge Nash Holmes. Did you interpret it to be a "grievance"? How is that designation arrived at? You
refused to identify the names of any other judges from whom you have received any other similar such materials and
further refused to allow me to view and such items. I asked for a copy of the large box of documents, and other FOIA
request materials and you refused. Further, you told me you didn't care I received anything you sent me and stated that
I did not have a right to review such complaint letters, grievances, or other materials, prior to being questioned by you
and before any such meeting. I informed you that I am considering different attorneys to represent me right now, and
indicated I need these materials to prepare for any future meeting with you. My records incidate that yaur letter af
3/16/12 is inaccurate to the extent it indicates that I was copied on that letter via email on that date. Please let me know
if you received any sort of "return to sender" letter for that mailing.
Sincerely,
"
:.
' "
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel : 775 338 81 18, fax: 949 667 7402;
ZachCoughlin@hotmail.cam Nevada Bar No: 9473
10
02761
02761
DaW
1io: Patfitk King; Glenn Machado;

Clark
,<,./
Dear Bar Cou nsel,

J ust q uickly (ie, not an exhaustive list as I have a dead l i ne to meet) the
facts that you seem to have confused so far i ncl ude :
1 . Mr. King wrote a 9 am on 3/ 1 6/12 to i ndicate my time to reply to H il l's
grievance had passed or that he has received my reply, when, in fact, Mr.
King had, in writing given me u ntil 3 pm on 3/ 1 6/ 1 2 a nd had been given
notice in writing that I would be submitti ng further materia l s i n reply.
2.: . Mr. King asserted that multiple convictions are at issue here. As far as I
know there is one conviction, in 1 1 CR 22 176, which I report to Bar Cou nsel
Clark a nd Assista nt Bar Counsel Machado prior to ever havin g any
i nvolvement with Mr. Ki ng . As far as I know, a fi nding of civi l contempt
under N RS 22 . 0 1 0(3) (summary contempt for conduct committed in the
court's presence) does not requ i re reporting u nder SCR 1 1 1 a nd is not
crimi nal i n natu re. I could be wrong about that, J udge Flanaga n recently
expressed that there was some uncertai nty i n the judicia ry on that paint,
but regardless, nothing i n either Summary Contempt Order contains
mention of a ny conduct that, i n my opinion, comes with i n the purview of
SCR 1 1 1 (6), or is tantamount to a "serious offense" conta i ni ng a ny of the
elements cited therein. Its not that I do not take such a thing seriously,
however, I just do not read SCR 1 1 1 or Mr. Machado's Nevada Lawyer
article expl icating that rule to require reporting, a nd therefore, be relevant
to Mr. Ki ng's i nquiry. That is a theme here. Mr. King's i n q u i ry seems to be
about as broad a nd open e nded as cou ld me and conta in i ng noth i ng in the
way of jurisdictional restrictions, much less procedural protection (Mr. King
did say he didn't ca re if I received notice of the J udge Holmes grievance,
and there was a rea l troubling tone to the way he said it a nd the look on h i s
face when making that statement) . How Hill ca n file a grievance on behalf
ofGessi n or someone other than H i l l has not been made clear. Further
p(oblematic is the va rying standard of proof seemingly applied to the
g rievances I filed and those fi led by H i l l and J udge H olmes (unattributed
hearsay goes a long way when coming from H i l l a nd J udge
Holmes . . . . . written documentation and transcripts of hearing supporting my
4
02762
02762
,.
"......
...,.
.....,
contentions don't even result i n any investigation from M r. King given his
quick d raw determination that the "clear and convincing" standard would
not be met . . . . " . Further, this i s the fi rst M r. Ki ng has made a ny mention of
knowi ng of the seizure of my personal property ( i ncluding a smart phone)
by Judge Holmes (somethi ng I would hope the Bar wou ld ta ke some
9ffense to g iven the implications of such a practice and for which the Bar
may have a duty to report to the J udicia l Discipline Com mission, according
to my research). J ust today is the first I have ever hea rd of M r. King
asserting he knew, i ndependently of the materials I provided him, that
J udge Holmes had seized my phone. Richard Cornell, Esq . seemed to thi n k
that was tanta mount to a "seizu re", not entering, or booki ng i t i nto
evidence .
3 ' A nother fact M r. King seems to have confused is whether, on 3/16/12,
as nis letter indicates, he actua l ly had a copy of his letter of that date
e91a iled to me. : It certa inly was not faxed, despite my requesting it be and
despite my having and providing a fax n u m ber for my office. I wrote all
Bar. Cou nsel req uesting to be sent a ny notices or correspondences via fax or
email in light of my status as a victim of domestic violence and regarding
the .m isconduct bf the USPS supervisors at my postal station and the
interference with my mail by the domestic a b u sers and negl igent property
manager (whom did admit, u nder oath, that one of her managers had
received approval from the HOA for my former housemates to be at the
1422 E. 9th St. #2 townhome, where they were for over 9 months before
this Owner of the property management com pany a pparently coaxed a
reSig nation out of the former manager (on January 5th, 2012) who entered
s.uch a n arrangement found out. Suddenly, thi s owner of Western Nevada
Management, Sue King, apparently wa nts everyone to drop everything,
excuse her negligence and alleged lack of knowledge of that arrangment,
and cou ntenance her allegedly im ploring NV Energy to refuse to a l low me to
have power turned on one the domestic a buser former housemates had it
shut off (NV Energy did wait 7 days before finally agreeing to let me have
the power turned on i n my name . . . . so I did not have power for from
February 3 to February 1 0, tha nks to Ron Jones, of NV Energy, a nd,
a pparently, the infl uence of HOA resident agent Gayle Kern, Esq . , LTD and
her property m a nager, Sue King, owner of Western Nevada M anagement),
_ . ; ::
02763
02763
then King a l legedly i mplores the USPS to refuse me a mailbox key, which
they respond to by inform ing me they are "feds" a nd "don't have to follow
state laws" ( l i ke N RS 1 1 8A. 160 and 1 18A. 1 90, etc . ) a nd "aren't going to put
up with any more of your garbage" and "don't care if you are a lawyerll,
etc., etc., beca use (Golden Va lley Station e m ployees Buck Hyde, Terri
James and " M s . " Passot) "we think you are a sq uatter anyways and aren't
going to waste o u r time going out an changing the lock since you will
probably j u st get evicted anyhow . . . ". It would be great if the State Bar of
Nevada may be a ble to provide some help i n getting these monolithic
entities to fol low the law rather than retal iate again st a lawyer.
L . Mr. King seems to have confused what occurred on 3/23/ 1 2 . I appeared
at te State Ba r Offices to view the "other different j udges" g rieva nces that
Mr.: King would only let me view by so appeari ng i n person . I informed h i m
Fwould not consent to o r be able to meet with h i m at that time, b u t was
apparing o nly to view the documentation in the only manner being
afforded me by Mr. King's approach . Mr. Kin g now seeks to categorize my
appearance to view such documentation as a "meeting" along the l i nes of
those traditiona lly held i n the informal stage of an i nquiry l i ke this. It was
not. Further, Mr. Ki ng's characterization of my document viewing on that
date is i ntellectually d ishonest, overly hosti le and aggressive, a nd i n l i ne
with m uch of the prosecutorial misconduct that I have written of
recently. There are a n u m ber of other such i nsta nces where material facts
have been "co nfused" by M r. King, but those wil l n eed to be addressed at a
later date .
Sincerely,
lach Coug h l i n, Esq .
,. ..
02764
02764
,-.
\w.I
From:
Sent:
To:
Subject:
Zach Coug h l i n <zachcou g h l in@ hotmail.co m >

Friday, March 30, 2012 9:03 PM
Patrick King; David Cla rk; Glenn Machado
RE: my attempt to be p rovided access to the g rievances filed today
Dear Bar Counsel,

Why did you earlier mention more than one conviction? That is exactly what I
mean by "getting confused about material facts" . Similarly, Mr. King was confused
about whether any email is sent from a web site or an email address and whether
anyone from the State Bar of Nevada emailed me Mr. Kings 31 1 61 1 2 letter (that was
when Mr. King indicated he did not care if I received that letter or not in an
alarming delivery). Why would you bring up anything about a conditional
admission when the conditions expired in 2008? It is this alarmingly loose
approach to maintaining some fidelity to traditional notions of due process and fair
play that Mr. King exhibits that troubles me the most. For instance, he blanket
refusal to provide anything in response to my FOrA and other requests. How could
that possibly be fair? I have provided additioanl documentation in support of the
grievances against the Christiansens, Sanfi, Kevin Kelly and Eichman. Do you still
60niend that there is no basis for any further inquiry? Further, you mention a
clisability approach, however, you fail to cite with any specificity why you suggest
that approach. Please do so. Please explain to me how your stance is anything
other than "well, these powerful people are asking me to mash on you and that
generally is in my best interest and helps me avoid having any skin in the game,
and, yeah, I know, ideals, ideals, stand up for brave lawyers, bar counsel duties,
etc., but really, come on, why should I stick out my neck" , etc., etc.
When and how did you become aware that Judge Nash Holmes seized my phones
and other property. Seizing a smart phone is like seizing 1 0 filing bins. But I am
hot sure you understand that because you seem confused over whether an email is
sent from an email address or from a website, as indicated in your statements while
I was viewing the documentation. I ask that you understand some of what I have
been through with the Bar. You really cannot imagine what I have been through
unless you lived it. It completely raped my life and it didn't stop when getting
admitted in in 2005 . It carried on for several more years, especially in
California. $SK for Christiansen was an outrage, then to have him appear at the
hearing and say he was doing it "pro bono", especially after Kevin Kelly's
02765
02765
,.-..
-'''''
'-"
'
statements about providing me "the names of three attorneys who will do you case
ptobo'ilo" is further alarming. How in the world Kevin Kelly can be on the
Character and Fitness Committee for a decade while owning the Spearmint Rhino
truly mystifies. Its nots the ownership, its the alarming Nifong approach he took
with me, especially vis a vis his democratic party buddy Mark Tratos. Clearly,
Tratos received my paper and he and LaFrance were just playing kick the can with
me. I swear to god on mine and everyone in my families life I turned in that paper,
and that guy knows it. He swore under oath at the California hearing that he had
lost .other students papers previously. I know legion of people who loath
him. Whatever, I don't like to embrace hate. Life is short.
Mr. King , I do get a sense about you that you are interested in fairness in your
heart. However, I recognize when a scenario is stacked in a way that is likely to
affect one's judgment. This is such a scenario. But you know what? Judge
Flanagan told Richard Hill to put the clown makeup down the other day. Judge
Sferrazza seemed to be tiring of how flagrant Hill was beign with thing, especially
with the reputations of those he was dragging into hsi chicanery. I destroyed Hill's
contractor on cross examinatino on March 23, 20 1 2 . Judge Flanagan actually
lauged and smiled a couple times at how ridiculous Phil Stewart's testimony
got First it was he "assumed I climbed on the truck because he felt a depression
occur on the vehicle when allegedly the 240 pound Coughlin supposedly climbed
up on the truck, depsite the fact that Stewart had to admit that the modified 2 ton
dumptruck had approximately 1 500 pounds of a "luxury sedan car seat collection"
and other personal property. . . then it was, that "he felt the depression lift from the
truck after he got out to look in the blind spot behind the truck to see what Coughlin
was doing. . . .then it was, oh wait, he felt the depression of weight lift before he
alighted from the vehicle ", that he misspoke, then it was "well, I know you climbed
on the truck because I saw your head atop the contents of the dumptruck in the
mid.dle ofthe area above the tailgate in my rear view mirror". . . .Really? Why go
into all that about alighting, and depressions of weight, and "assuming" . . . . Why not
j ust say you saw a guy's head in the rear view mirror in a place that would indicate
he had climbed on the truck rather than demonstrated an ability to levitate? Judge
Flanagan was done with the whole matter after that. He ruled for me and Hill and
Baker knew they better not be stupid enough to even try to put on any more
evidence, and it didn't seem like Judge Flanagan was much interested in their doing
so at that point anyway.
I
saw Mr. Clark speak at the Family Law conference in Ely in 2008, I believe, and
spoke with him on the phone about a year and a half ago when I had a question
2
02766
02766
.wl
....i
abQut whether there is a respository of contempt orders issued against attorneys. I

hon
est feel sanctions under NRS 1 8.0 1 0(2)(b) and NRS 22.0 1 0(3) are becoming
very big problems in our field. The access to justice is being curtailed through a
bullying approach to applying such mechanisms. Rather than allowing market
forces dicate that rich powerful parties engage in legitimate settlement discussion
when the law is not on their side (ie, when Merliss and Hill wish to ran a summary
eviction procedure through a court where doing so is per se impermissible in light
of the tenant beign a commercial one and the notice failing to allege nonpayment of
tent).
IY
But at my core, what really drives me is a belief in competition. If Hill and Merliss
can run that game on most people, it is what it is. But I suited up and showed up
and:battled and I deserve to have those skills, efforts, energies, guts, and passions
thatI displayed in doing so translate into something tangible in a court of law,
particularl where the law and facts were as favorable to my case as they were. I
Clon'! deserve some compassion fascism witch trial.
Sincerely
Zach Coughlin, Esq.,
PO BOX 60952, RENO, NV, 89506,
tel: 775 338 8 1 1 8,
ZachCough lin@hotmail.com Nevada Bar No: 9473
fax:
949 667 7402;
From : PatrickK@nvbar.org
To: ,chcoughlin@hotmail .com
Subject: RE: my attempt to be p rovided access to the grievances filed today
Da te : ,Fri, 30 Mar 2012 19:01:56 +0000
Dear M r. Cough lin,
I uhderstand that there is one conviction. I a l so u nderstand that there a re othe r cri m i n a l charges pending that have not
been reso lved . One is set for a tria l o n April 12, 2 0 12, a trespass c h a rge. I am a lso a w a re of contempt o f Court Orders.
you were cond itio n a l l y

If s o , p e r h a p s we c o u l d discuss a sti p u lation
This behavior on you r pa rt a ppears to be contrary to the com m itment you made w h e n
a d m itted.
Do yo u t h i n k y o u n e e d a n d w o u l d benefit fro m treatment?
pursuant to SCR 117
2 fo r yo u go o n a d isa b ility status w hile you obta i n treatment. Such a n agreement might be
b e n eficial fo r you. Please let me know if you want to discuss a stipulatio n .

Patrick King, Assistant Ba r Counsel

30, 2012 10: 14 AM
Sent: Friday, March
02767
02767
i
.......
Patrick King
Zach Coughlin < zachcoughlin@hotmai l oco m >
From:
Sent:
Friday, M a rch 09, 2012 5:45 P M
To:
Patrick King; G lenn Machado; David Clark
response to grievance fro m NV
Subject:
Attachments:
Attorney
3 9 12 fax to State Bar of Nevada Bar Cou nsel requesting extension of time to respond
to Richard G . H ill, Esq. g rievance.pdf
Zach Coughlin, Esq.

Nevada Bar No: 9473
1 422 E.
9th St. #2
RENO, NV 895 1 2
tel: 775 3 3 8 8 1 1 8
775 328 6045 fax: 949 667 7402
ZachCoughlin( )hotmail.com
a
State Bar of Nevada
P,D. Box 50
Las Vegas , NY
8 9 1 25-0050
600 E. Charleston B lvd.
Las Vegas, NV 89 1 04
sent by fax and email only to;
Reno Office: 775 329 0522
Las Ve gas Office: 702 3 85 2878
DavidC@nvbar. com, Patrick:K@nvbar.com, GlennM@nvbar.com
March 9, 2 0 1 2,
,
,
', . ' ,
pear Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
(Jnly just now received the letter, dated February
1 4th, 20 1 2 that Assistant Bar Counsel King sent me, wherein
the grievance filed by Richard G. Hill, Esq. is set forth. Mr. King wrote, "please respon d in writing to this
grievance within ten ( 1 0) days from th e date of this letter . "
I am' requesting an extension of time to respond to this matter. I literal ly just received this mai ling from you
within the last hour, and was unaware of this prior to that. Further, I hope I can demonstrate to you and the
State Bar of Nevada that circumstances at least somewhat beyond my control have prevented me from receiving
my mail in an orderly and consistent fashion. These circumstances resulted in two different D omestic Violence
Protection Orders being granted to me against my former housemates by
Master Edmondson of the Second
Judiial District Court in FV 1 2-00 1 88 and F V 1 2-00 1 87. Further, the electricity to my location was interrupted
from 'one week (though I attempted to get NV Energy to accept payment from me for services) from February
3rd to February 20th, 20 1 2, incident to one of the individuals against whom a protection order was issued
1
02768
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ng electrical service.
attempt ng to prevent me from obt
rlame individuals against whom
Additionally, th
these protection orders were issued interfered with my access to my mail from the USPS, and it has taken some
time to get the USPS Postal Inspectors to release my mail to me and or allow me to receive mail atmy
location.
Please note that I did recently send Bar Counsel David Clark and Assistant Bar Counsel Glenn Machado a
\wittcn request that the State Bar of Nevada please help me in remaining aware of any correspondence being
sent me from the State Bar while I work to get
my mailbox situation settled (please see below):
On February 22nd, 2 0 1 2 I wrote to Bar Counsel Clark and Assistant Bar Counsel Machado that "I had to move
recently and moved in with two individuals who I ultimately wound up getting Protection Orders against, and
they have
interfered with my ability to receive my mail with absolute certainty (I have received much of my
mail, and have pending correspondences/requests with the Postmaster for Reno, NV to obtain a permanent and
newly rekeyed lock and key to access my mailbox. . .! have been informed by USPS Reno Postmaster agent
named Mr. Heister that if I fax him proof of my location at 1 422 E. 9th St. #2, he will then allow me to get a
mailbox key made . .I faxed him proof and will call him again tomorrow to see how much longer I must wait. . . .if
.
i'ts much longer I will make alternate arrangments, however, I anl an electronic filer in both courts that I
am
appearing in (NVB and WCDC) . . . ). I am writing to ask that any correspondences/notices etc. that you or
the
y
State Bar of Nevada may have for me or ma have mailed to me be, if possible, copied to me via my
fax number or email address."
.
.
- . i .. , " .
I iJl 'strongly that Mr . Hill's allegations are ones I will wish t o contest vigorously, and I hope J am afforded an
opportunity to do so. There
is a lot more to this situation than Mr. Hill indicates.
Sincerely,
Zach Coughlin
Zach Coughlin, Esq. , 1 422 E. 9th 8t. #2, RENO, NV 895 1 2, tel: 775
ZachCoughlin@hotm ail.c
Nevada Bar No : 9473
3 3 8 8 1 1 8, fax: 949 667 7402;
02769
02769
.........
Nevada Bar No: 9473

1 422 E. 9th St. #2
RENO, NV 895 1 2
tel: 775 3 3 8 8 1 1 8
775 328 6045 fax: 949 667 7402
ZachCough li n@h otmail . com
'
State Bar of Nevada
P.O.
Box 50
UlS Vegas, NV 891 25-0050
600 E. Charleston Blvd.
sent by fax and email only to:

Las Vegas Office: 702 3 8 5 2878
DavidC@nvbar.com, PatrickK@nvbar.com, GlennM@nvbar.com
March 9, 20 1 2,
'
D Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
i only just now received the letter, dated February 1 4th, 20 1 2 that Assistant Bar Counsel King sent
me:,; wherein the
grievance filed by Richard G. Hill, Esq. is set forth. Mr. King wrote, "please
respond in writing to this grievance within ten ( 1 0) days from the date of this letter. "
I am
requesting an extension of time to respond to this matter. I literally just received this mai l ing
rom you within the last hour, and was unaware of this prior to that. Further, I hope I can
f
demonstrate to you and the State Bar of Nevada that circumstances at least somewhat beyond my
c ontro l have prevented me from rece iving my mail in an orderly and consistent fashion. These
sircum stances resulted in two different D ome stic Violence Protection Orders be ing granted to me
agai nst my former house mate s by Master E dm onds on of the Second Judicial District Court in
FV 1 2-00 1 88 and FV1 2-00 l 87 . Further, the electricity to my location was interrupted from one
week (though I attempted to get NY Energy to accept payment from me for services) from
February 3rd to February 20th, 20 1 2, incident to one of the individuals against whom a protection
order was issued attempting to preventme from obtaining electrical service. Additionally, the same
individuals against whom these protection orders were issued interfered with my access to my mail
from the USPS, and it has taken some time to get the USPS Postal Inspectors to release my mail to
me' and or allow me to receive mail at my location.
Please 'note that I did recently send Bar Counsel David Clark and Assistant Bar Counsel Glenn
3
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Machad
'..""".,
a written request that tState Bar of Nevada please help m'e'in remaining aware of any
correspondence being sent me from the State B ar while I work to get my mailbox situation settled
(please see below):
On February
22nd, 20 1 2 I wrote to B ar Counsel Clark and Assistant B ar Counsel Machado that
had to move recently and moved in with two individuals who I ultimately wound up getting
"1
Protection Orders against, and they have interfered with my ability to receive my mail with
absolute certainty
(I have received much of my mail,
and have pending correspondences/requests
\.vith the Postmaster for Reno, NV to obtain a permanent and newly rekeyed lock and key to access
ormed by USPS Reno Postmaster agent named Mr. Heister that if I fax
my mailbox. . .I have been inf

him proof of my location at
1422 E.
9th St. #2, he will then allow me to get a mailbox key made.
.I
faxed him proof and will call him again tomorrow to see how much longer I must wait.. . . if its much
longer I will make alternate arrangments, however, I am

appearing in
(NVB and WCDC) ) I
am writing to
...
an
electronic filer in both courts that I
am
ask that any correspondences/notices etc.
that yo u or the State Bar of Nevada may have for me or may have mailed to me be, if
possible, copied to me via my fax number or email address. "
J;
l, fed strongly that Mr. Hill's allegations are ones I will wish to contest vigorously, and I hope I am
afforded an opportunity to do so. There is a lot more to this situation than Mr. Hill indicates.
Sincerely,
Zach Coughlin"
".
.'
Zach' Coughlin, Esq., 1 422 E. 9th St. #2, RENO, NY 89 5 1 2, tel: 775 338 8 1 1
8, fax: 949 667 7402
'
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NY 895 1 2

tel: 775 338 8 1 1 8, fax: 949 667 7402;
,
Nevada Bar No: 9473
From : zachcoug hlin@hotm ail.com

To : Istuch e:" @was oecounty. uSi mkandaras@da.washoecounty .usi drakej@re
no.govi kadlicj@re no.govi
.
dbker@ lchardhlllaw.co ; Jbols@callatg.com; bbuckley@ lacsn,orgi daolshan@yahoo.comi jsoderlund@nlslaw.n
et;
]dehkanakls@swlaw.com; ]goodmght@washoecounty. us; jbosler@washoecounty . us;
bdogan@washoecQunty .us;
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'-'
..
I'nechols@maclaw.com; mclarkson@puc.nv.gov
Subject: Evictions RE: WCSO Deputy Machem's "personally served" Affidavit of 1 1/ 1/20 1 1
Date: Fri/ 10 Feb 2 0 12 1 2 : 14:0 1 -0800
Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 1 1 1 1 120 1 1

Date: Tue, 7 Feb 201 2 1 1 :40 :39 -0800
From: LStuchell@washoecounty.us
CC : mkandaras@da.washoecounty.us
Mr. Coughlin
Our records indicate that the eviction conducted on that day was personally served by Deputy
Machen by posting a copy of the Order to the residence. The residence was unoccupied at the time.
). . .
'
Liz Stuchell, Supervisor

WCSO Civil Section
Serit:. Monday, February 06, 20 1 2 2:58 AM
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov;
fourthestate@gmail.com; jamesandreboles@msn.com
S ubject: WCSO Deputy Machem's "personally served" Affidavit of 1 11 1 /20 1 1
Dear IA Supervisor Stuchell and DDA Kandaras,
realize you will likely not read all of this. The main thing is I am respectfully requesting that you
60nfirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order
m m,e at 1 2 1 River Rock St., Reno 895 0 1 on November 1 , 20 1 1 at 4:30 pm, in connection with
performing the lockout. It is my position that I was not "personally served" and I am trying to
figure out whether Deputy Machem is lying or whether the phrase "personally served" means
something other than what I believe it means, etc., etc. I appreciate your attention to this.
I
i am writing to inquire about and complain with regard to
Affidavit of Service filed by or for

WCSO Deputy Machem with respect to the service of a Order Granting Summary Eviction against
me (in my law office where non-payment of rent was not alleged, no less in violation ofNRS
40.253 and where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6),
especially where a stay of eviction was not granted even while the RJC held on to most all my
money ... )
My issue with the WCSO is that Machem's Affidavit of Service indicates that he "personally
served" me, which kind of reminds me of all that robo-signing and MERS fraud I come across in
my day job (and do you wonder how many attorneys in the foreclosure defense game I am in
constant contact with who are watching and witness the potential RICO violations this writing
Dlentions?), which includes being a foreclosure defense attorney. So which is it? Did Machem
';'personally serve" me the Summary Eviction Order? Richard O. Hill, Esq. likes to argue that I was
an
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p:
..
"5'erved ;' in compliance with all e related rules because it was don'e'm the "usual custom and
practice of the WCSO. What, exactly, is the "usual custom and practice of the WCSO? I hear a lot
about this "within 24 hours" stuff. So, I go hunting for some black letter law to support what those
at the RJC and in the clueless community at large (which often includes Nevada Legal Services and
Washoe Legal Services, the people you guys had such trouble actually serving in the lawsuits I
filed, which may have actually helped improved legal services in this community, if they were not
dismissed due to insufficiency of service of process, even where the IFP required the WCSO to
served the defendants . . . . ). Anyway, back to the "within 24 hours" phraseology: "
This whole business about "The court may thereupon issue an order directing the sheriff or
.constable of the county to remove the tenant within 24 hours after receipt of the order... " is
inapplicable to this situation, where an Order Granting Summary Eviction was signed by October
27th, 201 1 . That language is only found in situations inapplicable to the current one. NRS
40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections ofNRS 40 where this "within 24
hours" language occurs, and those situations only apply where, in:
40253(3)(b)(2): " 3 . A notice served pursuant to subsection 1 or 2 must: ... (b) Advise the tenant:
; : . . (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may
issue a summary order for removal of the tenant or an order providing for the nonadmittance of the
tenant, directing the sheriff or constable of the county to remove the tenant within 24 hours after
receipt of the order"
d,
40.253(5)(a): "5 . Upon noncompliance with the notice: (a) The landlord or the landlord' s agent
may apply by affidavit of complaint for eviction to the justice court of the township in which the
dwelling, apartment, mobile home or commercial premises are located or to the district court of the
county in which the dwelling, apartment, mobile home or commercial premises are located,
whichever has jurisdiction over the matter. The court may thereupon issue an order directing the
sheriff or constable ofthe county to remove the tenant within 24 hours after receipt of the order."
The way these summary eviction proceedings are being carried out in Reno Justice Court presently
shocks the conscience and violates Nevada law. There is not basis for effectuating a lockout the
way WCSO's Deputy Machem did in this case. The above two sections containing the "within 24
hours of receipt" language are inapplicable, as those situations do not invoke the present
circumstances, where the Tenant did file an Affidavit and did contest this matter to a degree not
often seen. To require Nevada's tenants to get up and get out "within 24 hours" of "receipt of the
order" (what does that even mean? The use of terms like "rendition", "rendered", "notice of entry",
I'pronounced", is absent here, and this "receipt of the order" language is something rarely found
elsewhere in Nevada law-see attached DMV statutory citations, and in employment law litigations
vhere one must file a Complaint within 90 days of "receipt" of a Right To Sue Letter, a situation
\vhich follows NRCP 5(b), and NRCP 6(e) in imputing receipt of such a letter, when actual receipt
is not shown, by applying a "constructive notice" standard that relies upon the days for mailing
extension of time for items served in the mailing, etc.). In Abraham v. Woods Hole Oceanographic
Institute, 553 F.3d 1 14 ( I st Cir. 2009), the record did not reflect when the plaintiff received his
right-to-sue letter. The letter was issued on November 24, 2006. The court calculated that the 90day period commenced on November 30, 2006, based on three days for mailing after excluding
Saturdays and Sundays. In order to bring a claim under either Title vn or the ADA, a plaintiff must
ehaust administrative remedies and sue within 90 days of receipt of a right to sue letter. See 42
U.S.C. 2000e-S(f)( 1 ). See Baldwin County Welcome Center v. Brown, 466 U.S. 1 47, 148 n. l ,
6
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'.
'
1 04 S.Ct. 1 723, 80 L.Ed.2d 1 96 ( 1 984)(granting plaintiff an additio three days for mailing
pursuant to Rule 6) ...." . . .
'-"
pear Washoe County Sheriffs Office,

http://en.wikipedia.orgiwiki/Service_ofyrocess
1',Substituted service
When an individual party to be served is unavailable for personal service, many jurisdictions allow
for substituted service. Substituted service allows the process server to leave service documents
with another responsible individual, called a person of suitable age and discretion, such as a
cohabiting adult or a teenager. Under the Federal Rules, substituted service may only be made at
the abode or dwelling of the defendant.[4] California, New York,[5] Illinois, and many other
United States jurisdictions require that in addition to substituted service, the documents be mailed
to the recipient. [ 5] Substituted service often requires a serving party show that ordinary service is
impracticable, that due diligence has been made to attempt to make personal service by delivery,
and that substituted service will reach the party and effect notice.[5]"
iam pretty sure "personally served" means you served the person in person, not that a person
pamed Machem went and posted a notice on a door, personally himself. See, I think you guys are
thillking of the "person" in the word personally as applying to the server, when in all instances I
have ever seen it used in the law, the "person" part of "personally" applies to the person being
served. Help me out here, Mary.
https:llskydrive.live.comlredir.aspx?cid=43 08463 8f32f5f28&resid=43 08463 8f32F 5 F28 ! 1 897 &parid=root
Also, does the WCSO have a position on what type of service is required of eviction orders prior to
the WCSO or whoever does it, being able to conduct a lockout?
http://www.leg.state.nv.us/courtrules/nrcp.html
NRCP RULE 60. RELIEF FROM JUDGMENT OR ORDER... (c) Default Judgments: Defendant
'Not Personally Served. When a default judgment shall have been taken against any party who was
not personally served with summons and complaint, either in the State of Nevada or in any other
jurisdiction, and who has not entered a general appearance in the action, the court, after notice to
the ' adverse party, upon motion made within 6 months after the date of service of written notice of
t>ntry of such j udgment, may vacate such judgment and allow the party or the party's legal
representatives to answer to the merits of the original action. When, however, a party has been
personally served with summons and complaint, either in the State of Nevada or in any other
jurisdiction, the party must make application to be relieved from a default, a j udgment, an order, or
other proceeding taken against the party, or for permission to file an answer, in accordance with the
provisions of subdivision (b) of this rule.
Okay, so, really, you guys do this for a living, right...you serve people things .... and sign Affidavits
n<ier p enalty of perjury and stuff, and you are telling me you believe "personally served " can
7
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included situations where the person was not there? Okay..... you doow that, like, a Summons
and Complaint need to be "personally served" in the sense that, say Machem, would need to see
that person and serve it on them (I don't think they have to take the paper, they don't need to agree
to accept service, but Machem does need to see that person, in person, personally when he is
:swearing under penalty of perjury that he "personally served" somebody. Usually "personally
served " is only done in the case of the first thing filed (unless there is an IFP) in a case, the
Summons and Complaint. Thereafter, typically, people just effect " substituted service" because its
cheaper, less of a hassle, and "personal service" is only required for serving the pleadings that start
a case, the Summons and Complaint. Wow.... Okay, so this is my whole point, these state sponsored
lockouts under color of state law should not be being done so fast, unless you guys "personally
serve" the tenant, I feel the law is quite clear, you have to effect "substituted service" which, under
NRCP 6(a) and NRCP 6(e) and NRCP 5(b)(2) (and NRCP, not JCRCP is applicable to eviction
matters according to NRS 1 1 8A) the tenant cannot be deemed to have received or constructively
received the Order until the 3 days for mailing has passed.
,
........
..
'
fters?nal service by process server

Personal service is service of process directly to the (or a) party named on the summons, complaint
or petition. In most lawsuits in the United States, personal service is required to prove service. Most
states allow substituted service in almost all lawsuits unless you are serving a corporation, LLC,
LLP, or other business entity; in those cases, personal service must be achieved by serving (in
hand) the documents to the "Registered Agent" of a business entity. Some states (Florida) do not
require that the documents actually be handed to the individual. In California and most other states,
th documents must be visible to the person being served, i.e., not in a sealed envelope. If the
IIldividual refuses to accept service, flees, closes the door, etc., and the individual has been
positively identified as the person to be served, documents may be "drop" served, and it is
considered a valid service. Personal service of process has been the hallmark for initialing litigation
for nearly 1 00 years, primarily because it guarantees actual notice to a defendant of a legal action
against him or her. Personal service of process remains the most reliable and efficacious way to
both ensure compliance with constitutionally imposed due process requirements of notice to a
defendant and the opportunity to be heard. [2]'" The National Law Review: The Continuing
Relevance of PersonaL Service of Process
And even if something indicates Coughlin "knew" about the Order, much like in the case of
Coughlin's that was dismissed where the Washoe County Sheriffs didn't manage to get the
"personal service" of the Summons and Complaint done in time, or "sufficiently", opposing counsel
in that matter could tell you that "actual notice" is not a substitute for compliance with the service
equirements.
Which is nice because folks like Richard G. Hill, Esq. have less of an opportunity to game the
system and swoop in with lockout then assert a bunch of hooey . about NRS 1 1 8A.460 "reasonable
torage, moving, and inventorying expenses" subjecting the tenant's personal property to a lien.
Richard G. Hill insisted on throwing away the last thing my beloved grandmother gave me before
he died 2 years ago in the town dump. He and his contractor lied about so many things, including
8
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..,...
tbe fact that they used my own damn plywood to board up the back porch of the property, then
submitted a bill to the court in an exhibit for $ 1 ,060 for " securing" the property (which doesn't
really apply to NRS 1 1 8A.460's "reasonable storage moving and inventorying expenses" like it is
$900 a month for storage and sent me a bill for such prior to
my arrest for trespassing at the 1 2 1 River Rock location, . . .well if they charged me $900 to have a
required to . . . further, the charged me
.home law office there, then how is it someone could be trespassing if they are being charged the
full rental value for "use and occupancy of the premises"? Further, even if it was a storage
situations, there are sections ofNRS 1 1 8A devoted to evicting someone from a storage facility, not
arresting them for trespass, and certainly not a custodial arrest where the
RPD Officer Carter and
Sargent Lopez admit they never issued a warning to me or asked me to leave prior to conducting a
custodial arrest (which required $800 of bail, great! , and
3 days in jail, no less). This is especially
poor form where Officer Carter admitted to me that he takes bribes from Richard Hill. Hey, if
Officer Carter did not say that to me, go ahead and sue me, my man. . . .I'm waiting. . . . .that's what
thought.
fie can say he was j oking all he wants, but it ain't no joking ass situation to me when you are
rresting me and causing a google search result for my name to show an arrest.. . .that's damaging
tqe cmly thing I have of monetary value (my professional reputation and name). It ain't no stand up
hciur, when you are putting me in cuffs, bro. And Officer Carter and Sargent Lopez ref
used to
properly query Hill as to whether he had sent me, prior to the trespassing arrest, a bill for the "full
r.enl value" of the property, a value that, at
occupancy" of the premises. And Richard
$900, was the same charge for the full "use and
G. HIll, Esq. was too busy chortling and filling out the
Griminal Complaint to bother setting them straight, despite my cues, I guess.
NbW, add to that malfeasance the fact that Judge Sferrazza let Casey Baker, Esq. prepare the Order,
\hich means faithfully put to writing what the Judge announced, not attempt to steal $2,275 for
your Californian Beverly Hills High S chool graduate neurosurgeon client by slipping in something
the j udge never said, ie, that the neurosurgeon gets to keep the
$2,275 that Judge Sferrazza order
the tenant to pay into the Reno Justice Court as a "rent escrow" deposit required to preserve the
right to l itigate habitability issues. Now, nevermind the fact that Judge Sferrazza actually did not
have the j urisdiction to require that (there is not JCRLV 44 in Reno, that's a Vegas rule, and if Reno
wants a rule l ike that of its own JCRCP 83 requires the RJC to publish it and get it approved by the
Neyada Supreme Court first.. . . period.). Okay, so, to take it a step even further, B aker's order goes
!1c to say "but the $2,275 won't be released to the neurosurgeon yet, "instead that sum shall serve as
security for Coughlin's cost on appeal, pursuant to Nevada JCRCP 73 ". But wait, doesn't that
l11 e an Coughl in then gets a Stay of Eviction during the pendency of the Appeal? Isnt' that was a
...
security that large must be for? Because the "Appeal Bond" is set by statute at only a mere
$250 . . . . so holding on to 1 0 times that much of Coughlin's cash must have been for the "Supersedeas
40.380 and 40.3 85.
Bond" mentioned a yielding one a Stay of Eviction in NRS
I know, I know, its confusing because actually those sections force the landlord, his attorneys and
the RJC to choose between viewing Coughlin as a residential tenant whose rent is less than $ 1 ,000,
and whom therefore is only required to post a measly supersedeas bond of $250 (and remember, a
supersedeas bond equals a stay of eviction equals not trespassing) or the the other choice is to view
9
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..
r
,.,."':s"'....:
Coughi in as a commercial tenan which would allow charging a hi

supersedeas bond (except
for that pesky part about his rent being under the $ 1 ,000 required by the statute to do so, his rent
being only $900), except, darn it, old Richard G. Hil1, Esq. and Casey Baker, Esq. elected to pursue
ihis summary eviction proceeding under a No Cause Eviction Notice, which is not allowed against
a commercial tenant (ie, you can't evict a commercial tenant using the summary eviction
procedures set forth in NRS 40.253 unless you alllege non payment of rent and serve a 3 0 Day Non
Payment of Rent Notice To Quit, which they didn't because they "are just taking the path of least
resistance here, Your Honor (insert their smug chuckling and obnoxious/pretentious "can you
believe this guy?" laughter and head shaking ... ).
NRS 40.380 Provisions governing appeals. Either party may, within 1 0 days, appeal from the
judgment rendered. But an appeal by the defendant shall not stay the execution of the j udgment,
unless, within the 1 0 days, the defendant shall execute and file with the court or justice the
defendant' s undertaking to the plaintiff, with two or more sureties, in an amount to be fIxed by the
court' or justice, but which shall not be less than twice the amount of the judgment and costs, to the
effect that, if the judgment appealed from be affIrmed or the appeal be dismissed, the appellant will
pay the judgment and the cost of appeal, the value of the use and occupation of the property, and
damages justly accruing to the plaintiff during the pendency of the appeal. Upon taking the appeal
and filing the undertaking, all further proceedings in the case shall be stayed.
So, why on earth is the City Attorney's Office still trying to try Coughlin on the trespass charge for
which he endured a custodial arrest and for which old Richard Hill is still filing Motion's to Show
Cause on in the appeal of the summary eviction matter in CV I 1 -03628? Why, oh why? Does the
Reno City Attorney's Office have some sort of vested interest in keeping Coughlin down, busy,
besotted, encumbered, or otherwise? It, why, it couldn't be because Coughlin has a really good
wrongful arrest cause of action against the Reno Police Department, could it?
http':/Iwww.youtube.com/watch?v=5PR7q4015bO
And, well, yeah the Washoe County Sheriff's Office didn't quite get those Summons and
Complaints served in that one case Coughlin was suing his former employer in, the one where
Coughlin was granted an Order to Proceed In Forma Pauperis, which required the Washoe County
Sheriff's Office to serve the Summons and Complaints ....But what does that have to to with the 6
days Coughlin spent in jai l on the arrest shown in the youtube video above? Its not like the Washoe
County jailed videotaped a scene where they were forcing Coughlin to get naked and put on a green
aress. What's that? It is? They did do that? Really? No ... What? They also forced him to simulate
oral and anal sex with deputies, in the guise of some ridiculous "procedure" necessary to insure
Deputy safety? Oh, wow. And they retaliated against him for failing to answer their religious
preference interrogation questions by placing him in an icy cold cell for hours at a time, refusing
him medical care despite his plaintive cries for help, while wearing a thin t-shirt? Wow. They didn't
jam a taser needle in his spine for extended periods of time, though, did they? Your kidding! Whats
r,:text, your going tell me Sargent Sigfree of the Reno PD ordered a custodial arrest on Coughlin for
"jaywalking" while Coughlin was peacefully filming, from a public spot, Richard G. Hill's
fraudulent contractor Phil Howard destroying and taking to the town dump items of enormous
senthnental value to Coughlin that he was prevented from retrieving from the property during the
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.,...
...
scant tie he was allowed to (afthe paid $480 worth of a lien for wt he knew not, because,
despite, 01' Contractor Phil's fraudulent $ 1 ,060 bill for "securing" the back porch (with screws
facing the outside, inexplicably, and a window unit alc left in the window facing the sidewalk near
the Lakemill Lodge, secured by nothing but duct tape
It is
kind of a combo neon sign that says "Burglarize this Place, Everybody! ") , Coughlin's former
home law office was burglarized on December 1 2, 201 1 while Richard G. Hill was holding its
contents (including, tackily, Coughlin's client's files, like the ones for the foreclosure defense
actions, etc.), asserting his "lien". A lien for "storage" where the charge for storage, $900, was the
same as the charge for "full use and occupany" was. However, that $900 a month for "storage" also
included another $ 1 ,060 charge for "securing" (and that bill actually listed "fixing a leak in the
basement. ..neither of which seem to have much to do with the "reasonable storage, moving, and
inventorying" expenses such a lien is provided for under NRS 1 1 8A.460 .... ) . Jeez, your probably
going to tell me Sargent Sigfree ordered another custodial arrest on Coughlin j ust two days after the
jaywalking arrest, for the same fact pattern that Master Edmondson granted Coughlin's applications
for Protections Orders against based upon the battery and assaults that his former housemates
committed. Because, Sargent Sigfree thinks its "misuse of 9 1 1 " for Coughlin to call when he
returns home at night and his dog has mysteriously disappeared, and his housemates make
menacing commentary about it. Surely, Coughlin, a former domestic violence attorney would have
nothing helpful to add to Sargnet Sigfree's expert opinion that "animal abuse is not domestic
violence" (tell that to NRS 3 3 .0 1 0, Sarge) and that its, rather, "a matter for animal control" and that
Sargent Sigfree was "trying to help" Coughlin by arresting him, again, and necessitating the $ 1 ,500
bail associated with the gross misdemeanor charge, "Misuse of 9 1 1 " because, as Sargent Sigfree
told Coughlin "you keep putting yourself in situations where you are victimized" so it was
necessary to arrest Coughlin in that regard.
But hey, at least NV Energy hasn't refused to let Coughlin get any electrical service for the past
week since those with the Protection Orders against them cancelled the service and NV Energy shut
it off, without providing any notice to Coughlin, right. Nevermind. But. . . but surely when NV
Energy shut of the power to Coughlin's home law office on October 4th, 20 1 1 , just hours prior to
the bad faith "inspection" with videographer of Coughlin' . s home law office that Casey Baker, Esq.
thought so very necessary one day before Coughlin's Tenant Answer was due ... surely NY Energy
did not leave the back gate to Coughlin's home law office open and speed off, Coughlin's beloved
mountain bike suddenly missing (the one the parents of his girlfriend of 5 years gave him)? Well,
NY Energy is probably not retaliating against Coughlin for complaining about that by refusing him
electric service for the past seven days, you would have to assume ....
tJRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession ofpremises to
pay rent during stay. Upon an appeal from an order entered pursuant to NRS 40.253 :
1. . Except as otherwise provided in this subsection, a stay of execution may be obtained by filing
with the trial court a bond in the amount of $250 to cover the expected costs on appeal. A surety
upon the bond submits to the jurisdiction of the appellate court and irrevocably appoints the clerk
9fthat court as the surety's agent upon whom papers affecting the surety's liability upon the bond
may be served. Liability of a surety may be enforced, or the bond may be released, on motion in the
appellate court without independent action. A tenant of commercial property may obtain
a stay of
11
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execution only upon the issuance of a stay pursuant to Rule 8 of the'l1evada Rules of Appellate
Procedure and the posting of a supersedeas bond in the amount of 1 00 percent of the unpaid rent
claim of the landlord.
'
2'. A tenant who retains possession of the premises that are the subject of the appeal during the
pendency of the appeal shall pay to the landlord rent in the amount provided in the underlying
contract between the tenant and the landlord as it becomes due. If the tenant fails to pay such rent,
the landlord may initiate new proceedings for a summary eviction by serving the tenant with a new
notice pursuant to NRS 40.253 .
NRS 40.390 Appellate court not to dismiss or quash proceedings for want of form. In all cases of
appeal under NRS 40.220 to 40.420 inclusive the appellate court shall not dismiss or quash the
proceedings for want of form, provided the proceedings have been conducted substantially
according to the provisions ofNRS 40.220 to 40.420, i nclus ive ; and amendments to the complaint,
answer or summons, in matters of form only may be allowed by the court at any time before final
judgment upon such terms as may be just; and all matters of excuse justification or avoidance of
the allegations in the complaint may be given in evidence under the answer.
NRS 40.400 Rules of practice. The provisions ofNRS, Nevada Rules of C iv i l Procedure and
Nevada Rules of Appellate Procedure relative to civil actions appeals and new trials, so far as they
are not incons istent with the provisions ofNRS 40.220 to 40.420, inclusive, apply to the
proceedings mentioned in those secti on s .
But, back to the Sheriffs Office. And, I am not really buying the idea that you guys don't know
NRCP 4 through 6 like the back of your hand, but.. .. hell, maybe you don't. But, clearly the
language in NRS 40 about how the Sheriff may "remove tenant from the property within 24 hours
of receipt of the Order" do not apply where the Tenant filed a Tenant's Answer and showed up to
the Hearing and litigated the matter. Especially where, as here the lease had not terminated, by its
terms, but was rather renewed. This is particularly true where NRS I I 8A prevents so terminating a
holdover te nant's lease for a retaliatory or discriminatory purpose.
I would hate to see people start to think the Washoe County Sheriffs Office is cutting comers on
the whole "personally served" thing (just so a landlord could get what they want quicker), just like I
would hate for people to think the Reno Municipal Court is letting the bottom line get in the way of
providing that whole Sixth Amendment Right To Counsel where jail time is even a possibility
thing. And, hey, if the RMC denies an indigent attorney the Sixth Amendme nt Right To Counsel,
the finds him guilty ofNRS 22.030, Summary Contempt Commited in the Presence of the Court,
and the puts him in cuffs when the Trial ends, summarily sentencing him to 3 days in jail for
violating NRS 22.030, well . .. .that's no big deal, right, I mean, the RMC technically kept its promise
that the underyling charge, though technically it could result in incarceration would not...because
the incarceration was for a whole dang different charge, ie, Summary Contempt in the presence of
the Court. ...and so what if the whole "zealous advocate" thing and the denying the Sixth
Amendment Right to Coun sel thing and the Summary Contempt thing don't go so wel1
together.... Or if 6 court employees had to stay til 9pm getting paid overtime at the RMC to get 'r
done ...
,\
12
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'-'
4: " ( d) Summons: Personal Service. The summons and complaint shall be served together.
NRCP
The plaintiff shall furnish the person making service with such copies as are necessary. Service
shall be made by delivering a copy of the summons attached to a copy of the complaint as
follows: .. . (6) Service Upon Individuals. In all other cases to the defendant personally, or by leaving
copies thereof at the defendant' s dwelling house or usual place of abode with some person of
suitable age and discretion then residing therein, or by delivering a copy of the summons and
complaint to an agent authorized by appointment or by law to receive service of process. [As
amended; effective January 1 , 2005 .] (e) Same: Other Service. ( 1 ) Service by Publication. (i)
General. In addition to methods of personal service, when the person on whom service is to be
made resides out of the state, or has departed from the state, or cannot, after due diligence, be found
within the state, or by concealment seeks to avoid the service of summons, and the fact shall
appear, by affidavit, to the satisfaction of the court or judge thereof, and it shall appear, either by
affidavit or by a verified complaint on file, that a cause of action exists against the defendant in
respect to whom the service is to be made, and that the defendant is a necessary or proper party to
the action, such court or judge may grant an order that the service be made by the publication of
summons. Provided, when said affidavit is based on the fact that the party on whom service is to be
made resides out of the state, and the present address of the party is unknown, it shall be a
sufficient showing of such fact if the affiant shall state generally in such affidavit that at a previous
time such person resided out of this state in a certain place (naming the p lace and stating the latest
date known to affiant when such party so resided there); that such place is the last place in which
such party resided to the knowledge of affiant; that such party no longer resides at such place; that
affiant does not know the present place of residence of such party or where such party can be
found; and that affiant does not know and has never been informed and has no reason to believe
that such party now resides in this state; and, in such case, it shall be presumed that such party still
resides and remains out of the state, and such affidavit shall be deemed to be a sufficient showing
of due diligence to find the defendant. This rule shall apply to all manner of civil actions, including
those for divorce"
I guess it don't matter much to me which one of you pays me my damages for the wrongful
eviction, illegal lockout, whether its the landlord, his attorney, or the Sheriffs Office. Your money
is always good with me.
Zach Coughlin, Esq.
Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 1 111120 1 1
Date: Tue, 7 Feb 20 1 2 1 1 :40 :39 -0800
CC: mkandaras@da.washoecounty.us
KiT. Coughlin,
bur records indicate that the eviction conducted on that day was personally served by Deputy
Liz S tuchell, Supervisor
13
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...............
CSO Civil Section

From: Zach Coughlin [mailto :zachcoughlin@hotmail.com]
Sent: Monday, February 06, 20 1 2 2 : 5 8 AM

To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; S ilva, Roxanna; kadlicj @reno.gov;
;ubj ect: WCSO Deputy Machem's "personally served" Affidavit of 1 1 / 1 /20 1 1
r realize you will likely not read all of this. The main thing is I am respectfully requesting that you
confirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order
on me at 1 2 1 River Rock St., Reno 895 0 1 on November 1 , 20 1 1 at 4:30 pm, in connection with
something other than what I believe it means, etc., etc.
I appreciate your attention to this.
t am writing to inquire about and complain with regard to an Affidavit of Service filed by or for
40 .253 and where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6),
e'Specially where a stay of eviction was not granted even while the RJC held on to most all my
!!.loney . . . ).
My issue with the WC SO is that Machem's Affidavit of Service indicates that he "personally
my day j ob (and do you wonder how many attorneys in the foreclosure defense game I am in
mentions?), which includes being a f
oreclosure defense attorney. So which is it? Did Machem
"personally serve" me the Summary Eviction Order? Richard G. Hill, Esq. likes to argue that I was
"served" in compliance with all time related rules because it was done in the "usual custom and
at the RIC and in the clueless community at large (which often includes Nevada Legal Services and
constable of the county to remove the tenant within 24 hours after receipt of the order... " is
27th, 20 1 1 . That language is only found in situations inapplicable to the current one. NRS
40.253(3)(b)(2), and NRS 40.253(5 )(a) are the only sections ofNRS 40 where this "within 24
40.253(3 )(b)(2) : " 3 . A notice served pursuant to subsection 1 or 2 must: . . .(b) Advise the tenant:
. . (2) That if the court determines that the tenant is guilty of an unlawful detainer. the court may
.
14
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.::r
is'sue a ummary order for remo

of the tenant or an order providin
r the nonadmittance of the
and,
sheriff or constable of the county to remove the tenant within 24 hours after receipt of the order."
The way these summary evic60n proceedings are being carried out in Reno Justice Court presently
eircumstances, where the Tenant did file an Affidavit and did contest this matter to a degree not
order" (what does that even mean? The use of terms like "rendition", " rendered", "notice of entry",
" pronounced", is absent here, and this "receipt of the order" language is something rarely found
where one must file a Complaint within 90 days of "receipt" of a Right To Sue Letter, a situation
\vhich follows NRCP 5(b), and NRCP 6(e) in imputing receipt of such a letter, when actual receipt
Institute, 5 5 3 F.3d 1 1 4 ( 1 st C ir. 2009), the record did not reflect when the plaintiff received his
S aturdays and Sundays. In order to bring a claim under either Title VII or the ADA, a plaintiff must
exhaust administrative remedies and sue within 90 days of receipt of a right to sue letter. See 42
U.S:C. 2000e-5(t)( l ). See Baldwin County Welcome Center v. Brown, 466 U.S. 1 47 , 1 48 n. l ,
104 S .Ct. 1 723, 80 L.Ed.2d 1 96 ( 1 984)(granting plaintiff an additional three days for mailing
pursuant to Rule 6).
Further, despite what the inaccurate handouts of Nevada Legal Services may say about this "24
hours" and the applicability of the JCRCP to cases like these, NRS 40.400 Rules of practice, holds
that : "The provisions of NRS, Nevada Rules of Civil Procedure and Nevada Rules of Appellate
Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with
the provisions ofNRS 40 .220 to 40.420, inclusive, apply to the proceedings mentioned in those
sections. As such NRCP 6(a),(e) applies to the Order of Summary Eviction that WCSO Deputy
Machem alleged, under penalty of perjury, that he "personally served" upon me on November 1 ,
201 1 . That is a lie by Mr. Machem, unless "personally served" is def
med in a rather impersonal
way and or Machem and I have totally different understanding of the def
mition of "personally
served", which may be the case. Or, perhaps the Sheriff s Office is busy and doesn't want to wait
around to "personally serve" every tenant it wishes to evict. Fine, then just use the "mail it and
a,llow three days" rule in NRCP 6(e) ...the landlord's might not like it, but they can use that
frustration as
an
incentive not to jump to litigating every disagreement about habitability that a

15
02782
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'
te'nant b rings to them. You may
. >,
",....
..
realize how ridiculous some lan
d'itrd's get. In my case, I
offered to fix basic things that clearly implicated the habitability rules in NRS
1 1 8A.29 0 and the
Californian neurosurgeon, B everly Hill High School graduate landlord balked and complained then
hired and attorney four days into a dispute .....at which point the rules against contacting represented
pCl.rties prevented much in the way of real settlement discussion, particularly where opposing
counsel has continuously demonstrated a complete indifference to pursuing settlement (why would
he at the rates he bills hours at?). I just don't think the Sheriffs Office needs to sully its image or
damage the citizen tenants of Washoe County in the name of pleasing people like Dr. Matt Merliss
or Richard G. Hill, Esq.
,I AM REQUESTING, IN WRITING, THAT BOTH OF YOUR OFFICES INVESTIGATE THIS

AND PROVIDE A SWORN AFFIDAVIT FROM
MR. MACHEM TRAT ADMITS TRAT I WAS
NOT PERSONALLY PRESENT WHEN HE SERVED THE ORDER FOR SUMMARY
EVIC TION IN RJC REV20 1 1 -00 1 708 ON 1 1 1 1 1 1 2 AT 4:30 PM (ACCORDING TO HIS

AFFIDAVIT OF SERVICE). YOU NEVER KNOW, I MIGHT HAVE IRREFUTABLE PROOF
THAT I WAS SOMEWHERE ELSE AT THAT TIME, SO, BE CAREFUL. There simply is not
anything specific in Nevada law addressing how such Summary Eviction Orders are to be served
and carried out. The sections dealing with
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant
for default in payment of rent.. . .
6., Upon the filing by the tenant of the affidavit permitted in subsection 3 , regardless of the
inf
ormation contained in the affidavit, and the filing by the landlord of the affidavit permitted by
subsection 5, the justice court or the district court shall hold a hearing, after service of notice of the
hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or notice
provided for in this section. If the court determines that there is no legal defense as to the alleged
unlawful detainer and the tenant is guilty of an unlawful detainer, the court may issue a summary
order for removal of the tenant or an order providing for the nonadmittance of the tenant. . . .
7 . The tenant may, upon payment o f the appropriate fees relating to the filing and service o f a
motion, file a motion with the court, on a form provided by the clerk of the court, to di spute the
amount of the costs, if any, claimed by the landlord pursuant to NRS 1 1 8A .460 or 1 1 8C .230 for the
inventory, moving and storage of personal property left on the premises. The motion must be filed
within 20 days after the summary order for removal of the tenant or the abandonment of the
premises by the tenant, or within 20 days after:
(a) The tenant has vacated or been removed from the premises; and
(b) A copy of those charges has been requested by or provided to the tenant,
E whichever is later.
S. Upon the filing of a motion pursuant to subsection 7, the court shall schedule
hearing on the
motion. The hearing must be held within 1 0 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 1 1 8A.460 or I 1 8C.230
and any accumulating daily costs; and
(b) Oider the release of the tenant' s property upon the payment of the charges determined to be due
?r if no charges are determined to be due. . . . "
16
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'-'
I also want to know why NRS 40. 253(8) was not followed with resp to my November 1 7th,
201 1 filing of a Motion to Contest Personal Property Lien. Why didn't the WC SO serve notice, as
required by NRS 40.253 (8) upon the landlord's attorney Richard Hill? Why didn't
I get a hearing
vithin the 1 0 days called called for by that section (to get back my client's files no less), but rather,
I. had to wait a full 33 days to get a hearing, and service of notice of the hearing was not
effectuated, as required by NRS 40.23 5(8), by the WCSO. Why?
Please provide an indication, in writing, of the names and case numbers for the last 20 incidences
when the WCSO has served notice of a hearing set pursuant to NRS 40.253(8). What's that? The
WCSO has NEVER served such notice? Yet the WCSO is there with bells on (or Machem is) to lie
in Affidavits of Service to lock out the citizen tenants of Washoe County impermissilby early vis a
vis NRCP 5(b)(2) and NRCP 6(e)? Why is that? Is it a conspiracy? Does money talk? When I was
arrested for trespassing on November 1 2th, 201 1 by RPD Officer Chris Carter and S argent Lopez,
Carter admitted to me that "Richard Hill pays him
lot of money and therefore he arrests whom
Richard Hill says to and does what Richard Hill says to do . . . . " Both Carter and Sargent Lopez
refused to investigate, despite prompting, whether Richard Hill has sent the tenant/arrestee a bill or
dei-nand letter in bill for the full rental value of the property, $900 per month, under some
interpretation of the "reasonable storage, moving, and inventorying expenses" collectable by a
Umdlord under a p ersonal property line set forth in NRS 1 1 8A.460 (one could also interpret such a
bill as Hi ll's withdrawing or eradi cating the Order of Summary Eviction itself, which was not
\'personally served" by the Washoe County Sheriff (despite what their Affidavit of S ervice says . . .I
wasn't even there at the time they changed the locks . . . and so the Summary Eviction Order was not
properly served under NRCP 6, and despite the Reno Justice Court impermissibly converting $2300
of my money under a "rent escrow" Order its required I comply with in order to litigate habitability
issues in a summary eviction proceeding under NRS 40.253, despite NRS 40.25 3 (6)'s express
dicate against such an Order (unless, pursuant to JCRCP 83, a justice court gets such a rule, like
Justice Court Rule of Las Vegas (JCRLV) Rule 44, published and approved by the Nevada
Supreme Court, which the RJC has not, rather, the RJC applies all these insidious secret "house
rules" (like forcing tenants to deliver themselves to the filing office to submit to personal service
notice of a summary eviction hearing within, like, 1 2 hours of the Tenant filing a Tenant's Answer
r Affidavit in response to an eviction Notice, rather than the service requirements of such notice
following NRCP 6 (days for mailing, etc., etc., in other words, in the RJC everything is sped up
rinperissilby to help landlord's out, and the NY. S . Ct ruling in Glazier and Lippis clearly
tontemplate personal liability against the Court and or Judges themselves for so doing) ....A Qui
Tam action or something a la Mausert's in Solano County,
I believe, in California, would be very
interesting . . . Still haven't heard anything from the Reno PD about the various complaints I have
filed with them in writing related to the wrongful arrests, excessive force and other misconduct
committed against me, though they did arrest me the other day for calling 9 1 1 incident to some
domestic violence for which I was granted to Extended Protection Orders against my former
housemates . . . . old Sargent Sigfree ordered that arrest, as he did two days prior when he ordered a
custodial arrest of me f "j aywalking" .

or
Funny thing,
I never heard anything back from the RPD
about complaints like the fol1owing one:
\\From:
f-fvRenoPd@coplogic.com
, '
17
02784
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.......
'
Sent:
Wed
9107/1 1 1 0:5 1 PM
To : ' zachcoughlin@hotmail.com
* * * *DO NOT RESPOND TO THIS E-MAIL* * * *
We're sorry the following problem was found during review

of your submitted report T I 1 00 5 9 5 6 :
THIS IS NOT THE FORUM FOR THIS TYPE O F COMPLAINT HOWEVER THIS REPORT
WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT WILL
BE
ADDRESSED.
Thank you,
Officer WOZNIAK,
Reno Police Department"
What is interesting there is that at least I was provided the name of an officer, a "Womiak" (though
I have been unable to confirm the existence of
such an RPD Officer. . .
or whether " THIS IS NOT THE FORUM FOR THIS TYPE OF COl\1PLAINT HOWEVER THIS
REPORT WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND
WILL' B E
ADDRES SED. "
IT
What is more strange is that I submitted several online police reports to the Reno PD (a couple of
which asserted complaints against various Reno PD officers, or asked why RDP Officer Carter,
whom admitted taking bribes from Richard G. Hill, Esq. at the tirne of my custodial arrest for
trespassing (the one where Richard Hill signed a Criminal Complaint for trespass, then Officer
Carter and Sargent Lopez refused to follow up on my imploring them to ask Hill whether he has
recently sent me a bill for the "full rental value" of the property, the same amount that had been
charged for the "use and en
joyment" of the premises,
$900, in comparision to what NRS 1 1 8A.460
may deem "reasonable storage" expenses for which a lien is available to a landlord, though NRS
1 1 8A. 520 has outlawed rent distraints upon tenant's personal property....Regardless, between
January 8
1 2th, 20 1 2, and was arrested twice by the Reno PD shortly after submitting these
PD.
written complaints to the Reno
Actually, upon being released from j ail on November 1 5th, 20 1 1 , incident to the custodial trespass
arrest, I went to Richard HIll's office to get my wallet and driver's license. He refused to provide it
to me until late November 22nd, 201 1 . Hill called the Reno PD on the 1 5th (or maybe I did because
he was . withholding my state issued ID, the one I would need to rent a room, drive my car, and my
wallet, which is kind of useful in such situations . . . . ). Anyways, Sargent Tarter of the Reno PD
showed up, he went inside Hill's office with Hill for quite some time and the result was Tarter
telling me to leave. I did, but while driving down st. Laurence towards S . Virginia (Hill's office is
at 652 Forrest St. 89503 and would have required turning down the wrong way of a one way street,
Forrest, to go back to Hill's Office (so clearly I was not headed to Hill's office) S argent Tarter
begt;ln tailing me, then he pulled me over, then he gave me a ticket, in retaliation if you ask me for
reporting RPD Officer C arter admitting that he takes bribes from Hill to Sargent Tarter minutes
earlier. Uh, well, anyways, another Sargent calls me later that night, taking the "good cop" role. But
18
02785
02785
..."I
.....,.
llpon informing him of what RPD Officer Carter told me about Hill paying him money to arrest
people during the 1 1 1 1 211 1 trespassing arrest, that Sargent immediately informed me that, despite
this being the first he heard of that, he was sure that was not happening .1 guess RPD Officer
Carter is trying to explain away his comments about Richard Hill paying him money to arrest
people by dismissing them as sarcasm, a joke, said in jest, whatever. . . . but I don't see how that
situation (a license attorney getting arrested for a crime, a conviction for which would result in that
ttomey being required to report said conviction to the State Bar of Nevada under SCR 1 1 1 , etc.,
and possibly resulting in a suspension of that attorney's license to practice law, or worse ... ) is all
that jocular of a situation. Combine that with the too quick to dismiss my reports of bribery by
Richard Hill to officer Carter to the RPD Sargent who called me on 1 1 1 1 5/1 1 regarding the
retaliation by Sargent Tarter that I complained of, and I don't think: it is all that unreasonable for
anyone to take RPD Officer Carter at his word regarding Richard G. Hill, Esq. paying him money
to arrest whom Hill says to arrest. Add to that Sargent Sigfree ordering my arrest for jaywalking
(by a trainee RPD Officer) on January 1 2th, 20 1 1 (custodial arrest, bail of $ 1 60 emptied my bank:
account out, or pretty close to it) while I was peacefully filming from a public spot Richard G. Hill,
Esq's contractor Phil Howard, whom had submitted bills in courts records and filings under the lien
for "reasonable storage moving and inventorying" found in NRS 1 1 8A .460, even where old Phil
used my own plywood at the property to board up the back porch (curiously leaving the screws
holding up the plyWood exposed to exterior of the property where anyone could easily unscrew
them, and also leaving in a window unit ac secured only by ducttape in a window facing a sidewalk
by the LakeMill Lodge .... which resulted in $8,000 at least of my personal property being
burglarized from my former home law office on Decmeber 1 2th, 20 1 1 while Hill was asserting a
Hen on all my personal property found therein (and my client's files, which arguably are not even
my property, but rather, the client's property). Hill went on to place what he believes to be my
social security number in court records, on purpose, despite his signing an Affirmation pursuant to
NRS 239B.030 that that was not the case (attaching a two page report to the RPD as an Exhibit).
Then Hill and his contractor Phil Howard both committed perjury when the s i gned Declarations
attesting that I had climbed on the contractors truck or ever touched Hill. Hill lies constantly,
whether under penalty of perjury or now, so I don't have time to rebut every little lie he makes (he
makes me out to comes across as a Yosemite Sam caricature of a human being in his filings when
he describes me . . . )
. . .
Further, why am I arrested for trespassing and not those from Nevada Court Services where they
went behind closed gate the the backyard of my home law office and banged on window extremely
loudly for 40 minutes at a time 3 times a day, one guy ringing the doorbell, one guy moving around
all other sides of the property banging on the windows, peering in closed blinds, and affecting a
phony "color of law" tone, resemblance, and verbal communications, misleadingly announcing that
they were "Court Services, come out now!", wearing their pretend Sheriff outfits, big equipment
saddled belts (including firearms, I believe, and radios), etc. ,etc.
http://www.youtube.comiwatch?v=jQ I 32q207DY
Add to that that Nevada Court Services Jeff Chandler drives by in his Monster Truck baring his
personalized "NCS" license plate while 1 am in the RPD squad car, handcuffed, outside my former
law office at 1 2 1 River Rock, at the time of the 1 11 21 1 2 jaywalking arrest and the appearances are .
troubling. Now, add to that that Lew Taitel, Esq. was my court appointed public defender in the
Reno Municipal Court in the trespass case, and that Judge Gardner had refused to provide me the
19
02786
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mimes f prospective appointed d:fense counsel (I wanted to run a c o'irtlicts check) at my

arraignment (where Marshal Mentzel barked at me in a threatening tone, using menacing
language), whereupon Taitel was appointed as my defense attorney and filed a notice of
appearance, and received my confidential file, pc sheet, arrest reports, ssn, etc .... only its turns out
that Taitel shares and office and a receptionist with Nevada Court Services and they list him and his
picture on their website as "associated with" their Process Server corporation, despite the
prohibition lawyers face against fee sharing with non-lawyers. Then, Taitel somehow manages to
get out of defending my case without filing a Motion to Withdraw as Counsel, despite that being
required by the Reno Municipal Court Rule 3(B):
RMCR Rule 3(B): Authorization to Represent (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.
But, perhaps most troubling of all is the implication that the Reno City Attorney's Office, which
defends actions against the City of Reno Police Department and its Officers, has a vested interest in
discrediting me in advance of the wrongful arrest lawsuit that the Reno City Attorney's office knew
was imminent at the time of all of the above incidents, relating to the following August 20th, 201 1
wrongful arrest by RPD Officer's Duralde and Rosa.
http://www.youtube.com/watch?v=SPR7q40ISbO So, that's what attempting to coerce a suspect's
consent to an impermissible search sounds like? Add to that that the trespassing case is before
Judge Gardner, whom most recently was employed with the Reno City Attorney's Office.
And, you know what is funny? Officer Del Vecchio cuffed me and placed me in his squad car last
summer after he terrified me and another gentleman who had bicycles. He veered across the road
and screeched his squad car to a halt, jumped out, and did some other stuff, then demanded my
name and ID ... and the lawyer in me didn't like that that much, and he didn't like me not wanting to
give it to him. This occurred right in front of my home law office in the summer of 20 1 1 . He cuffed
me and told me I was going to jail for something about a light on the front of my bicycle (the one
NV Energy likely stole when the shut off my power, unnoticed, on October 4, 20 1 1 ) despite my
bike actually having such a light.... but then Del Vecchio's partner did him a solid and talked some
Sense into him, and I humbled it up for Del Vecchio and we both let it go, and I didn't go to
Jail. . .. Until Del Vecchio was present supervising some Officer's training at the scene of my
custodial (9 hour) jaywalking arrest) on 1 /1 2/12. But Del Vecchio, I guess either didn't want to or
wasn't able to talk some sense into Sargent Sigfree ..... and then Sargent Sigfree (the spelling is
likely off) had me arrested and charged with a gross misdemeanor, "Misuse of 9 1 1 " just two days
later, on January 1 4th, 20 1 1 when I called 9 1 1 to report that my roommates were laughing
menacingly when I asked them why my dog was missing (I had also been chased up to my room
numerous times since moving in with these people, something I had to do because so much of my
money had been taken up with bail or lost earnings due to all these wrongful arrests and abuse of
processes mentioned above . . . also these housemates had chased me with a ten inch butcher knife,
two of my tires were slashed, I was locked out all night on New Years Even when these changed
the locks at around midnight, had my furniture thrown in the street, property stolen, coffee thrown
on me, destroying my smart phone in the process, etc., etc ...And despite the housemate having an
dutstanding arrest warrant, and animal abuse being listed amongst the elements of domestic
violence, Sargent Sigfree told me he was arresting me because I "keep putting yourself in these
situations", like, where I am a victim, and that he was "trying to help you", he said with a smirk and
20
02787
02787
.. .
a hugh to his fellow RPD Officers, whom then proceeded to use exc ive force against me. I
guess he was helping me by saddling me with a gross misdemeanor with a $ 1 ,500 bail, especially
where its been arranged for Court Services, or pre-Trial Services to forever deny me an OR, despite
my meeting the factors for such set forth in statute (30 year resident, entire immediate family lives
here, licensed to practice law in Nevada, etc., etc) . '! guess it should not be too much of a surprise
to me that Reno City Attorney Pam Roberts failed to address the perjury of all three of her
witnesses or that her fellow Reno City Attorney Christopher Hazlett-Stevens lied to me about
whether or not the Reno City Attorney's Office even had any documentation related to my arrest or
whether it would in the month before my arraignment, despite that fact that subsequent productions
of discovery tend to indicate that the Reno City Attorney's Office did have those materials at the
time. I could be wrong about some ofthis ...But that would require and awful lot of coincidences.
,.
Sincerely,
Zach Coughlin, Esq.
1 422 E. 9th St. #2
RENO, NV 895 1 2
tel: 775 3 3 8 8 1 1 8
fax: 949 667 7402
Nevada Bar No: 9473
* Notice* * This message and accompanying documents are covered by the electronic
ommunications Privacy Act, 1 8 U.S.C. 25 1 0-252 1 , 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.
zachcoughlin@hotma il.com
Subject: Contact
Date: Fri, 16 Mar 20 1 2 16: 10:24 +0000
To:
March 1 6, 20 12
Zachary Coug h l i n
21
02788
02788
Dear Zach,
Tha n k you for sending me your reply to the grievance fi led by Rich a rd H i l l . From you r
explanation i t is clear that things a re not as they should be. Please cal l m e ASAP so
that we can ta ke the a ppropriate action to help you and to stop these types of
disturbi ng complai nts.
Patrick King, Assista nt Bar Counsel (775) 328- 1384
'
22
02789
02789
,
.
. .
Patrick King
From:
Sent:
To:
Subject:
Attachments:
Zach Coug h l i n <zachcoug h l i n @ hotmaiLco m >
Friday, March 16, 2012 1:40 P M
Patrick King; clarkd @ nvbar.org; G lenn Machado

RE: Contact
THE 2 11 12 email to WCSO RPD Reno City Atto rney H i l l N P U C H i l l et al b.pdf
Mr. King,
I have not sent you my Reply to the Grievance. You gave me until today, and I am finishing it
up. Additionally, I was subj ect to what I believe is a wrongful eviction yesterday, and would like
additionaly time to respond to Richard HIll's grievance, which he appears to be filing on behalf of
various third parties, and his associate, who doesn't bother to sign it. Basically, Mr. HIll constantly
seeks to leverage courts, police, and now, Bar Counsel, to further his nefarious approach to
litigation, rather than roll up his sleeves and find some law in favor of his positions and apply
actual facts to them, rather than make up things or quote to third parties and other hearsay (I never
made contact with or touched Mr. Hill, I never climbed on anyone's truck, Mr. Hill is not a licensed
mental health professional, yet he sounds like a walking DSM-IV when he writes of me). I will
stibmit something to you today in response to Hill's grievance, with the caveat that I am requesting
more time, in part due to the fact that the Washoe County Sheriffs Deputies have just yesterday,
minutes before my hearing in Judge Beesley's courtroom, unlawfully stormed into my location at
1 422 E. 9th St,
#2, with guns drawn and pointed at me, without previously identifying themselves
as law enforcement in any way, and demanding I grab a few things in a couple minutes and
lea\ie. This unlawf eviction was pursuant to an eviction hearing held that morning by Reno
ul
Justice Court Judge Jack Shroeder, the same Judge who screamed at me "do you want to go to j ail"
wht:m I attempted to address in any way whatsoever Richard Hill's abuse of process in getting a
Order' of Protection from Judge Schroeder in a scant
40 minutes, and having me arrested on 1 11 21 1 2
(two' days before Hill's grievance was sent to you), at the extension hearing on January 3 1 , 2012,
where Hill admitted he didn't have a good reason for seeking an extension and withdrew his
application. I wanted to address Hill's abuse of process for the record, Judge S chroeder decided to
scream at me instead. It was reminscent of Judge Nash Holmes telling me, on the record, in Reno
Municipal Court case 1 1 TR 26800 that she would have me arrested and placed in j ail if I said
Richard G. Hill's name one more time. I cross examined RPD Sargent Tarter about whether he had
a retaliatory motive in ticketing me outside Hill's office on 1 1 / 1 5/ 1 1 after Hill refused to give me
my 'driver's license, and I reported to Sargent Tarter that RPD Officer Chris Carter had admitted to
taking bribes from RiChard Hill.
Actually, there is some footage of the "terror" Richard G. Hill was exposed to that necessitated him
seeking a Protection Order (the "RPD made him" do it,

honest): http://WVv.W.youtube.com/watch?v=gBu9zflGALE
. .
I . don't know why Sargent Sifre (whom makes more money than a District Court Judge) should be
so upset with lawyers like me, who work in the foresclosure defense field (you might see if Geof
Giles, Esq. thinks I am quite the "Yosemite S am " caricature of a cartoon villian that Richard G. Hill
1
02790
02790
....,.'
'...,I
pqints me to be, or if Thomas J. Hall thinks that much of Rich and his "tactics", which are like
those of a malignant frat boys armed with daddy's pleadings). After all, Sargent Sifre has benefitted
f
rom foresclosure defense work: http://stopforeclosuref
raud.coml20 1 1 10 1 I29/nevada-dist-court
quiet-title-viable-sif
re-v-wells-fargo-bankl
Regardless,
I have not "ghostwritten" any pleadings for Mr. Gessin or anybody else. I am listed as
I ever filed for him
clearly indicated that I was not appearing as attorney of record and that the Answers to the
att,omey of record on adversary proceedings for Gessin, though the only things
Complaints in those two adversary proceedings were being submitted on an "unbundled services"
,arrangement. The bankruptcy court nonetheless listed me as attorney of record and I have been and
am
in the process of having that changed.
office supervisore Debbie Gallagher
I have communicated with clerk Holly Estes and filing

in those regards.
I need more time to research and investigate the other allegations Hill m akes, though I do not wish
yqu to infer and admission on my part to any allegation by Hill.
1 have, researched this service of eviction Order issues extensively, it relates to the Hill matter, and
believe the WCSO and Hill are not following the law.
Lam: not sure why you wrote what you did at 9 : 09 am this morning considering you granted me
until '3 :00pm today to 'file my response, which I intend to along with a request for more time to
supplement it:
From:Patrick King (PatrickK@nvbar.org)
Sent: Mon 3/1 21 1 2 9: 1 5 AM

To:
zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Cc :
David Clark (DavidC@nvbar.org); Glenn Machado (GlennM@nvbar.org)
a rc h 12, 2012
'
To : Zach Coughlin
D,ep r M r. Co ughlin,
I cini i n receipt of yo u r e-mail below, requesting additional time to respond. Please be advised that you r response to the
grie ,a nce, including the e-mail letter below, become part of the record and may eventually b e reviewed by a d isciplinary
p a n eL With that said, it is im portant that we receive yo ur response. P u rsuant to yo u r req uest, you are granted until
Friday, M a rch 16, 2012 by 3 :00pm to delive r your written response to the State Bar Office in Reno,
Thank you for your cooperation.

Patrick King, Assistant Bar Cou nsel

Snt: Friday, March 09, 2012 5:45 PM
Subject: response to grievance from NV Attorney
Zach Coughlin, Esq.
2
02791
02791
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02792
02792
S TAT E B A R O F N E VA D A
600 East Charl$[on BI.d.

L... Veg NY 89104 1 %3
phone 702.382.2200
March 1 6, 20 1 2
.nD (,"
800.2S4.2797
f.. 702.385.2878
Double R Blvd. St. B

8952 1 5977
phon, 775.329.4 100
f.. 77S.329.0S22
94S6
Sent Via U.S. Mail, Certified Mail and via E-Mail
Reno. NV
Zachary B. Coughlin, Esq.

1 422 E. N inth Street, #2
eno, NV 895 1 2
www.nvbar.or
g
RE: Attorney Discipline

Dear Mr. Coug h li n :
The Office of B a r Counsel h a s received several grievances concerni ng your
conduct as a lawyer. The grievances include supporting evidence in the form of:
audio of your conduct in court proceedings and copies of pleadings and documents
prepared and filed by you in Justice and District Court. Together these grievances
raise serious q uestions regarding your competency and ability to practice law.
These concerns are serious and the Office of Bar Counsel is considering the
necessity of seeking a Petition to Determine Competency p u rsuant to Supreme
Court Rule 1 1 7.
I am enclosing with this letter copies of a grievance letter, from the Municipal
Court and a copy of an Order from District Court. Please respond to allegations
pertaining to your conduct. I will make available for your review and inspection the
supporting documents nd audio recordings
'
U S Postal Ser v ice
CE'RTI FI ED MA IL " RE CE IPT
I have left phone messages
of the drafting of this letter you ha' cO
that we can discuss this i mportant

you . Aga i n , please call me at you r .Jl
Sincerely,
-jJz;(
Patrick King
Assistant Bar Counsel
."
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[SentTo
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fV\c., (
02793
02793
I
i
I
!
Form;]1 Hearing Pleadings

SBN v.Zachary Coughlin
Case Nos. NG12-0204, NG12-0435, NG 12-0434
1"/1 SMEAD- I
ND. 1~7
amead.com . ...ct. In USA
"-
02794
--..
- .- --~-
--- ...............------.-- ..
-~ ~
....--....,-,.- ...-.--. .
- . ~, - . - -. ---~- - ~-----. -. -.-, ---
...
AFFIDAVIT OF LAURA PETERS

CUSTODIAN OF RECORDS
2
STATE OF NEVADA
COUNTY OF WASHOE
) 55 :
LAURA PETERS, under penalty of perjury, being first duly sworn , deposes and
5
says as follows :
6
That Affiant is employed as a paralegal for the discipline department of the State
7
Bar of Nevada and in such capacity is the custodian of records for the State Bar of
8
Nevada;
9
That on September 11 , 2012, at approximately 4:45 p.m ., Zachary Coughlin

10
called Affiant to confirm that a hearing was still scheduled to take place on September
11
25, 2012. Affiant explained that the hearing would not take place on September 25th
12
and that date had been scheduled prior to the filing of a formal Complaint.
13
Mr. Coughlin reacted as if he had no knowledge of a Complaint. Affiant then

14
explained that, in fact, a copy of the Complaint, sent via certified mail on August 23,
15
2012, from the Reno office of the State Bar, had been returned and marked
16
"unclaimed ".
17
Affiant further explained that since service had not been affected, a new certified
18
copy would go out the next day. Affiant requested that when Mr. Coughlin received said
19
copy , he should return the postcard attached to the mailing and his twenty '(20) day
20
period in which to answer the Complaint would start running at that point.
21
However, in speaking to Assistant Bar Counsel Patrick King , it was determined
22
that personal service should be affected upon Mr. Coughlin. Reno Carson messenger
23
service was engaged to attempt personal service despite Mr. Coughlin not providing the
24
State Bar with a physical address.
25 11
I" i
"
Ii
Ii
02795
02795
On September 25. 2012, Mr. Coughlin arrived at the Reno office of the State Bar
2
allegedly expecting a hearing to take place. At that time, Mr. Coughlin was again told ,
both by Affiant and Assistant Bar Counsel Patrick King, that no hearing would be taking
place that day and that an answer to the State Bars Complaint had not been received .
Affiant personally served Mr. Coughlin with a copy of the Complaint on his visit to
th
the Bar office on September 25
State Bar. Mr. Coughlin insisted that the hearing which had been previously scheduled
for that day should be taking place because he needed to be removed from temporary
suspension.
as witnessed by Paula Campbell, an employee of the
10
Mr. Coughlin has also been instructed by Assistant Bar Counsel Patrick King that
11
he cannot file pleadings with the State Bar via e-mail, which he continues to attempt.
12
The Motion to Dism iss, which Mr. Coughlin now insists should be granted as it has gone
13
unopposed by the State Bar, was never presented to Affiant for filing but was rather
14
mailed prior to Affiant's conversation with Mr. Coughlin on September
15
Coughlin under no uncertain terms told Affiant that he had not yet received the
16
Complaint.
11th
8-
when Mr.
FURTHER YOUR AFFIANT SAYETH NOT.
17
18
Dated this 9" day of October, 2012.
19
20
.~~
21
Office of Bar Counsel

SUBSCRIBED AND SWORN to
before me this 9 th day of
October, 2012.
22
23
:: .NQ~%stpC4dC1i
II
iJ
I'
Ii
02796
02796
Case No: NG12-0204, NG12 043 5 and NG12-0434

-
$WE
i
STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY BOARD
rr
OF N:Vjilil
I!.,!S ,'1,
4
5
6
7
STATE BAR OF NEVADA,

Complainant,
ZACHARY B. COUGHLIN
Bar No. 9473
Resondent.
9
10
ORDER
vs.
The Formal Hearing in these matters is scheduled to take place on Wednesday,
11
November 14, 2012, beginning at 9:00 at the Northern Nevada Bar Center, 9456 Double R.
12
Blvd., Suite B, Reno, Nevada 89521. Several motions have been filed and are pending. The
13
Formal Hearing Panel Chair has had an opportunity to review and consider the following
14
motions and responsive pleadings:
15
Therefore, I T IS HEREBY ORDERED:
16
1.
17
18
Motion to Dismiss prepared September 16, 20 12, and filed October 16, 2012,
is DENIED.
2.
Motion for Order to Show Cause Regarding Improper Attempt by Bar Counsel
19
and, Possibly, NNDB to Delay and Obstruct Hearing Required by Courts June ih, 2012
20
Order in Case No. 60838 and Coughlin's SCR 102(4)(d) Petition in Case 61426 prepared
21
October 2,2012,and filed October 16, 2012
22
23
24
25
3.
is DENIED.
Motion to Review and Inspect Bar Records; Motion to Bifurcate Hearing;
Motioh to Dismiss for Complaint [sic] Failure to
Sufficiently
State the Charges with
Specificity and Support and for Utter Failure of Bar Counsel to Perform Reasonable
Investigation prepared October 15, 2 012
and filed October 16, 2012, is GRANTED IN

1
02797
02797
- -- - --...- - .....,-
....... ...
-..--- ----"-.- '--'-'-'---"'-----
..
.
.... --~---.------
...
...
PART AND DENIED IN PART. The Office of Bar Counsel will arrange for copies of the file
to be delivered to Mr. Coughlin at the address that he has provided to the State Bar at the
ea rliest opportu nity.
The Motion to Bifurcate Hearing and the Motion to Dismiss for Complaint [sic] Failure
10 Sufficiently State the Charges w~h Specificity and Support and for Utter Failure of Bar
Counsel to Perform Reasonable Investigation are both DENIED.
IT IS FURTHER ORDERED that the Formal Hearing in these matters will proceed on
a default basis pursuant to the State Bar's Notice of Intent to Proceed on a Defa ult Basis
10
11
12
13
14
filed October 9. 2012, unless Mr. Cough lin prepares and fi les a Verified Answer to the State
Bars Complaint by Friday, November 9,2012. The State Bar is prepared to proceed with a
full evidentiary hearing in the event that Mr. Coughlin does file a Verified Answer to the
State Bar's Complaint and is present for the Formal Hearing sched uled to take place on
/. ~
DATED this, .., /
15
Wednesday , November 14, 2012 .
day of October, 2012.
16
17
18
y:f.~~~~~~~~~~ohn P.
h ~erria , Esq., Chair
Formal He
n9 Panel
19
20
21
22
23
24
25
2
02798
02798
-.- ----""'-... -"--------~.--,-----.- -~- . ."-......----~,------~---._------
The undersigned hereby cenifies that a true and correct copy of the foregoing Order was
deposited in the United States Mail at Reno, Nevada, postage fully pre-paid thereon for certified and
first class mail addressed to the following:
Zachary B. Coughlin
147 1 E. 9th SI.
Reno NY 89505
DATED lhis 31 s1 day of October. 20 12.
8
9
Laum Pe ers, an employee of

the State Bar of Nevada
10
11
12
13
US Pastil I Sen'lc.p
14
c
15
16
CERTIFIED
a-
18
o
'"
o
C . _ F. .
_~ "-
(E'1IdotMm8n! RtlCl!.ir9d)
RM10btcI Oetwery F..
.,
,..
T<DI~OII&'F_
.:::: (~~ Reqund)
19
20
21
RE CEIPT
'''~'''J"cl'
CvvNolqe P'V ~ lded
OFFI CIAL USE
17
~1AIL
(Comus/u; AfiJlI Only No
" .'.r.
r:
...-
< h ( : ~ - . 6 . rrL...r"
I""
22
23
24
25
02799
02799
---
._- --.. - _.---.- - .---. --~----..------.-----------._.---_._.
CASES NO'd. NGl 2-0204 ; NG12-0435 and NRI2-0434

2
STATE BAR OF NEVADA
4
5
Complainant,
)
)
)
VS.
ZACHARY B. COUGHLIN .
Bar No. 9473,
)
)
)
ORDER APPOINTING
FORMAL HEARING PANEL
)
)
9
Respondent.
10
)
)
II
PLEASE BE ADVISED that a Formal Hearing Panel of the Northern
12
Nevada Disciplinary Board has been scheduled for Wednesday, November 14, 2012, at
13
the hour of 9:00 a.m., to convene at the Reno office of the State Bar of Nevada, 9456
14
Double R Boulevard , Suite 8 , Reno, Nevada 89521.
IT IS HEREBY ORDERED that the following membe rs of the Northern
15
16
Nevada Disciplinary Board have been designated as members of the hearing panel:
t7
1.
John P. Echeverria, Esq ., Chair;
18
2.
Michael K. Johnson, Esq.;
19
3.
Clark V. Vellis, Esq. ;
20
4.
Stephen Kent, Esq.; and,
21
5.
Karen Pearl, Laymember.
DATED this 29~ day of October. 2012.
22
STATE BAR OF NEVADA
23
24
5
/seh
USICH,
HAIRMAN
o hem Nevada Disciplinary Board
02800
02800
~~_
___ _
._. _
L-.... _
___ .~
._
~_
1
2
_ . _ _ . _ - . . . . _.-. _ _ _
_ _
_ _ _ _ _ _ _ _ ... _ _ _ _ _ , _
_ _ _ _ _ _
The undersigned hereby certifies thai a true and correct copy of the foregoing Order
Appointing Formal Hearing Panel was deposited in the United States Mail at Reno, Nevada, postage
fully pre-paid thereon for certified and first class mail addressed to the following:
5
6
7
8
9
10
Zachary B. Coughlin
1471 E. 9th St.
Reno NV 89505
DATED th;s 30,h day o[October, 2012.
//~" -~/'J
~-;::71i;::-Pe rs, an employee of

11
12
13
14
15
u.s. Postal ServIce

CERTIFIED MAIL
RECEIPT
(DomeS/Ie Mall Only. No Insurance CovNaqr' ProW(}erJ)
16
17
18
19
20
21
22
23
24
25
02801
02801
-.. - -...- -------.--.--..--.-----..-----.-..-..--.--..-.---------.-- _ .- . .
- _.-
Case No: NG12-0204, NG12-0435 and NG12-0434
2
STATE BAR OF NEVADA
3
4
5
6
7
8
11
12
13
14
15
16
Motion to Bifurcate Hearing.

Motion to Dismiss
ZACHARY B. COUGHLIN
Bar No. 9473
Respondent.
10
OPPosition to Respondenfs
Complainant,
vs.
Respondent , Zachary Coughlin ("Coughlin) filed a motion asking to review and inspect bar
records; Motion to Bifurcate Hearing and Motion to Dismiss. Patrick King , Assistant Bar Counsel, on
behalf of the State Bar of Nevada responds as follows:
Zachary Coughlin may inspect the evidence that the State Bar has pertaining to his discipline
matters up to three (3) days prior to the hearing , pursuant to SCR 105(2)(c). Coughlin has been sent,
via both certified and first class mail , a Notice of Hearing which was accompanied by a Designation of
Witnesses and Summary of Evidence prepared by bar counsel pursuant to Supreme Court Rule. To
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the extent that Coughlin wants to review the disciplinary files pertaining to his case, Bar Counsel has
18
no objection.
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Coughlin's Motions to Bifurcate and to Dismiss must be denied as totally lacking in merit.
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Consistent with other pleading filed by Coughlin , the instant motion is twenty-seven (27) pages long
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including over one hundred (100) pages of attached documents. Together the motions lacks merit
22
and must be denied.
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The Complaint in this matter is sufficiently clear and specific as to inform Coughlin of the
charges against him and the underlying conduct supporting the charges. The Complaint includes two
criminal convictions and a Court Order finding that by dear and convincing evidence Coughlin
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02802
-_._----- ----- -- - ------ - - ------ - - -
violated numerous rules of professional conduct See SCR 105(2). Coughlin had twenty (20) days to
file a verified answer to the Complaint. Instead. Coughlin attempted to avoid service and now argues
that the Complaint be bifurcated and! or dismissed.
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Coughlin has been temporarily suspended by the Nevada Supreme Court as a result of a
SCR 111 petition filed after appeal of a misdemeanor conviction. The Court referred the matter to a
disciplinary panel of the Northern Nevada Disciplinary Board . The pending formal Complaint filed by
the State Bar of Nevada was not based exclusively on the SCR 111 pelition , but primarily from
7
grievances filed with the Office of Bar Counsel.
8
Coughlin is misapplying the Court Order resulting from a SCR 111 petition. The Supreme
9
Cou rt said , regardi ng the criminal conviction, that the only thing to be decided is the discipline or
10
penalty that should be imposed. The Court's position on this is consistent with the fact that Coughlin
11
was found guilty beyond a reasonable doubt and therefore the State Bar need not prove that
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Coughlin committed the crimes. Coughlin would like that interpretation to mean that that State Bar
may nol bring multiple disciplinary charges against Coughlin in the Complaint.
Clearly Coughlin's
interpretation is wrong. The Supreme Court in the same Order found that Coughlin is suspended
pending a disciplinary hearing.
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Coughlin's Motion to Dismiss, while largely unintelligible, is based on Coughlin's assertions
17
that Bar Counsel failed to conduct an adequate investigation. See Motion page 16 II 10- 12 where.
18
Coughlin argues as follows:
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So Coughlin has been and continued to tell King about the ridiculousness of the
conviction and dismissal of the appeal in the criminal trespass matter, and King gets all
spooked about his utter failure to investigate , and tries to jam through a scr 11 1 filing
while on the phone with Coughlin.
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Motion page 161110-12.
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02803
02803
- ------ --.- ---. --~-. ----....----- -.--- . ---"".... .
.. . ---'~'-'- ------
...
1
This matter has been investigated. The Supreme Court in response to the first SCR 111
Petition suspended Coughlin pending disciplinary hearing. Coughlin has not filed an Answer to the
Complaint. Coughlin's Motion 10 Dismiss and Motion to Bifurcate should be denied.

Respectfully submitted this
ZS

STATE BAR OF NEVADA
DAVID A. CLARK , BAR COUNSEL
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By
'4o-~'
Patrick O. King~tant Bar Counsel

Nevada Bar No. 5035
9456 Double R. Blvd .. Ste. B
Reno, NV 89521
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02804
- ---- - ----------- -
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-------.---_._
.--------------
TIle undersigned hereby certifies that a true and correct copy of the foregoing Opposition to
Respondent's Motion to Bifurcate Hearing, MotioD to Dismiss was deposited in the United States
Mail at Reno, Nevada, postage fully pre-paid thereon for certified and first class mail addressed to the
followi ng:
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Zachary B. Coughlin
1471 E. 9th SI.
Reno NV 89505
DATED this 24" day of October, 2012.
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Lauro eler.;:, an employee of

the tate Bar of Nevada
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02805
02805
CASE NUMBER: ng12-0204 ng-0435 ng-0434 motion to bifurcate

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IFrtodt: 0'
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,..~~
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STAlE ~~ OF NEVADA
STATE BAR OF Ni:VADA
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)
)
Rc MaUer of:
ACHARY BARKER COUUHLlN, ESQ,
) ng 12-0204 ng-0435 ng-0434 motion to

) bifurcate 10 15 12.odl
cvada Bar No: 9473
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Motion to Review and Inspect Bar Records; Motion to Bifurcate Hearing; Motion to Dismiss for
Complaint Failure to Sufficient ly State the Charges with Specificity and Support and for Utter Fai lure
of Bar Counsel to Perform Reasonable Investigation
18
COMES NOW. ZACHAR Y BARKER COUG IILl N, ESQ .. and file s this limited .:!ppearancc.1
JC
2.
not in any way waivi ng the deticiences of service of process of the above numerated SCR Complaint
(given the tailure to have a Milparty serve Cough lin under SCR 109 in combination with the S8l\!
anestations and promises respecting remailing a certified mail eopy of such Complaint on or about
September 101h. 2012 (whidl was never done. rather the improper altempts to have a party. Laura
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,
,
Peters or tht:: SBN serve Coughlin on September 25th, 2012. was done instead). above naru.cd
document and
1110VCg
this COlli'. (or, if the case may he. the NNDB , the NNDP, the Bar. Bar Counsel, !
Court Clerk tor the SHN. etc) fo r the relief requested herein. This filing is funher based upon the
- 1/27-
Complain!' Fai lure to Surfici;:ntly Statt! th\! Charges with Specificity and Support and for Utter Failure
of Bar Cl)Unsel (0 Perform Reasonable Investigation
02806
02806
papers and pleadings on file herein and in the companion case before the Nevada Supreme Court in
60838 and 61426. The following is roughly what was said at the SBN's Northern Office whe
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Coughlin showed upon on September 25th, 2012 for the Hearing that had been set, calendared,
noticed, and scheduled:
"King: No, the suspension is pending the disciplinary action that I bring. I have not filed any
disciplinary action they suspended you pending the disciplinary action, and this is that
disciplinary action (King then resumes motioning to the stack of papers on the ground that he
purports to be a SBN v Coughlin SCR 105 Complaint).
Coughlin: SCR 111(8) and the Supreme Court's order said that the hearing is limited to the sole
purpose of determining Mr. Coughlin's punishment for that upon which the SCR 111 Petition
was brought.
King: It does not say that, it says 'pending a disciplinary action by the State Bar'
Coughlin: I am talking about the "hearing before the Disciplinary Panel" under SCR 111(8)
and the Court's June 7th, 2012 Order, that is different than some hearing Under an SCR 105
Complaint. That the whole import of the language in SCR 111(8), which the Court quotes
exactly in its June 7th, 2012 Order for Temporary Suspension of Law License where it reads,
"the supreme court shall"..."refer the matter to the appropriate disciplinary board for the
institution of a formal hearing before a hearing panel in which the sole issue to be
determined shall be the extent of the discipline to be imposed".
FACTS
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1..1 Patrick King, Esq., Bar Counsel of the North, and NNDB Chairman J. Thomas Susich
continue to display an alarming lack of appreciation for due process, basic fairness, and other notions
of fair play and substantial justice...and now seeks to subvert the express ruling of the Nevada
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Supreme Court in its June 7th, 2012 Order by turning the Hearing that has already been set (as
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confirmed by the SBN's Laura Peters, in writing) for September 25th, 2012 into a "due process combo
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pack express package" wherein all the various matters set forth in King's Complain shall also be
26
addressed, despite the Order by the Nevada Supreme Court and the text of SCR 111 very clearly
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indicating the "sole purpose" of the hearing will be to determine the punishment for the one criminal
- 2/27 -
Complaint Failure to Sufficiently State the Charges with Specificity and Support and for Utter Failure
02807
conviction contained in Bar Counsel's SCR 111 petition of May 10, 2012 in 60838 and where an
"immediate hearing" is further required in light of Coughlin's SCR 102(4)(d) Petition filed, and
unopposed by the SBN in 61426.
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2. SBN Clerk of Court of the Laura Peters has assured Coughlin that no service of any SBN v
Coughlin Complaint has been effected as of this date and that Coughlin is in no danger of defaulting
for failure to answer any such Complaint. However, Clerk of Court Peters indicated to Coughlin that
she did not file Coughlin's September 17th, 2012 Motion to Dismiss in light of directions from Bar
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Counsel Patrick O. King, Esq., and further, NNDB Chairman, J. Thomas Susich has made similar
indications of the extent to which King is attempting to circumvent procedural rules attendant to these
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matters and cause Coughlin further damages and delay, particularly with regard to the dictates of SCR
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116. The scheduling of the hearing is the domain of the NNDB and is not to be handed of to the
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prosecutor here, Bar Counsel Pat King. Peters, King, and Clark have all admitted that King and
Clark are seeking to circumvent the procedural rules and Order related to the scheduling and holding
of the hearing in response to the Court's June 7th, 2012 Order in 60838 and with regard to the
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"immediate hearing" required upon Coughlin's August 13th, 2012 Petition in SCR 61426, which Bar
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Counsel has failed to Oppose, and for which, therefore, Coughlin is entitled to the relief he therein
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sought, ie, the dissolution of the temporary suspension of his license to practice law.
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3. By and Order of the Nevada Supreme Court on June 7th, 2012 Coughlin's constitutionally
23
protected property right, his law license, was temporarily suspended: "Pursuant to SCR 111,
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temporary suspension and referral to the appropriate disciplinary board are mandatory when an
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attorney has been convicted of a "serious" crime, which includes theft. SCR 111(6)-(8). Accordingly,
pursuant to SCR 111(8), we refer this matter to the appropriate disciplinary board for the institution of
- 3/27 -
02808
a formal hearing before a hearing panel in which the sole issue to be determined shall be the extent
of the discipline to be imposed. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend
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attorney Zachary B. Coughlin from the practice of law in Nevada, pending final disposition of the
disciplinary proceedings."
4. In a written communication from SBN Clerk of Court Laura Peters on July 26th, which
was cc'd to Bar Counsel Patrick King, Clerk Peters wrote: " Mr. Coughlin: I have been contacted by
Tom Susich of the Northern Nevada Disciplinary Board. I understand that you would like to schedule
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a formal hearing in your matter. I have gathered some available dates in September and October let
me know what will work for you: September 25, 26 or 27 October 15, 16, 17, 18, 30 or 31 Thank you,
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Laura Peters". In an written correspondence from Coughlin to Clerk of Court for the SBN Peters:
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"Subject: Hearing... Dear Ms. Peters, Please set the hearing date as soon as possible for any matter
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involving me that has been referred to the bar or the disciplinary panel. thanks Zach Coughlin". The
SBN's Peters responded, in writing, on August 17th, 2012, to Coughlin: "RE: Hearing...Zach: How
about September 25th, work for you?". Coughlin responded to Peters, in writing, on August 17th,
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2012: "That works thanks" with a copy of Peter's correspondence of August 17th, 2012 setting forth
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the September 25th, 2012 Hearing date. Coughlin wrote to NNDB Chairman J. Thomsas Susich, Esq.
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on September 11th, 2012 indicating, in writing: " The hearing is set for... Hearing date... I look
forward to our Hearing on September 25th, 2012. Zach Coughlin".
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4.1 Upon information and belief, in early May 2011, prior to any SCR 111 Petition or SCR
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105 Complaint being filed, Bar Counsel violated SCR Rule 121(5) Confidentiality: "5. Temporary
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suspension under Rule 102(4). In the event that the state bar files a petition with the supreme court for
the temporary suspension of an attorney before a formal complaint is filed in the underlying
- 4/27 -
02809
disciplinary proceeding, then the matter shall be treated as confidential. If the court grants the
petition, then the matter shall become public upon entry of the order granting the petition. If the
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court denies the petition, then the matter shall remain confidential until a formal complaint is
filed or the matter is otherwise concluded."
5. On September 11th, 2012, in a telephone conversation with Coughlin, SBN Clerk of Court
confirmed that the hearing previously noticed, set, and schedule for September 25th, 2012 was "still
scheduled" and "on the calendar". During that conversation, Clerk of Court Peters admitted that
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"there is a hearing set for the 25th (of September), we set that just on the SCR 111 Petition. Now
there is a Complaint and I think that Pat and David want to combine it, I didn't know that at the time
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that I set your hearing date." Coughlin then asked Peters "So, the hearing is still set on the
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calendar?". Peters responded "on the calendar it is". Then Peters indicated that "as soon as the
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Hearing was set, they (Pat King and David Clark) said 'oh, wait, wait, we want to combine it with the
Complaint's Hearing as well, so they filed a Complaint and I served it on you." when I set your
hearing (for September 25th, 2012), I did not know that David (Bar Counsel David Clark) and Pat
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(Pat King) wanted to combine that (hearing on the SCR 111 and SCR 102(4)(d) Petitions in 60838
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and 61426) with a SBN v. Coughlin Complaint the SBN has been threatening to file against
20
Coughlin)".
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6. Bar Counsel King has continually referred to Coughlin, as a "former attorney", often when
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speaking directly to Coughlin, and has further mentioned to Coughlin that Coughlin has been
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"disbarred", while speaking in a mock devastated tone when mentioning the sadness King would
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himself feel if Coughlin lost his law license, which echoed the venomous chill in the air when David
Clark recalled to Coughlin, regretfully about that one time an attorney committed suicide before Clark
- 5/27 -
02810
got a chance to prosecute him, and that regret, to be clear, was due to missing the chance to prosecute
that attorney prior to the suicide. King is apparently unaware that disbarments were made irrevocable
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in Nevada in 2008 or the fact that one is still "an attorney" during a temporary suspension of one's law
license.
7. Coughlin appeared at the northern officer the State Bar for the calendared, agreed upon,
noticed, and set September 25, 2012 Hearing notice to him and the NNDB's Chairman Susich and
required by this Court's June 7th, 2012 Order and SCR 111(8). While Coughlin sat waiting in the
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lobby out walked Clerk of Court Peters and Bar Counsel Patrick King, King holding a stack of papers
then handing them to Clerk Peters, and King whom greeted Coughlin and entere a conversation that
when approximately like this:
King: Zach.
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Clerk Peters: I am supposed to hand you this Complaint.
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King: Your're served (motioning to Clerk Peters to hand Coughlin the stack of papers). You are
officially served. She's the Court Clerk. You're served.
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Coughlin: Aw.. I think one has to be served by a non-party under SCR 109.
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King: No, you're served ,she's the Clerk of Court, so take it. She's serving you, your are officially
served and so I will issue a default judgment against you if you don't accept it.
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Peters: I mailed it out.
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Coughlin: Is my hearing going to be held right now?

King: First, take this.
Coughlin: What about my Hearing that's what I'm here for right now.
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Coughlin I think you actually can't serve people when they are showing up for a Hearing.
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King yes I can absolutely can,
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Coughlin: I have cases that say you can't.
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King: I absolutely can things don't go your way because you don't accept responsibility (King grabs
the stack of papers from Peters and attempt to insert them into Coughlin's suit jacket after pulling the
middle button on Coughlin's blazer away from Coughlin's torso, whereupon King gives up on that
- 6/27 -
02811
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approach). I'll drop it at your feet here your served (King bends down and places the stack of papers
on top of Coughlin dress shoes).
Coughlin you are a party though it has to be a non-party that's the law
King: Zach. don't play games!
Coughlin: It's not a game, Pat, it's the law.
Peters: Zach, please?
Coughlin: Where is my hearing?
King: Hi Paula where you witness that I'm serving or that rather Laura is serving Zach Coughlin with
the Complaint.
Paula: Sure? (looking bewildered beyond all measure).
King Here is this, take it, take it, Zach.
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Coughlin: We go to have my hearing today?

King: First order of business is for you to accept the Complaint
Coughlin: For you may be Pat, but you're not the one who hasn't had a law license last four months
over a candy bar so
King are going to take the complaint it's a formal complaint I'm been a default you him him. You can
pretend you didn't get it else is take a default
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Coughlin: Pat I filed a motion to dismiss. Seems like you are trying to put Clerk of Court Peters in
kind of a bad spot.
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King No, you haven't filed it it's been rejected,
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Coughlin: By who, the prosecutor? The prosecutor rejected it, Pat?
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King: Listen the Clerk of Court Peters rejected it because it doesn't say what it's dismissing. You are
not even acknowledging that you have been served so take the Complaint and then you can answer it.
You're been served right now
Coughlin: well I guess you're free to argue that, that you a party that is serving me.
King: No, the Court clerk is serving you. Your at the State Bar office being served with a Complaint
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Coughlin I I've got cases this the you can serve a criminal defendant when they show up to a civil
proceeding
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King: This is State Bar.
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Coughlin: Oh, I get it. We're playin' prison rules, huh? Like in that movie The Cable Guy when Jim
Carrey is playing pickup ball and says "Oh, we're playing prison rules,huh?" to the guys who just
fouled him so hard? I guess, we are "playin' 'prison rules'" down here at the State Bar, huh? Are we
going to have my hearing today? Because the Hearing is limited in scope and purpose, right?
King: Zach, listen to the Court Clerk.
Coughlin: Okay.
- 7/27 -
02812
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Peters: when you and I talked about the date for September 25th that was a tentative thing. I have not
formally noticed that. I never did.
King: Because you did not answer the Complaint...because you did not answer the Complaint by me
explain Mr. Coughlin the suspension that you received from the Supreme Court which is their Order
so if ya have a problem with the Supreme Court...
Coughlin I did with the SCR 102(4)(d) Petition? Why didn't you answer that, Pat? Now, I win on
that on default, too?
King: That's the Supreme Court... they suspended you pending...pending a disciplinary
Complaint which is what that is (motioning to a stack of papers King had earlier laid at
Coughlin's feet).
Coughlin: So this is a new Complaint filing?
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King: No, the suspension is pending the disciplinary action that I bring. I have not filed any
disciplinary action they suspended you pending disciplinary action, and this is that disciplinary
action (King then resumes motioning to the stack of papers on the ground that he purports to
be a SBN v Coughlin SCR 105 Complaint).
purpose of determining Mr. Coughlin's punishment for that upon which the SCR 111 Petition
was brought.
King: It does not say that, it says 'pending a disciplinary action by the State Bar'
Coughlin: I am talking about the "hearing before the Disciplinary Panel" under SCR 111(8)
and the Court's June 7th, 2012 Order, that is different than some hearing Under an SCR 105
Complaint. That the whole import of the language in SCR 111(8), which the Court quotes
exactly in its June 7th, 2012 Order for Temporary Suspension of Law License where it reads,
"the supreme court shall"..."refer the matter to the appropriate disciplinary board for the
institution of a formal hearing before a hearing panel in which the sole issue to be
determined shall be the extent of the discipline to be imposed".
King: Listen to me, I am trying to help you. That Complaint (pointing at the stack of papers on
the ground) is the Complaint that we will have the Hearing on...
Coughlin: We are having a Hearing today, and if we don't, you default, and I get my license
back.
King: If you answer that Complaint, then..you will have the right to appear at a Hearing and
argue your case to the Disciplinary Panel. If you do not file a Verified Answer to the
Complaint, then we will move forward, and proceed on a default basis, and the Panel may
accept every allegation in the Complaint as true.
Coughlin: So you refused to file the Motion to Dismiss I submitted for filing?
King: What Motion to Dismiss?
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Coughlin: The one Clerk Peters said you told her not to file.
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King: I didn't tell...I don't tell the Court Clerk what to do...
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- 8/27 -
02813
Coughlin: I sent it to you, Pat. 'What Motion to Dismiss'?
King: What are you asking to be dismissed? It doesn't say what you are asking to be dismissed.
You can't have it both ways, Zach.
Coughlin: Pat, do you have a case number,? Do you have a case number on that, on that, Pat?
King: Pick it up and read it. Pick it up and read it.
Coughlin: I can wait around her a little while longer for you to get my Hearing going, but at
some point I think I would be justified in assuming you are refusing to proceed with or hold the
Hearing you set and noticed, so...you might want to get Chairman Susich or somebody down
here and get this Hearing, here, happenin', Pat.
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8. Now Pat King and Laura Peters purport to have calendared, set, and noticed a hearing from
November 14th, 2012, combining both the SCR 111 matter and the new SCR105 Complaint herein,
despite their failure to comply with the dictates of SCR 105 respecting 30 days before so having such
a hearing. Is there any due process requirement corner that the SBN does not cut?
LAW AND LEGAL ARGUMENT
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A state cannot exclude a person from the practice of law in a manner or for reasons that
contravene the due process or equal protection clauses of the Fourteenth Amendment. in Louisiana
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State Bar Association v. Keys, 567 So. 2d 588 (La. 1990), noted that "due process prohibits
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sanctioning the attorney for unrelated misconduct revealed by the evidence in the disciplinary
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proceeding when the attorney had not been notified that the uncharged violations would be
considered as disciplinary offenses ... In Louisiana State Bar Association v. McGovern, 481 So. 2d
574 (La. 1986)" and that "the purpose of requiring notice of the charges ... is to prevent prejudice to
the accused attorney in preparing and presenting a defense." Id. at 591 (emphasis added).
CLEMENTS v. ALABAMA STATE BAR.: 1101167. -- July 06, 2012. :"Clements first
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argues that "the Alabama State Bar violated her due process rights as a result of the Bar's failure to
bifurcate the [disciplinary hearing on the] two unrelated bar complaints against her." Clements's brief,
26
at 40. Clements argues that "[t]he issue of a combined hearing involving unrelated bar complaints has
27
not been previously directly addressed by the Alabama Supreme Court. However, the Supreme Court
28
- 9/27 -
02814
has made a specific guarantee of due process as it relates to State Bar hearings." Id. She then quotes
Ex parte Case, 925 So.2d 956, 960 (Ala. 2005), for general principles of law regarding procedural due
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process, including the right to "`"an orderly proceeding appropriate to the case or adapted to its
nature, just to the parties affected, and adapted to the ends to be attained; one in which a person has an
opportunity to be heard, and to defend, enforce, and protect his rights before a competent and
impartial tribunal legally constituted to determine the right involved."'" (Quoting Katz v. Alabama
State Bd. of Med. Exam'rs, 351 So.2d 890, 892 (Ala. 1977), quoting in turn 2 Am. Jur. 2d
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Administrative Law 353.) Bifurcated hearing: Mirch asserts that the panel erred by allowing prior
bad acts and victim impact testimony before a violation was found because this evidence improperly
influenced the panel. Mirch failed to request a bifurcated disciplinary hearing, however, and thus he
13
waived this argument . See Diamond Enters., Inc. v. Lau, 113 Nev. 1376, 1378, 951 P.2d 73, 74
14
(1997)While the United States Supreme Court has stated that attorney discipline is a quasi-criminal
15
proceeding, and therefore due process rights apply,5 . 5. In re Ruffalo, 390 U.S. 544, 551 (1968).
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"15 On May 14, 2008, this court issued an order regarding the inclusion of reciprocal
18
discipline counts and standard professional misconduct counts (i.e., those not arising from
19
discipline imposed in other jurisdictions) in the same complaint. Given the contrast between the
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streamlined process for considering reciprocal discipline and the lengthier process for standard
professional misconduct counts under SCRs 22.15-.17, we agreed with Attorney Crandall's position
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that the reciprocal discipline counts should not have been combined in the OLR's complaint with
24
unrelated counts arising out of other grievances subject to the standard grievance procedure. We
25
therefore ordered that the reciprocal discipline counts (Counts 8-9) would be considered by this court
26
separately from Counts 1-7, which were referred to a referee for further proceedings under SCRs
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22.15 and 22.16. We now direct that in all future situations involving the potential imposition of *43
- 10/27 -
02815
reciprocal discipline, any reciprocal discipline counts should be brought in a separate proceeding."
Wis.,2008. In re Disciplinary Proceedings Against Crandall 314 Wis.2d 33, 754 N.W.2d 501, 2008
WI 112.
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Coughlin formally
request a bifurcation of the hearing contemplated for the SCR 105 Complaint
and that required pursuant to the SCR 111 60838 and SCR 102(4)(d) Petition in 61426:
SCR 111(7).Suspension on certification.Upon the filing with the supreme court of a petition
with a certified copy of proof of the conviction, demonstrating that an attorney has been convicted of
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a serious crime, the court shall enter an order suspending the attorney, regardless of the pendency of
an appeal, pending final disposition of a disciplinary proceeding, which shall be commenced by the
12
appropriate disciplinary board upon referral by the supreme court. For good cause, the court
13
may set aside its order suspending the attorney from the practice of law.
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I think Bar Counsel's argument that the "proceeding" call for in the Court's June 7th, 2012 Order
(which quotes SCR 111(7) may include some SCR 105 Complaint (ie, a SBN v. Zachary B.
Coughlin Complaints bringin in all sorts of matters, including pending criminal actions, and wearing
pajamas, and Orders by Judges purporting to take away this or that right of Coughlin's to practice this
or that in some court (an Order which Patrick King reference to me and Chief Bar Counsel Clark,
and, apparently, to a client of mine in early May 2012 (the client is the only other place I have ever
heard of such an unpublished "Order" purporting to have said effect) despite the dictate against Bar
Counsel's doign so in SCR 121 (the SCR 11 Petition was not even filed at that point, and one has to
wonder if some deal between that client, Bar Counsel, and the new attorney that client can now
magically afford was worked out, with nothing said of any torts that client committed against
Coughin, etc., etc., much less criminal law violations, which Coughlin just put up with).
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But my point is, Bar Counsel King points ot the "pending final disposition of a disciplinary
proceeding" language of SCR 111(7)...which is quoted in the Court's June 7th, 2012 ORder (though I
feel Bar Counsel is taking the quote out of context and ignoring the express language of SCR 111(7)
in making this argument that the "pending final disposition of the disciplinary proceedings" language
in the Court's June 7th, 2012 Order entitles Bar Counsel to file a SBN v. Coughlin Complaint deny
Coughlin that afforded under SCR 111(8) (which the JUne 7th, 2012 Order cites to as well), and,
given Coughlin's Petition in 61426, filed and served on August 13th, 2012 (the service of which was
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consented to or waived by Bar Counsel King and Clark where they directed Clerk Laura Peters to
sign "Proof of Receipt" thereof on August 13th, 2012...), Coughlin is now entitled to an "immediate
hearing" pursuant to SCR 102(4)(d), and SCR 111(10).
The Court's June 7th, 2012 Order reads, in relevant part: "Pursuant to SCR 111, temporary suspension
and referral to the appropriate disciplinary board are mandatory when an attorney has been convicted
of a "serious" crime, which includes theft. SCR 111 (6)-(8). Accordingly, pursuant to SCR 111
(8), we refer this matter to the appropriate disciplinary board for the institution of a formal
hearing before a hearing panel in which the sole issue to be determined shall be the extent of the
discipline to be imposed. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend
Zachary B. Coughlin from the practice of law in Nevada, pending final disposition of the
disciplinary proceedings." Note that the Order says "pending final disposition of the
disciplinaryproceedings" . It does not say "pending final disposition of an SCR 105 Complaint filed
by SBN as the complainant (see Ching). And, in fact, SCR 111(8) clear that up further,
I give Patrick King credit for making a crafty argument, but its just not colorable. I am so used to this
with Pat by now, he plays dumb in a way that screw one out of their due process, but it is clear he
knows exactly what he is doing, that crafty sum'itch.
SCR 111(8): "8.Referral to disciplinary board.Upon receipt of a petition filed under subsection
4 of this rule, demonstrating that an attorney has been convicted of a serious crime, the supreme court
shall, in addition to suspending the attorney in accordance with the provisions of subsection 7 of this
rule, refer the matter to the appropriate disciplinary board for the institution of a formal
hearing before a hearing panel in which the sole issue to be determined shall be the extent of the
discipline to be imposed."
But the clearest expression of authority to defeat Bar Counsels stated goal of "combining" the
Hearing required by the Court's June 7th, 2012 Order and the Supreme Court Rules with some SCR
105 (or SCR 102, natch) style SBN v. Coughlin Complaint that Bar Counsel wishes to file is found in
SCR 111(7): "the court shall enter an order suspending the attorney...pending final disposition of a
disciplinary proceeding, which shall be commenced by the appropriate disciplinary board upon
referral by the supreme court."
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And, right there, Bar Counsel's attempt to combine these affairs must fail. That's the thing,
though...the phrase "commenced by the appropriate disciplinary board". It does not say "commenced
by the State Bar of Nevada as a complainant, under Ching, filing an SCR 105 Complaint...It just does
not say that. SCR 111(7), rather, reads "which shall e commenced by the appropriate disciplinary
board".
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So, to sum it up Bar Counsel's attempts combine these must fail in light of the following:
"SCR 111(8): "the supreme court shall...refer the matter to the appropriate disciplinary board for
the institution of a formal hearing before a hearing panel in which the sole issue to be
determined shall be the extent of the discipline to be imposed."
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SCR 111(7): "the court shall enter an order suspending the attorney...pending final disposition of a
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disciplinary proceeding, which shall be commenced by the appropriate disciplinary board upon
referral by the supreme court."
However, Bar Counsel and the Disciplinary Board should recognize the import of SCR 111(7)-(8)
and refuse to allow Bar Counsel to "combine" or consolidate, or "fail to bifurcate. What Bar Counsel
is thinking of is SCR 105(2):."Commencement of formal proceedings.Formal disciplinary
proceedings are commenced by bar counsel filing a written complaint in the name of the state bar.
The complaint shall be sufficiently clear and specific to inform the attorney of the charges against him
or her and the underlying conduct supporting the charges."
However, SCR 111(7) and SCR 105(2) are entirely different animals. In one, SCR 111(7) calls for:
"the court shall enter an order suspending the attorney...pending final disposition of a disciplinary
proceeding, which shall be commenced by the appropriate disciplinary board..."
In the other, it is Bar Counsel doing the "commencing" of SCR 105(2):."Commencement of
formal proceedings.Formal disciplinary proceedings are commenced by bar counsel filing a
written complaint in the name of the state bar...."
The distiction and diferences are revealed in the Supreme Court Rules by whom is doing the
"commencing" and just what it is they are "commencing", ie, a "formal proceeding (in the case
of SCR 105(2), or a "dsiciplinary proceeding",
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There is a difference, and that difference entails bifurcating things or refusing to consolidate
these affairs, and I am formally making that request upon the Board here now.
Severance in General
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The Nevada Rules of Civil Procedure concerning severance are NRCP 13(i), NRCP 14(a),
NRCP 21, and NRCP 42(b). These rules provide in pertinent part as follows:
NRCP 13(i)
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(i) Separate Trials: Separate Judgments. If the court orders separate trials as provided in Rule
42(b), judgment on a counterclaim or cross-claim may be rendered in accordance with the terms of
Rule 54(b) when the court has jurisdiction so to do, even if the claims of the opposing party have
been dismissed or otherwise disposed of.
History, Purpose, and Basis of Severance Rules
NRCP 42(b) allows separate trials of various claims and issues in furtherance of convenience, or to avoid
prejudice, or when separate trials will be conducive to expedition and economy. The matter of ordering separate trials
rests largely in the discretion of the trial judge. See California State Auto. Assn Inter-Insurance Bureau v. Eighth Judicial
Dist. Court, 106 Nev. 197, 199, 788 P.2d 1367, 1368 (1990). In addition, the Nevada courts may order a separate trial for
any issue or any number of claims, cross-claims, counterclaims, or third-party claims. Gojack v. Second Judicial Dist.
Court, 95 Nev. 443, 445, 596 P.2d 237, 239 (1979); see also NRCP 42(b).
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The factual questions of judicial convenience and prejudice should be resolved at the trial court level. Cal. State
Auto. Assn Inter-Insurance Bureau, 106 Nev. at 199, 200, 788 P.2d at 1368-69. The trial courts discretion must be
applied in such a manner as to preserve inviolate the right of trial by jury. NRCP 42(b). The procedure under NRCP
------------------------------------------------------------------------------------------------------------Page 19-7 (Rel. 15)
42(b) for separate trials should be distinguished from severance of claims under NRCP 21. Separate trials under NRCP
42(b) usually result in a single judgment, whereas claims severed under NRCP 21 become independent actions to be tried
and adjudicated separately. Essentially, NRCP 42(b) is a counterbalance to the broad joinder provisions contained in
NRCP 13, NRCP 14, and NRCP 18 to NRCP 24, which place few restrictions on joinder during the pleadings stage.
14.
Severance or Separate Trials: Procedure
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Any party may move for separate trials or the court may so order on its own motion. Bifurcation of the trial on the
issues of liability and damages may be ordered if the two issues are separate and distinct. If the nature of the injuries has
an important bearing on the issue of liability, the Nevada Supreme Court has held bifurcation to be an abuse of discretion.
See Verner v. Nev. Power Co., 101 Nev. 551, 554, 706 P.2d 147, 150 (1985) (separate trials under NRCP 42(b) held
improper where the issues of liability and damages were inextricably interrelated).
The Nevada Supreme Court has also held bifurcation to be an abuse of discretion when separate proceedings
required a departure from specific statutory mandates. See Gojack v. Second Judicial Dist. Ct., 95 Nev. 443, 446, 596 P.2d
237, 239 (1979) (order bifurcating divorce trial improper because, by statute, court may not enter final divorce decree
without contemporaneously determining property and related rights and responsibilities of the parties). Even when
bifurcation is proper, the district court must, when relevant, give at least a modified version of the contributory negligence
instruction mandated by NRS 41.141. Verner, 101 Nev. at 555-56, 706 P.2d at 151.
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Although bifurcation of personal injury cases usually saves time, some federal studies indicate that separate trials
of liability and damages issues should not be routinely ordered because bifurcation often reduces the instances in which
personal injury plaintiffs are successful. The Advisory Committee to the 1966 amendment of FRCP 42(b) suggested that
bifurcation should be encouraged where experience has demonstrated its worth, but that it is not to be routinely
ordered.
A separate trial may also be ordered when evidence admissible only on a certain issue may prejudice a party on
other issues, as where in a single trial the jury would learn that the defendant is insured, and the issues are unrelated. See
Larsen v. Powell, 16 F.R.D. 322 (D. Colo. 1954). However, such prejudice does not come into play where the action is to
be heard by the court rather than a jury. See Organic Chemicals, Inc. v. Carroll Products, Inc., 86 F.R.D. 468 (W.D.
Mich. 1980). In determining whether one or two trials will best serve the convenience of the parties and the court, avoid
prejudice, and minimize expense and delay, the major consideration should be which procedure is more likely to result in
a just and final disposition of the litigation. See In re Innotron Diagnostics, 800 F.2d 1077, 1084 (Fed. Cir. 1986). In this
regard, it should be noted that Nevada trial courts have other means aside from those found in NRCP 13(i), NRCP 14(a),
NRCP 21, and NRCP 42(b), to control the course and conduct of proceedings before the court. Specifically, NRS 50.115
provides in relevant part:
1. The judge shall exercise reasonable control over the mode and order of interrogating witnesses and presenting evidence:
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(a) To make the interrogation and presentation effective for the ascertainment of the truth;
(b) To avoid needless consumption of time; and
(c) To protect witnesses from undue harassment or embarrassment.
Nevada trial courts may order separate trials of any cross-claim or counterclaim pursuant to NRCP 13(i). An order
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separating such claims should be issued for the reasons provided in NRCP 42(b). Judgment on the separate claims may be
certified as final in accordance with the terms of NRCP 54(b) if the judgment is final as to fewer than all of the claims or
parties. Further, NRCP 14(a) provides that any party may move to strike a third-party claim, or for its severance or
separate trial. Similarly, any claim against a party may be severed and proceeded upon separately pursuant to NRCP 21.
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When separate trials are ordered, the court may stay or postpone discovery of the issues to be tried in the second
trial pending completion of the first trial. For example, courts may defer discovery on damages issues until liability is first
proven. See In re Master Key Antitrust Litigation, 70 F.R.D. 23 (D. Conn.), appeal dismissed, 528 F.2d 5 (2d Cir. 1975).
Different juries may hear the bifurcated liability and damages issues if the issues to be tried are distinct and not
interwoven, and no injustice would result. Id. However, some federal commentators believe the preferred practice is to use
the same jury for all issues, even though the trials are conducted at different times. 9 Wright & Miller, Federal Practice
and Procedure 2391, at 512 (1994).
SCR 105(2) holds
2. Commencement of formal proceedings. Formal disciplinary proceedings are commenced

by bar counsel filing a written complaint in the name of the state bar. The complaint shall be
sufficiently clear and specific to inform the attorney of the charges against him or her and the
underlying conduct supporting the charges. A copy of the complaint shall be served on the
attorneyand it shall direct that a verified response or answer be served on bar counsel within 20
days of service; the original shall be filed with bar counsel's office. The time to respond may
be extended once by the chair for not more than 20 days for good cause or upon stipulation of
the parties. In the event the attorney fails to plead, the charges shall be deemed admitted;
provided, however, that an attorney who fails to respond within the time provided may thereafter
obtain permission of the appropriate disciplinary board chair to do so, if failure to file is
attributable to mistake, inadvertence, surprise, or excusable neglect.
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Kings Complaint lacks specificity and relies upon "summary criminal contempt" Orders that
rely upon conduct allegedly occuring outside the presence of the court, where no Affidavit by
Marshal Harley was ever relied upon, given at the March 12th, 2012 court date that SBN was
provided audio of, Judge Nash Holmes purports to have had Harley follow Coughlin into a restroom
stall and watch him "dissassemble" a smart phone...Further, JUdge Nash HOlmes was divested of
Jurisdiciton by Coughlin filing a NOtic eof Appeal on March 7th, 2012, so her various ORders
thereafter are void, and were double jeopardy of here February 28th, 2012 ORder, which she mailed
to an address she knew was no good for Coughlin, or should have (every other department in the
RMC had Coughlin's address right....). to the extent Coughlin's "verified response" may not be a
Moiton to Dismiss or similar, Coguhlin hereby, under protest, answer sto charges by deny every last
effin' one of them, period.
SCR 105(c):
(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
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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."
By purporting to have mailed notice ot Coguhlin on last Friday, October 12th, 2012, even a
charitable 3 days for mailing conswtructive notice analysis indicates the October 14th, 2012 date
would provide only 29 days notice, by my count, and notice cannot even be sent out until an answer
or response is filed, and given the SBN's refusal to file Coughlin's september 17th, 2012 responsive
pleading, a Motion to Dismiss...corner cuttin' on due process down at the SBN, attack doggin' for the
Rich., said Pat King "What, jUdge William Gardner and Judge LInda Gardner are realted? Well, I
never!". Yeah, sure, Pat. Also, Pat is gettin' realy crafty about not indicating where the old NG0435,
stamp received 3 15 12 in the SBN, consisting of Judge Sister LInda Gardner's April 2009 Order for
Sanctions, which her brother Judge William Garnder, admitted he passed on to Judge Nash HOlmes,
who passed it to Pat, who got his "attack dog for the rich and powerful" routine goin'.
So Coughlin has been and continued to tell King about the ridiculousness of the conviction
and dismissal of the appeal in the criminal trespass matter, 11cr26405, and King gets all spooked
about his utter failure to investigate, and tries to jam through a scr 111 filing while on the phone with
coughlin.
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Mon 10/15/12 5:03 PM
To:
patrickk@nvbar.org; davidc@nvbar.org; nvscclerk@nvcourts.nv.gov
Hotmail Active View
4 attachments (total 7.4 MB)
sbn v cou...pdf
Download(388.4 KB)
DistCtOrd...pdf
Download(145.1 KB)
rev2011-0...pdf
Download(3.2 MB)
Download all as zip
Mr. King,
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This writing memorializes, in part, our conversation about your failure to investigate, in any real way,
the criminal trespass allegations, in violation of the Claiborne decision. Upon my asking you pointed
questions, you hurriedly filed a SCR 111 Petition in an attempt to excuse your failure to ask any of
the pointed questions I have previously put forth to you regarding that criminal trespass matter,
further you admitted to being unaware (allegedly) of the familial relation between Judge William
Gardner and Judge Linda Gardner (despite that being quite clear in my recent filings to you).
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You might want to look at AB226 and the Committee on the Judiciary notes from March 31, 2011.
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This correspondence reminds you of and further places you on notice of that the fact that you have
been placed on a LITIGATION HOLD NOTICE. THE VIDEO FILMED BY RICHARD HILL OF
THE RENO POLICE DEPARTMENT'S CHRIS CARTER AND SARGENT LOPEZ IN THE TIME
PRIOR TO THE LANDLORD, MERLISS ALLEGEDLY KICKING DOWN THE DOOR, IS OF
MATERIALLY RELEVANCE TO SEVERAL CIVIL LAWSUITS AND CRIMINAL
PROCEEDINGS. RICHARD LIED IN COURT, UNDER OATH WHEN HE TESTIFIED THAT
THE RPD ANNOUNCED THEMSELVES AS LAW ENFORCEMENT AND ORDERED
COUGHLIN TO COME OUT OF THE BASEMENT PRIOR TO THE DOOR BEING KICKED IN.
RICHARD SENDS THE STATE BAR OF NEVADA LETTERS ON
FURTHER, OFFICER CARTER'S POLICE REPORT IS DEMONSTRATED TO BE FULL OF
LIES BY THE VERY VIDEOS THAT HILL PROPOUNDED TO THE CITY OF RENO
PROSECUTORS, PARTICULARLY WITH RESPECT TO WHETHER COUGHLIN REFUSED
TO LEAVE AFTER BEING WARNED OR TOLD TO DO SO AND THE EXTENT TO WHICH
CARTER WAS UNABLE TO ISSUE A CITATION OR RELY ON A SIMPLE WARNING IN
LIGHT THEREOF. COUGHLIN ACTUALLY ASKS CARTER IN THE VIDEO HILL FILMED
WHY HE DOESN'T JUST ISSUE SUCH A WARNING OR CITATION. Then, Carter goes on to
attempt to offer his views on "service", however rudimentary they may be. being careful to note to
Coughlin "you're not the victim here." To the extent that Hill and Merliss trespass into Coughlin's
former law office on this date, with the help of the RPD, Soldal v Cook County has been violated, and
Carter and Lopez have violated Wheeler v Coss.
Any Eviction Order signed by Judge Sferrazza was stale in light of the failure to have the lockout
order served upon Coughlin and a lockout performed "within 24 hours" of the Sheriff's receipt of the
Order of both Oct 25th, 2011 (the simple one page Order signed by Judge Sferrazza and notated in his
own handwriting) and or the October 27th, 2011 Findings of Fact, Conclusions of Law, and Order for
Summary Eviction) both of which were received by the WCSO well over 24 hours from when the
lockout's were conducted, and therefore, both such Orders were stale, and therefore, Richard G. Hill,
Esq. committed trespass upon Coughlin's former home law office, threw away a great deal of
Coughlin's personalty (some of it very sentimental), and both Hill and Baker have lied repeatedly in
court filings in indicating that Coughlin was served the Summary Eviction Order on November 1st,
2011 were they also admit that Coughlin was not at his former home law office at the time WCSO
Deputy Machen posted it on the door thereof and effectuated a lockout (and Machen lied under oath
in his November 7th, 2011 filed Affidavit of Service attesting to have "personally served" Coughlin
the Summary Eviction Order on November 1st, 2011 (WCSO Civil Division Supervisor admitted as
much to Coughlin in writing:
NRS 40.253:
5. Upon noncompliance with the notice:
(a) The landlord or the landlords agent may apply by affidavit of complaint for eviction to the
justice court of the township in which the dwelling, apartment, mobile home or commercial premises
are located or to the district court of the county in which the dwelling, apartment, mobile home or
commercial premises are located, whichever has jurisdiction over the matter. The court may
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thereupon issue an order directing the sheriff or constable of the county to remove the tenant within
24 hours after receipt of the order. The affidavit must state or contain:
(1) The date the tenancy commenced.
(2) The amount of periodic rent reserved.
(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the
first months rent, by the tenant.
(4) The date the rental payments became delinquent.
(5) The length of time the tenant has remained in possession without paying rent.
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(6) The amount of rent claimed due and delinquent.

(7) A statement that the written notice was served on the tenant in accordance with NRS
40.280.
(8) A copy of the written notice served on the tenant.
(9) A copy of the signed written rental agreement, if any.
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(b) Except when the tenant has timely filed the affidavit described in subsection 3 and a filestamped copy of it has been received by the landlord or the landlords agent, and except when the
landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlords agent may, in a
peaceable manner, provide for the nonadmittance of the tenant to the premises by locking or
otherwise.
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Further where is my damage deposit (either $500, or, arguably $700 given the extent to which the
Standard Rental Agreement afforded me the choice with respect to how cleaning was to be done and
the extent to which Hill and Baker have failed to comply with
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Mr. Baker, you have committed professional misconduct (and Hill filed a grievance against me in a
letter to the SBN dated January 14th, 2012 purporting to be sent on your behalf in "fulfilling your
RPC 3.8 obligation"...simpy put, Mr. Baker, in your Opposition to MOtion to constest Personal
Property Lien in Rev2011-001708, on page 5, you lie where you write "when Coughlin refused to
emerge from the basement after being ordered to do so by the police, Merliss was forced to kick down
the door to gain access to his own property". You know that that is not true. The Reno Police
Department did not identify themselves as law enforcement or otherwise issue an lawful Orders
directing Coughlin to "emerge from the basement". You have demonstrated a lack of candor to the
tribunal in that regard in conspiracy with Richard Hill. In a videotaped interview, RPD Sargent
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Lopez admits that neither she nor Officer Carter, nor anyone else that day, identified themselves in
any way to Coughlin in the "basement" or otherwise issued him any sort of "warning to leave" or
"order to emerge" of any sort, whatsoever. Mr. Baker, you were not even there. Yet, you viewed the
video taken by Richard Hill of the moments in question where the RPD were at the basement door
prior to Dr. Merliss kicking it down, including those moments where Dr. Merliss is seen in one video
whispering to Richard Hill. If there really was all this identifying themselves as law enforcement and
issuing Coughlin an order to emerge which went unheeded, then why the whispering? Why did
Richard fail to include the he took of the moments where the RPD were at the "basement" door an
failed to identify themselves or issue any lawful Orders? How would Coughlin know that any voices
that may have been audible did not simply belong to more of the goons Hill and Baker routinely hire
from Nevada Court Services to trespass behind Coughlin's former home law office's backyard gate,
visiting in pairs, threes times a day, one ringing the door bell repeatedly for 30 minutes at a time,
while the other (R. Wray, Joel Durden, and other licensed process servers) trespasses behind a a
latched backyard gate and bangs on windows and peers through closed blinds while issuing threats
intended to indicate they are being made by someone with color of law behind their words, while
dressed up in an outfit specifically intended to confuse the public into thinking these process servers
are Sheriff's Deputies?
Regardless, the real fly in the ointment is the fact that RPD Sargent Lopez admitted that neither she,
nor Carter, nor anyone else identified themselves as law enforcement and or issued Coughlin an order
to emerge from the "basement". Indeed, in Hill's Declaration in REv2011-001708, filed a scant 7
days after the arrest, Hill certainly fails to mention any such alleged moment where the RPD identify
themselves as law enforcement and issue Coughlin an order to emerge prior to Merliss kicking the
door in. Hill writes letters to the SBN accusing Coughlin of having a "crack pipe and bag of weed"
and "large quantity of pills" (the videos Hill took that day reveal those "pills" are vitamins, something
Hill fails to clarify with the SBN, and Hill never has provided any sort of indication of what the
"crack pipe and bag of weed" looked like exactly, nor has he responded to requests for photographs
thereof, or made indication why he did not call the police, given the fact that he has involved law
enforcement at every other possible turn.
Hill and Baker have continued to fail to deliver Coughlin's security deposit, and in doing so, where
they failed to provide the requisite correspondence within 30 days of any such eviction, have violated
Nevada law:
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Oh, and Judge Williamn Gardner violated NRS 178.405,like Judge HOlmes did on 2/27/12, where he
plowed ahead and set a trial date on May 8th, 2012, even though the Order in cR12-0376 finding
Coughlin competent did not get signed and filed under the next day, May 9th, 2012 so the whole
trespass conviction is void, Keith Loomis is a shameful public defender for hire for the RMC, King
completely failed to investigate a grievance against Loomis incident to Coughlin's Sixth Amendment
rights in that trespass matter 11 cr 26405, and the appeal in cr12-1262 was dismissed on some
timeliness theory under 189.010, even though Coughlin has and has submitted proof of filing the
notice of appeal on June 28th, 2012 for the June 18th, 2012 conviction...though Judge William
Gardner and his staff are pretty mum about that. and that pam longoni in cr12-1018 has some
issues....and she failed to prepare a transcript for Coughlin's wal-mart conviction, which Judge Elliot
based the refusal to overturn in the appeal of that matter upon Coughlin's failing to cite to a transcript,
and he mentioned a civil state in support of his contentions. There's gonna be a few mandamus
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actions, and possibly some judicial discipline commission complaints if people don't get their souls
right pretty quick. Consdier this your "come to Jesus" talk, or insert whatever denomination you like.
further the nrs 22.somethign statute Judge Nash Holmes does not delineate as "criminal contempt",
and here March 12th, 2012 ORder was too late to be a sua sponte NRCP 59 alter or amend...and she
and the RMC broke the law by trying to do a search incident to arrest a day after the smartphone and
micro sd card were booked into coughlin's personal property locker at the WCDC, sending a marshal
to come get the phone and sd card, violated the law without a warrant, and returning tehm 37 days
later to Coughlin erased is, well...but the february 28th, 2012 order make sthe subsequent ORders
double jeopardy as they purport to rule on the same thing, further, HOuston v Eight Judicial District
was not met in that the conduct prohibited was not made sufficiently clear, etc., etc.
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Am Jur. ATTY AND CLIENT 105. Due process requirements; notice and opportunity to be heard
An attorney is entitled to due process in disciplinary proceedings concerning his or her
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conduct.[FN1] Due process in disciplinary proceedings requires that the attorney be given notice of
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the proceeding and an opportunity to defend at a hearing, and that the proceeding be essentially fair.
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[FN2] Due process requires that, in an attorney disciplinary proceeding, the attorney must be notified
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of clear and specific charges and must be afforded an opportunity to anticipate, prepare, and present a
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defense.[FN3] The precise procedural protections of due process vary, depending upon the
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circumstances, because due process is a flexible concept unrestricted by any bright-line rules.[FN4]
What is important is that the disciplinary board's recommendations put the attorney on notice
of the charges he or she must answer to the satisfaction of the court.[FN9] As to the discipline
imposed, due process requires that an attorney facing discipline be permitted to explain the
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circumstances of the alleged offense and to offer testimony in mitigation of any penalty to be
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imposed.[FN10] Where the evidence at the hearing discloses misconduct not charged in the original
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notice, the bar may move to amend the notice to conform to the proof, but if no such motion is made,
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the attorney may be disciplined only for the misconduct alleged in the original notice.[FN11] An
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attorney may be temporarily suspended without a pre-suspension hearing where the risk of erroneous
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02825
deprivation is minimized by provisions allowing the attorney to continue his or her existing practice
for a specified time and allow for immediate hearing and prompt resolution of the matter.[FN12]
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Attorney was not denied due process at presentment before trial court in disciplinary
proceeding by admission of complainant's testimony at earlier hearing before reviewing committee;
complainant was unavailable, and attorney had a full and fair opportunity to and in fact did cross
examine complainant at hearing before review committee. Statewide Grievance Committee v.
Johnson, 108 Conn. App. 74, 946 A.2d 1256 (2008), certification denied, 288 Conn. 915, 954 A.2d
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187 (2008). A license to practice law was a property right. U.S.C.A. Const.Amend. 14. In re
Gargano, 460 Mass. 1022, 957 N.E.2d 235 (2011). Supreme Court observes due process in
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exercising disciplinary jurisdiction over an attorney. U.S.C.A. Const.Amend. 14. In re Disciplinary
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Action against Garcia, 792 N.W.2d 434 (Minn. 2010).
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[FN1] The Florida Bar v. Carricarte, 733 So. 2d 975 (Fla. 1999). [FN2] Bradley v.
Fisher, 80 U.S. 335, 20 L. Ed. 646, 1871 WL 14737 (1871); Jaen v. Coca-Cola Co.,
157 F.R.D. 146, 31 Fed. R. Serv. 3d 178 (D.P.R. 1994). [FN3] In re Disciplinary
Proceeding Against Marshall, 160 Wash. 2d 317, 157 P.3d 859 (2007). [FN4] Steinert
v. Winn Group, Inc., 440 F.3d 1214 (10th Cir. 2006). [FN6] The Florida Bar v.
Daniel, 626 So. 2d 178 (Fla. 1993). [FN7] The Florida Bar v. Committe, 916 So. 2d
741 (Fla. 2005), cert. denied, 547 U.S. 1098, 126 S. Ct. 1890, 164 L. Ed. 2d 569
(2006). [FN8] In re Krouner, 920 A.2d 1039 (D.C. 2007). [FN9] Zauderer v. Office of
Disciplinary Counsel of Supreme Court of Ohio, 471 U.S. 626, 105 S. Ct. 2265, 85 L.
Ed. 2d 652 (1985). [FN10] The Florida Bar v. Carricarte, 733 So. 2d 975 (Fla. 1999).
[FN11] Edwards v. State Bar, 52 Cal. 3d 28, 276 Cal. Rptr. 153, 801 P.2d 396 (1990).
[FN12] In re Lamm, 116 N.C. App. 382, 448 S.E.2d 125 (1994), decision aff'd, 341
N.C. 196, 458 S.E.2d 921 (1995). [FN13] Lasar v. Ford Motor Co., 399 F.3d 1101
(9th Cir. 2005), cert. denied, 546 U.S. 873, 126 S. Ct. 381, 163 L. Ed. 2d 167 (2005).
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SCR Rule 119. Additional rules of procedure.
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1. Record. The record of a hearing shall be made available to the attorney at the attorneys expense
on request made to bar counsel. Willner v. Committee on Character and Fitness, 373 U.S. 96, 83
S. Ct. 1175, 10 L. Ed. 2d 224, 2 A.L.R.3d 1254 (1963).
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2. Time limits not jurisdictional. Except as is otherwise provided in these rules, time is
directoryand not jurisdictional. Time limitations are administrative, not jurisdictional. Failure to
observe directory time intervals may result in contempt of the appropriate disciplinary
- 21/27 -
02826
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board or hearing panel having jurisdiction, but will not justify abatement of any disciplinary
investigation or proceeding.
3. Other rules of procedure. Except as otherwise provided in these rules, the Nevada Rulesof Civil
Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
Clerk Peters and Pat King have conspired to fail to file the September 17th, 2012 MOtion to
Dismiss submitted for filing by Coughlin, in violation of NRCP 5(e) and various case law in
Nevada.
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Failure of the SBN to oppose Coughlin's MOtion to Dismiss must be taken as an admission of the
legitimacy of its contentions, and a dismissal is in order. Further, the undersigned (Coughlin)
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submitted to the Supreme Court of Nevada's electronic filing system an Opposition to Bar Counsel's
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petition on or about May 24th, 2012, as an original matter given the online system would not allow
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filings in the case itself (60838). The Clerk's Office refused to file, mark as received, or,
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apparently, in any way make the Justices of this Court away of the Opposition. Only after the
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undersigned reputation has been sullied by news outlets far and wide (an article appeared in papers
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in at least three different cities, separated by the vast expanse of our state) did the Clerk's Office
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allow Coughlin to file something in an attempt to tell his side of the story here and avoid the
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prejudice that would be done his child custody, foreclosure defense, bankruptcy, and other other
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clients should Coughlin's law license be suspended, even temporarily.. SERVICE AND FILING OF
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PLEADINGS AND OTHER PAPERS....NRCP 5(e), Filing With the Court Defined: The filing of
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pleadings and other papers with the court as required by these rules shall be made by filing them
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with the clerk of the court....The clerk shall not refuse to accept for filing any paper presented
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for that purpose solely because it is not presented in proper form as required by these rules or
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any local rules or practices. NRCP 5(e).
Coughlin is not accused of stealing $755,000 candy
bars from a client yet he was temporarily suspended and his suspension has now lasted over four
- 22/27 -
02827
months. Only after the undersigned reputation has been sullied by news outlets far and wide (an
article appeared in papers in at least three different cities, separated by the vast expanse of our state)
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did the Clerk's Office allow Coughlin to file something in an attempt to tell his side of the story here
and avoid the prejudice that would be done his child custody, foreclosure defense, bankruptcy, and
other other clients should Coughlin's law license be suspended, even temporarily...
It is the official duty of the clerk of a court to record (Nash v. Campbell County Fiscal
Court, 2011 WL 1620587 (Ky. 2011). [FN2] ) or file all the papers in a cause presented by the
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parties, and to indorse the correct date of the filing on them. Estate of Johnson v. Ciarpelli, 71
A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010); In re Simmonds, 271 S.W.3d 874 (Tex. App.
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Waco 2008)The duty is purely ministerial (Benson v. District Clerk, 331 S.W.3d 431 (Tex. Crim.
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App. 2011) (writ of habeas corpus) and the clerk may not refuse to perform except on the order
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of the court. Cave v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010); In re Smith, 270 S.W.3d 783
(Tex. App. Waco 2008).
It is important to note that Coughlin has already had a very important attempted filing
rejected by the Clerk of the Supreme Court of Nevada, and now Bar Counsel Patrick King, Esq. is,
according to Clerk of Court of the State Bar of Nevada, Laura Peters, telling her not to file something
Coughlin has submitted for filing.
F
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AFFIRMATION Pursuant to NRS 239B.030
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The undersigned does hereby affirm that the preceding document does not contain the social security
number of any person.
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- 23/27 -
02828
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Declaration: I declare under penalty of perjury pursuant to NRS 53.045 that,

to the best of my knowledge, the information contained herein is true and
correct to the best of my knowledge though some assertions may be based
upon information and belief.
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Respectfully submitted this: October 15th 2012,
/s/ Zach Coughlin, signed electronically
Zach Coughlin, Esq.
PO BOX 3961
Reno, NV 89505
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Pro Per Attorney
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- 24/27 -
02829
Proof of Service:
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On this date, I, Zach Coughlin electronically served a true and correct copy of the foregoing
document to all registered electronic filers or those otherwise consenting to electronic service in a
waiver of the application of NRCP as set forth in SCR 109, and to those whom are not I placed a true
and correct copy of the foregoing document in the USPS mail on this date and or complied with all
service requirements set forth in SCR 109, except for the State Bar of Nevada, to whom I "personally
served" this document by delivering it and posting it to their door or dropbox (a nod to WCSO
Machen interpretation of "personally served", though I won't be evicting the SBN at gunpoint today,
like the WCSO does, after breaking into citizens residences, sometimes with Richard G. HIll, Esq. in
tow filming one's medicine cabinent, even though AB226, and the fact that the summary eviction
order was stale, meant the WCSO violated Soldal v. Cook County.:
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Patrick O. King, Esq. Assistant Bar Counsel

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

J. Thomas Susich, Esq., Chairman NNDB
Nevada Employment Security Division
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Address: 1675 E. Prater Way, Suite 103
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Sparks , NV 89434
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Fax number: 775-284-9513
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Dated this October15th, 2012
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/s/ Zach Coughlin

- 25/27 -
02830
Zach Coughlin
Pro Per Attorney
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- 26/27 -
02831
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<------
'----------- ,- - ----- ,- -...
"
INdex 10 Exhibits
1. Exhibit 1: various relevant materia ls: 1000 pages and a cd of the variosu relevant videos
,
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B
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2B
- 21rl.7 -
Motion to Rev iew and Inspect Bar Records~ Motion to Bifurcate Hearing; Motion to Dismiss for
Complaint Failure 10 Suffi ciently State the Charges with Spec ificity and Support and fo r Utter Failure
02832
02832
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Electronically Filed
Oct 05 2012 09:40 a.m.
Tracie K. Lindeman
Clerk of Supreme Court

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...
- -~------------~----------.--.-----.
CASE NUMI3IoOl{ :NG I 2-0204, NG-0435, NG 0434

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STATE BAR OF NEVADA

NORTHERN NEVA OA OISCIPLINARY BOARD
B
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ACHARY B. COUGHLIN. ESQ

Bar No. 9473
1\
t%
Complainant.
s.
) CASE NUMBER :NG I2-0204. NG-04 35, NG

) 0434
)
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STATE BAR OF NEVADA

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Respondent.
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MOTION FOR ORDER TO SHOW CAUSE RF.GARO ING IMPROPER ATfEMPT BY BAR
COUNSEL AND. POSSIBLY, NNDB TO DELA Y AND OBSTRUCT HEARING REQUIRED BY
COURTS JUNE 7TH. 2012 ORDER IN CASE 60838 AND COUGHLlN'S SCR 102(4)(d)
PETITION IN CASE 6 1426
COMES :'-JOw. ZACHARY BARKER COUGHLIN. ESQ., and files this limited appearance
o contcst the insufficiency of sen.'ice of process of the SCR 105 Complaint(s) numerated above. and
does not waive any service or jurisiditional deficiencies in hi s ca"e, above named document and
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moves this Board. Panel. Bar. or Court for the relief requested herei n. This filing is further based
- 1.'62MOTION FOR ORDe R TO SI-IOW CAUSE REGARDING I MPROPER ATrCMPT BY BAR COUNSEL AND.
I'OSS IBLY. NNDB TO DELAY AND OIlSTRLJCT HEARING REQU IRED BY COU RTS JUNE. 7TH.201 2 ORDER
IN CASE 60838 AN D COUG HLIN'S SCR I02(4Xd) PETITION IN CASE6 14::!6
02849
02849
upon the papers and pleadings on file herein and in the companion case before the Nevada Supreme
Court in 60838 and 61426.
FACTS
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1. Patrick King, Esq., Bar Counsel of the North, and NNDB Chairman J. Thomas Susich
continue to display an alarming lack of appreciation for due process, basic fairness, and other notions
of fair play and substantial justice...and now seeks to subvert the express ruling of the Nevada
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Supreme Court in its June 7th, 2012 Order by turning the Hearing that has already been set (as
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confirmed by the SBN's Laura Peters, in writing) for September 25th, 2012 into a "due process combo
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pack express package" wherein all the various matters set forth in King's Complain shall also be
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addressed, despite the Order by the Nevada Supreme Court and the text of SCR 111 very clearly
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indicating the "sole purpose" of the hearing will be to determine the punishment for the one criminal
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conviction contained in Bar Counsel's SCR 111 petition of May 10, 2012 in 60838 and where an
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"immediate hearing" is further required in light of Coughlin's SCR 102(4)(d) Petition filed, and
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unopposed by the SBN in 61426.
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2. SBN Clerk of Court of the Laura Peters has assured Coughlin that no service of any SBN v
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Coughlin Complaint has been effected as of this date and that Coughlin is in no danger of defaulting
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for failure to answer any such Complaint. However, Clerk of Court Peters indicated to Coughlin that
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she did not file Coughlin's September 17th, 2012 Motion to Dismiss in light of directions from Bar
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Counsel Patrick O. King, Esq., and further, NNDB Chairman, J. Thomas Susich has made similar
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indications of the extent to which King is attempting to circumvent procedural rules attendant to these
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matters and cause Coughlin further damages and delay, particularly with regard to the dictates of SCR
116. The scheduling of the hearing is the domain of the NNDB and is not to be handed of to the
- 2/62 MOTION FOR ORDER TO SHOW CAUSE REGARDING IMPROPER ATTEMPT BY BAR COUNSEL AND,
POSSIBLY, NNDB TO DELAY AND OBSTRUCT HEARING REQUIRED BY COURTS JUNE 7TH, 2012 ORDER
IN CASE 60838 AND COUGHLIN'S SCR 102(4)(d) PETITION IN CASE 61426
02850
prosecutor here, Bar Counsel Pat King. Peters, King, and Clark have all admitted that King and
Clark are seeking to circumvent the procedural rules and Order related to the scheduling and holding
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of the hearing in response to the Court's June 7th, 2012 Order in 60838 and with regard to the
"immediate hearing" required upon Coughlin's August 13th, 2012 Petition in SCR 61426, which Bar
Counsel has failed to Oppose, and for which, therefore, Coughlin is entitled to the relief he therein
sought, ie, the dissolution of the temporary suspension of his license to practice law.
3. By and Order of the Nevada Supreme Court on June 7th, 2012 Coughlin's constitutionally
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protected property right, his law license, was temporarily suspended: "Pursuant to SCR 111,
temporary suspension and referral to the appropriate disciplinary board are mandatory when an
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attorney has been convicted of a "serious" crime, which includes theft. SCR 111(6)-(8). Accordingly,
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pursuant to SCR 111(8), we refer this matter to the appropriate disciplinary board for the institution of
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a formal hearing before a hearing panel in which the sole issue to be determined shall be the extent
of the discipline to be imposed. Furthermore, pursuant to SCR 111(7), we hereby temporarily suspend
attorney Zachary B. Coughlin from the practice of law in Nevada, pending final disposition of the
disciplinary proceedings."
4. In a written communication from SBN Clerk of Court Laura Peters on July 26th, which
was cc'd to Bar Counsel Patrick King, Clerk Peters wrote: " Mr. Coughlin: I have been contacted by
Tom Susich of the Northern Nevada Disciplinary Board. I understand that you would like to schedule
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a formal hearing in your matter. I have gathered some available dates in September and October let
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me know what will work for you: September 25, 26 or 27 October 15, 16, 17, 18, 30 or 31 Thank you,
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Laura Peters". In an written correspondence from Coughlin to Clerk of Court for the SBN Peters:
"Subject: Hearing... Dear Ms. Peters, Please set the hearing date as soon as possible for any matter
involving me that has been referred to the bar or the disciplinary panel. thanks Zach Coughlin". The
02851
SBN's Peters responded, in writing, on August 17th, 2012, to Coughlin: "RE: Hearing...Zach: How
about September 25th, work for you?". Coughlin responded to Peters, in writing, on August 17th,
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2012: "That works thanks" with a copy of Peter's correspondence of August 17th, 2012 setting forth
the September 25th, 2012 Hearing date. Coughlin wrote to NNDB Chairman J. Thomsas Susich, Esq.
on September 11th, 2012 indicating, in writing: " The hearing is set for... Hearing date... I look
forward to our Hearing on September 25th, 2012. Zach Coughlin".
4.1 Upon information and belief, in early May 2011, prior to any SCR 111 Petition or SCR
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105 Complaint being filed, Bar Counsel violated SCR Rule 121(5) Confidentiality: "5. Temporary
suspension under Rule 102(4). In the event that the state bar files a petition with the supreme court for
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the temporary suspension of an attorney before a formal complaint is filed in the underlying
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petition, then the matter shall become public upon entry of the order granting the petition. If the
court denies the petition, then the matter shall remain confidential until a formal complaint is
filed or the matter is otherwise concluded."
5. On September 11th, 2012, in a telephone conversation with Coughlin, SBN Clerk of Court
confirmed that the hearing previously noticed, set, and schedule for September 25th, 2012 was "still
scheduled" and "on the calendar". During that conversation, Clerk of Court Peters admitted that
"there is a hearing set for the 25th (of September), we set that just on the SCR 111 Petition. Now
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there is a Complaint and I think that Pat and David want to combine it, I didn't know that at the time
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that I set your hearing date." Coughlin then asked Peters "So, the hearing is still set on the
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calendar?". Peters responded "on the calendar it is". Then Peters indicated that "as soon as the
Hearing was set, they (Pat King and David Clark) said 'oh, wait, wait, we want to combine it with the
Complaint's Hearing as well, so they filed a Complaint and I served it on you." when I set your
02852
hearing (for September 25th, 2012), I did not know that David (Bar Counsel David Clark) and Pat
(Pat King) wanted to combine that (hearing on the SCR 111 and SCR 102(4)(d) Petitions in 60838
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and 61426) with a SBN v. Coughlin Complaint the SBN has been threatening to file against
Coughlin)".
6. Bar Counsel King has continually referred to Coughlin, as a "former attorney", often when
speaking directly to Coughlin, and has further mentioned to Coughlin that Coughlin has been
"disbarred", while speaking in a mock devastated tone when mentioning the sadness King would
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himself feel if Coughlin lost his law license, which echoed the venomous chill in the air when David
Clark recalled to Coughlin, regretfully about that one time an attorney committed suicide before Clark
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got a chance to prosecute him, and that regret, to be clear, was due to missing the chance to prosecute
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that attorney prior to the suicide. King is apparently unaware that disbarments were made irrevocable
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in Nevada in 2008 or the fact that one is still "an attorney" during a temporary suspension of one's law
license.
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7. Coughlin appeared at the northern officer the State Bar for the calendared, agreed upon,
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noticed, and set September 25, 2012 Hearing notice to him and the NNDB's Chairman Susich and
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required by this Court's June 7th, 2012 Order and SCR 111(8). While Coughlin sat waiting in the
lobby out walked Clerk of Court Peters and Bar Counsel Patrick King, King holding a stack of papers
then handing them to Clerk Peters, and King whom greeted Coughlin and entere a conversation that
when approximately like this:
King: Zach.
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Clerk Peters: I am supposed to hand you this Complaint.
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King: Your're served (motioning to Clerk Peters to hand Coughlin the stack of papers). You are
officially served. She's the Court Clerk. You're served.
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Coughlin: Aw.. I think one has to be served by a non-party under SCR 109.
02853
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King: No, you're served ,she's the Clerk of Court, so take it. She's serving you, your are officially
served and so I will issue a default judgment against you if you don't accept it.
Peters: I mailed it out.
Coughlin: Is my hearing going to be held right now?
Coughlin: What about my Hearing that's what I'm here for right now.
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Coughlin I think you actually can't serve people when they are showing up for a Hearing.
King yes I can absolutely can,
Coughlin: I have cases that say you can't.
King: I absolutely can things don't go your way because you don't accept responsibility (King grabs
the stack of papers from Peters and attempt to insert them into Coughlin's suit jacket after pulling the
middle button on Coughlin's blazer away from Coughlin's torso, whereupon King gives up on that
approach). I'll drop it at your feet here your served (King bends down and places the stack of papers
on top of Coughlin dress shoes).
Coughlin you are a party though it has to be a non-party that's the law
King: Zach. don't play games!
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Coughlin: It's not a game, Pat, it's the law.
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Peters: Zach, please?
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Coughlin: Where is my hearing?
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King: Hi Paula where you witness that I'm serving or that rather Laura is serving Zach Coughlin with
the Complaint.
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Paula: Sure? (looking bewildered beyond all measure).
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King Here is this, take it, take it, Zach.
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Coughlin: We go to have my hearing today?
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King: First order of business is for you to accept the Complaint
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Coughlin: For you may be Pat, but you're not the one who hasn't had a law license last four months
over a candy bar so
King are going to take the complaint it's a formal complaint I'm been a default you him him. You can
pretend you didn't get it else is take a default
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Coughlin: Pat I filed a motion to dismiss. Seems like you are trying to put Clerk of Court Peters in
kind of a bad spot.
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King No, you haven't filed it it's been rejected,
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Coughlin: By who, the prosecutor? The prosecutor rejected it, Pat?
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King: Listen the Clerk of Court Peters rejected it because it doesn't say what it's dismissing. You are
not even acknowledging that you have been served so take the Complaint and then you can answer it.
You're been served right now
Coughlin: well I guess you're free to argue that, that you a party that is serving me.
King: No, the Court clerk is serving you. Your at the State Bar office being served with a Complaint
Coughlin I I've got cases this the you can serve a criminal defendant when they show up to a civil
proceeding
King: This is State Bar.
Coughlin: Oh, I get it. We're playin' prison rules, huh? Like in that movie The Cable Guy when Jim
Carrey is playing pickup ball and says "Oh, we're playing prison rules" to the guys who just fouled
him so hard? I guess, we are "playin' 'prison rules'" down here at the State Bar, huh? Are we going to
have my hearing today? Because the Hearing is limited in scope and purpose, right?
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King: Zach listen to the Court Clerk.

Coughlin: Okay.
Peters: when you and I talked about the date for September 25 that was a tentative thing I have not
formally notice that I never did
King: Because you did not answer the complaint because you did not answer the complaint by me
explain Mr. Coughlin the suspension that you receive from the Supreme Court which is their order
safety of a problem with the Supreme Court.
Coughlin I did with the SCR 102(4)(d) Petition? Why didn't you answer that, Pat? Now, I win on
that on default, too?
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King: That's the Supreme Court they suspended you pending...pending a disciplinary Complaint
which is what that is (motioning to a stack of papers King had earlier laid at Coughlin's feet).
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Coughlin: So this is a new Complaint filing?
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King know the suspension is pending the disciplinary action that I bring. I have not filed any
disciplinary action they suspended you pending disciplinary action him this is disciplinary and him
(motioning to the stack of papers on the ground).
purpose of determining Mr. Coughlin's punishment for that upon which the SCR 111 Petition was
brought.
King: it does not say that, it says 'pending a disciplinary action by the State Bar'
Coughlin: I am talking about the "hearing before the Disciplinary Panel" under SCR 111(8) and the
Court's June 7th, 2012 Order, that is different than some hearing Under an SCR 105 Complaint. That
the whole import of the language in SCR 111(8), which the Court quotes exactly in its June 7th, 2012
Order for Temporary Suspension of Law License where it reads, "the supreme court shall"..."refer the
matter to the appropriate disciplinary board for the institution of a formal hearing before a hearing
panel in which the sole issue to be determined shall be the extent of the discipline to be imposed".
02855
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King: Listen to me, I am trying to help you. That Complaint (pointing at the stack of papers on the
ground) is the Complaint that we will have the Hearing on...
Coughlin: We are having a Hearing today, and if we don't, you default, and I get my license back.
King: If you answer that Complaint, then..you will have the right to appear at a Hearing and argue
your case to the Disciplinary Panel. If you do not file a Verified Answer to the Complaint, then we
will move forward, and proceed on a default basis, and the Panel may accept every allegation in the
Complaint as true.
Coughlin: So you refused to file the Motion to Dismiss I submitted for filing?
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King: What Motion to Dismiss?

Coughlin: The one Clerk Peters said you told her not to file.
King: I didn't tell...I don't tell the Court Clerk what to do...
Coughlin: I sent it to you Pat. What Motion to Dismiss?
King: What are you asking to be dismissed? It doesn't say what you are asking to be dismissed. You
can't have it both ways, Zach.
Coughlin: Pat, do you have a case number,? Do you have a case number on that, on that, Pat?
King: Pick it up and read it. Pick it up and read it.
Coughlin: I can wait around her a little while longer for you to get my Hearing going, but at some
point I think I would be justified in assuming you are refusing to proceed with or hold the Hearing
you set and noticed, so...you might want to get Chairman Susich or somebody down here and get this
Hearing, here, happenin', Pat.
LAW AND LEGAL ARGUMENT
A state cannot exclude a person from the practice of law in a manner or for reasons that
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contravene the due process or equal protection clauses of the Fourteenth Amendment. 105. Due
process requirements; notice and opportunity to be heard
An attorney is entitled to due process in disciplinary proceedings concerning his or her
conduct.[FN1] Due process in disciplinary proceedings requires that the attorney be given notice of
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the proceeding and an opportunity to defend at a hearing, and that the proceeding be essentially fair.
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[FN2] Due process requires that, in an attorney disciplinary proceeding, the attorney must be notified
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of clear and specific charges and must be afforded an opportunity to anticipate, prepare, and present a
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02856
defense.[FN3] The precise procedural protections of due process vary, depending upon the
circumstances, because due process is a flexible concept unrestricted by any bright-line rules.[FN4]
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An attorney is not denied due process where he or she voluntarily leaves the hearing with full
knowledge that the proceedings will continue in his or her absence.[FN5] There is no denial of due
process where an attorney is served with a complaint and requests for admissions before the bar files
the complaint in the supreme court where the rules do not require that the complaint be filed before it
is served.[FN6] In addition, an attorney's due process rights are not violated, even though the attorney
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is not allowed to attend a grievance committee meeting, if the attorney is served with notice of the
bar's charges and is afforded an opportunity in the disciplinary hearing to be heard.[FN7]
A statute providing for automatic disbarment of an attorney for conviction of an offense involving
moral turpitude does not violate due process if the attorney has notice of the disbarment proceedings,
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and is able to present his or her position to the board on professional responsibility and argue that his
or her crimes did not involve moral turpitude.[FN8]
What is important is that the disciplinary board's recommendations put the attorney on notice of the
charges he or she must answer to the satisfaction of the court.[FN9] As to the discipline imposed, due
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process requires that an attorney facing discipline be permitted to explain the circumstances of the
alleged offense and to offer testimony in mitigation of any penalty
to be imposed.[FN10]
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Where the evidence at the hearing discloses misconduct not charged in the original notice, the bar
25
may move to amend the notice to conform to the proof, but if no such motion is made, the attorney
26
may be disciplined only for the misconduct alleged in the original notice.[FN11]
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02857
An attorney may be temporarily suspended without a pre-suspension hearing where the risk of
erroneous deprivation is minimized by provisions allowing the attorney to continue his or her existing
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practice for a specified time and allow for immediate hearing and prompt resolution of the matter.
[FN12]
Due process requires a court to provide notice and opportunity to be heard to an attorney prior
to imposing a lifetime ban on the attorney's pro hac vice status in the court's local division.[FN13]
8
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Attorney suspended from practice of law was not deprived of due process by state court
10
disciplinary procedure, as would warrant imposition of different discipline in reciprocal discipline
11
proceeding, for attorney's ethics violation in misleading lower court in underlying inheritance action
12
by filing motion to withdraw funds consigned in lower court for client, but failing to disclose that
13
client had died and misstating that there were no minors involved, since attorney had full notice and
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opportunity to be heard in state court disciplinary proceeding. In re Oliveras Lopez De Victoria, 561
F.3d 1 (1st Cir. 2009).
Attorney was not denied due process at presentment before trial court in disciplinary
proceeding by admission of complainant's testimony at earlier hearing before reviewing committee;
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complainant was unavailable, and attorney had a full and fair opportunity to and in fact did cross
21
examine complainant at hearing before review committee. Statewide Grievance Committee v.
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Johnson, 108 Conn. App. 74, 946 A.2d 1256 (2008), certification denied, 288 Conn. 915, 954 A.2d
23
187 (2008).
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Attorney was properly notified of disciplinary proceeding, and the Supreme Court had jurisdiction to
26
proceed, where hearing notification was sent by both regular and certified mail to attorney's last
27
address on file with the Clerk of Appellate Courts and both mailings were returned, marked "not
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02858
deliverable as addressed," and same notice was mailed to Colorado address that attorney had listed in
a responsive pleading in a prior disciplinary action, and that notice was also returned, marked "return
to sender." Sup.Ct.Rules, Rule 215. In re Lober, 241 P.3d 81 (Kan. 2010).
4
5
Attorney had no due process right to jury trial in discipline proceeding, even though license to
practice law was a property right. U.S.C.A. Const.Amend. 14. In re Gargano, 460 Mass. 1022, 957
N.E.2d 235 (2011).
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9
Supreme Court observes due process in exercising disciplinary jurisdiction over an attorney, but
10
disciplinary proceedings are not encumbered by technical rules and formal requirements. U.S.C.A.
11
Const.Amend. 14. In re Disciplinary Action against Garcia, 792 N.W.2d 434 (Minn. 2010).
12
Attorney's conviction for two misdemeanor counts of theft warranted immediate suspension of
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attorney's license under disciplinary rule authorizing immediate suspension pending final disposition
15
of disciplinary proceeding predicated upon conviction for serious crime. In re Disciplinary Action
16
Against Fisher, 2008 ND 151, 754 N.W.2d 802 (N.D. 2008).
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19
The standards of due process in an attorney disciplinary proceeding are not equal to those in a
criminal matter. Disciplinary Counsel v. Heiland, 116 Ohio St. 3d 521, 2008-Ohio-91, 880 N.E.2d
20
467 (2008). [FN1] The Florida Bar v. Carricarte, 733 So. 2d 975 (Fla. 1999). [FN2] Bradley v.
21
Fisher, 80 U.S. 335, 20 L. Ed. 646, 1871 WL 14737 (1871); Jaen v. Coca-Cola Co., 157 F.R.D. 146,
22
31 Fed. R. Serv. 3d 178 (D.P.R. 1994). [FN3] In re Disciplinary Proceeding Against Marshall, 160
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Wash. 2d 317, 157 P.3d 859 (2007). [FN4] Steinert v. Winn Group, Inc., 440 F.3d 1214 (10th Cir.
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2006). [FN5] Colangelo v. State Bar, 53 Cal. 3d 1255, 283 Cal. Rptr. 181, 812 P.2d 200 (1991).
26
[FN6] The Florida Bar v. Daniel, 626 So. 2d 178 (Fla. 1993). [FN7] The Florida Bar v. Committe,
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916 So. 2d 741 (Fla. 2005), cert. denied, 547 U.S. 1098, 126 S. Ct. 1890, 164 L. Ed. 2d 569 (2006).
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02859
[FN8] In re Krouner, 920 A.2d 1039 (D.C. 2007). [FN9] Zauderer v. Office of Disciplinary Counsel
of Supreme Court of Ohio, 471 U.S. 626, 105 S. Ct. 2265, 85 L. Ed. 2d 652 (1985). [FN10] The
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7
8
9
10
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12
13
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Florida Bar v. Carricarte, 733 So. 2d 975 (Fla. 1999). [FN11] Edwards v. State Bar, 52 Cal. 3d 28,
276 Cal. Rptr. 153, 801 P.2d 396 (1990). [FN12] In re Lamm, 116 N.C. App. 382, 448 S.E.2d 125
(1994), decision aff'd, 341 N.C. 196, 458 S.E.2d 921 (1995). [FN13] Lasar v. Ford Motor Co., 399
F.3d 1101 (9th Cir. 2005), cert. denied, 546 U.S. 873, 126 S. Ct. 381, 163 L. Ed. 2d 167 (2005).
SCR Rule 119. Additional rules of procedure.
1. Record. The record of a hearing shall be made available to the attorney at the attorneys expense
on request made to bar counsel. Willner v. Committee on Character and Fitness, 373 U.S. 96, 83
S. Ct. 1175, 10 L. Ed. 2d 224, 2 A.L.R.3d 1254 (1963).
2. Time limits not jurisdictional. Except as is otherwise provided in these rules, time is
directoryand not jurisdictional. Time limitations are administrative, not jurisdictional. Failure to
observe directory time intervals may result in contempt of the appropriate disciplinary
board or hearing panel having jurisdiction, but will not justify abatement of any disciplinary
investigation or proceeding.
15
3. Other rules of procedure. Except as otherwise provided in these rules, the Nevada Rulesof Civil
Procedure and the Nevada Rules of Appellate Procedure apply in disciplinary cases.
16
The undersigned (Coughlin) submitted to the Supreme Court of Nevada's electronic filing
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system an Opposition to Bar Counsel's petition on or about May 24th, 2012, as an original matter
given the online system would not allow filings in the case itself (60838). The Clerk's Office
refused to file, mark as received, or, apparently, in any way make the Justices of this Court away of
the Opposition. Only after the undersigned reputation has been sullied by news outlets far and wide
22
(an article appeared in papers in at least three different cities, separated by the vast expanse of our
23
state) did the Clerk's Office allow Coughlin to file something in an attempt to tell his side of the
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story here and avoid the prejudice that would be done his child custody, foreclosure defense,
bankruptcy, and other other clients should Coughlin's law license be suspended, even temporarily..
SERVICE AND FILING OF PLEADINGS AND OTHER PAPERS....NRCP 5(e), Filing With the
02860
Court Defined: The filing of pleadings and other papers with the court as required by these rules
shall be made by filing them with the clerk of the court....The clerk shall not refuse to accept for
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6
filing any paper presented for that purpose solely because it is not presented in proper form
as required by these rules or any local rules or practices. NRCP 5(e).
Coughlin is not
accused of stealing $755,000 candy bars from a client yet he was temporarily suspended and his
suspension has now lasted over four months. Only after the undersigned reputation has been sullied
by news outlets far and wide (an article appeared in papers in at least three different cities, separated
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by the vast expanse of our state) did the Clerk's Office allow Coughlin to file something in an
attempt to tell his side of the story here and avoid the prejudice that would be done his child
custody, foreclosure defense, bankruptcy, and other other clients should Coughlin's law license be
suspended, even temporarily...
It is the official duty of the clerk of a court to record (Nash v. Campbell County Fiscal
Court, 2011 WL 1620587 (Ky. 2011). [FN2] ) or file all the papers in a cause presented by the
parties, and to indorse the correct date of the filing on them. Estate of Johnson v. Ciarpelli, 71
18
A.D.3d 1482, 896 N.Y.S.2d 752 (4th Dep't 2010); In re Simmonds, 271 S.W.3d 874 (Tex. App.
19
Waco 2008)The duty is purely ministerial (Benson v. District Clerk, 331 S.W.3d 431 (Tex. Crim.
20
21
App. 2011) (writ of habeas corpus) and the clerk may not refuse to perform except on the order
of the court. Cave v. Elliott, 190 Md. App. 65, 988 A.2d 1 (2010); In re Smith, 270 S.W.3d 783
22
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(Tex. App. Waco 2008).

It is important to note that Coughlin has already had a very important attempted filing
rejected by the Clerk of the Supreme Court of Nevada, and now Bar Counsel Patrick King, Esq. is,
according to Clerk of Court of the State Bar of Nevada, Laura Peters, telling her not to file somethign
Coughlin has submitted for filing.
02861
Further, Coughlin served his SCR 102(4)(d) Petition in SCR 61426 and his SCR111(10)
1
2
3
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5
6
Motion to Dissolve Temporary Suspension upon both Bar Counsel for the North, Patrick King and
Bar Counsel for all of Nevada and the main Southern Office of the SBN, David Clark on August
13th, 2012, with both consenting to waive any personal service by a non party rule under SCR 109,
and further, where Clerk of Court Laura Peters signed a "Notice of Receipt" of those documents that
also bore a heading that it was a "Proof of Service". See attached in Exhibit 1. So, the SBN wants to
deem Peters "not a party" sufficient to serve Coughlin with something requiring personal service, but
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12
does not want Peters to be deemed "a party" sufficient that her signature attesting to a "Notice of
Receipt" effectuates any SCR 102(4)(d) requirement that a "Petition shall be served on Bar
Counsel"? Or, the SBN has just failed to timely respond to Coughlin's August 13th, 2012 SCR
13
102(4)(d) Petition in 61426 and his SCR 111(10) Motion to Dissolve Temporary Suspension in
14
60838, both served on the SBN and NNDB Chairman J. Thomas Susich that very day, August 14th,
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2012.
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Rule 104(3). State bar counsel....

3. A grievance against bar counsel or bar counsels staff shall be investigated at the direction
of the president of the state bar and heard by the board of governors. A decision of the board of
governors against bar counsel may be appealed to the supreme court under the Nevada Rules of
Appellate Procedure.
SCR 105(2):. Commencement of formal proceedings. Formal disciplinary proceedings are
commenced by bar counsel filing a written complaint in the name of the state bar. The complaint
shall be sufficiently clear and specific to inform the attorney of the charges against him or
her and the underlying conduct supporting the charges. A copy of the complaint shall be
served on the attorney and it shall direct that a verified response or answer be served on bar
counsel within 20 days of service; the original shall be filed with bar counsels office. The time to
respond may be extended once by the chair for not more than 20 days for good cause or upon
stipulation of the parties. In the event the attorney fails to plead, the charges shall be deemed
admitted; provided, however, that an attorney who fails to respond within the time provided may
thereafter obtain permission of the appropriate disciplinary board chair to do so, if failure to file is
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02862
The SBN has admitted, via Clerk of Court Laura Peters, that not only has the SBN
agreed to and already set for hearing the referral to the Board called for in the Nevada Supreme
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Courts June 7th, 2012 Order Temporarily Suspending Coughlins License to Practice Law, but also
that any SBN v. Coughlin Complaint Bar Counsel Pat King wishes to throw together at the last
minute in an attempt to skirt the limits of the jurisdiction granted the Board in the Courts June 7th,
2012 Order, given Kings stated intention to attempt to make a combo-hearing out of the Hearing
called for in that Order, despite its sole purpose language and the same found in SCR 111(8), in
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addition to the fact that given Coughlins Petition in 61426, under SCR 102(4)(d), requires an
immediate hearing, and that Petition was duly served on August 13th, 2012, both on the Board via
Chairman Susich and both offices of the SBN, via Clark and King, and Peters personal receipt
13
thereof, which the SBN has still failed to respond to (much less challenge the reconsideration motion
14
in 60383, etc. (who is talking about whos competence, again?)...
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17
Further, it is a virtual certainty, given Pat Kings established modes., that any such
Complaint he files, upon it being properly served and not insufficient due to illegibility of the
18
photocopies of any exhibits (take it from me given 60302 and 60317, I know...) will be wholly
19
insufficient in that it will in no way comply with SCR 105(2), and so, as a preemptive measure,
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please be advised that any such Complaint ought take particular care to state who brought what
grievance, and avoid conclusory assertions about something lacking legal merit or otherwise
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broadly demonstrating incompetence.

Further, any assertions by the SBN that sending such a Complaint via certified mail,
especially where a phone call to SBN Clerk of Court Peters on September 14th, 2012 yield her giving
Coughlin the SBNs word that given the SBNs apparent attempt to serve Coughlin via Certified
mail some Complaint Pat King apparently followed through on in his promise to thrown together
02863
haphazardly in hopes of defeating any due process accorded the hearing on September 25th, 2012,
would not require a response at least until the SBN receives back as unclaimed some second
attempted certified mailing under SCR 109.
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5
Proceedings instituted a long time after the commission of the act complained of are
regarded with disfavor. In re Bridwell, 25 Utah 2d 1, 474 P.2d 116 (1970). Bar Counsel is
purportedly, and ever so conveniently seeking delay Coughlins procedural rights to a hearing on the
temporary suspension of his law license (which has already lasted longer than the NNDBs
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punishment for an attorney who admitted to misappropriating about 755,000 candy bars, from his
clients, during the course of his duties as an attorney rather than, allegedly, on a Saturday night at a
12
Wal-Mart an in no way connected to the practice of law, and under circumstances that indicate the
13
conviction stemmed from a proceedign wholly devoid of due process, and where the appeal thereto
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was improperly dismissed based upon a failure of the RMC to order the transcripts produced within
10 days (the District Court cited to a civil statute in blaming Coughlin for failing ot point to a
transcript in his Appeal Brief where the RMCs practice of demanding indigent defendants use one
and only one court approved transcriptionist and pay her up front is violative of Nevada law.
Since it is essential that the bar and the public perceive the process of the discipline of an
attorney as fair, orderly, and rational, and implicit in this perception is the timely and efficient
resolution of complaints. In re Grossman, 448 Mass. 151, 859 N.E.2d 423 (2007). A delay in
23
bringing disciplinary proceedings against an attorney it is to be placed into context as a
24
mitigating factor to be balanced against a number of aggravating factors. In re Disciplinary
25
Proceeding Against Boelter, 139 Wash. 2D 81, 985 P.2d 328 (1999).
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02864
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The purpose of the attorney disciplinary process is not to punish the offender[FN4] but to
protect the public. Attorney Grievance Com'n of Maryland v. Goff, 399 Md. 1, 922 A.2d 554 (2007),
reinstatement granted, 2007 WL 2128391 (Md. 2007). The principal reason for attorney discipline is
to preserve the confidence of the public in the integrity and trustworthiness of lawyers in general. In
re Scanio, 919 A.2d 1137 (D.C. 2007) Attorney discipline is designed to protect the public, the legal
profession, and the legal system and to deter other attorneys from engaging in unprofessional
conduct. In re Non-Member of State Bar of Arizona, Van Dox, 214 Ariz. 300, 152 P.3d 1183
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(2007). Thus, the judgment of a disciplinary proceeding must be fair to the attorney. The
Florida Bar v. Cox, 718 So. 2d 788 (Fla. 1998).
12
The purpose of the temporary suspension of a lawyer is more than disciplinary; it is also
13
intended to prompt a response to the board's inquires so the disciplinary action may proceed in a
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timely and informed fashion. Iowa Supreme Court Attorney Disciplinary Bd. v. Fields, 790 N.W.2d
791 (Iowa 2010).
Upon information and belief, in early May 2011, prior to any SCR 111 Petition or SCR 105
Complaint being filed, Bar Counsel violated SCR Rule 121(5) Confidentiality: "5. Temporary
suspension under Rule 102(4). In the event that the state bar files a petition with the supreme court
for the temporary suspension of an attorney before a formal complaint is filed in the underlying
23
petition, then the matter shall become public upon entry of the order granting the petition. If the court
24
denies the petition, then the matter shall remain confidential until a formal complaint is filed or the
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matter is otherwise concluded." In early May 2012 Coughlin received a disturbing phone call from a
client wherein the exact same information regarding some purported "taking away your right to
practice in (REDACTED) Court" was mentioned by the client, despite not such deprivation of
02865
Coughlin's right to practice in said (REDACTED) Court ever being mentioned by anyone other than
Bar Counsel Pat King (whom referenced such a non-existent Order to Coughlin and Chief Bar
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6
Counsel David Clark during an informal three hour meeting Coughlin had with those Bar Counsel in
Reno on August 13th, 2012, while serving the SCR 102(4)(d) and SCR 111(10) filings by Coughlin).
King is simply wrong, recklessly and negligently so, and in violation of SCR 111. King needs to
stop behaving like a fall semester freshman high school girl with no self esteem taken by every
letterman walking past her wearing a football jersey to school on a Friday game day, eager to be
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12
accepted by the "in crowd" with the "juice" in Nevada legal circles (and overly willing to be used for
even the most loathsome of chores, like, say a SCR 117 Petition for a Judge whom had Coughlin
arrested for "criminal summary contempt), and, rather, faithfully uphold the duties of his Office, as
13
the integrity of the legal profession in this State requires it. No such "Order" was ever entered by the
14
(REDACTED) Court, and it is obvious that King had improper communications with Coughlin's then
15
client.
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17
Such an anticipated SBN v Coughlin SCR 105 Complaint, according to King, will be based
18
largely upon Coughlin allegedly wearing "pajama bottoms" to the Reno Municipal Court filing
19
counter one day while inquiring about a parking ticket or some other non-sensensical high school
20
21
jibberish, will contain more of the same reckless and lacking in foundation mentions of "breaking
into" the former law office and "broken locks" despite the fact that no factual support exists for such
22
23
an allegation, there were no "broken locks" ever mentioned by anyone (and if Hill is willing to make
24
up finding a "bag of weed and crack pipe" along with describing what Hill's own videos show to be
25
vitamins as a "large quantity of pills", then you know Richard G. Hill, Esq. would have been all over
26
any "broken locks" at the former home law office, yet, there simply were none, not that that would
27
28
stop Pat King or J. Thomas Susich from cobbling together such an allegation in the SCR 117 Petition
02866
in 60975) along with something about Coughlin being subject to a custodial arrest for "jaywalking"
by the Reno Police Department while Coughlin was filming Richard G. Hill, Esq.'s contractor's crew
3
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6
loading up a dump truck with items of personal property then located in Coughlin's former home law
office (the arrest occurred shortly after Coughlin discovered that Hill's contractor, Phil Stewart, had
used Coughlin's own distinctive plywood to "secure" or "board up the property" in December 2011,
for which the landlord was ultimately awarded costs, $1,060 of which were based upon Stewart's
invoice for "securing the property", which included the cost of plywood, and "fixing a leak in the
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12
basement" despite NRS 118A.460 only allowing costs for "moving, storing, and inventorying" a
tenant's personal property), which Coughlin was unable to remove during the scant 13 hours he was
afforded to do so by the Reno Justice Court's Order following a Hearing on Coughlin's November
13
16th, 2011 Motion to Contest Personal Property Lien (the Hearing was not set or conducted with the
14
"10 days" required by NRS 40.253(7)-(8) because Richard G. Hill, Esq. needed to go on a six-week
15
vacation shortly after Coughlin's November 16th, 2011 filing (in a matter now on appeal in SCR
16
60331 and 61838, wherein, somehow, a commercial tenant, Coughlin (whom was both running a law
17
18
practice and Coughlin Memory Foam, a foam mattress business from his home, which was
19
previously utilized for commercial purposes by a drug and alcohol rehabilitation counseling business
20
and is zone for mixed use purposes) was summarily evicted based upon a No Cause Eviction Notice
21
only (ie, the non-payment of rent was neither noticed, pled, nor argued by the landlord) despite the
22
clear dictate against the use of summary eviction proceedings against commercial tenants not based
23
24
upon the non-payment of rent (Bench Book stuff) set forth in NRS 40.253. The December 21st,
25
2011 Order "Resolving" Coughlin's Motion to Contest Personal Property Lien actually required
26
Coughlin to pay the exact same amount of rent for 17 days (November 1 to November 17th, 2011),
27
$480 (ie, pro-rated from the $900 per month rental agreement) as Coughlin would have under a "fair
28
02867
rental value", for the "full use and occupancy of the premises" despite the fact that Hill somehow
signed a Criminal Complaint for Trespass Against Coughlin, on November 13th, 2011 despite any
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6
Summary Eviction Order not being served in accordance with NRS 40.400 (and therefore NRCP 5
and 6(e) vis a vis the "within 24 hours" of "receipt" of the lockout order, and, therefore, any such
lockout that had occured being rendered a nullity or pursuant to a void Order) and where the Washoe
County Sheriff's Office Civil Process Service Supervisor Liz Stuchell has admitted in writing that the
Affidavit of Service filed November 7th, 2011 by Deputy Machen, attesting to having "personally
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12
served" the Summary Eviction Order on November 1st, 2011, was, in fact, purportedly merely posted
to the door of Coughlin's former law office while Coughlin was not home, at which point a Soldal v.
Cook County violating illegal lockout occurred. In a February 7th, 2012 written correspondence to
13
Coughlin, Stuchell wrote: "Mr. Coughlin, Our records indicate that the eviction conducted on that
14
day was personally served by Deputy Machen by posting a copy of the Order to the residence. The
15
residence was unoccupied at the time. Liz Stuchell, Supervisor WCSO Civil Section".
16
The text of
NRS 40.253 speaks to service of Lockout Orders: The court may thereupon issue an order directing
17
18
the sheriff or constable of the county to remove the tenant within 24 hours after receipt of the
19
order... is inapplicable to this situation, where an Order Granting Summary Eviction was signed by
20
October 27th, 2011 (though not mailed to Coughlin until after the November 1, 2011 lockout had
21
allegedly already occured). That language is only found in situations inapplicable to the one incident
22
that in the summary eviction from Coughlin's former home law office. NRS 40.253(3)(b)(2), and
23
24
NRS 40.253(5)(a) are the only sections of NRS 40 where this within 24 hours language occurs, and
25
those situations only apply where, in: 40.253(3)(b)(2): 3. A notice served pursuant to subsection 1
26
or 2 must: ...(b) Advise the tenant: . (2) That if the court determines that the tenant is guilty of an
27
unlawful detainer, the court may issue a summary order for removal of the tenant or an order
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02868
providing for the nonadmittance of the tenant, directing the sheriff or constable of the county to
remove the tenant within 24 hours after receipt of the order and, 40.253(5)(a): 5. Upon
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5
6
noncompliance with the notice: (a) The landlord or the landlords agent may apply by affidavit of
complaint for eviction to the justice court of the township in which the dwelling, apartment, mobile
home or commercial premises are located or to the district court of the county in which the dwelling,
apartment, mobile home or commercial premises are located, whichever has jurisdiction over the
matter. The court may thereupon issue an order directing the sheriff or constable of the county to
9
10
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12
remove the tenant within 24 hours after receipt of the order. The way these summary eviction
proceedings are being carried out in Reno Justice Court presently shocks the conscience and violates
Nevada law. There is not basis for effectuating a lockout the way WCSO's Deputy Machem did in
13
this case. The requirements attendant to serving Summary Eviction Orders and conducting lockouts
14
are found in NRS 40.253 in two sections containing the within 24 hours of receipt language are
15
inapplicable, as those situations do not invoke the present circumstances, where the Tenant did file
16
an Affidavit and did contest this matter to a degree not often seen. To require Nevada's tenants to get
17
18
up and get out within 24 hours of receipt of the order (what does that even mean? The use of
19
terms like rendition, rendered, notice of entry, pronounced, is absent here, and this receipt
20
of the order language is something rarely found elsewhere in Nevada law-see attached DMV
21
statutory citations, and in employment law litigations where one must file a Complaint within 90
22
days of receipt of a Right To Sue Letter, a situation which follows NRCP 5(b), and NRCP 6(e) in
23
24
imputing receipt of such a letter, when actual receipt is not shown, by applying a constructive
25
notice standard that relies upon the days for mailing extension of time for items served in the
26
mailing, etc.). In Abraham v. Woods Hole Oceanographic Institute, 553 F.3d 114 (1st Cir. 2009), the
27
record did not reflect when the plaintiff received his right-to-sue letter. The letter was issued on
28
02869
November 24, 2006. The court calculated that the 90-day period commenced on November 30, 2006,
based on three days for mailing after excluding Saturdays and Sundays. In order to bring a claim
3
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5
6
under either Title VII or the ADA, a plaintiff must exhaust administrative remedies and sue within 90
days of receipt of a right to sue letter. See 42 U.S.C. 2000e-5(f)(1). See Baldwin County Welcome
Center v. Brown, 466 U.S. 147, 148 n.1, 104 S.Ct. 1723, 80 L.Ed.2d 196 (1984) (granting plaintiff an
additional three days for mailing pursuant to Rule 6).... Further, as seen in the Anvui case, there is
some argument respecting not effecting a lockout for at least 5 days where a lease has not expired by
its terms, as Coughlin's arguably had not.
10
11
However, in his January 20th, 2012 Second Motion for Order to Show Cause, Richard G.
12
Hill, Esq. did not get all bogged down in legal research and stuff, instead he just pointed out:
13
"FACTS SHOWING CONTEMPT OF COURT 6. EXHIBIT 1 (the Summary Eviction Lockout
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17
Order) was served on Coughlin on November 1, 2011 by the Washoe County Sheriffs Department
in its customary manner, by posting same on the front door of the property in the manner
customary for evictions in Washoe County. The locks to the premises were changed at that time,
18
thereby ejecting and dispossessing Coughlin of possession of the Property." Hill went on to lie again
19
in that January 20th, 2012 Motion when he equated his offer to let Coughlin get some of the
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21
personalty Coughlin was unable to remove, due largely to Hill failing to remove the chain link
padlock from the backyard gate that Hill had only just installed in time for the 13 hours Coughlin had
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23
to remove his property in exchange for Coughlin waiving his rights to the $700 damage deposit
24
Coughlin provided upon moving in, where Hill spins it: "12. On Friday, December 23, 2011,
25
Coughlin had a crew of helpers, and made progress. Nonetheless, Coughlin failed to remove all of
26
his belongings from the Property. Coughlin failed to remove his things despite having been given
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additional time to do so after the time set by the Reno Justice Court in its order of December 21,
02870
2011 (EXHIBIT 2) had expired." Apparently, to Hill, at least one has " failed to remove all of his
belongings from the Property. Coughlin failed to remove his things despite having been given
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additional time to do so" where Hill threatens to have one arrested for criminal trespass or larceny (of
their own stuff, arguably) if one is on the property one minute past 5 p.m., unless one waives any
right to their damage deposit (which neither Hill nor the Landlord eve did return, nor did they
comply with the requirement that they provide an itemized statement indicating an application
thereof justifying such a failure to return such deposit within 30 days....and Hill does not want to get
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into whether his conduct is violative of the FDCPA or whether he is licensed a as debt collector). In
that Motion, Hill continued on: "13. On December 30, 2011, Coughlin moved this Court for a
temporary restraining order to prevent Merliss from disposing of the items he (Coughlin) had
13
abandoned on the Property. Coughlin's motion was fully briefed, and the Court entered its order
14
denying the motion on January 11, 2012. A true and correct copy of this Court's January 11,2012
15
order is attached hereto as EXHIBIT 3. 14. On Thursday, January 12, 2012, in accordance with
16
EXHIBIT 2 and EXHIBIT 3, a licensed contractor hired by Merliss began cleaning up the Property
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and disposing of the abandoned items still remaining there. 15. Early that afternoon, while the
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contractor was hauling the first of several loads of abandoned property to the transfer station (dump)
20
for disposal, Coughlin stopped the contractor in traffic and attempted to prevent him from carrying
21
out his task. 16. Specifically, Coughlin stood in front of the contractor's vehicle in an effort to
22
prevent him from proceeding to the transfer station. Coughlin threatened to sue the contractor.
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Coughlin climbed up on the contractor's vehicle. Coughlin then called the police and falsely told
25
them that the contractor had stolen his possessions, and that the contractor had tried to run him over.
26
Coughlin's acts were specifically calculated to prevent the contractor from disposing of the
27
abandoned property, and to frustrate and interfere with Merliss' compliance with this Court's January
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02871
11, 2012 order. 17. When Mr. Hill of the undersigned's office was notified of the foregoing, he went
to the transfer station and presented EXHIBIT 2 and EXHIBIT 3 to the police. The contractor was
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then allowed to proceed. 18. However, before the contractor could return to the River Rock Property,
Coughlin was there. He had his video camera and was walking up and down the street screaming and
yelling at the police, the contractor, and Mr. Hill, once Mr. Hill arrived. At the instruction of the
police, Mr. Hill then obtained a temporary protective order ("TPO") again~t Coughlin from the Reno
Justice Court. Coughlin ended up being arrested and taken to jail that day as a result of his antics at
the transfer station and the Property."
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The thing is, and Coughlin would sure like to get the 911 tapes (or, more likely, with Hill, any
12
recordings that may exist of Hill calling somebody in particular he may have had in mind with the
13
RPD) of calls by Coughlin (and if Wal-Mart can call 911 over a candy bar, or a skater board over an
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iPhone he seems to have set down on the concrete ground in downtown Reno, then skaterboarded off
some 100 yards away for sufficiently long period of time to seem to have been pretty much the only
person not to have heard somebody who picked it up threaten to throw it is in the river if it went
18
unclaimed can call 911 (and make up a bunch of lies on the spot for the purpose of manipulating the
19
police into assuages the skateboarders own negligence vis a vis the iPhone) is it unreasonable for
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Coughlin to call 911 upon happening, totally by chance, to cross paths with Hill's contractor while
driving, catching site of a huge dump truck full of Coughlin's personal property headed towards the
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town dump? Hill admits the Order denying Coughlin's Motion for a TPO (and hey, family heirlooms
24
are pretty fungible, right? Who needs a TPO for that? And its not like the landlord could just accept
25
rent in the meantime, or that the property still remains unrented to this day, some 11 months after the
26
lockout, and apparently, some $60,000 worth of attorney's fees paid to Hill for a two bedroom home
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that appraises at around $90,000 currently, if that. And Hill's fantastic legal work ("wrong site
02872
surgery" and all) was surely worth the risk of a wrongful eviction lawsuit (and check out those
potential damages under Winchell v. Schiff, 124 Nev. 938, 193 P.3d 946 (2008), not that the loss of a
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patent attorney's career could amount to all that much). Regardless, its not all that colorable for Hill
to allege Coughlin was violating some Order entered on January 11th, 2012 by Coughlin's conduct of
January 12th, 2012 when NRCP 6(e) provides that 3 days for mailing is to be accorded to account for
the service of filings, even filings electronically served on registered efilers like Coughlin. Its
similar to Hill wanting a criminal trespass arrest where NRCP 6(e)'s three days for mailing where no
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personal service was accomplished (by way of NRS 40.400) and Hill's et al did not even comply with
the constructive service requirements of mailing the summary eviction lockout order prior to Hill's
breaking into Coughlin's former home law office on November 1st, 2011, with the help of the
13
WCSO, in violation of Soldal v. Cook County where Coughlin was not accorded the "24 hours"
14
cushion after Coughlin's "receipt" of the lockout order mentioned in this Court's own packets on the
15
service of Lockout Orders, which Hill himself attached as a subsequent exhibit recently...It gets
16
funnier. The civil division of the Justice Court and the Sheriff's Office think that whole "within 24
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hours" language in NRS 40.253 means "within 24 hours" of the Sheriff's "receipt" of the Order from
19
the Justice Court...While other's think it is "within 24 hours" of the tenant's receipt of the Order from
20
the Sheriff...and this Court's official forms and instructions seem to imply that "at least 24 hours"
21
from "receipt" of the lockout Order must be accorded to a tenant. Who knows? But, it is not clear,
22
as Hill suggests, that the "usual custom and practice of the Washoe County Sheriff's Office" is black
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letter law upon which Bar grievances, custodial criminal trespass arrests, multiple Motion for Order
25
To Show Cause, tens of thousands of dollars in attorney's fees sanctions against a pro se appellant,
26
etc. are warranted. Somehow the District Court found a way to sanction Coughlin with $40,050
27
worth of attorney's fee in that appeal of the summary eviction without holding a single hearing, well,
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02873
other than the Hearing on Hills Order to Show Cause, which was denied when Coughlin destroyed
Hill's contractor Phil Stewart on cross-examination. (Really, Phil? Really? You could fell "a
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depression" in your 2 ton loaded to capacity dump truck upon Coughlin allegedly "climbing up on
it", though you indicated you had already "alighted from the vehicle", but, wait, you could see
Coughlin's head above the tailgate walls in your rear view mirror (which doesn't seem to be there on
any the many videos of the events of that day. And even if such a mirror where present on Stewart's
truck, that doesn't really explain how all the personalty stacked up so high in the truck bed (replete
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with specialized add-on high stack retaining walls) wouldn't obscure any purported view of
Coughlin's head high above the area above the specialize hydraulic dump truck's tailgate, confirming
Stewart's mere suspicion that Coughlin climbed on his truck. Coughlin swears under oath he did not
13
climb on Stewart's truck. Hill needed a little "fact" to spice up his Motion to Show Cause just
14
enough, and "Coughlin climbed up on the truck" was "just the ticket", and Stewart did not mind
15
going along for the ride, so long as... And none of the many videos from that day actually show any
16
of the Yosemite Sam cartoon villian type behavior Hill attributes to Coughlin in his wonderfully
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imaginative Motion for Order to Show Cause and or Application for Order of Protection concerning
19
the events involved in the jaywalking custodial arrest Hill had Coughlin subjected to on January
20
12th, 2012.
21
Much like Hill's contractor, Phil Stewart, flat out lying in an affidavit when he swore
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23
Coughlin "climbed up on" his truck, Hill similarly lied in an affidavit about Coughlin, apparently
24
while "engraged" making "physical contact" with Hill. On Page 2 of Hill's Affidavit attach to his
25
Motion for Order to Show Cause, January 20th, 2012, Hills attests: "5. On Friday, December 23,
26
2011, we unlocked the house at 9:00 a.m. as ordered. We overlooked the chain on the back gate.
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There was nobody at the house when we were there. At approximately noon, my staff informed me
02874
that an enraged Mr. Coughlin had called the office screaming that he could not get in the back yard.
When I finished the meeting I was in, I immediately went over and unlocked the back gate. Coughlin
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had a small crew. He charged at me and made physical contact. He was enraged. We left. When we
returned at 5:00 p.m., Mr. Coughlin was screaming and yelling obscenities. He drove off in a small U
-Haul. His crew remained. We walked the property with them. The inside .ground floor was mostly
cleared of all but a big TV. The basement had been cleared somewhat, but there was still a lot of
"junk. " We could not access the attic. We went outside. I told Coughlin's crew they could remove
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anything and everything outside, if they would only try to rehang the gate that Mr. Coughlin had
taken off the hinges before we could get over to unlock it. I told them I would lock the gates in the
morning.
That is really interesting. Compare the above to the following excerpt from page 3 of Hills
January 3rd, 2012 Opposition in CV11-03628, the appeal of the summary eviction Order: "12. While
at the property to remove the padlock, Coughlin, on more than one occasion, screamed profanities at
Merliss' counsel, and, at one point, charged Mr. Hill and attempted to physically intimidate him.
18
At least the audio of this incident was captured on tape. 13. Nevertheless, at 5:00 p.m. on Friday,
19
December 23,2011, counsel granted Coughlin and his agents additional, unfettered, and
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unlimited access to the outside of the property to remove any remaining items." Whereas in his
January 20th, 2012 sworn Declaration Hill goes so far as to indicate Coughlin "made physical
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contact" (which is a damn lie anyways), in Hill's then associate Casey Baker, Esq.'s NRCP 11 signed
24
January 3rd, 2012 Opposition, HIll's associate Baker will only go so far as to say that Coughlin, "at
25
one point, charged Mr. Hill and attempted to physically intimidate him." Baker was standing directly
26
next to Hill during the interacation wherin Hill swore, under penalty of perjury, that Couglhin "made
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physical contact" with Hill). Sounds like Casey Baker, Esq. was not quite willing to "spice up" the
02875
story line as Hill himself was. Casey probably did not have enough reason to sign on to the lies
about Coughlin "climbing on" the contractor's truck. In Hill's Application for a Protection Order
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against Coughlin Hill slips up and claims that Coughlin was "climbing on the contractor's truck,
picking through the contents" back at Couglin's former home law after the interaction at the "transfer
station" (town dump), whereas Hill's contractor indicated in his Affidavit that the alleged "climbing"
on his truck occurred at the "transfer station". However, both Hill and his contractor, Phil Stewart
indicate that the Reno Police Department "requested" that Hill filed a Protection Order Application
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against Coughlin. If that is true, its improper. The RPD can provide individuals information about
seeking one, but when the RPD goes a step further and starts urging individuals to file protection
order applications, or, as has recently been the case with RPD Officer Alan Weaver and Sargent
13
Oliver Miller, whom, upon information and belief, urged Northwind's apartment maintenance man
14
Milan Krebs to sign a fraudulent criminal complaint against Coughlin for "disturbing the peace" on
15
July 3rd, 2011, and again urged Superior Mini Storage's Matt Grant to sign a similar baseless
16
"disturbing the peace" criminal Complaint against Coughlin on approximately September 21st, 2012
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then there is more than a little indication that the RPD is out of control and attempting to incite
19
members of the public to sign fraudulent criminal complaints based upon a retaliatory animus by the
20
RPD towards Coughlin. Officer Weaver and Sargent Dye showed up to an unnoticed July 5th, 2012
21
bail hearing for Coughlin, presided over by Judge Linda Gardner's brother RMC Judge William
22
Gardner (whom received Coughlin's timely Notice of Appeal of the criminal trespass conviction,
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under NRS 189.010, yet failed to forward it on to the District Court, which somewhat recently
25
dismissed Coughlin's appeal in that matter, wherein Sargent Dye and Officer Weaver testified under
26
oath, with City Attorney Jill Drake singing backup, the the effectd that, despite bail only being valid
27
based upon one reason in Nevada (to secure the defendant's attendance at trial) the "public health and
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02876
safety" dictated increasing the cash required to bail out Couglin TENFOLD, from a bondable $1,415
to a CASH ONLY $3,000. Consequently, upon Judge Gardner so impermissibly raising Coughlin's
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bail, alleging a "public health and safety" rationale for so doing, Couglin was forced to spend 18 days
in jail, wherein the opportunity to timely contest the $40,050 attorney fees award to Richard Hill
incident to the summary eviction appeal ran, all while Coughlin was denied any opportunity to access
justice or file documents from jail, and where Coughlin sustained signficant damages, financial and
otherwise, and where the jail refused to transport Coughlin to a hearing on a landlord tenant matter
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wherein he was a named party. The extent to which local law enforcement is willing to play "kick
the can" with an attorney, particularly where Bar Counsel Pat King is so willing to join the chorus, is
troubling, and indicates the judiciary need issue a clarion call out to announce the extent to which
13
such misconduct can not, and will not, be tolerated. Such a retaliatory animus towards Coughlin by
14
the RPD is likely due to his September 7th, 2011 Complaint with respect to a wrongful, retaliatory,
15
and fraudulent arrest by RPD Officer Nicholas Duralde, which was accompanied by extortionate
16
threats by RPD Officer Ron Rosa that if Coughlin didn't cooperate they would "call the Nevada Bar
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and let them know how you cooperated with our investigation. How's that runnin' for ya?" While
19
Duralde testified that he did not hear or recall Rosa's coercive threats to Coughlin just prior to the
20
arrest, the fact that Duralde echoed those threats by saying "Now, I can arrest you for larceny. Now,
21
I can do a search incident to arrest. How's that?" tends to undermine Duralde's contention that "he
22
doesn't recall" hearing anything like what Officer Rosa was capture on tape saying to Coughlin just
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prior to the arrest. Upon making a Fourth Amendment violating arrest completely lacking in
25
probable cause, and smugly "joking" to Coughlin about the "benefits" associated with charging
26
Coughlin with a "felony", (at the time of the August 20th, 2011 arrest, the felony larceny amount
27
limit was $250 and above) compared to a misdemeanor (under some half baked "grand larceny" of an
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02877
allegedly lost or mislaid or abandoned three year old iPhone 3G that the alleged victim testified was
only then worth "about $80-100" on eBay or Craigslist), ie, search incident to custodial arrest
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possible where probable cause lacking to arrest, or even reasonable suspicion missing to do a pat
down, where alleged crime occured outside officer's presence, after 7 p.m., and no citizens arrest
immediately effectuated, particularly where Coughlin himself made a 911 call prior to Officer's
arriving and where video from minutes prior to officer arriving reveal Coughlin suggesting the 8-12
hostile late teens to early twenties skater boarders relax, stay peaceful, refrain from assaulting and
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battering Couglin, and wait for the police arrive so a lawful, peaceful resolution could be attained
(with Coughlin even cautioning the youths about a then recent tragic death occurring not far from
that location).
Further Hill just flat out lies in his January 3rd, 2012 Opposition to Amended Motion for
Emergency Restraining Order. Well, he did tell the truth when he wrote, on page 3: "11. On Friday,
December 23,2011, counsel for Merliss neglected to remove the padlock to the back gate of the
property." That is true, he did do that, and it did prevent Coughlin from removing all his property
18
during the scant 13 hours Coughlin had to move it. But, when Hill swears, on page 3, that:
19
"Coughlin's access to the house itself was never hindered.:" he is just "sippin' drank" or something,
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as, obviously failing to remove a lock on a gate gonna tend to have that effect, now...and when Hill
swears: " 13. Nevertheless, at 5:00 p.m. on Friday, December 23,2011, counsel granted Coughlin and
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his agents additional, unfettered, and unlimited access to the outside of the property to remove any
24
remaining items. The only condition placed on that access was that Coughlin's helpers agreed to
25
replace the gate on its hinges as best they could. Coughlin and his agents failed to remove the
26
remainder of Coughin's property from the yard that night, and failed to put the gate back on the
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02878
hinges." Coughlin was never made aware of any such "offer" by Hill, and, even if he had been, hey,
it's the "outside of the property", Rich, people generally put their valuables inside, you know?
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Then the HIll prevarication and obfuscation express kicks into overdrive, when, in his
January 3rd, 2012 Opposition he continues on: "C. Coughlin is Not Entitled to A Stay Coughlin
claims to have deposited $250 with the justice's court pursuant to NRS 40.385, although he has not
provided any proof in support of his claim. Attached hereto as EXHIBIT 10 is a true and correct
copy of the justice's court's docket as of December 19, 2011. That docket shows that Coughlin paid a
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11
filing fee for his appeal on December 12, 2011, in the amount of $216.00." Well, actually, Judge
Sferrazza waived the Justice Court's $24.00 filing fee, and the $216.00 represents the District Court's
12
filing fee, and its not really clear whether that date is when the check was cashed by the District
13
Court, or whether the Justice Court held on to the check for quit4e awhile before shipping it along
14
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with the ROA to the District Court, etc., etc. Hill continues: "It is entirely unclear from the following
entries of that docket whether or when Coughlin ever paid an additional $250.00 under NRS 40.385."
That might, technically be true, Rich, to the extent that you wrote it on January 3rd, 2012, and are
18
sneakily indicating that you are looking at an old docket from the Justice Court from December 19th,
19
2012, even though Coughlin made a big deal to you and the Justice Court, in writing, that he was
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21
depositing the $250.00 supersedeas bond mentioned in NRS 40.385, on December 22nd, 2011, a fact
which Hill himself mentions in his own filings...So, kind of a lack of candor to the tribunal there to
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make all this argument based upon some old docket and the extent to which it fails to reveal or
24
"make clear" matters to which Hill had ready written notice of via his own e-Flex account and
25
service of filings upon him connected thereto, in addition to Coughlin's faxes, emails, and there
26
might have even been a service of a Notice of Posting Supersedeas Bond (need to check on that
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more), etc. in connection with the depositing on December 22nd 2012, the $250 required for a stay
02879
during appeal of a summary eviction in NRS 40.385. And, actually, Hill slipped up a bit there, in
light of the following: And, actually, Hill, in his January 20th, 2012 filing, admitted that Coughlin
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sent him that December 22nd, 2011 email notifying him of the posting of the $250 supersedeas bond
seeking a stay, when he admits, on page 3: "11. Pursuant to EXHIBIT 2, Coughlin was provided
access to the Property on Thursday, December 22, 2011. That day, Coughlin sent an email to the
undersigned and Judge Sferrazza, in which he essentially announced that he was entitled to a
stay, and to return to and continue in possession of the Property. Judge Sferrazza quickly
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13
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responded by email, and reminded Mr. Coughlin that the stay had been denied." Found in
Exhibit 1 is the December 22nd email to Hill's Office that alerts them to the posting of $250 ,
specified as a "supersedeas bond", with a citation to NRS 40.385:
Hill's January 3rd, 2012 Opposition continues, on page 8: "Even if Coughlin eventually paid
some amount toward an appeal bond, it was not in time to stay the eviction during this appeal. To do
that, a proper motion must be made and granted, and the bond posted, prior to the lockout. The
lockout here occurred on November 1, 2011. By the time Coughlin managed to find that statute and
18
pay any money to the court, he had been locked out of the property for six weeks. As such, any
19
request for a stay was, and is, moot. At this point, Coughlin does not have any rights in either the real
20
21
or personal". Oddly, Anvui saw a stay granted after a lockout was conducted, and Hill (RPC 3.1
"meritorious contention" issues) cites to no legal authority for his contention that "to stay the eviction
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during this appeal...a proper motion must be made and granted, and the bond posed, prior to the
lockout." Citation? None.
Despite Hill's strange approach of not actually indicating that his office did not get an
December 22nd, 2011 email notifying them of the posting of $250 for a supersedeas bond seeking a
stay under NRS 118A.385 (but rather, Hill focuses on what one cannot glean from looking at a dated
02880
docket...), Hill's Office was made aware of such matters, in writing, in the following December 22nd
email to Hill's Offiee: "...Further, this is all moot at this point as I have filed a Supersedeas Bond of
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$250, and according to NRS 40.385, I automatically get a stay of eviction and am entitled to
return to the property and continue in possession. The statute sets the Supersedeas Bond
(which yields a stay) at $250 if rent is under $1000, unless the Court wishes to rule that I am a
commercial tenant. However, if the court does rule that I am a commercial tenant, the No
Cause Eviction Notice in this case, under NRS 40.253 makes a Summary Eviction Proceeding
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12
impermissible, as Summary Eviction Proceedings are not allowed against commercial tenants
where only a No Cause Eviction Notice is filed. Its one or the other, but Mr. Hill and Baker
cannot have it both ways. Further, the Courts Order of December 21, 2011 is just that, and
13
Order, its not an agreement, its not a settlement, etc, etc. and the audio record clearly reflects
14
that. NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of
15
premises to pay rent during stay. Upon an appeal from an order entered pursuant to NRS
16
40.253: 1. Except as otherwise provided in this subsection, a stay of execution may be obtained
17
18
by filing with the trial court a bond in the amount of $250 to cover the expected costs on
19
appeal. In an action concerning a lease of commercial property or any other property for which
20
the monthly rent exceeds $1,000, the court may, upon its own motion or that of a party, and upon a
21
showing of good cause, order an additional bond to be posted to cover the expected costs on appeal.
22
A surety upon the bond submits to the jurisdiction of the appellate court and irrevocably appoints the
23
24
clerk of that court as the surety's agent upon whom papers affecting the surety's liability upon the
25
bond may be served. Liability of a surety may be enforced, or the bond may be released, on motion
26
in the appellate court without independent action. 2. A tenant who retains possession of the premises
27
that are the subject of the appeal during the pendency of the appeal shall pay to the landlord rent in
28
02881
the amount provided in the underlying contract between the tenant and the landlord as it becomes
due. If the tenant fails to pay such rent, the landlord may initiate new proceedings for a summary
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5
eviction by serving the tenant with a new notice pursuant to NRS 40.253. Sincerely, Zach Coughlin,
Esq.".
Oh, and Hill and Stewart admit to this in a video. Richard Hill's contractor, for some strange
reason, removed a ladder Coughlin owns from the property, preventing Coughlin's access to the attic
upon his being allowed that scant 13 hours to remove his property (and the attic had been renovated
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11
to allow for storage of a considerable amount of property. If Coughlin was Hill he would have called
the RPD to report the "larceny" of his ladder by Hill, in a RICO thing with his contractor. But Hill
12
escaped prosecution that time, over they whole ladder deal. It never was made clear why the
13
contractor removed the ladder from the property, other than, perhaps, like the applying of a lock to
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22
the backyard gate, make it even more unlikely that Coughlin would be able to remove all he needed
to, especially given the limited funds for moving vehicles and hired help, in the scant 13 hours
allowed under the December 21st, 2012 Order.
Things have just gotten too ridiculous where an attorney's license gets placed in jeopardy for
saying "Wow" in court (or King threatens to buttress an SCR 105 Complaint upon such scandalous
behavior while the RPD can violate the Fourth Amendment while making threatening, coercive
statements and smugly, menacingly joking to an arrestee (whom dared ask if the officer actually had
23
reasonable suspicion to conduct such an evasive Terry Stop style weapons check pat down on one
24
whom himself called 911 to report an attack by skater youths, while holding his Pekingness and
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bicycle, which the skaters were trying to rob the attorney of when they weren't "jokingly" making
sudden attempts to reach into the attorney's pockets) about overcharging an arrest to get around the
dictates against conducting a custodial arrest and search incident thereto for some ill supported petty
02882
larceny of an iPhone, allegedly occuring after 7 pm, outside the officer's presence, based upon some
"lost, mislaid, or abandoned" property fact pattern worthy of a law school final exam where someone
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6
finds an iPhone on the ground in downtown Reno, offers it up to the denizens of a downtown skate
plaze shortly before midnight on a Saturday, then threatens to "throw it in the river" if someone does
not claim it immediately, which eventually leads to an attorney being attacked by a group of youthful
skateboards making up every lie they can think of to prevent any inference that said iPhone was
abandoned and or rescued from waste or destruction or that assaulting and battering one who does
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not immediately turn over an iPhone to a hostile, violent group of 8 to 12 late teens early twenties
skaterboards yelling things like "give us the phone faggot". Further, in Nevada, a larcenous intent
must exist at the time one takes possession of lost or mislaid property. "A taking with the intention
13
of returning the property, or a taking without the intent to permanently deprive the owner of his
14
property, will not amount to larceny, even though the perpetrator, after gaining possession of the
15
property, formed that intent. State v. Clifford, 14 Nev. 72, 33 Am.Rep. 526; State v. Ward, 19 Nev.
16
297, 10 P. 133; Robinson v. Goldfield Merger Mines Co." Harvey v. State, 78 Nev. 417, 422-23, 375
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18
P.2d 225, 227-28 (1962) [78 Nev. 417, Page 420] , 46 Nev. 291, 213 P. 103. The requirement that the
19
original taking and the felonious intent coexist in point of time was properly mentioned in the written
20
instructions given in the instant case. Moreover, we recognize that the question of whether the
21
property was originally taken with such intent is one of fact, the determination of which is to be
22
made from a consideration of all the circumstances preceding, attending and following the taking of
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24
the property. State v. Cudney, 47 Nev. 224, 218 P. 736.
25
There has already been testimony in such a pending criminal matter against an attorney the
26
the attorney did not attempt to furtively or immediately flee the scene where he was allegedly free
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handed such an iPhone, and where the Witness Statements conveniently left out the whole bit about
02883
the man holding the phone up and threatening to "throw it in the river" (an an admission by several
hostile witnesses that that did occur was caught on videotape) and, not only that, but actually lied an
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indicated these witnesses "personally eye witnessed" the attorney just walk up and "grab" the iPhone
off the ground, etc. Oh, also, the whole arrest was caught on tape too, as were the moments prior
thereto, and the alleged victims are clearly shown lying to 911 operators about someone "socking a
minor" to engender a more rapid and urgent police response. Never mind that the alleged "socking"
was actually flinching went an 18 year old, along 8-12 of his hostile and aggressive friends
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attempting to rob the attorney of his bicycle and or dog, made a "joking" and sudden movement
intended to make the attorney think the 18 year old was "reaching in" the attorney's pockets...Add to
that the fact that they Officer announced to the attorney within seconds of arriving on seen that he
13
was going to conduct a search incident to arrest, and only later made up a bunch of pretextual
14
rationale to support conducting a Terry Stop pat down, then a search incident to arrest, while alleging
15
the attorney's question as to, whether the officer had a sufficient basis to conduct such a pat down or
16
search incident to arrest, without anything more to support a larceny probable cause analysis than an
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allegation that one possessed an iPhone that was purportedly left on the ground, whereupon that
19
person called 911 upon being attacked by a group of 8-12 immediately after failing to instantly
20
adhere to their threatening demands to consent to a search on one's pockets, accompanied by a touch
21
of assault and battery to boot, and some hate speech. Such is not supportable, particularly where
22
merely pending for denying one due process required under the law, and particularly SCR 102(4)(d)
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and SCR 111(8) and SCR 111(10).

The fact that the criminal trespass custodial arrest occurred at a time when Coughlin still had
not received back the $2,275 "rent escrow" the Reno Justice Court forced Coughlin to deposit with
the RJC in that very summary eviction proceeding/"Trial" (all while Coughlin was, at least according
02884
to Hill, supposed to hire movers and rent a U-Haul and otherwise have sufficient funds to conduct a
large scale move of a home law office after having just gone from zero to expert on landlord tenant
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law litigating a "Trial" for a law office tenant in a matters of days...). Coughlin made such a deposit
or $2,275 "rent escrow" with the RJC on October 17th, 2011 (after the October 13th, 2011 summary
eviction hearing in Rev2011-001708 wherein the RJC Judge ruled that Coughlin "had established a
material issue of fact" as to retaliation and habitability (and perhaps discrimination, that is not clear)
and set a "Trial" (but only if Coughlin deposited $2,275 in a "rent escrow" account with the RJC by
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October 17th, 2011) for October 25th, 2011 (despite a "Trial" under JCRCP 109 requiring 20 days to
respond to a Complaint, under NRS 40.251, ie, a plenary unlawful detainer action with all the
attendant due process trimmings). Further, the Summary Eviction Order stemming from the October
13
25th, 2011 "Trial" (it was noticed as a "Trial" in writing by the Court, referred to as a Trial by the
14
Court) and the accompanying criminal trespass conviction stemming therefrom are likely void do to
15
the fact that Coughlin filed, on October 18th, 2011 a Notice of Appeal (on a form that, by the way,
16
indicated McLaughlin's exposure for any attorney's fee award would be limited to $15.00, much less
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the $40,050 ultimately entered against Coughlin in an attorney's fee sanction in CV11-03628 by
19
Judge Patrick Flanagan. That Notice of Appeal form was provided to Coughlin by a Clerk of the
20
RJC in response to a specific request by Coughlin for the form to appeal the Order stemming from
21
his October 13th, 2011 summary eviction proceeding, and the forms on the RJC web site at the time,
22
under a heading of "Notice of Appeal" linked to that same form, and did not in any way specify such
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form to only apply to appeals of small claims actions). Coughlin's filing of a Notice of Appeal of
25
that October 13th, 2011 Order following the summary eviction proceeding, under Mack v. Mack-
26
Manley, divested any jurisdiction of the RJC to hold such a "Trial" on October 25th, 2011, and any
27
such "Trial" was void for lack of jurisdiction anyway, NRCP 60(b)(4) in light of the dictates of NRS
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02885
40.253(6) ("shall make no further Order" upon the Justice Court finding tenant had established a
genuine issue of material fact, which Judge Sferrazza indicated Coughlin had in his Order following
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the October 13th, 2011 summary eviction proceeding, and again, on the record, during the October
25th, 2011 Trial, Judge Sferrazza again stated that he set the matter for "Trial" upon his making a
"finding that Coughlin established a genuine issue of material fact", which, under Anvui, and NRS
40.253(6), prevented Judge Sferrazza from making any further order, and the lack of a corollary to
Las Vegas Justice Court Rule 44 in the RJC, along with the dictates against unwritten/not approved
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by the Nevada Supreme Court and counter to express statutory mandates in NRS 118A and NRS 40
"house rules" set forth in JCRCP 83 should have prevented forcing Coughlin to make any "rent
escrow" deposit of $2,275 right in the middle (actually after it should have ended) of a summary
eviction proceeding.
JCRCP RULE83.RULES BY JUSTICE COURTS
Each justice or justice court in a township with more than one justice, by
action of a majority of the justices thereof, may from time to time make and
amend the rules governing its practices not inconsistent with these rules.
Copies of rules and amendments so made by any justice court shall upon
their promulgation be furnished to the Supreme Court, but shall not
become effective until after approval by the Supreme Court and
publication. In all cases not provided for by these rules the justice
courts may regulate their practice in any manner not inconsistent with
these rules.
Further, any "Trial" in that summary eviction matter, and therefore any
criminal trespass arrest based upon any failure to properly adhere to some
improperly served Lockout Order stemming therefrom, is also void in light
of the noncompliance with JCRCP 109: SETTING OF TRIAL IN
ACTIONS
"(a)In no case shall a trial on the merits be set less than 20 calendar
days after service of summons and complaint."
To continue the temporary suspension of Coughlin's constitutionally protected
(under the Fourteenth Amendment, a law license is a "property right") law license
02886
based upon conjecture, hearsay, Pat King's "innocent" mistakes about "facts" and
various orders so terribly subject to being found void under NRCP 60(b)(4), etc. and a
criminal trespass conviction similarly suspect, particularly where Coughlin's filings
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Further, Judge Sferrazza admitted that the RJC did not have a rule for forcing
Coughlin to make such a "rent escrow" deposit at the time such was ordered on
October 13th, 2011 in the summary eviction proceeding. And even if the RJC did
have such a rule speaking to "deposits" with the RJC, JCRRT Rule 2 makes clear that
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such a rule does not apply to "landlord tenant matters":

JCRRT Rule 2. Application of Rules. Except as otherwise provided by
statue, these rules apply to all civil proceedings filed in Reno Township
except small claims and landlord tenant matters.
Oh, and Hill still managed to get Coughlin subject to the November 13th, 2011 custodial
arrest (ie custodial have someone with color of law make you strip naked and spread your buttocks
search incident to arrest, and even apparently allow a complete copying and, some times "erasing" of
16
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one's smart phone, separate micro sd data card, or laptop pursuant to such a "search incident to
18
arrest"...like what occurred on February 27th, 2012 incident to the traffic citation trial before RMC
19
Judge Nash Holmes (whom told Coughlin she would have him arrested if he said Richard G. Hill's
20
name one more time) in 11 TR 26800 2I stemming from the three traffic citations RPD Sargent John
21
Tarter called in a different RPD Officer to issue Coughlin incident to Coughlin being told to leave
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Richard G. Hill, Esq.'s law office where Coughlin had gone (upon being released from jail on
24
November 15th, 2011) to retrieve his keys, wallet, state issued identification and client's files from
25
Hill, whom refused to provide such items to Coughlin, upon Coughlin being bailed of jail after
26
spending three days there in connection with the criminal trespass arrest connected to the criminal
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Complaint signed by Richard G. Hill, Esq. At that February 27th, 2012 traffic citation Trial in RMC
02887
11 TR 26800 (and not even some juicy reckless driving thing, just a plain old "failure to come to a
complete stop at a stop sign/California Roll/Boulevard Stop traffic ticket"), Coughlin was sentenced
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to five days jail, denied a stay (despite being a practicing attorney with actual clients depending upon
him) by RMC Judge Dorothy Nash Holmes seconds after Coughlin testified that RPD Sargent Tarter
"lied" during his testimony concerning what Coughlin's purported to be a retaliatory issuance of
multiple traffic citations incident to Coughlin repeating to Tarter what may have been a sarcastic
repose to Coughlin by RPD Officer Chris Carter during the criminal trespass arrest from Coughlin's
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former home law office just days prior, when Coughlin queried Carter if he, too, was on Hill's
payroll. In Judge Nash Holmes written February 28th, 2012 Order Finding Defendant in Contempt
of Court and Imposing Sanctions (a five day immediate trip to jail, and a failure to release Coughlin
13
after the fourth day despite the RMC accepting and failing to return $100 Coughlin's mother
14
deposited with the RMC upon an agreement being made to so release Coughlin at the end of the
15
fourth day...which was not adhered to), Judge Nash Holmes somehow found it fair to impose the
16
following upon a pro se indigent criminal defendant (much in line with the RMC's prerecorded
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arraignment videos which basically attempt to scare any and all out of even darign to represent
19
themselves before the RMC, especially where Keith Loomis, Esq. and the boys down there provide
20
such a ready lubricant to the, uh, justice the RMC dispenses: "The court had the defendant sworn at
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the beginning of the trial, stating that the court has found that most self-represented defendants tend
22
to testify a great deal as they cross- examine opposing witnesses, so the defendant would be under
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oath from the start, too. exhibits were marked or admitted." That practice apparently is read to
25
provide support for some contention that Coughlin violated some RPC while appearing as a pro se
26
criminal defendant in a traffic citation Trial, where Coughlin's smart phone and micro sd card were
27
searched incident to his arrest for "summary contempt committed in the Court's presence" and
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02888
"booked into evidence" where they stayed for some 37 days, and where returned to Coughlin with all
the data erased, but not before lots of contradictory statements were made by the Sheriff's Office, the
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City of Reno Marshal's, the RMC, the Washoe County District Attorney's Office, and the Washoe
County Detention Facility regarding the chain of custody of that smart phone and data card, whether
it was removed from the evidence room at the jail and transported back to the RMC on February
28th, 2012, whether a micro sd card was even included in the property so inventoried then booked
into evidence, and whether that micro sd card was released to an associate of Coughlin or kept with
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the smart phone for those 37 days. Curiously, in Judge Nash Holmes March 30th, 2012 Order
Releasing Property, that Order indicates: "IT IS ORDERED that the Washoe County Sheriffs Office
shall release to the Defendant, ZACHARY BARKER COUGHLIN, three items taken from him on
13
February 27, 2012 at Washoe County Regional Detention Facility during his booking for
14
incarceration pursuant to the imposition of a 5-day jail sentence for Contempt of Court in the above-
15
entitled case, to wit: one Samsung Cell Phone; one T-Mobile Cell Phone; and one Braun Electric
16
Razor, as identified in Case Number WC 12-1805 and referred to under Control # C-47951."
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That's the thing, though. There were four items, not three. Marshal Harley, whom made sure
he was the one doing the lookin' through of the pockets and pattin' down of the body and all that, he
made a big deal about how the micro sd card was not in the smart phone. Actually, Marshal Harley
pretty much rendered an Order convicting Coughlin of this and that in conjunction with his
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conducting the search incident to arrest of Coughlin. The fourth was a micro sd card, capable of
24
holding an entire libraries worth of books on it in digital format. While the smart phone was
25
returned, with the micro sd data card inserted into it, it was not found that way during the "search
26
incident to arrest". The micro sd card was not inserted into the phone. Such a micro sd card can be
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inserted into a flash drive adapter, into a digital camera, into a lot of things, not necessarily one's
02889
smart phone. And the Washoe County Regional Detntion Facility did not return the phone
immediately in compliaince with the Order, but rather indicated that the Washoe County District
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Attorney Office had to give permission and or get to possess the materials first, with "Maddy" of the
WCSO indicating Coughlin need contact Mary Kandaras of the WCDA's Office.
Eventually, after 37 days, the smart phone and micro sd card were returned to Coughlin with
all the date therein erased, but not before Judge Nash Holmes entered an Order accusing Coughlin,
vaguely, of lying (not getting all that specific though with respect to just what it was Coughlin was
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apparently "lying" about, but some reference was made to rules related to the media and court
proceedings...and then a laundry list copy and pasted from teh RPC of all the purported violations of
various RPC's that Coughlin was found to have committed "by clear and convincing
13
evidence"...including such vague and entirely devoid of any explication or factual rulings that
14
Coughlin was guilty of demonstrating a "lack of fairness to opposing counsel" or "prolonging
15
proceedings", etc...Coughlin did report to City Attorney Allison Ormaas during a brief plea
16
bargaining session immediately before the Trial that RPD Officer Carter made a statement (perhaps
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said sarcastically while arresting an attorney for criminal trespass where the RPD refused to issue a
19
citation or identify themselves as law enforcement prior storming in Coughlin's former law office's
20
"basement", where a stay is mandated under NRS 118A.380, where one's rent is less than $1,000 and
21
damages awarded are nil, for no more than a $250 deposit, at a time when Coughlin had yet to be
22
returned the $2,275 impermissible "rent escrow" deposit forced upon him in a summary eviction) that
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"Richard Hill pays me a lot of money so I arrest who he says to arrest and do what he says to do"
25
upon Coughlin asking Carter if he, too, was on Richard G. Hill's payroll. It appears that at some
26
point, perhaps while they were whispering in each other's ears (as Coughlin noted on the record
27
during the Trial in 11 TR 26800) during the Trial that Marshal and City Attorney Ormaas were
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02890
afraid Coughlin may have some evidence of Ormaas's admitting to Coughlin that she was in no way
going to following up on an statements by an RPD Officer that may tend to present and admission of
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accepting some improper benefit in exchange for committing official misconduct under color of law,
or otherwise document such information. The RMC's Marshal Harley seemed to be upset about the
possibility that Coughlin may have some evidence of Harley purporting to personally serve Coughlin
the Order to Show Cause in CV11-03628 (and Machen's Affidavit of Service filed March 8th, 2012
indicates Machen "personally served" Coughlin, which not the case, as apparently Machen did not
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want to wait around for a few minutes for Coughlin's bargaining session with City Attorney Ormaas
to end, which means Machen was cutting a corner, which is something courts and local law
enforcement punish ordinary citizens for every day in Washoe County. When Marshal Harley began
13
to realize Coughlin's questions to him were revealing some questionable issue (so, you don't know
14
whoat WCSO Deputy handed you this Order to Show Cause? You have no idea? You didn't
15
recognize him at all? Did he "personally serve" me it, or did you, Marshal Harley? Why is this even
16
being personally served? And why while I am attending court on a totally unrelated matter? Is that
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proper? Is that somewhat hostile and done in an attempt to embarass Coughlin at the courthouse? Is
19
that appropriate?
20
served"? Have not found one yet...Especially where Coughlin was a registerd efiler at the time, and
21
therefore, likely had already been deemed served. Where the subsequent Affidavit of Service thefore
22
Is there even a rule requiring such an "Order to Show Cause" be personally
indicated it was actually the same WCSO Deputy Machen having "personally served" such Notice on
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Coughlin, along with some impromptu questioning of Harley as to whether such service was being
25
done bas To the extent City of Reno Marshal Harley barged in to that bargaining session purporting
26
to personally serve Coughlin Notice of a Hearing and or Order to Show Cause in connection with
27
Hill's Motion for Order to Show Cause in the appeal of the summary eviction matter (which resulted
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02891
in a quadruple jeopardy cocktail courtesy of Hill, based largely upon the same acts which resulted in
Coughlin being arrested for "jaywalking", and Hill getting a TPO, and Bar Counsel Pat King making
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a federal case of Hill's January 13th, 2012 grievance against Coughlin submitted to the SBN, wherein
Hill leads off with an allegation that Coughlin was "ghostwriting for" someone for whom Coughlin
was listed as attorney of record. Huh? Then Hill went to "comply with his RPC 8.3 obligation" by
reporting the conviction underpinning the current temporary suspension (something Coughlin
himself reported in compliance with SCR 111 prior to any knowledge of Hill's having done so, not
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that Bar Counsel bothered to mention that in its SCR 111 Petition, something this Court made note of
a lack thereof in its June 7th, 2012 Order).
12
Incidentally, RPD Sargent Monica Lopez admitted during a videotaped interview that neither
13
she nor her fellow office, Carter, identified themselves as law enforcement while calling to Coughlin
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at the basement door prior to the landlord opening it, nor requested or warned Coughlin to leave the
property prior to arresting him from criminal trespass from Coughlin's former home law office on
November 13th, 2011...despite Hill testifying under oath that they did so identify themselves prior to
18
the landlord opening the "basement" door and that the RPD Officer did issue a warning to leave to
19
Coughlin or otherwise provide Coughlin a chance to heed such a warning prior to effecting a
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custodial arrest. What makes that even more troubling is the fact that Hill provided the City of Reno
prosecutors video of pretty much all events other than the "knock and identify themselves" as law
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enforcement Hill purports the RPD did (even where RPD Sargent Lopez indicates neither she nor
24
Officer Carter did so identify themselves prior to the basement door being opened by the landlord).
25
Amongst the videos that Hill filmed on November 13th, 2011 that Hill did manage to provide to City
26
of Reno prosecutors was a video of Coughlin asking Officer Carter and Sargent Tarter, prior to the
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point of arrest, why, if they felt he was trespassing, they wouldn't simply issue a citation in lieu of
02892
making a custodial arrest. Hill's own video establishes that Hill's testimony during the criminal
trespass matter is extremely problematic respecting whether the RPD identified themselves prior to
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the landlord opening the door and whether the RPD issued Coughlina warning to leave and
opportunity to heed it prior to effecting a custodial criminal trespass arrest. Hill had Coughlin
arrested for criminal trespass, even where Coughlin had to pay for "storage" the same amount, $480
as the Lease Agreement required for "full rental value for full use and occupancy of the premises"
for 17 days of "storage" of Coughlin's personal property, and even where NRS 108.475 and NRS
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40.760 indicate a summary eviction is required where one is "using a storage facility as a residence"
(if that was the case, which has not been established), not a criminal trespass arrest, particularly
where RPD Officer Chris Carter, in violating Soldal v. Cook County, expounded to Coughlin upon
13
his learned views on "service" of eviction orders like some modern day Friedenthal. Then there is
14
the fact that Coughlin's former home law office was robbed of approximately $8,000 worth of
15
personalty on December 12th, 2011 (during the six week wait for a Hearing on Coughlin's Motion to
16
Contest Personal Property Lien, again, because, according to Hill, the RJC was going to postpone
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setting any such hearing until Hill's six week vacation was over, despite the statutory dictate that
19
such a hearing be set within 10 days of Coughlin's November 16th, 2011 filing of a Motion to
20
Contest Personal Proeprty Lien). The December 21st, 2011 Order on Coughlin's Motion to Contest
21
Personal Property Lien required Coughlin to rush into his former home law office, and take in the
22
specter of it having been torn asunder and robber, with a chortling Richard G. Hill, Esq. standing on
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filming the occasion, and quickly throw together an "inventory of anything lost, stolen or damaged",
25
then hop over to Kinko's or some wi-fi and email the RJC with such an inventory, copying Hill in the
26
process. Even though the statutes in Nevada are amongst the harshest towards tenants compared to
27
the other 49 states, the RJC, Washoe County Sheriff's Office, Reno Police Department, and landlords
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02893
like Dr. Matthew Joel Merliss, MD (a Chico, Ca. based neurosurgeon whom graduated from Beverly
Hills HS) and their attorney (or, their unauthorized practice of law committing "eviction consulting
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and process service" company, like Nevada Court Services) really go the extra mile in making
Nevada a very dangerous, and perhaps, lethal, place to be a tenant. Oh, and the Judge finding
Coughlin guilty of the Reno Municipal Code's version of criminal trespass, RMC Judge William
Garnder, found support for the "when on property with an intent to vex and annoy" the owner of a
property version of criminal trespass where the Judge and prosecution also maintained that Coughlin
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was "secretly" going on the property (apparently Coughlin was haunting the subconscious of the
property owner where the prosecution did not have support for the "failed to leave after being warned
to do so" version of criminal trespass in RMC 8.10.010 is also the brother of the Family Court Judge
13
Linda Gardner whose April 2009 Order for Sanctions of Coughlin incident to Coughlin's service for
14
legal aid organizations Washoe Legal Services as a domestic violence attorney was cited as the "sole
15
reason" for Washoe Legal Service firing Coughlin, and which formed the basis for Coughlin's
16
Petition for Writ of Mandamus challenging said Order for Sanctions in 54844 and whom admitted,
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18
on the record, in the case flowing from Coughlin's criminal trespass arrest, in RMC 11 CR 26405,
19
that he "passed along" to his fellow RMC Judge Nash Holmes "his own sister's" over three years old
20
Order for Sanctions ($1,000 attorney's fee award personally payable by Coughlin under NRS 7.085
21
despite Coughlin's citing to an ALR article demonstrating the position he maintained to be the
22
majority viewpoint in Amercian jurisprudence, ie, no setting off "duty" such as alimony for
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unsecured third party credit card debt where other spouse is sole signatory. A far flung doctrine of
25
the necessaries threat by various unsecured debt holders, where none of the debts are likely large
26
enough to engender much litigation, hardly makes vexatious a failure to agree to John Springgate's
27
proposed marital settlement agreement
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02894
. RMC Judge William Gardner refused to recuse himself from Coughlin's criminal trespass trial
despite acknowleding that he was aware that his passing on his sister's 2009 Order for Sanctions to
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Judge Nash Holmes had resulted in a grievance being filed with the SBN, based upon his sister's
Order for Sanctions, upon Judge Nash Holmes forwarding said Order onto the SBN. Bar Counsel
King issued that "grievance" based upon Judge Linda Gardner's 2009 Order for Sanctions its own
case number, yet has continued to refuse to specify how that case came to be, who filed the grievance
based upon that Order, or in any other way indicated that such grievance came to be other than an
immaculate conception of sorts.
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Speaking of RMC Judge Nash Holme's submission of grievances and complaints to the SBN
12
immediately after Coughlin, unsuccessfully sought to invoke his right to appeal the "criminal
13
summary contempt" Order Judge Nash Holmes rendered on February 27th, 2011 in the Trial for a
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traffic citation, in Coughlin's March 7th, 2012 filing in 11 TR 26800 of a Notice of Appeal (which
despite the dictates of NRS 189.010, .020, .030, and .060 and ATTY GEN. OPINION NO. 79-4
Criminal Appeals From Municipal CourtNRS 189.010 and 189.020 (1979). The RMC has
18
continued to fail to transmit Coughlin's appeal of the criminal summary contempt Order to the
19
District Court. Further, Coughlin's own Washoe County Public Defender Biray Dogan, Esq.
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Then, Mr. King alleged he would point towards some pending criminal investigation as a
basis for a Compliant. Tell that to the indicted on federal compaign violation charges attorney's the
SBN is not commenting on.
Somehow, the District Court managed to find it equitable to sanction Coughlin $40,050 in
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attorney's fees in the appeal of that summary eviction matter, and the judge making that ruling was
previously a member of the same law firm as Coughlin, yet refused to recuse himself from the
02895
matter. Bar Counsel King has also previously threatened (while attempting to coerce Coughlin's
assent to some snake potion SCR 117 deal when King is not busy attempting to fabricate a SCR 105
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"informal meeting" with Coughlin out of a purported offer by King to actually let Coughlin even
view (not copy though) or "see the materials submitted along with the grievances", despite the fact
that King stormed away from the Bar's Northern Office conference room seconds into Coughlin
reviewing such materials, along with all such materials being stuffed back into their box, upon it
becoming clear that Coughlin wished to view the materials prior to being interrogated by King other
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otherwise have King deem the occasion an "informal meeting" under SCR 105). King seeks to
prolong a temporary suspension incident to a thoroughly defrocked "candy bar petty larceny"
conviction (and the dismissal of the appeal was based upon an impermissible applciation of NRS
13
189.030 and NRS 4.410(2) wherein a civil statue speaking to paying up front for a transcript was
14
applied to justify dismissal a criminal appellant's appeal (a growing in Nevada's courts as seen in a
15
similar case included in Exhibit 1) as a justification for placing a temporary suspension on Coughlin
16
throughout a lengthy potential SBN v Coughlin Complaint proceeding (that will be, according to
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King, based upon pending criminal charges, Coughlin wearing "pajama pants" to a Municipal Court
19
filing counter while checking on a traffic ticket, some alleged video of someone swearing in a police
20
officer's presence, a non-existent/CGI-ish "Order" by a (REDACTED) Court Judge that only exists in
21
the mind of Pat King (who is known for being rather sloppy and lazy like that, you know, when it
22
comes to due process and people's way of making a living, and constitutionally protected property
23
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rights, while bringing his dog to work to hang out in the Bar's Northern Office's lobby, a Great Dane,
25
which, admittedly, is a magnificently regal animal, though it was not in the December 2012 Animal
26
Law issue like Coughlin's Pekingnese Jackson Pawluck). "Patty Ice" knows Coughlin loves him.
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However, it is inappropriate for King to seek to prolong Coughlin's temporary suspension so

02896
unreasonably, where, especially, King has maintained he intends to seek a "combo-hearing" that will
largely be based upon a Complaint that alleges Coughlin has pending criminal charges: Where the
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only relevant factual allegation contained in Disciplinary Board's affidavit, filed in support of its
petition for attorney's temporary suspension from the practice of law, was that a criminal indictment
had been filed against the attorney, this sole allegation, without more, was insufficient to justify
summary suspension and the immediate imposition of temporary restrictions. Sup.Ct.Rules, Rules
102, subd. 4(a), 111, subd. 1. Matter of Monteiro, 1984, 684 P.2d 506, 100 Nev. 440. Coughlin has
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not been indicted on federal election law/campaign contribution violations. The charges Coughlin
does currently face say a lot more about the prosecutors than they do about Coughlin, and the fact
that a June 7th, 2012 email from Coughlin to a prosecutor was followed four hours later by a
13
suspension of this Court, signed by three Justices, one of whom has previously recused himself from
14
Coughlin's case appeal of the dismissal of Coughlin's wrongful termination lawsuit against Washoe
15
Legal Services, 60302 (and granted, the Justice referenced has longstanding ties to and altruistic
16
interactions with legal aid entities throughout the state...) provides a further reason for this Court to
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18
consider, en banc, Coughlin's various requests to have the temporary suspension of his law license
19
dissolved (Coughlin filed a Motion for Resconsideation of the Temporary Suspension on June 11th,
20
2012 in light of the Nevada Supreme Court's failure to file Coughlin's May 24th, 2012 attempt at
21
filing an Opposition to the SCR 111 Petition in 60838, in violation of NRCP 5(e), and a August 13th,
22
2012 SCR 102(4)(d) Petition in 61426, in addition to a SCR 111(10) Motion to Dissolve the
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Temporary Suspension of the same date in 60838.

As to the reasonableness of allowing Bar Counsel's attempt to subvert procedural SCR's
based upon pending criminal cases, the RJC docket in RCR2011-063341 is incorrect in that it fails to
detail the extent to which DDA Zach Young violated NRS 178.405 by filing, with a file stamp time
02897
of 2:55 pm an Opposition to Defendant's Motion to Appear as Co-Counsel despite the fact that DDA
Young and Coughlin's public defender Biray Dogan, in RCR2012-065630 met in a clandestine status
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conference on February 27th, 2012 at 1:30 pm, despite the fact that on February 24th, 2012 (and the
files documents this as well) that very MSC was continued until March 29th, 2012 in light of a
scheduling conflict attendant to the fact that Coughlin had a traffic citation trial involving Coughlin
in the RMC on that very day, February 27th, 2012 in 11 TR 26800 set for 1:00 pm. Bar Counsel
King has threatened to file a SBN v Coughlin SCR 105 Complaint based upon a filing by Coughlin
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incident to the defense of a "misuse of 911 or emergency services", a charge that presents DDA
Young with the difficult tasks of prosecuting one for (and some guessing is required here as DDA
Young is taken to not specifying much of anything in the information in his Complaints) calling 911
13
to report fear of the police and or a failure by a 911 operator to accord such an allegation any
14
legitimacy...which explains why DDA Young seeks to conspire with Coughlin's public defender
15
Dogan to amend such a charge to a "resisting arrest" simple misdemeanor, down from a gross, and
16
thereby leverage the threat of a conviction of a crime that actually, upon a conviction, would invoke
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a SCR 111(6) "serious offense) Petition by Bar Counsel) criminal matter that has been pending since
19
Coughlin was subject to a custodial arrest on January 14th, 2012 at his then shared residence with
20
two individuals from whom he rented a room, and against which he was ultimately awarded Orders
21
of Protection in FV12-00187 and FV12-00188. The same RPD Sargent, Paul Sifre, who ordered a
22
trainee, Officer Leedy, to effect a custodial arrest of Coughlin on January 12th, 2012 at Coughlin's
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former law office ordered Coughlin arrested again less than 48 hours later for the "misuse of
25
emergency services" incident to Coughlin calling 911 to report the sudden disappearance of his dog,
26
in the context of weeks of attacks by his two former housmates (slashed tires, furniture thrown in the
27
street, death threats, being chased up the stairs by a man with a 10 inch butcher knife yelling threats,
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02898
having hot coffee thrown on him, interference with his mail, etc., etc.), and despite the fact that NRS
33.018 does define "domestic violence" to include violence against one's pets or animals. Sargent
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Sifre indicated to Coughlin upon bringing 7 other RPD Officers to "respond" to Coughlin 911 call
upon the violent roomates making menacing statements and gestures in response to the
disappearance of Coughlin's dog, that it was merely a "matter for animal control" and that Sifre was
arresting Coughlin because "you keep placing yourself in situations where you are a victim", and
despite that statement being captured on tape, DDA Zach Young continues to prosecute that case.
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DDA Young and Coughlin's public defender did seek to prevent Coughlin from becoming aware of
their attempts to "reduce" that gross misdemeanor to one that would invoke an SCR 111(6) "serious
crime" Petition by Bar Counsel if a conviction is procured, as just because a charge is conveniently
13
reduced to "resisting arrest", and therefore a "lesser offense" (gross misdemeanor versus
14
misdemeanor) does not mean the impact on one's life would be less, especially in light of SCR 111.
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Dogan failed to apprise Coughlin of DDA Young attempt to so amend the Complaint in that Matter
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in his July 31st, 2012 filing in RCR2012-065630, despite Coughlin previously demanding notice of
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any and all filings by either side. Sandwiched between the two arrests in 48 hours by RPD Sargent
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Sifre, was an intervening pull over by the same RPD Officer whom wrongfully arrested Coughlin on
20
August 20th, 2011 in RCR2011-063341, Nicholas Duralde, along with 5 other cops assisting Duralde
21
in notifying Coughlin that his license plate was suddenly missing, shortly after Coughlin was
22
released from jail, on January 13th, 2012, incident to a "jaywalking" arrest. Coughlin attempted to
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submit a written complaint to the RPD regarding the retaliatory, coercive, pretextual conduct by RPD
25
Officer's Duralde and Ron Rosa, which the RPD rejected on September 7th, 2011)(and unless the
26
Ninth Circuit has a jewel somewhere that was missed, no matter how backwards and ignorant an
27
arrest is, how pretextual or baseless, even for "jaywalking", the police can copy, view, and search
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02899
one's laptop or smart phone (even a practicing attorney advocating on a client's behalf who gets
arrested for summary contempt committed in a the presence of a Judge: Some courts have relied on
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the Supreme Courts holdings in United States v. Robinson, 414 U.S. 218 (1973) and United States
v. Edwards, 415 U.S. 800 (1974) to hold that officers can search arrestees cell phones incident to
arrest, concluding that they are part of the arrestees person. See, e.g., People v. Diaz, 244 P.3d 501
(Cal. 2011); United States v. Finley, 477 F.3d 250 (5th Cir. 2007); United States v. Young, 278 F.
Appx. 242 (4th Cir. 2008); United States v. Mercado-Nava, 486 F. Supp. 2d 1271 (D. Kan. 2007).15
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Robinson and Edwards, decided nearly 30 years ago, should be read narrowly in light of the more
recent holdings in Chadwick and Gant. Searches of the person are distinguishable from searches of
electronic data stored in devices carried by the person, making Chadwick and Gant more directly
applicable).
Judge Nash Holmes has admitted in writing to communications with those involved in that
clandestine, unnoticed, violating of attorney client privilege, February 27th, 2012 MSC in RCR2012065630 involving Dogan and DDA Young. However, that did not, apparently, despite the dictates of
18
NRS 178.405, stop Judge Nash Holmes from continuing on with the traffic citation Trial minutes later
19
in 11 TR 26800, wherein she sentenced Coughlin's to 5 days in jail, and denied a stay to Coughlin
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despite his then representing client's as a lawyer in time sensitive matters, finding Coughlin's guilty of
"summary criminal contempt" (which Coughlin had to report to the United States Patent and
22
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Trademark Office and State Bar of Nevada as a SCR 111 criminal conviction). Curiously, the Order
24
for Competency Evaluation was signed by Judge Clifton, but the RJC's file and docket therein
25
indicate that Judge Schroeder presided over the 2/27/12 1:30 pm Status Conference, despite the fact
26
that the files indicates such a conference was reset, on 2/24/12 to 3/29/12 (RJC Judge Schroeder
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stated to Coughlin at the January 31st, 2012 Hearing on Extending the Stalking and Harassment
02900
Protection Order Richard G. Hill, Esq received within 40 minutes of filing it, on January 12th, 2012,
"do you want to go to jail" upon Coughlin attempting to broach the subject of whether, perhaps, Hill
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was abusing the TPO process to aid in preventing opposing counsel from collectin evidence in
support of a damages analysis incident to a wrongful eviction lawsuit, particularly one of a "wrong
site surgery" variety for Hill's neurosurgeon client, in that Hill utilized a summary eviction
proceeding against a commercial tenant not based upon the non payment of rent...ie, a "wrong site
surgery" to make an analogy Hill's neurosurgeon client might easily grasp.
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As to the purported "summary criminal contempt" Order by Judge Nash Holmes, it is not clear
there is such a "misdemeanor crime" in Nevada. That February 28th, 2012 Order read: "The court
12
finds that the defendant's actions were intentional and done in utter disregard and contempt for the
13
court, and in the presence of the court, for purposes of disrupting and delaying the proceedings and
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dishonoring the rule of law and this court, and constitute the misdemeanor of criminal contempt, a
violation of RS 22.0 I O. Good cause appearing therefore, the following sanctions are imposed: IT IS
ORDERED, pursuant to NRS 22.100, that the defendant be incarcerated at the Washoe County
18
Regional Detention Facility for the term of five (5) days, fro m the time he was taken into custody on
19
this court's order on February 27, 2012, and that sentence shall not be reduced for any reason...."
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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
02901
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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.
In Judge Nash Holmes February 28th, 2012 Order Finding Defendant in Contempt of Court
5
6
and Imposing Sanctions, the Order reads: "9) defendant's lying to the court in response to direct
questions posed by the court with regard to his recording the proceedings". No evidentiary support or
other allegation have been made by Judge Nash Holmes to support that finding. Further, that Order
seems to take an overly narrow view of what is permissible subject for cross-examining a police
10
officer, and at one point, Judge Nash Holmes stated, on the record, that she does not "care about
11
12
retaliation, or bribery, or corrutpion" or words substantially similar to that effect, and the Order itself
13
suggests Judge Nash Holmes finds those subject wholly irrelevant to a criminal prosecution,
14
regardless of the vast body of case law devoted to retaliatory arrests, witness bias, materials not
15
offered to prove the truth of the matter asserted, but rather the witness's state of mind, etc., etc. That
16
Order included the following: "defendant's repeatedly injecting allegations of bribery, perjury, and
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police retaliation into the matter after the court instructed him not to, and directed him to limit himself
to i sues pertaining to the facts of the "Boulevard Stop;" 5) defendant's repeatedly trying to insert
20
"Richard Hill" into his questions and statements when such person was not relevant to the
21
proceedings and the defendant had been ordered to stop discussing that...defendant's continually
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accusing the court of denying him the right or ability to ask questions...defendant' s failing and
refusing to properly examine the witness, despite numerous admonitions by the court to stop
repeating questions, misstating answers, injecting irrelevant material, arguing with the witness and
26
mischaracterizing the testimony. During that proceeding Judge Nash Holmes asked Coughlin "Are
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you recording this proceeding?". Coughlin prefaced his answer with an assertion that he a a
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02902
Constitutional Right now to be coerced into answering such sua sponte interrogation, but answered
truthfully that he was not recording the proceeding at the time that question was posed to him by
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Judge Nash Holmes, though, to be sure, the RMC was recording the proceeding, it is a part of the
public record, and Coughlin surely now has no means of confirming what exactly may have been on
his smart phone or micro sd data card given both were returned to him damaged and with all the data
previously therein erased, though likely not before his privacy had been raped by various local law
enforcement entitites perusing the contents therein under some "search incident to arrest" approach.
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In a letter/complaint/grievance to the SBN from the RMC's Judge Nash Holmes, dated March
12th, 2012, it is written: "We are setting that case for trial and attempting to serve him at the most
12
recent address we have (1422 E. 9th St. #2 Reno NY 89512), although I heard today he may be living
13
in his vehicle somewhere....It is my understanding that Reno Justice Court also has a matter pending
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on this attorney. My Judicial Assistant was contacted by the Washoe Public Defender in February...
and they stated that they represent him in a Gross Misdemeanor matter in RJC...You will have the full
cooperation of myself, the other judges, and the staff of Reno Municipal Court in your pursuit of this
18
matter. Mr. Coughlin has positioned himself as a vexatious litigant in our court, antagonizing the
19
staff and even our pro temp judges on the most simple traffic and misdemeanor matters. I do think
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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,
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and I felt it was important that the audios be included in the materials to be considered by the State
24
Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing law and had
25
appointments with clients. I do not know if that was true, but if so, he could be causing serious harm
26
to the practice of law in Northern Nevada and could be jeopardizing someone's freedom or property
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interests...." Such concern for Coughlin's client's "freedom or property interests" did not result in
02903
Judge Nash Holmes according any real consideration to issuing a stay of any sort to Coughlin prior to
the immediate and unfathomably unexpected summary 5 day jail sentence incident to a traffic citation
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Trial over a California Roll/Boulevard Stop. Why, in a letter date February 14th, 2012, when
Coughlin was still living at his fromer E. 9th St. address, Judge Nash Holmes would have "heard he
(Coughlin) may be living in his vehicle somewhere" is curious, though not at all out of line with
Coughlin's past experience with the some individuals at the RMC and the City of Reno Marshals.
Coughlin has no idea what "pro tem" Judges he ever had any interactions with at the RMC of an
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import whatsoever. The passage wherein Judge Nash Holmes apologizes for "taking two days to get
this package to you" implies a previous communication with the SBN, though hopefully not the sort
of attempts to drum up complaints where none should reasonably issue like that see with the RPD's
13
Office Weaver and Sargent Miller, or in the apparent exorting Richard Hill by the RPD to file a
14
protection order against Coughlin. Further, Judge Nash Holmes went on to issue what are likely void
15
"double jeopardy" violating Orders subsequent to Coughlin filing a notice of appeal on March 8th,
16
2012 of the Contempt finding. It is improtant to note, the February 28th, 2012 Order Finding
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Defendant in Contempt and Imposing Sanctions, which purports to issue a conviction for
19
"misdemeanor criminal contempt" was never received by Coughlin, despite it purportedly being
20
mailed to Coughlin's former home law office address at a time that the RMC had Coughlin's then E.
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9th St. address, and despite Coughlin having a change of address on file with the USPS at that time
22
(though there were issues with getting the USPS to process or recognize that incident to the domestic
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violence against Coughlin on E.9 9th St.). Regardless, Coughlin only ever first even saw the
25
February 28th, 2012 Contempt Order, and probably even then did not realize it purported to issue
26
"misdemeanor criminal contempt" conviction (Coughlin still has some confusion as to the distinction
27
between criminal and civil contempt and a reading of the NRS 22.010 cited does little to alleviate that
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02904
confusion, though Coughlin has gathered various ALRs and AmJurs on the appealability of summary
contempt findings and does not belive Judge Nash Holmes Order is sufficiently specific under the
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6
Houston decision (Judge Pomeranz, handcuffs, etc). Further, Bar Counsel King has gone on to
threaten Coughlin extensively with the use of sections of subsequenttly issued Orders by Judge Nash
Holmes that purport to make findings "by clear and convicing" evidence of various violations of
RPCs for conduct that Judge Nash Holmes already entered an Order on February 28th, 2012. That is
double jeopardy and or law of the case, and not a proper basis for delaying the hearing required under
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12
SCR 111(8), etc. The SBN and King can have it if they want it with Coughlin, but they ought to
have to do it in compliance with the rules, period, rather than have King get down on all fours an
surreptiously crawl behind a standing Coughlin's knees, only to have whoever give Coughlin a swift
13
push to the torso, causing him to topple over backwards. And the SBN should be prevented from
14
doing its bit where it shows Coughlin a flower, prompts him to smell it, then manipulates some
15
apparatus built into what is actually a phony flower that sprays water in Coughlin's face. And then
16
there is the cans of mixed nuts the SBN gave Coughlin that actually contained projectile confetti sorts
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21
of material.
Hill applied for a TPO against Coughlin on January 12th, 2012 when Hill noticed Coughlin
peacefully filming from the public sidewalk at Coughlin's former home law office Hill's crew
throwing into a dump truck the property that Coughlin was unable to remove in the scant 13 hours
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23
accorded him in the Order "Resolving" Coughlin's Motion to Contest Personal Property line, on
24
December 24th, 2011, especially where Hill placed a chain link and padlock on the backyard gate to
25
Coughlin's former home law office, making removing many, many items unfeasible. Hill failed to
26
remove the chain link padlock until only a couple hours remained to move a great deal of property,
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28
and said padlock was only placed on that back yard gate in the one or two days immediately prior to
02905
the time allowed to remove property....Further, despite billing Coughlin some $1,060 for "securing
the property" (one would think paying $460 under NRS 118A.460 for "storage" of personalty might
3
4
5
6
include "securing" it, but no, it would not...and Hill's contractor saved on expenses incident to such
"securing" by using Coughlin's own plywood to board up the back porch. Speaking of the extent to
which Judge Nash Holmes continued on to conduct the Trial in 11 TR 26800 despite the 2/29/12
Order for Competency Evaluation signed by Judge Clifton and file stamped 1:31 pm, despite the
statutory dictate that "the other departments" "shall suspend any other proceedings relating to the
9
10
11
12
defendant until to defendant is determined to be competent", found in NRS 178.405, DDA Young
himself violated NRS 178.405 in that his 2/29/12 Opposition to Defendant's Motion to Appear as Cocounsel bares a file stamp of 2:55 pm. Please correct the docket in this regard, as well as revising it to
13
reflect all of Coughlin's filings, which were all file stamped, yet are not indicated on the docket,
14
especially the Notice of Appearance Coughlin filed, while Coughlin was still a licensed attorney, in
15
addition to any Substitutions of Counsel Coughlin filed so very long ago (no matter what DDA
16
Young tries to argue about how "untimely" Coughlin's attempts to be rid of the public defenders
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21
obstructive presence are).

Additionally, there is a clear retaliatory animus evince by both Dogan and DDA Young's
participation in the Feburary 27th, 2011 "clandestine" Status Conference where Coughlin's filing of
February 17th, 2011 in that same case RCR20120-065630 That February 14th, 2012 filing by
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23
Coughlin in RCR2012-065630 was attached by Pat King and or J. Thomas Susich in the SCR 117
24
Petition in 60975 (and King has repeatedly threatened to attach it to or reference it in the SCR 105
25
Complaint he keeps hyping in an ill advised attempt to get Coughlin to sign up for a SCR 117 trip)
26
and referenced by Judge Nash Holmes in her various Orders and written complaint to the SBN when
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28
she cites Coughlin with "quoting lyrics to rock songs" in a filing was critical of Dogan's work as a
02906
public defender for Coughlin, especially where Dogan was attorney of record and failed to appear for
a hearing...Never mind that the only lyrics to any songs that were quoted by Coughlin in any filings
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so far was the quotation to a rap song in the February 17th, 2012 filing in the case that Dogan
represented Coughlin on in Reno Justice Court, RCR2012-065630, wherein an Order for
Competency Evaluation was entered at 1:31 pm on February 29th, 2012, whereupon, shortly
afterwards, Judge Nash Holmes continued on to hold the traffic citation Trial from which the
"summary criminal contempt" charge underpinning most of Bar Counsel King's SCR 117 Petition
9
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12
and from which most of King's threats of a SBN v Coughlin Complaint seem to rely (to the extent
such a Complaint would rely on anything other than King's typical legal drivel, which continually
fails to cite to any legal authority whatsoever and evinces the work of a man entirely unfamiliar with
13
Lexis, Westlaw, AmJur., ALR, Proof of Facts, or any other bastion of actual lawyering. The lyric
14
Coughlin quoted in that February 17th, 2012 filing (which was necessitated by the fact that Dogan
15
failed to appear for a court date on February 13th, 2012 for which he and Coughlin had, when they
16
met in person and spoke for over an hour about the case on or about February 7th, 2012 agreed
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Dogan would appear on Coughlin's behalf and that Dogan was already "attorney of record" in the
19
matter and assigned to the case) was quoted merely as a commentary on the spiritual choices one is
20
faced with various local power brokers and their agents are behaving like goons: "Okay, your a goon,
21
what's a goon to a goblin?". Hardly a rationale for pulling some lawyers ticket, Mr. King. Nor for
22
submitting a complaint questioning a lawyers competency to the SBN.
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SCR Rule 111(8). Attorneys convicted of crimes.

"8.Referral to disciplinary board. Upon receipt of a petition filed under
subsection 4 of this rule, demonstrating that an attorney has been convicted of a
serious crime, the supreme court shall, in addition to suspending the attorney in
accordance with the provisions of subsection 7 of this rule, refer the matter to
the appropriate disciplinary board for the institution of a formal hearing
02907
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2
before a hearing panel in which the sole issue to be determined shall be the
extent of the discipline to be imposed..."
SCR Rule 102(2). Types of discipline:
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Misconduct is grounds for: "2. Suspension by the supreme court. A suspension of

6 months or less shall not require proof of rehabilitation; a suspension of more
than 6 months shall require proof of rehabilitation to be demonstrated in a
reinstatement proceeding under Rule 116...."
Given that the Board and the SBN are and have effectively denied Coughlin a timely hearing
called for by the Court's Order and SCR 111(8), and now have failed to provide an "immediate
hearing" pursuant to Coughlin's filed and served SCR 102(4)(d) Petition in case number 61426.
SCR Rule 116. Reinstatement: "1. Order of supreme court required. An
attorney suspended as discipline for more than 6 months may not resume
practice unless reinstated by order of the supreme court. 2.Procedure for
reinstatement. Petitions for reinstatement by a suspended attorney shall be
filed with bar counsel's office, which shall promptly refer the petition to the
chair of the appropriate disciplinary board. The chair shall promptly refer the
petition to a hearing panel, which shall, within 60 days after referral, conduct
a hearing. ...
4. Tender of costs in advance. Petitions for reinstatement under this rule
shall be accompanied by an advance cost deposit of $1,000 to cover
anticipated costs of the reinstatement proceeding."
The 60 days mentioned above only further highlights the potential for a contempt finding
where the SBN and Board have failed to schedule a hearing for this matter despite Coughlin filing an
20
Opposition to the SCR 111 Petition, or at least submitting an Opposition as early as May 24th, 2012,
21
and eventually getting the Court to file something in that vein on June 10th, 2012, which has remain
22
unchallenged by Bar Counsel. Bar Counsel appears rather busy with other things, and any such
23
overburdened condition will only be exacerbated by a protracted involvement with Coughlin, who
24
25
can rake it a little if anyone hasn't noticed yet. King's close and prolonged involvement with Richard
26
G. Hill, Esq. (the were opposing counsel on one of the biggest cases of either of their careers, the
27
March 2012 reported decision in Milsner v Carstarphen)
28
02908
AFFIRMATION Pursuant to NRS 239B.030
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4
The undersigned does hereby affirm that the preceding document does not contain the social security
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7
Declaration: I declare under penalty of perjury pursuant to NRS 53.045 that,

to the best of my knowledge, the information contained herein is true and
correct.
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9
Respectfully submitted this: October 2nd, 2012,
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11
/s/ Zach Coughlin, signed electronically
12
Zach Coughlin, Esq.
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PO BOX 3961
Reno, NV 89505
Pro Per Attorney
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02909
Proof of Service:
On this date. !. Zach Coughlin electronically served a true and correct copy orthe foregoing
document to all registered electronic filers or those otherwise consenting to electronic service in a
waiver of the application ofNRep as set forth in SCR 109, and to those whom are not I placed a true
and correct copy of the foregoing document in the USPS mail on this date and or complied with all
service requirements set forth in SCR 109:
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7
Patrick O . King, Esq. Assistant RaT Counsel

9456 Double R. Blvd Suite B
Reno, NY 89521
David A Clark. Esq., Bar Counsel
State Rar of Nevada
J0
Address: 600 East Charkston Blvd.
II
Las Vegas , NV 89104
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Fax number: 702-385-2878
14
J. Thomas Susich, Esq., Chairman NNDB

16
Address: 1675 E. Prater Way, Suite 103
17
Sparks. NV 89434
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Fax number: 775-284-9513
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Dated this October 2nd. 2012
23
Is! lach Coughl in

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Zaeh Coughlin
Pro Per Attorney
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- 62/62MOTION FOR ORDER TO SHOW CAUSE REGARDING IMPROPER ATTEMPT BY BAR COUNSEL AND
POSSIBLY, NNDB TO DELAY AND OBSTRUCT HEARING REQUIRED BY COURTS JUNE 7TH, 20 12 ORDER
IN CASE 60838 AND COUGt-ILIN'S SCR I02(4)(d) PETITION IN CASE 61426
02910
02910
______
-' _~
.
.
_ _ _J__ ._ _ _ _ .. _ _
.
~"._.
_ __
2
J
,
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STATE BAR OF NEVA DA
'}
,
9
TATE BAR OF NEVADA.

)
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Complainant.
) CASE NUMBER ,NG12-0204, NG -O 35 ,

NG 0 434
s.
"
) MOTION TO OISMISS
ACHARY B. COUGHLIN. ESQ .
13
Bar No. 9473
14
15
espondcnt.
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17
I~
_________________________
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"
21
NOTICE OF APPEARANCE
COMES NOW. ZAC HA RY BARKER COUG HLI N, ESQ .. and fil es this limited. special
arpaarncc for the purpose arfili ng this Motion to Dism iss for Insufficient Service of Process.
22
fACTS
2J
, . SBN Clerk
or
25
26
SCR 105(2):. "Commencement of formal proceedings. Formal disciplinary proceedings

27
are commencl!d by bar counse l fil ing a wrinen complaint in the name of the state bar.
The complaint shall be sufficiently clear and specifie to inform the aUoro!:), of the
(harees aeaj nst him or her and the underlyim: conduct sUDDorCing tbe cbarges. A
-
I /S-
Motion 10 Dismiss
02911
02911
copy of the complaint shall be served on the attorney and it shall direct that a verified
response or answer be served on bar counsel within 20 days of service; the original shall
be filed with bar counsel's office. The time to respond may be extended once by the chair
for not more than 20 days for good cause or upon stipulation of the parties. In the event
the attorney fails to plead, the charges shall be deemed admitted; provided, however, that
an attorney who fails to respond within the time provided may thereafter obtain
permission of the appropriate disciplinary board chair to do so, if failure to file is
The SBN has admitted, via Clerk of Court Laura Peters, that not only has the SBN agreed to
1
2
3
4
7
8
and already set for hearing the referral to the Board called for in the Nevada Supreme Court's June
7th, 2012 Order Temporarily Suspending Coughlin's License to Practice Law, but also that any SBN
9
10
11
v. Coughlin Complaint Bar Counsel Pat King wishes to throw together at the last minute in an
attempt to skirt the limits of the jurisdiction granted the Board in the Court's June 7th, 2012 Order,
12
given King's stated intention to attempt to make a "combo-hearing" out of the Hearing called for in
13
that Order, despite its "sole purpose" language and the same found in SCR 111(8), in addition to the
14
15
16
17
fact that given Coughlin's Petition in 61426, under SCR 102(4)(d), requires an immediate hearing,
and that Petition was duly served on August 13th, 2012, both on the Board via Chairman Susich and
both offices of the SBN, via Clark and King, and Peters personal receipt thereof, which the SBN has
18
still failed to respond to (much less challenge the reconsideration motion in 60383, etc. (who is
19
talking about who's competence, again?)...
20
21
22
Further, it is a virtual certainty, given Pat King's established m.o., that any such Complaint he
files, upon it being properly served and not insufficient due to illegibility of the photocopies of any
23
exhibits (take it from me given 60302 and 60317, I know...) will be wholly insufficient in that it will
24
in no way comply with SCR 105(2), and so, as a preemptive measure, please be advised that any
25
26
27
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such Complaint ought take particular care to state who brought what grievance, and avoid
conclusory assertions about something "lacking legal merit" or otherwise broadly "demonstrating
incompetence".
- 2/5 -
Motion to Dismiss
02912
-..
--,
-.--".-.-,.,...-.-----......""----
. - --- --..-, --.~---"' ~---- '
.....
,-
1
2
3
- --_._--"..
------~.
Further. any assellions by (he SBN that sending such a Complaint via cellified mail,
especially where a phone call to SBN Clerk of Court Peters on September 14th, 2012 yie ld her
giving Coughlin the SBN's word that given the SBN's apparent attempt to serve Coughlin via
Certified mail some Complaint Pat King apparently followed through o n in his promise to thrown
together haphazardly in ho pes of defeating any due process accorded the hearing on September 25th.
2012, would not require a response at kast until the SBN m:eives back as unclaimed some second
attempted certified mailing under SCR 109.
AFFIRMATION Pursuant to NRS 2396,030

11
The unders igned does hereby affirm that the flreceding document does not contain the socia l security
13
Respectfully submitted this: September J 6th. 20 12>7"~
and submitted for filing
~~~~~1~5~th ,
2 01
and submitted for filing again on October 15th, 2012

15
ugh!in, Esq.
PO BOX 396 1
16
Reno, NV 89505
Pro Per Attorney
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2B
- 3/5 -
MOlino to Dismiss
02913
02913
,.----- - - - -------
_-_. __ ._-__
- ----__..
.....--
.
1
INDEX TO EXHIBITS
2
3
I. Exhibit I : 9 9 12 Lelter to Susich and King
,
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6
7
8
10
11
12
13
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18
19
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21
22
23
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26
28
- 515 Molion to D jsmjs"
02914
02914
--------------------------------------- ---------
Proofo(Scrvicc;
2
On this date, I. Zach Coughlin electronically served a true and correct copy of the fo regoing
document to all registered electronic filers or those otherwise consenting to electronic serv ice in a
waiver of the application of NRep as sel forth in SCR 109. and In Iho,"c whom are nOl I placed a lrue
and corTe!:' copy urlh~ foregoing document in the USPS mail on this date:
Patrick O. King, Esq . Assistant Bar Counsel
9456 Doub le R. Blvd Suite B
Reno. NV 89521
David A Clark. [ sq., Bar Counsel
State Bar of Nevada

Address: 600 East Churleston Blvd.
10
11
12
Las Vegas , NV 89 104

Phone Numbe r: 702382-2200
Fax number: 702-385 2878
13
14
J. Thomas Susich. Esq ., Chairman NNDB

Address: 1675 E. Pratt:r Way. Suite 103
Sparks. NV 89434
17
Phone Numbe r: 775-284-9533

Fax number: 775-284-95 13
19
20
21
22
2012
23
24
Zach Coughlin
Pro I'er Attorney

26
28
- 415-
Mplign to Dismiss
02915
02915
-- ~----.-~-.--.--.-~-. -------.- .-------.--- ---~-.-
._--
...-,-,
FILED
1
o~~
STATE Ml? OF NEVAD
STATE BAR OF NEVADA

5
6
7
8
9

NOTICE OF FORMAL HEARING
Complaina nt,
VS.
ZACHARY 8. COUGHLIN
Bar No. 9473
1I _____-.!R~e~s'Ep~o!!nd!!'e"'n.!!I~._
_ _ _ _
10
PLEASE TAKE NOTICE that the formal hearing in the above-entitled action has been
11
!:lcheduled for Wednesday, November 14.2012, beginning at the hour of 9:00 a.m. The hearing
12
wi ll be conducted al the Reno office of the State Bar of Nevada, located at 9456 Double R Blvd . Ste.
13
B, Reno, Nevada. You are entitled to be repre!:lcnted by counsel, to cross-examine witnesses, and to
14
present evidence.
15
DATED this
1<.
16

STATE BAR OF NEVADA
DAVID A. CLARK, Bar Counsel
17
18
19
20
21
By;
="7?-c:i?:z/~~O~/?,'7,,,-:-;o-~-,-- _ _
Patrick O. King. ACstant Bar Counsel
9456 Double R. Blvd., Ste. B

Reno, Nevada 89521
(775) 328-1382
Attorney for State Bar of Nevada
22
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25
1
02916
02916
-_...
_,
---------..
-
--~
...--...- ..
--
... ...
--.-
--- ~----.---,-,-
Case No: NG12-0204 , NG12-0435 and NG12-0434
STATE BAR OF NEVADA

3
4
Complainant,
VS.
ZACHARY B. COUGHLIN
Bar No. 9473
Respondent.
)
)
)
)
)
)
)
)
)
PLEASE TAKE NOTICE that the following is a summary of evidence and list of witnesses
10
11
which may be ofTered against Respondent at the time of the formal hearing on the above-entitled
12
complaint.
13
A.
Documentary Evidence
I.
14
Any and all documentation contained in the State Bar of Nevada's file regarding
15
grievance files NG 12-0204, NGI2-0435 and NG 12-0434, except for screening materials and Bar
16
Counsel work product. Pursuant to SCR 105 (2)(c) Respondtmt may inspect the State Bar file up to
17
three (3) days prior to the heari ng.
18
B.
19
20
21
22
23
24
Witnesses and Brief Stattmcnt of Fads

J.
Judge Dorothy Nash Holmes will appear by phone to testify with regard to
Respondent's conduct in connection with Case No. II-TR-26800 12 in Reno Municipal Court.
2.
Judge Kenneth R Howard is expected to testify about Respondent's conduct in
connection with Case No. 11 CR 21176 21 .
J.
Dr. Matt Mcrliss is expected to testify about the situation leading up 10 Respondent 's
arrest for trespassing.
25
2
02917
02917
. -'_. _
___ _ _ _
4.
5.
6.
7.
8.
9.
10.
Karen Stanek, Reno Justice Court employee, is expected to testify about Respondent 's
Robin Baker, Reno Justice Court employee, is expected to testify about Respondent's
Dr. Richard T. Bissett is expected to testify about the examination he performed on
Respondent in preparation for a competency hearing in Case No. 12-0376.
15
16
S teve T uttle, Reno Justice Court employee, is expected to testify about Respondent's
conduct when visiting the court complex.
13
14
Attorney Daniel Wong is expected to testify about Respondent 's conduct in Reno
conduct when visiting the court complex.
11
12
Scott Coppa. Marshall for the Reno Municipal Court is expected to testify about
conduct when visiting the court complex .
10
Attorney Richard Hill, Esq., is expected to testimony with regard to Respondent's
Justice Court.
7
8
Respondent 's disruptive behavior on March 22, 2012.
5
6
_ _ _ _ _ __
conduct in connection with Case No. CV 11-03628.
3
4
.A"'_. _ _~ _. ~ . _ . __ _ ._ . ~ _ .. _ _ _ _ _ __ __.. __ _ _ _ _ _ _ _ _ _
II.
Dr. Mary R. Vieth is expected to testify about the examination she performed on
Respondent in preparation for a competency hearing in Case No. 12-0376.
17
12.
A member of the staff of the State Bar of Nevada Ethics Department is
1B
expected ,to testify as Custodian of Records regarding documentati on contained in the records of the
19
State Bar of Nevada and Respondent's discipline and licensure history.
20
1/1
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1/1
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1/1
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3
02918
02918
-- ---.--.----~ - ~
3
4
13.
_ ~- ... -~...-.-- -~--.-- - .-------.---.----.------.....
Zachary B. Coughlin is expected to testify regarding the facts and circumstances in all
three disciplinary matters.

The State Bar of Nevada reserves the right to supplement this disclosure.
DATED this ~ day of October, 2012.

STATE BAR OF NEVADA
DAVID A. CLARK, Bar Counsel

6
7
By:
8
-T'.-d 0/7
Patrick O. King, Assistant Bar Counsel

9456 Double R Blvd., Ste. B
10
Reno , Nevada 8952 1

(775) 328-1382
Anomey for State Bar of Nevada
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4
02919
02919
1. ArtIcle AddresHd to:
If YES, enf8' ~ ~ billow:
G 9T~ Sf-
'('9 <>/2-
Zachary 8 . Coughlin
Post Office Box 3961

Reno. NV 89505
---
,_
..... _ _
No
7010 2760
ooq ~42<~ ,tt!IJU~ <
PS form 3811, February 2004 _ _~ Return A:.Ipt ~

._ _ _
.. , .... . _
~
.
..~~~':.40
." H .., .__ _ "';. .. ,
._
_
02920
02920
!TED STATES P OSTAl SERVrc<. : :'-" ,, ',
...
'J ~~'--- flfrs1-c'i':-eaid
- ,~. .;:;;1- -~~
".
.... .usPS _ . . . ,. . .
... -
.1':':) "..1'10. . I .ti) :'..!. 't>' it\.II:. l
_l _ ~::. "
. .eerTfiit ~lO_.:....
"'C'-' . . _, -,,-, . ' - , .
Sender: Please print your name, address, and ZIP+4 in this box
. "n .
STATE BAR O~ NEVADA

9456 Double R Blvd., Src. B
Reno, NV 8,)S2 1-S9n
WWWo""bar.o'T
1/"ld,/",'./,,,/,I,,,/I,/, ,/I, ,lu./,/,,/,/J .,,',I,,II .. ,,,
02921
02921
_ _-_ ..
..
.--.--.------.------.- -.... ----_.__. ------.-.
__._-_._ _--..
,-
The undersigned hereby certifies that a true and correct copy afthe foregoing Notice of
Formal Hearing was deposited in the United States Mail at Reno, Nevada, postage fully pre-paid
thereon for certified and first class mail addressed to the fo llowing:
Zachary B. Coughlin
Post Office Box 396 1

Reno, NV 89505
DATED this 121hday of October, 2012.
ers, an employee of
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11
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us
Post.11 Service
CERTIFIED MAIL
14
RE CEI PT
(Ooml!~ fl~ \1.11/ Only NO /f'$Jrallcr CO'''''' !) '' P,(mJrd.
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'"
c
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C
C
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'"
0-
-~,~
_.
""....
..
(~Reqund)
~~F ..
( E_ ~
TOlai ,..,... I F_
n>
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02922
02922
_____ _.--_
.... _ .._.
.,
.--.--.-~. -~--''''-'' P .~------------~--~"", --------
Case No: NG12-0204. NG12-0435 and NG12-0434
STATE BAR OF NEVADA

4
STATE BAR OF NEVADA.
5
Complainant,
6
vs .
NOTICE OF INTENT TO PROCEED ON

A DEFAULT BASIS
ZACHARY B. COUGHLIN
Bar No. 9473
9 11 ___ __ ~R~e~s~po~n~d~e~n~t._ __ _ ___

TO:
10
11
Zachary B. Coughlin
Reno . NV 89505
PLEASE TAKE NOTICE THAT unless the Slate Bar receives a responsive pleading in
12
13
the above-captioned matter by October 24, 2012, it will proceed on a defautt basis and the
14
charges against you shall be deemed admitted. Supreme Court Rule 105(2) states in
15
relevant part:
16
A copy of the complaint shall be served on the attorney and it shall direct that
a verified response or answer be served on bar counsel within 20 days of
service ... In the event the attorney fails to plead , the charges shall be
deemed admitted; provided, however, that an attorney who fails to respond
within the time provided may thereafter obtain permission of the appropriate
disciplinary board chair to do so, if failure to file is attributable to mistake,
inadvertence, surprise , or excusable neglect. {Emphasis added .}
17
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11/
21
III
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11/
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1
0 29 23
02923
__._----
._--- ----_.
1
2
Another copy of the Complaint previously served upon you accompanies this Notice.
Dated this 9th day of October, 2012
STATE BAR OF NEVADA

David A. Clark, Bar Counsel
5
6
By:
~~K'?ni~;stant
Bar Counsel
9456 Double R Blvd., Ste. B
Attorney for State Bar of Nevada
(775) 329-4100
10
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2
02924
02924
- -. ~ "
....-..
~~---. -
.. - ~ -~ - . -
- ---.--- - - - .....---- .---...

..
....
~-.- -.-
................
- - . - -- -~ -"
CERTIFICATE OF SERVICE BY MAIL
The undersigned hereby certifies that a true and correct copy of the foregoing Notice
of Intent to Proceed on a Default Basis was depOSited in the United States Mail at Reno,
Nevada, poslage fully pre-pa id thereon for certified mail, addressed to: Zachary B. Coughlin,
Post Office Box 3961 , Reno, Nevada 89505.
Dated this 9th day of October, 2012 .
7
8
9
aura eters , an employee of

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02925
02925
---- ---- '"-- ._------,- ----------_._-_. .------- ...

.
.
-
.....
Reno/Carson Messenger Service,lnc.
Invoice #: 14600
Dale: IMl6l2012
185 Martin Street
Reno .NV 89509

775.322.2424
Federal Tax 10: 88-0306306

NVSTAlELlC#322
Amount Due: $0.00

Phone number: 775-3294119
Fax number:
Email A<idress:LAURAP@NVBAR.ORG
Requestor. L. PETERS
Your File# COUGHLIN
Service '15653: ZACHARY B. COUGHLIN. ESQ., BAR NO. 9473
Manner of Service: NON-SERVE
Service DIllcfT'ime:1Ml6l2012 12:00 PM
Service addnll:94S W 12'n-l ST RENONV 89503
Served by:JOHNNO LA1ETICH
I~""'"
1:-
STATE BAR OF NEVADA NORlllERN DISCIPLINARY BOARD

STATE BAR OF NEVADA v. ZACHARY B. O)UGHUN, ESQ., BAR NO. 9473
Service
n......_,COMPLAINT:, flRST DESIGNATION OF HEARINCi PANEL MEM"BERS
......... uu'""
CloSEt: NGI2-0204. NGI2-D43S AND
NGll-0434
Strnee Noles
Service Comments:
O9IUf2\)llll;22
UFI' AN01HElt MESSAOe wrnt VOICH MAlL
~1211 :+4
AGAIN CAU..ED, WR COUOHUN ,o.NSWEltED. TllEH HUNO UP. AFFlAHl'

RKl.OWED WTT'H It. TE:XT aUT RECEIVED NO RESPONSB.
09i2 1
12012 11:19
CAlLED AND ILPT MESSAGE WITH VOICE MAn. ALSO 11!X1ID

SUBJECT.
09I21J2012 10;0:1
JOHNNO CAU.I!O CLIENf': ALSO CAu.ro ZAOf AND U!Fl' UESSAOB
Standard. Service
$0.00
TOTAL CHARGES:
$0.00
BALANCE:
$0.00
02926
02926
__ ._..- -.-.-_
...
--.--- ----. - -------.,~--.----.---
----.-.~---
AUG 2 3 2012
1
~~
SWE EAR OF NEVADA
STATE BAR OF NEVADA

4
5
6
7
8
Complainant.
vs.
ZACHARY B. COUGHLIN, ESa.,
Bar No. 9473
Respondent.
PLEASE TAKE NOTICE that pursuant to Supreme Court Rule ("SCR") 105(2) a
10
11
12
COMPLAINT
VERIFIED RESPONSE OR ANSWER to this Complaint must be filed with the Office of Bar
Counsel, State Bar of Nevada, 9456 Double R Boulevard, Ste. B, Reno, Nevada, 89521 ,
13
within twenty (20) days of service of this Complaint.
14
addressed in SCR 109.
15
16
Procedure regarding service is
Complainant. State Bar of Nevada rState Bar'). by and through its Assistant Bar
Counsel Patrick
o. King. is informed and believes as follows:
17
Zachery Coughlin ("Respondent"), Sar number 9473, is a member of the State Sar of
18
Nevada admitted on March 25. 2005. Respondent's date of birth is September 27. 1976.
19
The address that Respondent has on file with the State Bar of Nevada. in accordance with
20
Rule of Professional Conduct ("RPC") 79(1)(a) is Post Office Sox 3961 , Reno NV 89505.
21
Respondent engaged in acts of misconduct warranting the imposition of professional
22
discipline.
23
The State Bar alleges as follows :
24
1.
25
Multiple grievances were received by the Office of Bar Counsel between the
period of January 14 and March 15, 2012, concerning Respondent.
Due to the serious
02927
02927
allegations of misconduct, grievance files were opened and an investigation was initiated by
Assistant Bar Counsel Patrick King.
2.
Respondent was advised of the grievances via U.S. mail, e-mail and by a brief
meeting with Mr. King at the State Bar Office in Reno. Respondent did not cooperate with
the investigation and rather than respond to the grievances as requested, Respondent sent
non-responsive and disparaging e-mails.
8
9
10
11
12
13
3.
Respondent has not made a request to be placed on disability status, nor has
he acknowledged that he may have mental infirmity, illness, or addiction.

4.
The investigation of the grievances against Respondent shows a serious
pattern of misconduct.
5.
On September 9, 2011 , Respondent shoplifted a candy bar and cough drops
from a Wal-Mart store with an approximate value of fourteen dollars ($14.00). On November
30, 2011, Municipal Court Judge Kenneth R. Howard found Respondent guilty of the offense
14
of Petit Larceny, a violation of RMC 8.10.040.
Respondent appealed the judgment of
15
conviction. The judgment of conviction was affirmed on appeal.
See Exhibit 1.
16
6.
During the trial Respondent's conduct was so disruptive that Judge Howard
17
1B
found Respondent in direct contempt of Court and sentenced him to serve three (3) days in
jail. See ExhiM 2.
19
7.
20
21
22
23
24
25
On August 20, 2011 , Respondent was arrested on a second larceny charge for
allegedly stealing a cell phone. Those charges are currently pending in Reno Justice Court.
8.
Respondent was again arrested on January 13, 2012, for allegedly abusing 911
emergency services, a gross misdemeanor.
9.
On February 21, 2012, Respondent filed a document entitled, Notice of
Appearance. Entry of Plea of Not Guilty. Waiver of Right to Arraignment: Motion to Dismiss
2
02928
02928
in one of his pending criminal matters, Case No. RCR-2012 065630, City of Reno v. Zachary
Coughlin. The document clearly shows Respondent's unprofessional, disruptrve conduct,
and lack of respect for the court and opposing counsel .
5
6
10.
Respondent was arrested on November 13. 2011 by Reno Police Department
and charged with trespassing, a misdemeanor, for which he was later convicted.
11 .
The circumstances leading to the above-mentioned arrest are as follows: at an
eviction hearing Justice of the Peace Peter Sferrazza ordered that Respondent vacate the
home he was renting effective November 1. 2011 . After the locks were changed and the
10
11
12
13
14
eviction notice was posted on the front door the owner, Dr. Merliss, discovered that someone
had broken into the home and was barricaded in the basement. The Reno Police tried to
coax whoever was in the basement to open the door. Dr. Merliss was forced to kick open the
door where the Reno Police found Respondent. Respondent had broken into the home and
was living in the basement.
Respondent was arrested for criminal trespass and was
subsequently convicted of that charge.
15
12.
Respondent, representing himself as co-counsel, filed a 36-page motion to
16
dismiss on March 5, 2012 .
The motion was denied by Judge William Gardner and was
17
determined to be without merit. The motion, on its face, demonstrates that Respondent lacks
18
competence to practice law.

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20
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13.
Once Respondent was evicted, an order was obtained to remove his
belongings from the home. Respondent interfered with the contractor who was hired to
remove Respondenfs personal belongings. The police were called and after talking with
Respondent they recommended that he find something else to do. Respondent refused to
follow their advice and was subsequently arrested by the Reno police.
25
02929
02929
14.
In the case of City of Reno vs. Zachary Barker Coughlin, Case No. 11 TR
26800 21 , a trial was held on a traffic citation issued to Respondent. The matter was called
at approximately 3:00 p.m. and concluded without a verdict at about 4:30 p.m. after the court
held Respondent in criminal contempt of court for his behavior and activities committed in the
direct presence of the court during trial.
15.
In a March 12, 2012 Order, Municipal Court Judge Dorothy Nash Homes found
by "clear and convincing evidence" that Mr. Coughlin committed numerous acts of attorney
misconduct. See Exhibit 3.
9
10
11
12
13
Judge Holmes explained in her Order that after Respondent
served his five..<Jay contempt of court sanction imposed by the court on February 27,2012,
Respondent fax-filed to the court a 224-page document. Judge Holmes found that the
document contained rambling references to his personal life and was incoherent.
16.
In her Order, Judge Homes found by clear and convincing evidence that
Respondent violated Rule of Professional Conduct ("RPC") 1.1(Competence), RPC 1.3
14
16
Counsel), RPC 8.4 (c) (Engaging in Dishonesty, Fraud , Deceit or Misrepresentation) and
17
RPC 8.4(d) Engage in conduct that is Prejudicial to the Administration of Justice).
18
17.
Respondent filed Affidavits of Poverty in Support of his Motion to Proceed
19
Infonna Pauperis, wherein he fails to disclose that he is a licensed attorney and instead
20
under Employment and Self-Employment he identifies himself as a "Jack of All Trades".
21
22
23
24
25
18.
Despite a claim of poverty in the above mentioned affidavits, Respondent told
the Court that his incarceration for contempt would adversely affect his clients .
19.
On March 22, 2012, Respondent appeared at the Reno Municipal Court
wearing (smiley face) flannel pajamas. Respondent became argumentative and Marshals
were called to ask him to leave.
02930
02930
. .-----.-.---..
25.
----~- - ---- ~---.- ........
--.. . . . .
-~,-.~
_ . . . _ ------_ . . . . ._--..
On April 10, 2009, District Judge Linda Gardner of the Second Judicial District
Court executed an "Order After Trial," in case No. DV08-01168. In that case, Respondent
represented the Defendant/Counter Claimant.
Respondent's inappropriate behavior in part as follows:
The most troubling aspect of this case was Mr. Coughlin's rude, sarcastic and
disrespectful presentation at trial ; Mr. Cough li n's inability to understand a balance
sheet; his failure to conduct discovery and his lack of knowledge with regard to
the rules of evidence and trial procedure. All of this was compounded with a
continuously antagonistic presentation of the case that resulted in a shift from a
fairly simple divorce case to a contentious divorce trial lasting an excessive
amount of time.
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7
9
10
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13
In her Order Judge Gardner explained
27.
In light of the forgoing Respondent violated RPC 1,1 (Competence); RPC 1.2
(Diligence); RPC 3.1 (Meritorious Claims and Contentions); RPC 3.3 (Candor to the
Tribunal); RPC 3.4 (Fairness to Opposing Party and Counsel); RPC 3.5 (Impartiality and
Decorum of the Tribunal); RPC 4.1 (Truthfulness in Statements to Others); RPC 4.4
(Respect for the Rights of Third Persons); RPC SA (Relations with Opposing Counsel); RPC
14
8.I (Disciplinary Matters); RPC 8.2 (Judicial and Legal Officials); and RPC 8.4 (Misconduct).
15
WHEREFORE, Complainant prays as follows :
16
1.
That a hearing be held pursuant to Nevada Supreme Court Rule 105;
2.
That Respondent be assessed the costs of the disciplinary proceeding
17
18
pursuant to Supreme Court Rule 120(1); and
19
III
20
III
21
III
22
23
24
25
5
02931
02931
_ _ _ . _
____ _ _ _
3.
_0 _ . . . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _. . __ _ _ _ _ _
_ _ _ _
_ __
That pursuant to Supreme Court Rule 102, such disciplinary action be taken by
the Northern Nevada Disciplinary Board against Respondent as may be deemed appropriate
under the circumstances .
2 b
day of August, 2011 .
5
6
STATE BAR OF NEVADA

DAVID A. CLARK, BAR COUNSEL
7
8
9
10
11
By-fJDo7~
Patrick O. King , sslstant Bar Counsel
Nevada Bar No. 5035

9456 Double R. Blvd ., Ste. B
Reno, NV 89521
12
13
14
15
16
17
18
19
20
21
22
23
24
25
6
02932
02932
- -- -,------------------.--...
...-.- - - -
--
.,.--,,----- .....
.
~---~
Exhibit 1
_._- .._-,-_..
'-'---
02933
02933
--
----::: :==- -.--::::::::

-- ....--- -.. -~-...... -- .. ------~---~ -.-------~,
IN THE MUNICIPAL COURT OFTHE CITY OF RENO
COUNTY OF WASHOE, STATE OF NEVADA
ON E SOUTH SIERRA STREET, RENO, NV 89.505
Mallin,: P.O. 8011900, Reno. NV 39505
PHONE (715).334-1190 FAX (775)334-312"
... ~8pU.J
VI.
DEFENDANT: COUGHLIN, ZACHARY I!l\RKER

DOS: 0911711916
Accidcntll:
Court Cud': II CR %111611

Agency': RSICPIICII0617
--------..
'1 ': ".
919flOli
10/ 1012011
II /J0I2011
I IfJOIlOI I
0.:
. . .. ,
..
Slana: OPEN
~ngP :
--------------
~ ,' )l,~ IJ""l,It~)\~(II" ~"~fl;1
-------- -~ ----
H'''',l (;.,jI, '
{., :1.M', ~JI\"k',.
ArreJl Dt:
Pica:
CII31~e
--
---
FORMAL COMPLAINT FILED WrlH THI COURT

THE DEfENDANT APPlAUD, WAS EXPLAINED HI5IHER RIGffTS BY TilE JUDGE AND INDlCATDTHAT
"lIS"E UNDERSTOODTHt:M COMPLETELY.
CITV'S EXtllBIT MARKEDIADMITTEO t,
PRESF.NT IN CO URT FOR THE CITY OF Al.!"tO: PAM ROBERTS AND FOR Tilt DI:fl:NSE: PRO PER
Chll'ie I: " .10,040 PETIT LARC[NYrrIlEFT. VALUE LESS THAN 'l!1O-OO
n fTen5e Dt
Lan&ul&c: ENGLISH
15953
0911)9120 II
0911)9120 II
II /JMOII C Ui LTY
Fille ~btOl.r:
1:
f ee ( HEM,DV,O F,tUV,IDF,TTP,WITF) Subl Olal:
" '.00
360,00
Fc~
'i1l~i5lon
Ftc SulllOllll:
"'.00
~lIpY Fe~s)
"'0,01)
_ .00
Add itional
WRT.:
PCN': 15''''7916
Jail Days:
0
Suspended Days: 0
S40.00
o..e.
..
?I9I'ZOII
"
I)~ c .
O.re: II .J'lI : 1l 11
I' ~"l.
I .,
02934
02934
. ,t:NTF.N(E COMPLIANCE
WINDOW IS
IE FIRST
OF TIfE RENO MliNICIPAL
COURT, ONE sourn SIERRA ST, RENO, NV (77.5) ))42290.
ONTIMEANl)
HOURS WTTli TIlE SHERIFFS
COMPlY WITH ALL
AND PAY A
OR S]j FOR
TO
WORK
Ordeml Dt:
Next Proof Dt:
a.lance:
SERVICE
SHALL
HOURS
UNIT (AIU),
(S.c. W WITHIN
.P.)
SIGN
HOURSMlf,"iU~~JL
OFFICE,
SOLmf CENTER ST,
NeXl ProofOt:
a.tltlC:c:
Cornplelcd Dt
FA.ILURE TO COMPt.Y WITH ruE CONOITlONS OF BAIL AS DESCRIBED IN mls ORDER WILL RESULT IN mE ISSUANCE OF A
fAILURE TO COMPLY WARRANTOR IMMEDIATE ARREST AND INCARCERATION FOR CONTEMPT Of COURT ANDIOR BAIL
REVOCATION. FOR FURTHER INFORMA. nON, CONTACT n-iE SENTENCE COMPLIANCE WINDOW LOCA reo ON THE FIRST
FLOOR OF TilE RENO MUNICIPAL COURT, ONE SOUTH SIERRA ST, RENO, NY (77j) 334.2290.
n~E
DEFENDANT SllALL APPEAR AS ORDERED FOR ALL REVIEWS ANO SHALL COOPERATE FULLY WJTIf THE
RAlI.IFFS/MARSHALS AND ALL COURT STAFF.
TIfE DEFENDANT SHALL ATTEND ALL REVIEWS, COURT APPEA.lt:ANCES AND COURT"()RDERED PROGRAMS ON TIME AND
ALCOHOL AND ORUO FREE.
TIlE DEFENDANT SHALL KNOW HISIHER COURT DATE AND MAINTAIN CONT,\ CT WITIf III SIHER AITORNEY.
PRIOR TO CHANGING IIISJlIER ADDRESS OR PHONE NUMBER. mE DEFENDANT SHALL NOTlnY TIlE COURT OF SUCH
CHANGE.
Nexl Proof 01:

R.lll'ICe;
~
.'.
""
'1f4:~I 'i m;iin.'f, he
02935
It:\Ml" II,\M)\.:R
..,t In,t i . I, :
02935
';' I;~ ~EFENDANT SIIALL REPORT I d A . .....YOR UPON RELEASE fROM J,~IL, ~ Sr:.I~n:NCE COMPLIANCE WINDOW
,
lE
FOR ORI ENTATION AND TIIEREAf-,ER ASm-TEN AS UlRECTED BY THE RENO MUN ICIPAL COURT MARSHAL DIV ISION.
FAILURE TO DO SO WILL RESULT IN TIlE ISSUANCE OF A FAILURE TO COMPt. Y W,\RRANT AND INCARCERATION FOR
CONTEMPT OF COURT. TIlE SENTENCE COMPLIANCE WINDOW IS LOCATED ON THE FIRST FLOOR OF TIiE RENO MUNICIPAL
COURT. ONE sourn SIERRA ST, RENO, NV (11j) 3)41190.
TIlE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SfiALL COOPERATE FULLY WITH TIlE
BAILlFFSIMARSHALS AND ALl. CQURT STAfF.
THE DEFENDANT SHALL ATTEND ALL REV IEWS, COURT ,\PPEARANCES ANDCOURTORDERED PROGRAMS ON TIME A~D
ALCOHOL AND DRUG FREE.
PRIOR TO C!lAHGrNG H1S1HER ADDRESS OR PUONE NUMBER, mE DEFENDANT SHALL NOTIFIY TIlE COURT OF SUCH
CIIANGE.
OBEY AlL LAWS .
"1411011 ADDITIONAL CASE INFORMATION: 3 city witneS!Cl had appeared ror btnch trial
1111412011 ADDIT10NAL CASE INFORMATION: DEf ENDANT WAS IN CUSTODY AT TIME AND DATE OF BENCH TRIAL;
DEfENDANT WAS TRANSPORTED BUT NOT BROUGHT 000 COURT
1111 ",,2011 ADDIT10NAL CASE INFORMATION: BAIL FORFEITIJRE CANCELLFD
IIIlOI201 1 ADDITIONAl CASE rNFORMATION: CITY REST ITS Ct\SE; DEFENSE BEGrNS HIS CASE. 6:H
IIIJ0I2 0 11 ADDITIONAl CASE INFORMATION: DEFENDANT REFUSD TO STATE WJIETIIER OR NOT HE WOULD DE TESTIFIED;
I IIl0l201 I ADDITIONAL CASE INFORMATION: CLOSfNG BY BOTH PARTIES
1011012011 ADDITIONAL CASE INFORMATION: DEFENDANT DID NOT WANT A COURT APPOINTED ATIORNEY.
i TnE 1I0NOR,\BU
JUDGE'S SIGNt\TIJA[:
DATE:
You ;are ordered by the Coun to arrive druglalc uhollTee ~nd on lime ror III Coun he3rings and Coun relilted proganu . F"ilure to
i appear in Court will ruult in the iu uance ofa warrant for your arrest. Any violation oflhis ins!anl order may result in contempt
proceedings 'lod the fil ing of additional criminal charges. In acco rdance with ('\IRS 22.0ID, it is a misdemeanor for any penon to rail,
i r<!fU 5~ or n~illectto compl y wuh the I.:nns of .my tmler I ~SUCO by the MUniCIpal Coun Judge. I his o rOno w
in elfect
the
Coun issuu another order Jupcnechng it.
1)...,
J ~
1
/
I( I
I
!
) ' U:'IIDERSTA;'IIO .\:010 PROMISE TO OBf-V nilS ORDER.
DF['''D''NT~
tJ.
u7"
3z>
~ t:4 (JV-!-/I2l'/~,;".b L~
~*
~~
I, TilE SWORN INTPRt:TF.R II,\ V": fl.'U . Y I:'HF.RPRF:TEO TIllS ORDE R TO filE
r UEft:Nf),\ , \i r :
"
flATE :
RF.Cr.lVt:o BV IlfPt'TV : _ . ___ ~ _ _ . _. _ _ _ __ _ _ _ _ ___ _
: IIi";1
rn
tI' ""hll.\t .;
IH H . .'.. n.\ ... r .
on: flUN, I .\( 1t.\R'
1t.\KK~ M
. \c~nc)lII .
ICll1161'
rnnl 1)41.:
11 ,.'t), ~rll l
fh I"f.: . _ _ _ _ _ __
rI.\ I'-: _ _ __ _
u.\n;:
_. ___ . _. _. _.__ .. . _ .... .__ . . _
fI~tE : _ _ _ __
II" f. :
(O tRT C.\~r..tII .
lltR!!1 ~ 6!1
[loll n.l f : tl ' !O, ! rl1l
02936
02936
..
-.~ ,~--"----.----.-~--.- - -~- -----.~- .
_- -.... ----_., _----------_.------'-"
-- " - ...
...
. ..
\..
F I LED
Electronically
03-15-20 12:06:21 :48 PM
Clerk of the Court
.II.~nsaction " 2829786
2
3
4
5
7
8
9
ZACHARY BAKER COUGHUN,
10
Appellant,
11
case No.:
Dept. No.:
vs.
CRl1-2064'
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
CITY OF RENO,
a municipal corporation,
Respondent.
"---------------------~I
II'
ORDER AffiRMING RULING 0' THE RENO MUNICIPAL cGURI

Presently before the Court Is an Appeal from a ruling or the Reno Municipal COurt,
"led by Appellant ZACHARY BAKER COUGHLIN (hereafter "Appellant") on December 23,
2011. follOWing, on February 7, 2012, Appellant filed his Opening Brief on Appeal.
Thereafter, on February 23, 2012, Respondent CITY OF RENO (hereinafter "Respondent")
tiled Its Answering Brief. The matter Is now before the COurt for Its conSideration.
This matter comes before the COurt on a criminal appeal from the Reno Munidpal
Court. On November 3D, 2011, Appellant was convicted of Petit Larceny, a violation of
RMC 8.10.040. Thereafter, on December 13, 2011, Appellant flied a Notice of Appeal with
the COurt.
Although Appellant's arguments on appeal are unclear, Appellant raises a wide

variety of issues, Including, Inter all4: that he was denied his Sixth Amendment Right to
Counsel, that the Municipal Court erred In failing to grant him a continuance, that the
prosecution engaged In misconduct, that he was refused an opportunity to testify on his
.t _
I t..lfaby certify 1l1li .. ., tn and COtl',ct Copt)' of !he

IhI roccxdt olin. AIM ~ Coutt. RInO, WUhoe'~""=
Newlda. and lhallhe et.rIc of tile Cout1 11 ttl, ~ 1M
Ilrigln. f900Id
I "" ~ to makl lh. ;;;;"",;;;:
R
MU"",,~. C<>1'I'~
02937
02937
- --"", ~-.------.---.... ~ .-.,- . - .--..--.-- ....,..

,-.---.. . -.- ---.-- - - - -- .
~--.--~---
Amendment of the United States Constitution, that his convictIon Is not supported by
sufficient evidence, and that ' [f]urther ImpropMetles and due process den.clendes"
-~.-
own behalf, that certain evidence should have been suppressed pursuant to the Fourth
...
occurred.
Unfortunately, Appellant nelther supports his arguments with relevant authoMty nor
dtations to relevant portions of the record. Most ImportanUy, Appellant has failed to
provide this Court with a copy of the tran501pt of relevant proceedings In the Reno
Munldpal Court. The Nevada Supreme Court has held that an "[a]ppellant has the ulUmat
responsibility to provide this court with 'portions of the record essenUal to determination of
10
Issues raised In appellanrs appeal: " T1>omn v. State, 120 Nev. 37 n. 4, 83 P.3d 918
11
(2004) (cltlngNAAP 30(b)(3). Further, NRAP 28(e) provides that '[e]very assertion In
12
bMefs regarding matters In the record shall be supported by a reference to the page of the
13
transcript or appendix where the matter relk!d on Is to be found,"
14
. While Appellant did provide this Court with a Compact Disc containing a recording of
15
the Munldpal Court proceedings, Appellant did not cite to the portions of the Compact Disc
16
that he felt supported his arguments, and It Is not the responsibility of this Court to guess
17
which portions of the Compact Disc might support Appellanrs arguments. In short,
18
Appellant did not satisfy his responsibility to supply and cite to relevant portions of the
19
record merely by producing a Compact Disc recording of the entire Municipal Court
20
proceeding.
In light of Appellant's failure to provide this Court with an adequate appellate
21
22
record, and Appellant's correspondent failure to cite to such a record, this Court is unable
23
to conduct a meaningful review of Appellanrs appeal. Thus, Appellant has failed to meet
24
III
III
III
III
III
25
26
27
28
2'
02938
02938
'-.
1 his burden In providing an adequate appellate record, and this Court must affirm the ruling
0'
the Reno Munldpal Court. I
3
NOW, THI!RI!FORE, IT IS HI!RI!BY ORDI!RED that the ruling
4 Municipal Court Is AfFIRMED.
0'
the Reno
5
IT IS FURTHER ORDERID that this matter Is remanded back to the Reno
6 Munldpal Court 'or all further proceedings.
7
8
9
.."'.... -'2....,,, ..."" ,..,~

~_
10
P.EWOTT
DIstrict Judge
11
12
13
14
15
16
17
L8
L9
20
21
2l
23
24
25
1 It Is..o.tn notlnlllha!, pursuant to NItS ~.~10(1). '(tJI>e lees rer transcrtpts and copies (01 municipal court
proceedings) must be paid by the party ordering them. In a cJvll case Ihe preparation 01 the transcrtpt need
not commence until the leeo hav" been deposited with the deputy derlo
the court. ACCD<dlnglV. NRS
189.030.....hlch requires the muniCipal court 10 transmit yarlous paPIn to the district court upon appell. doe.
not require IcIIon un~1 such lees have been paid. Here. it appears that Appellant never paid the requlolte
I... to secure the tran5Cl1pUon 01 the Proceedln\lS. For this reason. the appellate record Is Incomplete
26
0'
27
28
,
II
.J.
I.
02939
-'
'
CERUFICAII or MAILING
1
2
I hereby certify that I electronically flied the foregoing with the Oer!< of the COurt by
3 using the ECF system which served the following parties electronically:
4 ZACHARY COUGHUN, ESQ, for ZAOiARY COUGHUN
5
6
7
8
PAMElA ROBERTS, ESQ. for CITY OF RENO
DATED this
/5
day of
n .'.__ ,.
~-==-~
March~201> ~
f
I HO
Judldal Assistant
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-+
02940
02940
Exhibit 2
--02941
02941
,- - --~.
---..
,.
RENO MUNICIPAL COURTF
WASHOE COUNTY, NEVADA
'L ED
NOV 30 2011
Court Dept.
4
5
10
II
12
13
14
15
ORDER FOR SUMMARY

PUNISHMENT OF CONTEMPT
COMMITTED IN THE IMMEDIATE
VIEW AND PRESENCE
OF THE COURT
ZACHARY COUGHLIN,
8
9
D.pt. 4
Plaintifft
...
6
7
Oeputy Cieri<
CITY OF RENO,
Derendant.
--"'W"H=E"RE""A"S"N=RS""'2"66""'.5"'7"'0:-:d"e:1cl"ares=':i::~t municipal judge may punish for contempt for
the same acts or omissions, in the same manner and with the same effects as provided for
judges in Chapter 22 of Nevada Revised Statute, and
WHEREAS NRS 22.030 declares that when a contempt is committed in the immediate
view and presence of the Court or judge at chambers, it may be punished summarily, for
which an order shall be made, reciting the facts as occurring in such immediate view and
presence, adjudging that the person p'roceeded against is thereby guilty of a contempt and that
he/she be punished as therein prescnbed, and
WHEREAS, on the 30th day of November, 20 II, the above named defendant appeared
before this court.
NAME: ZACHERY COUGHLIN, who is DEFENDANT
16
_ _ _ __
Party;
Witness:
Spectator, and
17
18
19
WHEREAS such individual committed the following act(s) in the immediate view and
presence of the Court:
Disorderly, contemptuous or insolent behavior toward the judge while he is

holding court, or engaged in his judicial duties at chambers,
20
21
22
23
24
A breach of the peace, boisterous conduct or violent disturbance in the presence of the
Court, or in its immediate vicinity, tending to interrupt due to the course of the trial or other
judicial proceeding,
25
_ _ _ _ Refusing to be sworn o r answer as a witness,
26
_ _ _ _ Disobeying a lawful writiorder/rulelp_itiiIII\I . . liJ, ""'1OIIi~ aI." ~ ... '"
27
....-,_
_. ,_
w
,,,,, .... ..
.. , ......... c .....
chambers, and WHEREAS such condultll ~ of 1M Rtno t.I\InICICIaI Court. RII'IO. WuftM
R~ and tMt 1M CIMc d 1M Court t. 1ft. ou.todIM 01
_ _ _ _ Ocmeane d the Court
ortgIqjNCOfdandttlllll.,..~k)mu. ....-;;;;;;';;~
28
__v-- Derogated the :lUthority of the Court

__
MUHI~
.........
AT
_ _::.V"" fntcrfcred with thc o rderly administration of justice and required immclliate
__
\lindication by the Court 10 preserve order 3llJ respect.
02942
02942
,.
Based upon the above finding ZACHARY COUGHLIN is Guilty of Direcl
Contempt.
3
4
The Contemnor, when asked iftf#she had anything to say as to why sentence should
not be pronounced replied:
.s:.~
c.".g.. !!t:wao
6
7
8
9
10
II
Therefore, IT IS HEREBY ORDERED, ADJUDGED, and DECREED thaI the
contemnor is hereby sentenced to the following punislunent:

A fine in the amount of ($500 or less).
Imprisonmenl for (25 days or less), NO ALTERNATIVE SENTENCING.
DEFENDANTTOBERELEASEDon
11-- ~-I{
;;}-8
'1m.
,20lL
12
13
A fine in the amount of _ _ _ _ ($500 or Jess) and imprisonment for _ _
14
DAYS WASHOE COUNTY JAIL - No allernative senlencing.
15
Release on Own Recognizance revoked, bail set at: _ _
16
Defendant is hereby remanded into the custody and win be seen in video
17
arraignments on _ _ _~,
2011, al 8:30 a.m. NO BAIL HOLD PENDING
18
19
20
21
22
SENTENCING.
DATED this 30th day of November, 2011.
KE<tftH~ik~JUDGE
Reno Municipal Court
23
24
25
26
27
..0
._'_
28
" . .. I<' ..... ~n. ~ u
-......' .. I ~ ' ...
02943
02943
..
__ __
.
_- -----_._---_.-
.-..
--
---_._ -----
ExhibIt 3
02944
02944
- -----_......
-.-~
----_- .....
.....
.-----
_--
- --.,--. -~-.-.---- -
',
_ - --.'lIo
...........
Case No_ II TR 2680021

2
Dept. No.3
J
4
5
6
COUNTY OF WASHOE STATE OF NEVADA
8
9
10
II
CITY OF RENO.
ORDER
Plaintiff,
vs.
12
IJ
ZACHAR Y llARKER COUGHLIN.

Defendnnt.
I
14
15
March 12. 2012
W;)5
the lime sct for the resumption oflhe traffic ciution trial of
16
Dcfendrutt ZACHARY BARKER COUGHLIN who, as member No. 9473 oflhe Nevada Oar.
17
is an atto rney representing himself. the defendant. The trial was continued on FebnJary 27,
18
2012, when. a fter approximately an hour and a half. thc defend0l111 was held in criminal
19
contempt by the court for his anlics and misconduct during that trinl. His behavior is noted in
20
detail in thc court's Order entered on February 27. 2010.
21
22
Today, Mr. Cou g,hlin fa iled to appear 10 complete this tri al. He has not conlactc:d th is
lJ
<!I)urt If) <!:<:pl ain 1 f excuse hi s J h~ t nc e , De puty Cily ..'''omey ,\I isiin Ormaas ,LppcureJ .lIld
1
w, .s pn:parl't1to
25
p r lll':":':I1.
She informed the cuurt that sho: had no 1,; 0111 : ( with ~ Ir , <"Hll;lhlin
;11'
u ther [han receiving .,.'ultuninou! f.1.1(I!J doculIlcnls from him at th.:
16
Office. rhe de fc nJ:ln[ ' s f:'t illire 10 ,Lppeaf ' \':u nOh,'J on the (l'cunJ.
27
l~ c JlO
('ic y ,.'Horney 's
:i
02945
02945
:J)
Allcr he served hislive.day Contempt of Court sanction imposed by this ,,, urt on
FcbmaJ)' 27, 2012, Mr. Coughlin faJHlled to this courtlll 224.page document cnlill..:d "Notice:
of Appeal of Summary Contempt Order; Morion to Return Personal Property Contisc3tcd by
Rc:no Municipal Court 3l1d Its Marshals; Motion for New Trial and to Alter or Amend
Summary Contempt Order," The document purported to appcaJ this court's Order holding
him in direct criminal contempt. It contained a portion of one sentence on p:lge ..a seeking a
cOnlinuance oflOday's hearing. but no further discussion of Ihtu topic. Il also mentioned
being a. "tolling" motion in an Ilpparent atlcrthought. It did not address most orlhe other
10
topics listed in the cnplion, Instcad, Ihc document contained rambling references fO his
II
12
personal life nnd this court's; his father 's footbaJl career in college; dozens of pages of stri ng
13
citations taken off the internet; documents from a prisoner online site; an anicIe about a
14
"police Slate;" an article about Discovery; a website printout showing a police onicer's salary:
15
and copy of court docwnenlS from a District of Columbia case.
16
It was a disjointed
~gurgitation
of case law citations from a legaJ research online site
17
18
wilh liule reference to, or argument about, the laelS of his instant " Ooulevard Stop" {r3f1ic
19
C.:lSe. nle document was an incoherent and pathetic demonstration ()fwhat might once have
20
been legal and academic prowess that appears to now be greatly damaged . I\ fr. CuuWhlin (ax-
21
filed :lOother document in which he apparently took a .\ fotion to Proceed rnforma
22
( ~ icl
Pauperi~
in ,Ulilthcr \."asc ,lnd typed over it "Requcst lor ,\ lIdi!') Rccllrding Ilff\."bnl..lI)' 2 ;rh, 21) 12
13
,
.,-
had Ihat liI..:.1 in Ih\:! in:, tant ,ase on ~fJrch 7. ~()12. c\"..:n though it
16
~o II.
, I
dated \'ov,..:nbcr :!1.
i
r
I
!
- I
"7
~ ,
W :15
:
" .' .
!.
.:
.. , I
.. . .
"'
02946
02946
._~
___
__ _ _ _
~4
_ _ . . . . . ._ _ _ _ _
_
---------- - -_. ----
Fl!bnlaty 11, 1012 di srupted Department J of this court and cau sed distress to this court and
its statT:lnd m:lIShals.
3S
well
the prosecutor ond the witness, and resulted in
3.3
~fr.
Coughlin
being hel d in contempt of court, his ruing and liling oflhese document! gTe.ul), J isrupted the
4
I.'l peration of the entire Reno Municipal Court system. including Ihe clerk ' s oflice and the
other depnrtmcnls. and nessililled that netion be laken by the Court Administrator and
6
7
Administrative Judge.
Apparently
be~inning
on Mnrch 9, 2012 31 t 2;38 p.m., Mr. Coughl in again undertol)k
:mother massive fMAilinglo Reno Municipal Court. This time it was a document that was
10
file-stamped by the clerk on March 12, 2012 at 8: 12 a.m. This second 2l8page document
II
purported to be yet nnother motion in thil case entitled " Motion to Rerum Cell Phones;
12
13
Motion to Set Aside Summary Contempt Order; and Not ice of Appeal of Summary Contempt
14
Order." With scant discussion of, or relevnnce to, the abovecaptioncd malter, sa id document
15
mostly argues against Judge Howard in a Department 4 case and again contains more Ihan
16
200 pages of string legal citations; lyrics to rocks songs; Mr. Coughlin's personal family
17
history; discussion o f an
18
~vicl io n
caSd and another contempt case; disjointed legal c itations,
anJ olher no nsens ical malters rhat have no apparent relevance 10 his traffic cil:ltion case.
19
20
90th documents were massive and took up a great dea l of lime because the court h:.IIJ loJ
21
revi ew them to look fo r some connection to the case. This court has the inherent authority to
12
mai ntain respect. order and decorum in the court, and to n~ ftlse to al low Ihe CHurt
h) ~
used
2.3
21
rhl! (olldlJ..:t of ~I r.
C , )u~hli n
has been in:lpprnpriatc. hiz:trre, Jj ..hOIl< ~ I . irr;Jl jon,tJ .1llJ
27
\
' . "
t.
' ,.. ... ..: .
~I
P ... ' ... li !. : ' ... ! :! J
, : ~. " t
H: : .
:. ~' ! "
!I
02947
02947
..
--~ - --~
-.....-,.---. - -- ....--..-.-- -----".~ ...
--_._- -_. _-----._ ....-- --_

.......
.....-
..
appear or e~p1ain his absence 10 the court. Inasmudl;Js the CQUJ1 has all~Jst four Jifferent
aJdr~sses for
him. it is unablt: to ,lSccrtain nil eXQct whereabout!. He shows signs of mt!ntal
instability. if nol serious mental illness.

Oased upon the lolal circumst3J1ces or lhis case, the incourt performance of tht!
defendant, ~ observL-d by Ihis court, Ihe written documents f.l.'(cd 10 the court for ti ling by
this dcfcnd:llll, the sl:lIements and behavior of this defendant and his overall conduct hac in.
this court linds, by clear and convincing C!videncC!, that Zachary Barker Coughlin. an allorner
\0
licensed to prnclice Inw in the St8te of Nevada. has committed numerous acts of uUom!!y
misconduct, including. but not limited to, violating the following Rules of Professional
II
12
Conduct:
IJ
SA(c}----cngaging in dishonl:sty. frnud, d\.!ceit or misrepresentat ion;
14
8.4 (d)-engaging in conduct thilt is prt'judiciallo Ihc: ndministration of justice;
15
J.J (a}-Iac k of candor to the court by knowingly making false slatements
16
17
18
19
20
21
22
:l tribunal;
3.1---<.lcfending in a proceeding by asserting or controverting an iSSUe! without a bnsis in

fac t and with matters that are known to be frivolous;
3.2- f.1ilure to make reasonable effortJ to e.'tpedile litigation. ond , in fo~t, taking
I.."xtreme rnt:asures to delay litigation;
J..l(e)-hcing unfair to opposing counscl by continually alluding 10 matters the Il1wycr
docs nnt rcason:lbly helieve nrc relcvont or ~upported by ndmiuible ev i denc~ ;
.J-failing: to act with r~:lSonahle diligen ce and promptness; .:Ind

. 1 I a~k
,.
-,
to
IIf
cornpC!~nce
in his prnclicc: anJ :lppl!aranco:s he for.: this \' U I I.1 .
219. ~ \..'ction 2(b).;ls amcnded hy ,\DKT ~../.9 0 n :\ tl!:w;r 1.20/ I. by ;u (rcp{ i l l lltl .~Ij' f\.'\ 1 1 ((lill .~
c6
..
"
02948
02948
.-_
---_.-.--_ ._.---_.....-
...-.-- ~ ..-,--~ .. _--._-'#"-'"'- --_. ... - -~~-- .....
Whether or not there ilrC medical re850ns to ~xplain Mr. Coughlin's actions is nol for
Ihis court 10 decide. He has become nothinalcSJ than a "'cxatious litigant to Reno Municip:d
Court due to his unorthodox. disruptive. bizarre und irmtion:d methods and practices Ihal go
5
6
7
8
9
10
beyond the: pale of anything that is civil. ~thical . professional or competent. GolJd cause
appearing therefore, the coun orders as follows:
IT IS ORDERED that this matter is continued, and aJJ proceedings relating thereto ilrc
tolled. until further order oflhi.! court. while the mailer of attomey Zachary Barker COll~hlin
is referred to the Slate Bill' ofNcvada;
IT IS ORDERED that no further action shall be taken by the Reno City Altomey's
II
12
13
14
15
16
Ollice. 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 fn:'Cing,
emailing, delivering, having delivered. serving. presenting for filing. personally or othen.... ise.
any mol ion or document to Reno Municipal Court. in the above-entitled case, pending further
17
18
order of this court.

Dated this 12th day of March, 2012.
19
f}tPt if4 }.(A7;{/~~-:;'0
20
21
The Hon. Do~y Nash Holmes

Reno Municlpnl Jll d ~c
22
2J
25
26
!
I
02949
02949
-"
"-'
1
Case No. NG12-0204, NG12-0435, NG12-0434
STATE BAR OF NEVADA
The following are members of the Disciplinary Board for the Northern District of
15
Nevada.
Pursuant to Nevada Supreme Court Rule 105, you may issue peremptory
16
challenge to five (5) such individuals by delivering the same in writing to the Office of Bar
17
Counsel on or before the date a response to the Complaint is due. The Chair of the
18
19
20
21
22
23
24
25
Northern Nevada Disciplinary Board, J. Thomas Susich, Esq., will thereafter designate a
hearing panel of five (5) members of the Disciplinary Board, incfuding at least one
member who is not an attorney, to hear the above captioned matter.
1.
Kathleen Breckenridge, Esq. (flkla Kathleen Price)
2.
Gregory Brower, Esq.
3.
Julie Cavanaugh-Bill, Esq.
4.
Trina Dahlin, Esq.
5.
linda Daykin. Esq.
- 1-
02950
02950
---, . . _-- ----_.._-..... -_.- -- . --.--~-.-.--.-.--- -
-,--~---.------- ...
-.-.- -- - ------
---- -
02951
02951
02952
02952
. ,. -. " .,,">-.~~ .... ~.-'-~'-
55.
Carolyn Vaught, Laymember
56.
John White, Laymember
Dated this
':l...'J
day of August, 2012.
STATE BAR OF NEVADA

5
6
7
8
9
By:
pO...zT 0 /"7'
Patrick O. King, ASSiStant Bar Counsel
9456 Double R Boulevard. Suite B
Reno. NV 89521
(775) 329-4100
ATTORNEY FOR COMPLAINANT
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
-4-
02953
02953
~-
...-- ..~--, - ~.--.-----~------.----.--.----...........-----.---------.-~----- ...
AFFIDAVIT OF MAIUNG
STATE OF NEVADA
COUNlY OF WASHOE
)
)55:
)
Laura Peters, under penalty of perjury, being first and duly sworn, deposes and
says as follows :
1.
capacity, Affiant is Custodian of Records for the Discipline Department of the State Bar of
Nevada.
2.
That Affiant is employed as a paralegal for the State Bar of Nevada. That in such
That Affiant States that the enclosed documents are true and correct copies of the
10
COMPLAINT and FIRST DESIGNATION OF HEARING PANEL MEMBERS in the
11
matter of the State Bar of Nevada v. Zachary B. Coughlin, ESQ. Case No. NG12-0204,
12
NG12-0435 and NG12-0434.
13
3.
14
Hearing Panel Members were served on the follOwing by placing a copy in an envelope
15
which was then sealed and postage fully prepaid for first class. certified mail, and
16
deposited in the Uniled States mail at Reno , Nevada to Zachary B. Coughlin, Esq., Post
17
Office Box 3961 , Reno, NV 89505.
18
That pursuant to Supreme Court Rule 109, the Complaint and First Desig nation of
Dated this
di
7...-3 day of August, 2012.
19
20
21
22
Of the State Bar of Nevada

SUBSCRIBED AND SWORN to
Before me this 23rd day of August. 2012.
23
25
-5-
02954
02954
I
1
1
jt
t
I
.
..
Grievance File #NG1

2-0204
A: Zachery Coughlin
G: Richard Hill, Esq.
11111 SMEAD-I
Made In USA
No. 14547
....,..1 .....
smead.com
LO
LO
(J)
02955
o
'"
CO
01
0>
STATE BAR
OF
NEVADA
HSG Double R. Blvd., Suit< B. Reno, NV 89;21

lVwrv.nI1bar.org
-_Ii,:,Dnum,,_
I II I II
Reno, I
CI
CI
p'
It:
ec:
1",1,1,
es
COUG952-
UNABL-E

1422 E Ninth Street. #2
7010 2780 0003 5429 6578
ci:;:i5i
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$ 005.95
_PITNEY BOOjVES
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00
eJ3;1.J.'2
.:tZ;J
02 1P
0003177932
MAR 162012
. MAILED FROM ZIP CODE 89502
<:
--.---- -.-----
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.'2
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02956
t,
if
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Received by (Prtnted Name)
It YES. enter delivery address below:
D. Is delivery address dlffelent from Item
B.
"Nil 03llUJ 1"C10 SS3'=1aO N::in-,-3H :toi1:W

l.l-iDld 3H.l 01 '3d013/1N:3:W cOll'1ftB:JU.S 3:)'Q'ld
I Complete Items 1. 2. and 3. Also complete
..
,
Item 4 If Restricted DeHvery Is deslrad.
I Print your name and ad on the reverse
so that we cametum the card to you.
. Attach this card to the back of the mallplece.
on the front If space pennIts.
or
Artlcle Addressed to:
\yZZ
DomestlcR9tum Receipt
7010 2780 0003 5429 6578

3811, February 2004
2. Article Number
(1l'ansferfromSfllYfce
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102595-02-M1540
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____
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N
o
02957
STATE BAR OF NEVADA
600 East Charleston Blvd.
las Vega,. NV 89104-IS63

702.382.2200
rhon,
March 16,2012
",II f,,, 800.254.2797
702.38S.2878
fat
Sent Via U.S. Mail, Certified Mail and via E-Mail

Zachary B. Coughlin. Esq.
1422 E. Ninth Street. #2
eno, NV 89512
9456 Double R Blvd.. St<. B

Reno. NV 895215977
phon' 775.329.4100
r
..
775.329.0522
www.nvbar.org
RE: Attorney Discipline

Dear Mr. Coughlin:
The Office of Bar Counsel has received several grievances concerning your
conduct as a lawyer. The grievances include supporting evidence in the form of:
audio of your conduct in court proceedings and copies of pleadings and documents
prepared and filed by you in Justice and District Court. Together these grievances
raise serious questions regarding your competency and ability to practice law.
These concerns are serious and the Office of Bar Counsel is considering the
necessity of seeking a Petition to Determine Competency pursuant to Supreme
Court Rule 117.
I am enclosing with this letter copies of a grievance letter, from the Municipal
Court and a copy of an Order from District Court. Please respond to allegations
pertaining to your conduct. I will make available for your review and inspection the
supporting documents and audio recordings.
I have left phone messages and sent you an e-mail asking you to call me. As
of the drafting of this letter you have not called me. I would like to meet with you so
that we can discuss this important matter and see if there is a way that we can help
you. Again, please call me at your earliest opportunity.
Sincerely.
-;Ozt cr
Patrick King
02958
02958
RENO MUNICIPAL COURT

CASSANDRA JACKSON
Court Administrator
nON. JAY D. DILWORTlI

1
Department
R E C EI\/C. I"'\halc\i
HON. WILLIAM L GARDNER
ll STIN ROPE R
Department
Department 2
of Alternative Sentencing
nON. DOROTHY NASIlIlOLMES
MAR 1 ,1 2ll,
Department 3
liON. KENNETH R. nOWARD

Department 4
STATE BAR OF NEVADA

RENO OFFICE
March 14.2012
Mr. David Clark, Esq.

State Bar of Nevada
9456 Double R Blvd., Suite B
CONFIDENTIAL
Reno, NV 89521
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
Mr. Coughlin has fax-filed 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 1 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
th
attempting to serve him at the most recent address we have (1422 E. 9 St. #2. Reno NV 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 hearings 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.
P.O. BOll 1900, Rnot NV 89!105-1900. I Svuth Siena Street, Reno, NV 89501
Telephone: 775-334-2290. Facsim i le : 775-334-3824
www.renomunidpalcourt.com
02959
02959
Mr. David Clark

March 14,2012
Page 2
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 infonnation 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 eyen 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. I
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.
Please contact me if you need any other infonnation. My direct line is 775-334-3823 and
my cell phone is 775-250-0330 (not for public dissemination). My email is HolmesD@reno.goy
My Judicial Assistant is Marilyn Tognoni and she can reach me at any time. Her number is 775-
334-3822 and her email is TogniniM@reno.gov
Thank you for your attention to this matter.

Yours truly,
7'-#-4
The Hon. Dorothy Nash Holmes

Reno Municipal Judge
enes.
P.O. 801:
1900,
Reno,
NY 89O-1900. 1 South Sierra Strut,
Reno,
NY 89501
Telephone: 775-334-2290. Facsimile: 775-334-3824

www.rtnomunicipaltourt.{om
02960
02960
F I LED
1
Electronically
04-13-2009:09:23:48 AM
Howard W. Conyers
Clerk of the Cour1
RECEIVED
CODE: 1845
T_ t# 70269
2
3
STATE BAR OF NE:-IADA
..
RENO OFFICE
8
7
IN TIm FAMILY DIVISION
OF THE SECOND JUDICIAL DISTRlcr COURT OF THE STATE OF NEVADA
10
11
ASHWlN JOOMI,
15
BHARTI JOSHI,
20
21
22
23
24
25
26
27
28
COP9
Defendantl CountercIaimant
ORDER AFI'ER TRIAL
17
19
t4
________________________________
16
18
DV08-01168
Dept. No.
vs.
13
14
Case No.
Plaintiff,
12
A Complaint for Divorce was filed by ASHWIN JOSHI
(hereinafter Mr. Joshi), by
and through his attorney, JOHN P. SPRINGGATI!, ESQ., on July 8, 2008 .
An Answer and
Counterclaim was filed by BHARll JOSHI (hereinafter 'Ms. Joshi'), by and
through her
attorney of record, ZACHARY B. COUGHLIN, ESQ., on July 18, 2008. A r gument was
heard
on March 12, 2009 and March 17, 2009. Mr. Joshi was present and represent ed by
John P. Springgate, Esq.i and Ms. Joshi, was present and represen ted by Zachary B.
Coughlin,
Esq., of Washoe Legal Services.
AU testimony and arguments having been heard, all pleadings on file having been
read, all exhibits, tapes, and notes having been
reviewed, the Court finds and Orders as
follows.
III
III
of originl eft file with the Secon' Judicil District Court
02961
02961
FINDINGS OF FAcr
2
1.
The parties were married May 11, 1987, in Bombay, India.
2.
The parties have two children, both of whom are now adults.
..
Although Mr. Yoshi has no obligation to support said children any longer
to NRS 125.S10(9)(b), Ms. Yoshi requests e financial assistance of Mr. Yoshi so
p ursuant
as to provide for the children's continuing education. (Answer, pg. 2, lines 16-18).
The Court notes that on August 1, 2008, Mr. Joshi filed a 'Motion For Return Of
Personal Property' requesting that Ms. Joshi return his passport, green card and social
security card. On August 7,2008, Ms. Joshi, by and through her attorney of record,
to
10
Mr. Cou ghlin, filed an Opposition
11
involving minor children and their support. Ms. Yoshi filed said opposition while
12
acknowledging the parties' children were both over eighteen years of age at the time. On
13
August 18, 2008, Judge Schumacher ordered Ms. Joshi to immediately return Mr. Joshi's
14
passport within five days.
the return of Mr. Joshi's passport citing case law
15
3.
16
In Mr. Joshi's Complaint filed July 8,2008, he indicated there was community
17
There is community property to be divided.
property and debts which should be divided by the Court.
18
Ms. Joshi filed an Answer and Counterclaim on July 18, 2008, indicating the
19
parties' community property should be equitably divided, including Ms. Joshi's
20
"women's wealth", the vehicles in each party's possession, the
21
p ossesion, and "the money the [Ms. Yoshi] earned while working for Legendary Luxury
s
22
Camping Safari in Houston Texas
23
account every month for two and one-baH years,
24
he would give to her." (Answer, pg. 2, lines 21-26).
25
28
which was automatically deposited in [Mr. Yoshi'sJ

[and] which [Mr. Yoshi] told
[Ms. Y08hi]
The Court notes the following information has been provided. and has been taken
into consideration on this issue:
27
28
vehicles in their children's
a.
"Women's Wealth" Property. The parties agreed that the parties'
conununity inte rest in the "woman's wealth" jewelry (location unknown) belongs to Ms.
Copy
of
ortginl on Fil.
with
tn. S.cond Judictl District Court
02962
02962
Joshi. Mr. Joshi stated that he would contact his relatives, who may have some of the
property, and will request Its immediate return to Ms. Joshi.
b.
Mr. IoshY. Vehlde Mr. Joshi introduced evidence that the balance
Exhibit "AH); and
on his 2005 Chevrolet Blazer is $15,009.75 as of March 6, 2009. (Trial
Kelley Blue Book value for the Blazer is 510,910 (Exhibit "B"). Therefore, a deficit in the
amount of approximately $4,100.00 exists on the vehicle. At the conclusion of trial, Mr.
Joshi requested that he be awarded the Chevrolet Blazer.

Ms. Joshi presente d no evidence on this issue. To the Court's knowledge, Ms.
s
9
Joshi conducted no d iscovery. on this issue.

c.
10
11
value of Ms.
Joshi's car.
d.
12
Ms.Iosbi's Vebide There was no evidence introduced regarding the
Son's Vehicle - Mr. Joshi testified that his ad ult son is presently
13
driving the Jeep Grand Cherokee and is making
14
lender, Oear Star Financial. Both parties testified that Ms. Joshi an d the parties' son are
15
named on the title.
18
Grand Cherokee.
17
18
the payments lor the car directly to the
No evidence was presented regarding the balance owed on the Jeep
Ms. Joshi pre sented no evidence
on this issue. To the Court's knowledge,
Ms. Joshi conducted no discovery on thJs issue.
19
e.
Oaus:hter's Vehicle Mr. Joshi testified that the parties' adult
20
daughter drives and makes
21
name of both Mr. Joshi and the parties' daughter.
22
payments on the Honda Accord and that title is held in the
Ms. Joshi testified that she made a payment of $6,000.00 on her credit card for said
23
automobile and the present balance on the credit card was approximately $5,000.00.
24
However, Ms. Joshi presented no evidence to corroborate this contention. Ms. Joshi did
2S
not
26
payments made on said credit card, and
'0
with a balance in the amount of $5,000.00 remaining thereon.
28
specify a date o n which said debt W8s1ncurred, she did not provide evidence of any
she did not present e vidence of any credit card
Ms. Joshi presented no further evidence on this issue.
cop, of erlgln.l on fl1. with tho Socond
Judie!.l District Court
02963
02963
e.
London Bank Accoun t Mr. Joshi testified that that he did not know
if Ms. Joshi's earnings from Tanzania were placed in a London bank account. Mr. Joshi
testified he did not control Ms. Joshi's money at that time.
4
5
Ms. Joshi presented no evidence that her earnings were placed in a Lond on bank
account
To the Court's knowledge, Ms. Joshi conducted no discovery on this issue.

f.
COmmunity Bank Accounts Ms. Joshi testified that she requested

-
access to
the bank accounts from Mr. Joshi, but that he would not let her see the bank
statements. Further, Ms. Joshi testified that she did have her own credit and she d id have
access to Mr. Joshi's credit card statements
10
There was no further evidence presented as to the conununity bank aCcounts.
11
4.
12
The Court notes the following information has been p rovided and has been taken
13
There is community debt to be divided.
14
a.
General Credit Card Debt Mr. Joshi testified that he owes

-
15
approximately $15,650 in credit card debt (Trial Exhibit liE"), and argued the charges
18
were incurred for community expenses, holidays, family expenses and household
17
expenses.
f8
Ms. Joshi presented no evidence r egarding commun ity credit card debt.
19
b.
Best Buy CredJt Card Debt
Mr. Joshi stated that the parties
20
purchased a computer and T.V. at Best Buy for approximately $1,314.00. Mr. Joshi
21
testified Ms. Joshi has both of these items.
22
23
Mr. Joshi requested he be awarded the computer presently in Ms. Joshi's

possesion and that she retain the T.V.
s
24
Ms. Joshi presented
215
28
27
c.
no ev idence on this issue.
Medical Debt - Mr. Joshi testified he owes $6,735.00 to St Mary's
Hospital lor surgery in May 2008 (Trial Exhibit UF") and 5500.00 to REMSA (Trial Exhibit
"G").
28
At trial, Mr. Joshi offered to pay these community debts.
copv of original
on
fl1
.ith th. Sond Judiial District Court
02964
02964
Ms. Jo shi presented no evidence on this issue. To the Court's knowledge, Ms.
2
Joshi conducted no disco ve ry on this issue.
3
4
5
Family Debt - there are two d ebts owing to family members or on
d.
behalf of family members that were presented at trial.
Mr. Joshi introduced evidence at trial regarding a $5,000.00 debt to Rod and
Meena Fowler (Trial Exhibit "H") in the form of a letter from Rod and Meena Fowler.
The letter states tha t the parties owe money in the amount of $6,000.00, which was lo ng
overdue" by approximately six (6) years, for money loaned to Mr. Joshi's mother when
she was ill. The letter references a "copy of your letter agreeing to pay us back", but did
"
10
not attach a copy of s a id letter. At trial, Mr. Joshi
11
the referenced letter. Ms. Joshi testified that this d ebt was "made up."
12
Mr.
testified that he did not have a copy of
Joshi testified regarding a debt of approximately $5,000 owing to a family
13
member by the name of Ashik Nanaby (sp?), for b uy i ng plane tickets for the Joshi family
14
to come to the
1S
information regarding this de bt as the other party "wanted to stay out of the divorce."
16
At trial, Mr. Joshi
17
18
Unites States in 2001. Ms. Joshi testified that she could not obtain any
e.
o ffered to pay these co nununity debts.
Gene ral Co mmun ity Debt Mr. Joshi testified that he pays
-
approximately $600 per month for community debts, excluding his car and insurance.
19
Ms. Joshi presented no evidence regarding general community debt.
20
Mr. Joshi offered to pay the community debt in his na me that he had been p ay ing
21
and take an unequal division of conununity
debt.
22
5.
23
Specifically, Ms. Joshi requested spousal support "until her death or remarriage,
24
25
28
27
28
Ms. Joshi requests spousal support.
whichever occurs first." (Answer, p. 3, lines 5-6).

The Court notes
into consid eratio n
on
the following information has been provided and has been taken
this issue:
Mr. Joshi is 51 years of age and Ms. Joshi i s 46 years of age. The parties moved to
the United States from Tanzania in 2001.
Copy of origin 8n file with the Second Judici.l
District Court
02965
02965
Ms. Joshi is a c oll ege graduate and has worked continuously since the parties
2
moved to the United States. Ms. Joshi is presentl y employ ed by Raley's as a
pharmaceutical technician and earned approximately $29,500.00 in 2008 . Ms. Joshi has
testified she has raised the parties' children and ther eby has foregone educational
opportunities and has put her dreams aside.

Mr. Joshi testified he is a high school graduate. Mr. Joshi is empl oyed as a cat ering
8
7
manager.
companies - American Bar and Restaurant and Sierra Sport Serv ice . At trial, Mr. Joshi
introduced his W-2 from American Bar and Restaurant reflecting eamJngs of $4,157.
In
2008, Mr. Joshi earned approximately $41,500.00 while w o rking for two
10
(Trial Exhibit "C"); and his W-2 from Sierra Sport Service in the amount of $37,504.18
11
(Trial Exhibit "0"). Mr. Joshi testified that business is slow and he is presen tly working
12
for only one company - American Bar and Restaurant. Mr. Joshi testified he has only two
13
weeks of work scheduled for March, 2009; and he filed for unemployment benefits in
14
March, 2009.
Mr. Joshi request ed the Court consider his net income after deducting taxes, factor
15
present $600 per month he is presently paying for community debt, and set off any
18
in the
17
alimony responsibility by his assumption of an une qual distribution of community debt.

Further, to protect Ms. Jo shi in the event Mr. Joshi flied f or bankruptcy, Mr. Joshi
18
19
suggested that the court maintain jurisdicti on over the issue of spousal support for five
20
years.
21
5.
Ms. Joshi requests reasonable attorney's fees be p aid to Washoe Legal
22
Services for the services of Mr. Coughlin. Mr. Joshi requests reasonable attorney's fees be
23
paid to his attorney, Mr. Springgate.
24
25
26
The Court notes the following information has been provided and has been taken
On July 18, 2008, Mr. Coughl in filed a Statement of Legal Aid Representation
27
which states Def endant is rece i ving "free legal assistance" from Washoe Legal Services
28
pursuant to NRS 12.015.
Copy of ortglnl on fil. with th.
Srcond
Judicial
District Court
02966
02966
On October 3, 2008, Judge Jor dan presided ov er
the parties' Case Management
Conference. At that hearing. the parties were unable to reach a settlement. Further, on
March 12, 2009, Ju dge Gardner conducted a Settlement Conference for approximately one
..
and one-half hours, prior to starting the trial at approximately 3:00 pm.
no t agree on settlement and
The parties did
trial was commenced.
In his dosing argument at trial, Mr. Coughlin, on behalf of Ms. Joshi, stated that he
6
7
did
with a nicer car.
other way. Mr. Coughlin cited an ALR article regarding community debt and stated his
not understand and could not agree with equalizing debt when one party ended up
He s tated that he had "crunched the numbers and could not see it the
10
client "does not have much for the creditors to take." He requested that his client assume
11
one-half the community debt and that the Court find Plaintiffs two $5,000 debts to family
12
members and friends as Mr. Joshi's separ ate debts. Mr. Coughlin stated his client is being
13
asked to "foot the bill" for Plaintiffs debts and referenced that Ms. Joshi is a caring and
14
conunitted mother.
15
18
Mr. Joshi testified that he had paid Mr. Springgate $4,000.00 since July, 2008,
for attorney's fees and costs.
17
Mr. Joshi requested that Mr. Coughlin personally pay his attorney's fees for 4.15
18
hours of trial at the rate of $225 per hour pursuant to NRS 7.085. Mr. Springgate testified
19
Mr. Coughlin had not conducted any discovery, had produced no evidence regarding
20
Ms. Joshi's community debts other than her Financial Declaration on file, had presented
21
no evidence regarding alimony, and had acted in a vexatious and unreasonable maIUler
22
in rep resenting
23
CONCLUSIONS OF LAW
24
25
Ms. Joshi in this divorce proceeding.
1.
Ongoing Support for the Adult Children's
Education -
Pursuant to NRS 125.510(9)(b), except where a contract providing otherwise has
28
been executed pursuant to NRS 123.080, the ob l igation for care, education, maintenance
21
and support of any minor child created by any order entered pursuant to this section
28
ceases:
(a> Upon the death of the person to w hom the order was directed; or (b) When
1
_. __.-
.. .. _._------
02967
02967
the child reaches 18 years of age if he is no longer enrolled in high school, otherwise,
2
when he reaches 19 years of age.
There has been no evidence presented
by Ms. Joshi justifying a request for
continuing su p p ort of the parties' adult children. As there has been no legal basis
presented to make such a finding, the Court denies Ms. Joshi's request that Mr. Joshi
financially provide for the adult children's education.
Community Propertyl Debt.
2.
Pursuant to NRS 125.150(1)(b) and Puttennan v. Puttmnan, 113 Nev. 606, 939 P.2d
1047 (1997), in g ranting a divorce, the Court shall ensure an equal di s p ositio n of the
10
community estate, absent compelling reasons. justifying an unequal distribution. The
11
Court must make written findings a s to wh y such a division i s appropriate.
12
a.
"Women's Wealth" - The parties have agreed that the parties'
13
conun unity interests in the "women's wealth" belongs entirely to Ms. Joshi acco rding to
14
their customary beliefs, and thereby should be declared her sole and separate property.
15
As such, Mr. Joshi is ordered to cont act any and all relatives who may have this property
16
and immediately retum said property to Ms. Joshi as soon as possible.
b.
17
Mr. Joshi'sVehicle - The 2005 C hevro let Blazer shall be considered
18
Mr. Joshi's sole and separate property. Mr. Joshi shall be responsible for the debt
19
remaining thereon. As the car is worth $10,910.00 but there is $15,009.75 due and owing
20
on said car, the Court will consider Mr. Joshi's assumption of this asse t as an under taki ng
21
of community debt of appr oxima tely $4,100.00.
22
c.
Ms. Toshi's Vehicle - Ms. Jo shi' s car shan be considered her sole and
23
separate p roperty. Ms.
24
there was no evidence presented as to its value (either posi tive or negative), the Court is
25
unable
28
Joshi shall be responsible for any debt remaining thereon.
As
to determine a value for this community asset.

d.
Son'svehicle - As the only evidence presented on this issue was the
27
fact that the parties' adult son drives this vehicle and makes the payments thereon, this
28
asset will not be divided among the community.
Copy of originil on fil with th. Spcond Judiciil District Court
02968
02968
e.
Daupter's Vehicle - The only evidence presented on this issue was
the fact that the parties' adult daughter drives th is car and makee payments thereon. Ms.
Joshi presented no evidence of a balance owing on the car or itaiair market value.
Thereby, this car will not be divided as a community asset.
f.
London Bank Account - there was no evidence presented to the
Court verifying said bank account exists. As such, there is no factual basis to suppo rt an
order dividing it as a community asset.
8
9
10
g.
Community Bank Accounts - there was no evidence present ed as to
the existence of community bank accounts. As s uc h, there is no factual basis to support

an order d ividing it as a community asset.
11
h.
Computer - Mr. Joshi is awarded the computer purchased at Best
12
Buy. Ms. Joshi shall deliver said computer to Mr. Springgate's office on or before Friday,
13
Apri117, 2009, at 5:00pm.
14
15
i.
Television - Ms. Joshi is awarded the television purchased at Best
Buy. It is the Court's understanding this television is currently in Ms. Joshi's possession.
j.
16
General Credit Card Debt - The evidence presented indicates a
17
general debt of approximately
18
$15, 650.00 which has been expended for community
purposes.
19
20
Mr. Joshi agreed to be responsible for this debt at trial. As such, Mr. Joshi shall be
solely and
separately responsible for this debt.

k.
21
Best BuyCredit Card Debt The evidence presented indicates there
22
is a debt of approximately $1,314.00 outstanding for the purchase of the television and
23
computer.
24
Mr. Joshi agreed to be r esponsi ble for this debt at trial. As such, Mr. Joshi s hall be
25
solely and separately responsible for this debt.
26
I II
27
III
28
02969
02969
1.
Medical Debt
As Mr. Joshi has offered to py these debts, he shall
be solely and separately responsible for the payment of $6,735.00 to St.Mary's Hospital;
and
$500.00 to Remsa.
..
m.
Family Debt There was no documentary evidence presented as to

-
the debt owing to Ashik Nanab y (sp 1) for buying plane tickets for the Joshi family.
Further,
Fowler indicates said debt was incurred for the benefit of Mr. Joshi s mother. As
Mr. Joshi has agreed to take on both of these debts, the y shall
separate responsibility.
as
the only evidence provided regarding the $5,000.00 de bt to Rod and Meena
'
10
n.
henceforth be his sale and
General COmmunity Debt There was no evidence other than

-
11
testimonial evidence to establish community debts. As Mr. Joshi has offe red to pay any
12
remaining community d ebt in his name that
13
the sol e and separate responsibility of Mr. Joshi.
is hereafter outstan ding, said debt shall be
14
The Court notes Mr. Joshi has likely incurred an unequal distribution of the
15
c ommunity debt i n this case. The Court finds his testimonial acquiescence at trial to take
16
on this debt is a compe lling reason to make an unequal distribution of the c ommunity
17
debt.
18
3.
19
The statutory mandate for alimon y is that it be "just a n d equitable."
Spousal Support -
post-<iecree needs and
20
NRS 125.15O(1)(a). Alimony is an equitable award to serve the
21
rights of the former spouse. Wolff v. Wolff, 112 Nev. 1355, 929 P.2d 916 (1996). Althou gh
22
post decree incomes need not be equalized, in marriages of some duration, alimony may
23
be used to narrow large gaps between the post-divorce earni n g capacities of the parties
24
and to a llo w the r ecip ien t spouse to Jive"as nearly as possible to the station in life
25
enjoyed before the divorce." Shydler v. Sbydler, 114 Nev. 192, 196 954 P.2d 37,.39
28
The individual circwnstances 01 each case wiU d etermi ne the appropriate amount and
27
length 01 any alilnony award. Id.
(1998).
28
10
02970
02970
Puzsuant to NRS 125.150(8), there are eleven (11) factors the court shall consi der in
awarding alimony .
Ms. Joshi presented no evidence in support of her request for alimony other than
..
her own testimonial evidence that she the parties' children, had foregone
educational oppor tunities, and put her dreams on hold while married. Ms. Joshi testified
that she is healthy and has always worked. There was no reference to any of the eleven
factors in NRS 125.150(8) in Ms. Joshi's presentation and argument in support of an
award of spousal support.
The Court finds that the parties preSt'.ntly earn approximately
the same amount,
10
Ms. Joshi earns $2,458 per month and Mr. Joshi earned approximat ely $3,125 per month
11
in 2008, but testified he is working substantially less in 2009 and has filed for
12
unemployment benefits the be ginning of March 2009.
13
parties have been married 21 yeaI'S and Ms. Joshi has always been employ ed during that
14
time.
1S
Mr. Joshi has a
16
able to work. (See NRS 125.150(8)(1<.
17
18
(See NRS 125.15O(8)(d.
(See NRS 125.150(8)(a.
The
Ms. Joshi obtained a college degree prior to marriage and
high school degree. (See NRS 125.150(8)(h. Both parties are healthy a nd
Based upon the eVidence presented and the applicable law, this Court does not
believe Ms. Joshi is entitled to an award of alimony .
10
4.
20
This Court enjoys discretion to award attorney's fees in a divorce action.
Attorney's Fees
21
NRS 125.150(3); Love v. Love, 114 Nev. 572, 959 P.2d 523 (1998).) Also, pursuant to
22
NRS 18.010(2)(b), the court has authority to order attorney's fees "when the court finds
23
that the ...defense of the opposing party was brought or maintained without reasonable
24
ground or to harass the prevailing party." Finally, pursuant to NRS 7.085, if a court
25
finds that an attorney has: (a) filed, maintained or defended a civil action or proceeding
26
in any court in this State and such action or defense is not well-grounded in fact or is not
27
warranted by existing law or by an argument for changing the existing law that is made
28
in good faith; or (b) unreasona bl y and vexatiously extended a
civil action or proceeding
11
cop of orlgll
Dn
flle with te See on. JUdiet.l District Court
02971
02971
before any court in this State, the court shall require the attorney personaUy to pay the
2
additional costs, expenses and attorney's fees reasonably incurred
conduct.
because of such
At trial, Mr. Springgate stated that Mr. Coughlin had conducted no discovery in
this case. In addition, Mr. Coughlin faUed to present one documentary piece of evidence
at trial on behalf of Ms. Joshi' s claims.
throughout trial and made sarcastic, derogatory remarks to the Cou rt, Mr. Springgate,
and Mr. Joshi throughout trial.
Mr. Coughlin argued incessant ly
with the Court
The Cou rt notes that there were wen over 40 objections durmg four (4) hours of
9
10
trial. Mr. Springgate's objections were well-founded and continuously sustained except
11
in one instance. Mr. Coughlin was overruled on every objection except one and argued
12
with the Court over most rulings. Mr. Coughlin was admonJshed approximately 15 times
13
by the Court to quit arguing, to ask specific questions, to discontinue asking questions
14
calling for a Jegal conclusion, and to refrain from makin g degrading remarks to both Mr.
15
Joshi and Mr. Springgate.
18
The Court notes that at one point, after an exhibit had been admitted,
17
Mr. Coughlin could not find the copy provided by Mr. Springgate in d iscovery. Mr.
18
Coughlin demanded a copy be provided at trial, stating
19
thIough my papers?
20
When asked if he had the copy of the document, Mr. Coughlin stated,
21
could spend my time and mental energy looking around for Mr. springgate's document
22
like I am his assistant, or we could ask Mr. Springgate to provide a copy at the time he is
23
seeking admission like I believe the rule states."
24
proceeded to interrupt the proceedings twice approximately five (5) minutes and twelve
25
(12) minutes post ruling to re-argue
26
by referencing when exactly the copy had been provided to Mr.
21
discovery and
26
Coughlin to quit arguing the point and reiterate that the exhibit had been admitted.
II
am I
supposed to be rifling
My understanding is that you are supposed to provide a c opy."

"I do not know. I
Mr. Coughlin cited no rule and then
the point. Mr. Springgate replied to the arguments
Coughlin during
where the copy could be located. The Court had to admonish Mr.
12
copy
of or1!1n . . o n f l U
wUh th' S.cand Judlc1U District Co.rt
02972
02972
Mr. Coughlin flled an Answer and Counterclaim on Ms. Joshi's behalf that
2
3
4
included allegati ons unsupported by law; and flied an Opposition to the request for
return of Mr. Joshi's passport without any factual or legal basis.
Further, at trial, Mr.
Coughlin presented almost no evidence to support Ms. Joshi's requests and claims.
The most troubling aspect of this case was Mr. Coughlin's rude, sarcastic and
disrespectful presentation at trial; Mr. Coughlin's inability to understand a balance sheet;
his fa
evidence and trial procedure. All of this was compounded with a continuously
antagonistic presentation of the case that les\llted in a shift from a fairly simple divorce
10
1f
12
13
14
is
16
17
ilure to conduct diSCOVery; and his lack of knowledge with regard to the rules of
case to a contentious divorce trial lasting an excessive amount of time.
For all these reasons, the Court finds that Mr. Coughlin's presentation of the case
and arguments in support thereof to be unfounded in fact, unwarranted by existing law,
unreasonable, and vexatious throughout th is entire proceeding.
Based upon the foregoing, Mr. Springgate's request that Mr. Coughlin personally
pay Mr. Joshi 4.15 hours at the rate of $225 per hour for the cost of the trial is GRANTED.
Mr. Coughlin shall submit a check to Mr. Joshi in the amount of $934 within 30 days of
this Order.
Preparation of the Decree -
18
5.
19
Mr. Springgate shall prepare the decree of divorce consistent with this
20
memorandum decision. Mr. Springgate shall tender his proposed decree to Mr.
21
Coughlin, pursuant to WDCR 9, within 20 days from the date of this order.
22
GOOD CAUSE APPEARING, IT IS SO ORDERED.
23
Dated: April
24
jJ;L2009. <--q
25
DISTRICT JUDGE
26
Ai
/J
27
28
13
02973
02973
CERTIFICATE OF MAILING
2
Pursuant to NRCP 5(b), I certify that I am an employee of the Second Judicial
(\3
District Court, and that on the
..
with the Oerk of the Court System which will send a notice of electronic fiUng to the
following:
day of April, 2009, I electronically filed the foregoin
6
7
8
9
10
Document: ORDER AFTER TRIAL

JOHN P. SPRINGGATE ESQ
ZACHARY B. COUGHLIN ESQ
11
12
13
ACiln0tI'iltiVeAssistant
'4
15
16
17
18
19
20
21
22
23
24
25
29
27
28
14
copy o f origin . l o n
fil. with th.
S.eond
Judie i.1 Oltrict Court
02974
02974
........
F I L ED
Electronically
06-25-20 1 2: 1 2:38: 1 5 PM
Clerk of the Court
Transaction # 3039397
1
2
3
4
5
6
8
9
ZACHARY BARKER COUGHLIN,
10
Case No.:
Dept. No. :
Appellant.
11
vs.
12
CV I I -03628
MAIT MERLISS,
13
14
Respondent.
--I
__
__
__
__
__
__
__
__
__
__
__
15
16
ORDER
Currently bef
ore this Court i s Respondent MATT MERLISS's ("Merliss")
Motion f
o
17
Attorney 's Fees filed on April 1 9, 2012.
18
ZACHARY BARKER COUGHLIN ("Coughlin"), Merliss submitted this matter for decision 0
19
May 9, 20 12. However, o n June 9, 20 1 2, Coughlin filed a Suppiemenl lo
20
f Attorney 's Fees.

or
21
f Attorney 's Fees

or
22
In the absence of any opposition from Appellan
In response, Merliss filed a
O
pposition 10 Mofio
Repl to Sup
y
plement to O position 10 Molio
p
on June 14, 2012, and submitted the matter-again--that same day.
Merliss requests this
Court to award attorney's fees in the amount of. $42,065.50 agains
23
Coughlin in the underlying summary eviction matter pursuant to NRS 69.050 and NRS 7.085
24
Merliss and his counsel aver these fees are reasonable, particularly given Coughlin'
25
"deliberate[] . . . pattern of abusive, vexatious, and most importantly, expensive behavior in bo
26
this appeal and in the case below [in Reno Justice Court)." (Mot. at p. 2) (Original emphasis.
27
Merliss avers Coughlin's litigation strategy "was simply to keep the fight going" and "require
28
substantial additional work by Merliss' counsel, far beyond anything in a no nnal eviction.'
'
'
02975
02975
(Mot. at p. 3.) Merliss asserts this additional work was necessary because he "could not risk th
court accepting some random citation in Coughlin' 8 papers and entering an adverse ruHn
because [he] had not opposed it." (Mot. at p. 5.)

Further, Merliss's counsel, Richard G. Hill, alleges these f
ees "do not include
substantial amount of editing and other activities perf

ormed by [Mr. Hill] in this case." (Mot. a
p. 6; Mot. Ex.
which to award the maximum amount justified by the substantial evidence before the court.'
(Mot. at p. 6.) Merliss goes even further and states:
4.)
Merliss contends "[i]t is hard to imagine a more appropriate case than this i
As proven above and below, the frivolity and vexatiousness of Coughlin's

maintenance and extension of this matter has been so beyond reason, and so
10
outrageous, and the nexus of his behavior to the f

ees incurred by Merliss 80 direct
11
and indisputable, that nothing less than a full award of those f

ees should even be
considered by the court. To not impose the full measure of the harm Coughlin has
12
caused would reward and encourage his vexatiousness in this and other cases.
13
14
There needs to be a day of reckoning f Coughlin's antics.

or
(Mot. at p. 8.)
15
Nevada law provides for "a reasonable attorney fee to be fixed and allowed by the distric
16
rom justice court

court for all services rendered in behalf of the prevailing party" on appeal f
17
NEV .
18
personally to pay reasonable attorney's fees incurred as a result of the filing, maintaining 0
19
def
ending of civil action where "such action or defense is not well-grounded in f
act or is no
20
warranted by existing law
21
attorney who has
22
STAT. 7.085{l )(b).
23
REv. STAT. 69.050.
In addition, NRS 7.085 requires the district court to order an attorne
. . "
.
"[u]nreasonably
NEV. REv. STAT. 7.085(1 )(a).
The same applies to
and vexatiously extended a civil action . . . . "
NEV. REv
If grounds exist to award attorney's f

ees, Nevada courts follow the lodestar analysis.
24
Shuette v. Beazer Homes Holdings Co

m., 1 2 1 Nev. 837, 864, 1 24 P.3d 530, 549 (2005) C'Th
25
lodestar approach involves mUltiplying the number of hours reasonably spent on the case by
26
reasonable hourly rate.") (Quotations and citations omitted.) In determining the reasonablenes
27
of the f award, the district court should consider the following four factors: (1) the advocates '
ee
28
qualities; (2) the character of the work; (3) the work perf
ormed; and (4) the result obtained. Se
02976
02976
Brunzell
v.
Golden Gate
Nafl Bank, 85 Nev. 345, 349, 455 P.2d 3 1 , 33 (1 969) (citation
omitted); Barney v. Mt. Rose Heating & Air Conditioning, 1 24 Nev. 82 1 829. 1 92 P.3d 730, 73
(2008) (per curiam) (applying the Brunzen f

actors)
After reviewing Merliss's moving papers-including the detailed and thorough summ
Declarations-and after considering all
of fees and his counsels' accompanying
arguments, this Court concludes Merliss's attomey's fees request is authorized by Nevada law
This Court also has considered the factors set forth in Brunzell, supra. After analyzing thos
factors, and given the unique features of this case, this Court concludes Merliss's fee request i
reasonable.
10
11
of the parties
Accordingly, Merliss's Motion f Attorney 's Fees is GRANTED in

or
$42,065.50.
12
I T I S SO ORDERED.
13
DATED this
J..5
day of June, 2012.
14
15
PATRICK FLANAGAN
16
Di strict Judge
17
18
19
20
21
22
23
24
2S
26
27
28
02977
02977
CERTmCATE OF SERVICE
Pursuant to NRCP 5 (b), I hereby certify that I am an employee of the Second Judicial
.15
District Court of the State of Nevada, County of Washoe; that on this
I electronically filed the following with the Clerk of the Court by using the ECF system which
will send a notice of electronic filing to the following:
day of June, 2012,
or
Richard Hill, Esq. f Matthew Merliss; and
Zachary Coughlin, Esq. for himself.
or
I deposited in the Washoe County mailing system f postage and mailing with the
9
10
United States Postal Service in Reno, Nevada, a true copy of the attached document addressed
to:
11
12
13
14
IS
16
17
18
19
20
21
22
23
24
25
26
27
28
02978
02978
Laura Peters
From:
D avi d C lark
Sent:
Monday, January
Subject:
FW: Attorney reporting
Laura Peters
To:
23, 2012 6:02
PM
under SCR 1 1 1
I guess t h i s is s a self-report.
David A. Clark
Bar Counsel
State Bar of Nevada
( 702) 3 1 7- ' 444 - direct
(800) 254-2 797
{ 702} 382-8 7 4 7
--"""" --'" . . '......'"' . - . ,. .

.. ..
fax
,..."........ -..--..- . "..
. " -'-" , " -------, --.- .
.._._........ . . . .. ,-
From :
Zach Coughlin [mailto:zachcoughlln@hotmail.com]

Sent: Monday, January 23, 2012 3 : 18 PM
To: David Oark
Subject: Attorney reporting under SCR 1 1 1
Dear Bar Counsel Clark,

It has recently come to my attention that Nevada Supreme Court Rule 1 1 1 may apply to a criminal conviction I
received (and for which an appeal is currently pending) in Reno Municipal Court in case RMC 1 1 CR 22176 for the
offense of petit larceny of a chocolate bar and some cough drops.
Supreme Court has obligation in discIplinary proceeding to look beyond label given to attorney's conviCtion to true nature
of facts, in order to determine whether underlying circumstances of conviction warrant discipline. Sup.Ct.Rules, Rule 1 1 1,
subel. 3. State Bar of Nevada v. Claiborne, 1988, 756 P.2d 464, 104 Nev. 1 15.
Sincerely,
Zach Coughlin, Esq.

1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8 1 18
fax: 949 667 7402
Nevada Bar No: 9473
1
02979
02979
.*
Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.c. 25 1 0-2521, and may contain
confidential inf
ormation intended for the specified individual (5) 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, intend only for the nam recipient(s) and may contain information
that is privileged, attorney work product or exempt from disclosure under applicable law. Ifyou are not the intended reclpient(s), you are
notifif!d that any disclosure, copying, distribution or any action taken or omittf!d to bf! taken in reliance on thf! contents of this inf
ormation
is prohibit and may be unlawful. If you recf!lve this mf!ssage In f!rror, or are not tht! no recipient(s), please notify the sender, delete
this e-moil from your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not
a waiver ofany attorney-client, work product, or other applfcable privilege.
02980
02980
To : 1 2 1 3fdd4- 6772-46ac-87ge-3Bc49 3 d
From : z ac ncough11n
3-09-12
6 : 17pa
p. 1
of 2
RECEIVED
Zach Coughlin. Esq.

Nevada Bar No: 9473
1 422 E. 9th St. #2
MAR 1. 3 2tl12
RENO, NV 895 1 2
tel: 775 338 8 1 1 8
STATE BAR Of NEVADA

RENO OFFICE
775 328 6045 fax: 949 667 7402
State Bar o f Nevada

P.O. Box 50
Las Vegas, NV 89125-0050
600 E. Charleston Blvd.
Las Vegas, NV 8 9 1 04
sent by fax and email only to :

Las Ve gas Offic e: 702 385 2878

DavidC@nvbar org. PatrickK@nvbar.org, GlennM@nvbar.org
.
March 9, 20 12,
Dear Bar Counsel Clark, Assistant Bar Counsel King and Assistant Bar Counsel Machado ,
I only just now received the letter, dated February 1 4th, 20 1 2 that Assistant Bar Counsel King
sent me, wherein the grievance filed by Richard G. Hill, Esq. is set f
orth. Mr. King wrote, "please
respond in writing to thi s grievance within ten ( 1 0) days from the date ofthis letter. "
I am requesting an extension of time to respond to this matter. I literally just received this
mailing from you within the last hour, and was unaware of this prior to that Further, I hope I can
.
demonstrate to you and the State Bar of Nevada that circumstances at least somewhat beyond my
control have prevented me from receiving my mail in an orderly and consistent fashion. These
circumstances resulted in two diff rent Domestic Violence Protection Orders being granted to me
e
against my former housemates by Master Edmondson of the Second Judicial District Court in FV 1200 1 88 and FV I2-001 87. Further, the electricity to my location was interrupted from one week (though
I attempted to get NV Energy to accept payment f
rom me for services) from February 3rd to February
20th, 2012, incident to one of the individuals against whom a protection order was issued attempting to
prevent me from obtaining electrical service. Additionally, the same individuals against whom these
protection orders were issued interfered with my access to my mail from the USPS, and it has taken
some time to get the USPS Postal Inspectors to release my mail to me and or allow me to recei ve mail
at my location.
Please note that I did recently send Bar CoWlsel David Clark and Assistant Bar Counsel Glenn
Machado a written request that the State Bar of Nevada please help me in remaining aware of any
1 12
02981
02981
To : 1213fdd4- 6772-46ac-87ge-38c493d
-.
From: zachcough11n
,."",,
3-09-12
6 : 1 7pm
p. 2
of 2
...,
correspondence being sent me f

rom the State Bar while I work to get my mailbox situation settled
(please see below):
On February 22nd, 20 1 2 1 wrote to Bar Counsel Clark and Assistant Bar Counsel Machado that
"I had to move recently and moved in with two individuals who I ultimately wound up getting
Protection Orders against, and they have interfered with my ability to
receive my mail with absolute
certainty (I have received much of my mail, and have pending correspondences/requests with the
Postmaster for Reno, NV to obtain a pennanent and newly rekeyed lock and key to access my
mailbox .. .I have been inf
ormed by USPS Reno Postmaster agent named Mr. Heister that if I fax him
proof of my location at 1422 E. 9th St. #2, he will then allow me to get a mailbox key made . . .! faxed
him proof and will call him again tomorrow to see how much longer I must wait....if its much longer I
will make alternate arrangments, however, I am an electronic filer in both courts that 1 am appearing in
(NVB and WCDC) ... ). I am writine to ask that any rormpondences/notices eke that you or the
State Bar of Nevada mayhave for me ormayhave maQed to me be. ifpossible. copied tome via
my faJnumberor email address."
I feel strongly that Mr. Hill's allegations are ones 1 will wish to contest vigorously, and I hope I
am afforded an opportunity to do so. There is a lot more to this situation than Mr. Hill indicates.
Sinc.re
Zach Coughlin
2/2
02982
02982
."""""
'-'
February 1 4, 20 1 2
600 Em Ch.rlescon Blvd.

L.u Vega., N V 89104-1 563
phon' 702.382.:1.200
",11 ii.:, 800.254.2797
f" 702.385.2878
Zach Cou hlin. Esq.

1 422 E. 9 Street
9456 Double R Blvd..
Sre. B
Reno, NV 8952 15977
Reno, NV 895 1 2
phon, 775.329.4 100

fax 775.329.0522
RE: Grievance File #NG 1 2-0204 / Richard G. Hill
www.nvbar.org
Dear Mr. Coughlin:

The Office of Bar Counsel has received the enclosed correspondence from Richard G.
Hill, Esq., which alleges professional misconduct on your part.
As such, a grievance tile has
been opened.
Please respond in writing to this grievance within ten ( l 0) days from the date of this letter
and kindly direct your response to the State Bar's Reno office. Your response should address
each allegation contained within Mr. Hill's grievance and, whenever possible, all applicable
documentation in support of your response should be included.
If you intend to supplement your response, please indicate an expected date of receipt for
the same in your response. If you have any questions, p lease do not hesitate to contact me.
Sincerely,
Patrick O. King
POKIlp
Enclosure
02983
02983
STAT E BA R O F N E VADA
February 1 4, 20 1 2
Las V.gas. NV 89104-1563
Richard O .
ph".. 702.382.2200
Hill, Esq.
toll h 800.254.2797
652 Forest Street

Post Office Box 255 1
Reno, NY 89505
f 702.385.2878
..
9456 Double R Blvd. St<. B

Reno, NY 89521 59n
phun< 775.329.4100
RE: Grievance File #NG I 2-02041 Zach Coughlin, Esq.

Dear Mr.
www.nvbar.or
g
Hill:
The Office of Bar Counsel
Iiu nS.329,OS22
is in receipt of your grievance relevant to attorney Zach

Please be advised that a gri evance
Coughlin, a copy of which has been f

orwarded to him.
tile has been opened concerning Mr. Coughlin and he has been directed to respond in writing
to this office.
The time necessary to conduct the investigation and review process cannot be
estimated, as it is dependent upon the complexity and volume of the complaints received at
any given time. However, you will be notified of the disposition of this matter following
review by an appointed Screening Panel.
Sincerely,
-r
,12' 0- J!ir
Patrick O. King
POKIlp
02984
02984
Laura Peters
Pat ri c k Ki n g
From:
F riday, F e bru a ry
Sent:
To:
10, 2012
3:33 PM
D av id Clark; obc
FW: more
Subject:
of mr co ughl i n
Appa rently Co ug hl in was a rrested for taking an I phone.

to give it back. This is h i s reply while being a rrested.
Go a l l the way down the page to the yo u t u b e l ink.

h i s pocket a n d t h e police want h i m
He has it i n
Patrick
From: Richard Hill [mailto : rhill@richardhillaw.com]

Sent: Friday, February 10, 2012 2:09 PM
To: Pa trick King
Subject: more of rnr coughlin

pat - here is his latest rant
the video lin!:?, about 1/2 way down is the incident where he was arrested for stealing an iphone
rgh
From: casey Baker

Sent: Friday, February 10, 2012 2:04 PM
To: Ri cha rd G. Hill
Subject: FW: EVictions RE: WCSO Deputy Machern's "personally served" Affidavit of 1 1{1{2011
From: Za ch Coughlin [mailto:zachcoughlin@hotmail.com]

sent: Friday, February 10, 2012 12: 14 PM
To: Istuche!l@washoecounty.usi rnkandaras@da.washoecountv. usi drakej@reno.gov; kadlicj@reno.gov;

cdbaker@richardhillaw.comi jboles@ca!latg.com; bbuckley@lacsn.org; daolshan@yahoo.com; jsoderlund@nlslaw.net;
jdelikanakis@swlaw.com; jgoodnjght@washoecounty.us; jbosler@washoecounty. us; bdogan@washoecounty.us;
mechols@maclaw.com; m clarkson@puc. nv.gov
Subject: Evictions RE: WCSO Deputy Machern's "personally served" Affidavit of 1 1/1/20 1 1
Subj ect: RE: WCSO Deputy Machem's "personally served" Affidavit of 1 1 1 1 /20 1 1
Date: Tue,
7 Feb 20 1 2
1 1 :40:39 -0800
CC : mkandaras@da.washoecounty.us
Mr. Coughlin
Machen by posting a copy of the Order to the residence. The residence was unoccupied at the time .
1
02985
02985
....... ....;T

WCSO Civil Section
Sent: Monday, February 06, 20 1 2 2:58 AM
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlici@reno.gov;
Subject: WCSO Deputy Machem's "personally served" Affidavit of 1 111120 1 1
I realize you will likely not read all of this. The main thing is I am respectfully requesting that you
confirm with Deputy Machem that he did, in fact, "personally serve" the S ummary Eviction Order
on me at 1 2 1 River Rock St., Reno 8950 1 on November 1 , 20 1 1 at 4:30 pm, in connection with
I am writing to inquire about and complain with regard to an Affidavit of Service filed by or for
WCSO Deputy Machem with respect to the service of a Order Granting S ummary Eviction against
40.253 and where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253(6),
money . . . ).
my day job (and do you wonder how many attorneys in the foreclosure defense game I am in
mentions?), which includes being a foreclosure defense attorney. So which is it? Did Machem
"personally serve" me the Summary Eviction Order? Richard G. Hill, Esq. likes to argue that! was
served the defendants....) Anyway, back to the "within 24 hours" phraseology: "
constable of the county to remove the tenant within 24 hours after receipt of the order. . . " is
40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of NRS 40 where this "within 24
.
02986
02986
""',,",
" "
40.2S3(3)(b)(2): " 3 . A notice served pursuant to subsection I or 2 must: ... (b) Advise the tenant:
. . . . (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may
and,
40.253(5)(a): "5. Upon noncompliance with the notice: (a) The landlord or the landlord' s agent
sheriff or constable of the county to remove the tenant within 24 hours after receipt ofthe order."
"pronounced", is absent here, and this "receipt of the order" language is something rarely found
which follows NRCP 5(b), and NRCP 6(e) in imputing receipt of such a letter, when actual receipt
Institute, 553 F.3d 1 1 4 ( 1 st Cir. 2009), the record did not reflect when the plaintiff received his
Saturdays and Sundays. In order to bring a claim under either Title VII or the ADA, a plaintiff must
U.S.C. 2000e-5(t)( 1 ). See Baldwin County Welcome Center v. Brown, 466 U.S . 147, 1 48 n. l ,
1 04 S.Ct. 1 723, 80 L.Ed.2d 1 96 (I 984)(granting plaintiff an additional three days for mailing
pursuant to Rule 6) .. .." . ..
Dear Washoe County Sheriffs Office,

http://en.wikipedia.org/wiki/Service of process
"Substituted service
When an individual party to be served is unavailable for personal service, many jurisdictions allow
for substituted service. Substituted service allows the process server to leave service documents
with another responsible individual, called a person of suitable age and discretion, such as a
cohabiting adult or a teenager. Under the Federal Rules, substituted service may only be made at
the abode or dwelling of the defendant.[4] California, New York,[5] Illinois, and many other
3
02987
02987
,>
United States jurisdictions require that in addition to substituted service, the documents be mailed
to the recipient.[ 5] Substituted service often requires a serving party show that ordinary service is
impracticable, that due diligence has been made to attempt to make personal service by delivery,
and that substituted service will reach the party and eff
ect notice.[5]"
am
pretty sure "personally served" means you served the person in person, not that a person
named Machem went and posted a notice on a door, personally himself. See,
I think you guys are
thinking of the "person" in the word personally as applying to the server, when in all instances I
have ever seen it used in the law, the "person" part of "personally" applies to the person being
served. Help me out here, Mary.
https:l/skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43 084638F32F5F28! 1 897&parid=root
Also, does the WCSO have a position on what type of service is required of eviction orders prior to
the WCSO or whoever does it, being able to conduct a lockout?
http://www.leg.state.nv.us/courtrules/nrcp.html
NRCP RULE 60. RELIEF FROM JUDGMENT OR ORDER.
. .
(c) Default Judgments: Defendant
Not Personally Served. When a default judgment shall have been taken against any party who was
not personally served with summons and complaint, either in the State of Nevada or in any other
jurisdiction, and who has not entered a general appearance in the action, the court, after notice to
the adverse party, upon motion made within 6 months after the date of service of written notice of
entry of such judgment, may vacate such judgment and allow the party or the party's legal
representatives to answer to the merits of the original action. When, however, a party has been
personally served with summons and complaint, either in the State of Nevada or in any other
jurisdiction, the party must make application to be relieved from a default, a judgment, an order, or
other proceeding taken against the party, or for permission to file an answer, in accordance with the
provisions of subdivision (b) of this rule.
Okay, so, really, you guys do this for a living, right...you serve people things . . . .and sign Affidavits
under penalty of perjury and stuff, and you are telling me you believe "personally served" can
included situations where the person was not there? Okay ..... you do know that, like, a S ummons
and Complaint need to be "personally served" in the sense that, say Machem, would need to see
that person and serve it on them (I don't think they have to take the paper, they don't need to agree
to accept service, but Machem does need to see that person, in person, personally when he is
swearing under penalty of perjury that he "personally served" somebody. Usually "personally
served" is only done in the case of the first thing filed (unless there is an IFP) in a case, the
Summons and Complaint. Thereafter, typically, people just effect " substituted service" because its
cheaper, less of a hassle, and "personal service" is only required for serving the pleadings that start
a case, the Summons and Complaint. Wow. . . .Okay, so this is my whole point, these state sponsored
lockouts under color of state law should not be being done so fast, unless you guys "personally
serve" the tenant, I feel the law is quite clear, you have to effect "substituted service" which, under
NRCP 6(a) and NRCP 6(e) and NRCP 5 (b)(2) (and NRCP, not JCRCP is applicable to eviction
matters according to NRS 1 1 8A) the tenant cannot be deemed to have received or constructively
received the Order until the 3 days for mailing has passed.
4
02988
02988
Personal service by process server

Personal service is service of process directly to the (or a) party named on the summons, complaint
or petition. In most lawsuits in the United States, personal service is required to prove service. Most
states allow substituted service in almost all lawsuits unless you are serving a corporation, LLC,
LLP, or other business entity; in those cases, personal service must be achieved by serving (in
hand) the documents to the "Registered Agent" of a business entity. Some states (Florida) do not
require that the documents actually be handed to the individual. In California and most other states,
the documents must be visible to the person being served, i.e., not in a sealed envelope. If the
individual refuses to accept service, flees, closes the door, etc., and the individual has been
positively identified as the person to be served, documents may be "drop" served, and it is
considered a valid service. Personal service of process has been the hallmark for initialing litigation
for nearly 1 00 years, primarily because it guarantees actual notice to a def
endant of a legal action
against him or her. Personal service of process remains the most reliable and efficacious way to
both ensure compliance with constitutionally imposed due process requirements of notice to a
defendant and the opportunity to be heard. [2]" The National Law Review: The Continuing
Relevance of Personal S ervice of Process
And even if something indicates Coughlin "knew" about the Order, much like in the case of
Coughlin's that was dismissed where the Washoe County Sheriffs didn't manage to get the
"personal service" of the Summons and Complaint done in time, or "sufficiently", opposing counsel
in that matter could tell you that "actual notice" is not a substitute for compliance with the service
requirements.
Which is nice because folks like Richard
G. Hill, Esq. have less of an opportunity to game the
system and swoop in with lockout then assert a bunch of hooey about NRS 1 1 8A.460 "reasonable
storage, moving, and inventorying expenses" subj ecting the tenant's personal property to a lien.
Richard
G. Hill insisted on throwing away the last thing my beloved grandmother gave me before
she died 2 years ago in the town dump. He and his contractor lied about so many things. including
the fact that they used my own damn plywood to board up the back porch of the property, then
submitted a bill to the court in an exhibit for $ 1 ,060 for "securing" the property (which doesn't
really apply to NRS 1 1 8A.460's "reasonable storage moving and inventorying expenses" like it is
required to . . . further, the charged me $900 a month for storage and sent me a bill for such prior to
my arrest for trespassing at the 1 2 1 River Rock location, . . .well if they charged me $900 to have a
home law office there, then how is it someone could be trespassing if they are being charged the
full rental value for "use and occupancy of the premises"? Further, even if it was a storage
situations, there are sections of NRS 1 1 8A devoted to evicting someone from a storage facility, not
arresting them for trespass, and certainly not a custodial arrest where the RPD Officer Carter and
Sargent Lopez admit they never issued a warning to me or asked me to leave prior to conducting a
custodial arrest (which required $800 of bail, great ! , and
days in jail, no less). This is especially
poor form where Officer Carter admitted to me that he takes bribes from Richard Hill. Hey, if
Officer Carter did not say that to me, go ahead and sue me, my man. . . J'm waiting .....that's what I
thought.
5
02989
02989
He can say he was joking all he wants, but it ain't no joking ass situation to me when you are
arresting me and causing a google search result for my name to show an arrest. . . .that's damaging
essional reputation and name). It ain't no stand up
the only thing I have of monetary value (my prof
hour when you are putting me in cuffs, bro . And Officer Carter and Sargent Lopez refused to
properly query Hill as to whether he had sent me, prior to the trespassing arrest, a bill for the "full
rental value" of the property, a value that, at $900, was the same charge for the full "use and
occupancy" of the premises. And Richard
G. HIll, Esq. was too busy chortling and filling out the
Criminal Complaint to bother setting them straight, despite my cues, I guess.
Now, add to that malfeasance the fact that Judge Sferrazza let Casey Baker, Esq. prepare the Order,
which means faithfully put to writing what the Judge announced, not attempt to steal $2,275 for
your Californian Beverly Hills High School graduate neurosurgeon client by slipping in something
the judge never said, ie, that the neurosurgeon gets to keep the $2,275 that Judge Sferrazza order
the tenant to pay into the Reno Justice Court as a "rent escrow" deposit required to preserve the
errazza actually did not
right to litigate habitability issues. Now, nevermind the fact that Judge S f
have the jurisdiction to require that (there is not JCRLV 44 in Reno, that's a Vegas rule, and if Reno
wants a rule like that of its own JCRCP 83 requires the RJC to publish it and get it approved by the
rrst. . . .period.). Okay, so, to take it a step even further, Baker's order goes
Nevada Supreme Court f
on to say "but the $2,275 won't be released to the neurosurgeon yet, "instead that sum shall serve as
security for Coughlin's cost on appeal, pursuant to Nevada JCRCP 73 . . . ". But wait, doesn't that
mean Coughlin then gets a Stay of Eviction during the pendency of the Appeal? Isnt' that was a
security that large must be for? Because the "Appeal Bond" is set by statute at only a mere
$250 . . . . so holding on to 1 0 times that much of Coughlin's cash must have been for the " Supersedeas
Bond" mentioned a yielding one a Stay of Eviction in NRS 40.380 and 40.385.
I know, I know, its confusing because actually those sections force the landlord, his attorneys and
the RJC to choose between viewing Coughlin as a residential tenant whose rent is less than $ 1 ,000,
and whom therefore is only required to post a measly supersedeas bond of $250 (and remember, a
supersedeas bond equals a stay of eviction equals not trespassing) or the the other choice is to view
Coughlin as a commercial tenant, which would allow charging a higher supersedeas bond (except
for that pesky part about his rent being under the $ 1 ,000 required by the statute to do so, his rent
being only $900), except, dam it, old Richard G. Hill, Esq. and Casey Baker, Esq. elected to pursue
this summary eviction proceeding under a No Cause Eviction Notice, which is not allowed against
a commercial tenant (ie, you can't evict a commercial tenant using the summary eviction
procedures set forth in NRS 40.253 unless you alllege non payment of rent and serve a 30 Day Non
Payment of Rent Notice To Quit, which they didn't because they "are just taking the path of least
resistance here, Your Honor (insert their smug chuckling and obnoxious/pretentious "can you
believe this guy?" laughter and head shaking. . . )
rom the
NRS 40.380 Provisions governing appeals. Either party may, within 1 0 days, appeal f
endant shall not stay the execution of the judgment,
judgment rendered. But an appeal by the def
unless, within the 1 0 days, the defendant shall execute and file with the court or justice the
defendant' s undertaking to the plaintiff, with two or more sureties, in an amount to be fixed by the
6
02990
02990
court or justice, but which shall not be less than twice the amount of the judgment and costs, to the
effect that, if the judgment appealed from be affirmed or the appeal be dismissed, the appellant will
pay the judgment and the cost of appeal, the value of the use and occupation ofthe property, and
damages justly accruing to the plaintiff during the pendency of the appeal. Upon taking the appeal
and filing the undertaking, all further proceedings in the case shall be stayed.
So, why on earth is the City Attorney's Office still trying to try Coughlin on the trespass charge for
which he endured a custodial arrest and for which old Richard Hill is still filing Motion's to Show
Cause on in the appeal of the summary eviction matter in CVI I -03628? Why, oh why? Does the
Reno City Attorney's Office have some sort of vested interest in keeping Coughlin down, busy,
besotted, encumbered, or otherwise? It, why, it couldn't be because Coughlin has a really good
wrongful arrest cause of action against the Reno Police Department, could it?
http://www.youtube.comiwatch?v=5PR7q40I5bO
And, well, yeah the Washoe County Sheriffs Office didn't quite get those Summons and
Complaints served in that one case Coughlin was suing his former employer in, the one where
Coughlin was granted an Order to Proceed In Forma Pauperis, which required the Washoe County
Sheriffs Office to serve the Summons and Complaints ....But what does that have to to with the 6
days Coughlin spent in jail on the arrest shown in the youtube video above? Its not like the Washoe
County jailed videotaped a scene where they were forcing Coughlin to get naked and put on a green
dress. What's that? It is? They did do that? Really? No . . . What? They also forced him to simulate
oral and anal sex with deputies, in the guise of some ridiculous "procedure" necessary to insure
Deputy safety? Oh, wow. And they retaliated against him for failing to answer their religious
preference interrogation questions by placing him in an icy cold cell for hours at a time, refusing
him medical care despite his plaintive cries for help, while wearing a thin t-shirt? Wow. They didn't
jam a taser needle in his spine for extended periods of time, though, did they? Your kidding! Whats
next, your going tell me Sargent Sigfree of the Reno PD ordered a custodial arrest on Coughlin for
"jaywalking" while Coughlin was peacefully filming, from a public spot, Richard G. Hill's
fraudulent contractor Phil Howard destroying and taking to the town dump items of enormous
sentimental value to Coughlin that he was prevented from retrieving from the property during the
scant time he was allowed to (after he paid $480 worth of a lien for what he knew not, because,
despite, 01' Contractor Phil's fraudulent $ 1 ,060 bill for " securing" the back porch (with screws
facing the outside, inexplicably, and a window unit alc left in the window facing the sidewalk near
the Lakemill Lodge, secured by nothing but duct tape
It is kind of a combo neon sign that says "Burglarize this Place, Everybody! "), Coughlin's f
ormer
home law office was burglarized on December 1 2, 20 1 1 while Richard O. Hill was holding its
contents (including, tackily, Coughlin's client's files, like the ones for the foreclosure defense
actions, etc.), asserting his "lien". A lien for "storage" where the charge for storage, $900, was the
same as the charge for "full use and occupany" was. However, that $900 a month for "storage" also
included another $ 1 ,060 charge for "securing" (and that bill actually listed "fixing a leak in the
basement. . .neither of which seem to have much to do with the "reasonable storage, moving, and
inventorying" expenses such a lien is provided for under NRS I 1 8A.460 .... ) Jeez, your probably
going to tell me Sargent Sigf
ree ordered another custodial arrest on Coughlin just two days after the
.
02991
02991
....
.. . /
jaywalking arrest, for the same fact pattern that Master Edmondson granted Coughlin's applications
for Protections Orders against based upon the battery and assaults that his former housemates
committed. Because, Sargent Sigfree thinks its "misuse of 9 1 1 " for Coughlin to call when he
returns home at night and his dog has mysteriously disappeared, and his housemates make
menacing commentary about it. Surely, Coughlin, a former domestic violence attorney would have
nothing helpful to add to Sargnet S igfree's expert opinion that "animal abuse is not domestic
violence" (tell that to NRS 3 3 . 0 1 0, Sarge) and that its, rather, "a matter for animal control" and that
Sargent Sigfree was "trying to help" Coughlin by arresting him, again, and necessitating the $ 1 ,500
bail associated with the gross misdemeanor charge, "Misuse of 9 1 1 " because, as Sargent Sigfree
told Coughlin "you keep putting yourself in situations where you are victimized" so it was
necessary to arrest Coughlin in that regard.
But hey, at least NY Energy hasn't refused to let Coughlin get any electrical service for the past
week since those with the Protection Orders against them cancelled the service and NY Energy shut
it off, without providing any notice to Coughlin, right. Nevermind. But...but surely when NV
Energy shut of the power to Coughlin's home law office on October 4th, 20 1 1 , just hours prior to
the bad faith "inspection" with videographer of Coughlin' s home law office that Casey Baker, Esq.
thought so very necessary one day before Coughlin's Tenant Answer was due ... surely NV Energy
did not leave the back gate to Coughlin's home law office open and speed off, Coughlin's beloved
mountain bike suddenly missing (the one the parents of his girlfriend of 5 years gave him)? Well,
NV Energy is probably not retaliating against Coughlin for complaining about that by refusing him
electric service for the past seven days, you would have to assume ....
NR S 40.385
Stay of execution upon appeal; duty of tenant who retains possession of premises to
pay rent during stay. Upon an appeal from an order entered pursuant to NRS 40.253 :
1 . Except as otherwise provided in this subsection, a stay of execution may be obtained by filing
with the trial court a bond in the amount of $250 to cover the expected costs on appeal. A surety
upon the bond submits to the jurisdiction ofthe appellate court and irrevocably appoints the clerk
of that court as the surety's agent upon whom papers affecting the surety' s liability upon the bond
may be served. Liability of a surety may be enforced, or the bond may be released, on motion in the
appellate court without independent action. A tenant of commercial property may obtain a stay of
execution only upon the issuance of a stay pursuant to Rule 8 of the Nevada Rules of Appellate
Procedure and the posting of a supersedeas bond in the amount of 1 00 percent of the unpaid rent
claim of the landlord.
2. A tenant who retains
possession of the premises that are the subject of the appeal during the
pendency of the appeal shall pay to the landlord rent in the amount provided in the underlying
contract between the tenant and the landlord as it becomes due. If the tenant fails to pay such rent,
the landlord may initiate new proceedings for a summary eviction by serving the tenant with a new
notice pursuant to NRS 40.253 .
NRS 40.390 Appellate court not to dismiss or quash proceedings for want of form. In all cases of
appeal under NRS 40.220 to 40.420, inclusive, the appellate court shall not dismiss or quash the
proceedings for want of form, provided the proceedings have been conducted substantially
according to the provisions ofNRS 40.220 to 40.420, inclusive; and amendments to the complaint,
8
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02992
"""'"'
answer or summons, in matters of fonn only, may be allowed by the court at any time before final
judgment upon such terms as may be just; and all matters of excuse, justification or avoidance of
the allegations in the complaint may be given in evidence under the answer.
NRS 40.400 Rules of practice. The provisions of NRS, Nevada Rules of Civil Procedure and
Nevada Rules of Appellate Procedure relative to civil actions, appeals and new trials, so far as they
are not inconsistent with the provisions of NRS 40.220 to 40.420, inclusive, apply to the
proceedings mentioned in those sections.
But, back to the Sheriff's Office. And, I
am
not really buying the idea that you guys don't know
NRCP 4 through 6 like the back of your hand, but. . .hell, maybe you don't. But, clearly the
language in NRS 40 about how the Sheriff may "remove tenant from the property within 24 hours
of receipt of the Order" do not apply where the Tenant filed a Tenant's Answer and showed up to
the Hearing and litigated the matter. Especially where, as here the lease had not terminated, by its
tenns, but was rather renewed. This is particularly true where NRS 1 1 8A prevents so tenninating a
holdover tenant's lease for a retaliatory or discriminatory purpose.
I would hate to see people start to think the Washoe County Sheriff's Office is cutting comers on
the whole "personally served" thing Gust so a landlord could get what they want quicker), just like I
would hate for people to think the Reno Municipal Court is letting the bottom line get in the way of
providing that whole Sixth Amendment Right To Counsel where jail time is even a possibility
thing. And, hey, if the RMC denies
an
indigent attorney the Sixth Amendment Right To Counsel,
the finds him guilty ofNRS 22.030, Summary Contempt Commited in the Presence of the Court,
and the puts him in cuffs when the Trial ends, summarily sentencing him to
days in jail for
violating NRS 22.030, well .... that's no big deal, right, I mean, the RMC technically kept its promise
that the underyling charge, though technically it could result in incarceration would not. .because
the incarceration was f a whole dang different charge, ie, S ummary Contempt in the presence of
or
the Court . . . . and so what if the whole "zealous advocate" thing and the denying the S ixth
Amendment Right to Counsel thing and the Summary Contempt thing don't go so well
together. . . .Or if 6 court employees had to stay til 9pm getting paid overtime at the RMC to get 'r
done . . .
NRCP 4: "(d) Summons: Personal Service. The summons and complaint shall be served together.
The plaintiff shall furnish the person making service with such copies as are necessary. Service
shall be made by delivering a copy of the summons attached to a copy of the complaint as
follows: . . . (6) Service Upon Individuals. In all other cases to the defendant personally, or by leaving
copies thereof at the defendant' s dwelling house or usual place of abode with some person of
suitable age and discretion then residing therein, or by delivering a copy of the summons and
complaint to an agent authorized by appointment or by law to receive service of process. [As
amended; effective January 1 , 2005 .] (e) Same: Other Service. ( 1 ) Service by Publication. (i)
General. In addition to methods of personal service, when the person on whom service is to be
made resides out of the state, or has departed from the state, or cannot, after due diligence, be found
within the state, or by concealment seeks to avoid the service of summons, and the fact shall
appear, by affidavit, to the satisfaction of the court or judge thereof, and it shall appear, either by
affidavit or by a verified complaint on file, that a cause of action exists against the defendant in
9
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02993
respect to whom the service is to be made, and that the defendant is a necessary or proper party to
the action, such court or judge may grant an order that the service be made by the publication of
summons. Provided, when said affidavit is based on the fact that the party on whom service is to be
made resides out of the state, and the present address of the party is unknown, it shall be a
sufficient showing of such fact if the affiant shall state generally in such affidavit that at a previous
time such person resided out of this state in a certain place (naming the place and stating the latest
date known to affiant when such party so resided there); that such place is the last place in which
such party resided to the knowledge of affiant; that such party no longer resides at such place; that
affiant does not know the present place of residence of such party or where such party can be
found; and that affiant does not know and has never been informed and has no reason to believe
that such party now resides in this state; and, in such case, it shall be presumed that such party still
resides and remains out of the state, and such affidavit shall be deemed to be a sufficient showing
of due diligence to find the defendant. This rule shall apply to all manner of civil actions, including
those for divorce"
I guess it don't matter much to me which one of you pays me my damages for the wrongful
eviction, illegal lockout, whether its the landlord, his attorney, or the Sheriffs. Office. Your money
is always good with me.
Zach Coughlin, Esq.
Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 1 1 1 1 120 1 1
Date: Tue, 7 Feb 20 1 2 1 1 :40:39 -0800
CC: mkandaras@da.washoecounty.us
Mr. Coughlin,
WCSO Civil Section
Sent: Monday, February 06, 20 1 2 2 :5 8 AM
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com ; Silva, Roxanna;
Subject: WCSO Deputy Machem's "personally served" Affidavit of 1 11 1 120 1 1
kadlici@reno.gov;
I realize you will likely not read all of this. The main thing is I am respectfully requesting that you
confirm with Deputy Machem that he did, in fact, "personally serve" the Summary Eviction Order
on me at 1 2 1 River Rock St., Reno 89501 on November 1 , 20 1 1 at 4:30 pm, in connection with
10
02994
02994
....., ....
.
......,,;
performing the lockout. It is my position that I was not "personally served" and I
am
trying to
am
writing to inquire about and complain with regard to an Affidavit of Service filed by or for
me (in my law office where non-payment of rent was not alleged, no less in violation of NRS
40.253 and where a $2,275 rent escrow deposit was foisted upon me in violation of 40.253 (6),
money . . . ).
my day job (and do you wonder how many attorneys in the foreclosure defense game I
am
in
mentions?), which includes being a foreclosure defense attorney. So which is it? Did Machem
"personally serve" me the Summary Eviction Order? Richard G. Hill, Esq. likes to argue that I was
constable of the county to remove the tenant within 24 hours after receipt of the order. . . " is
40.253(3 Xb )(2), and NRS 40.253(5)(a) are the only sections ofNRS 40 where this "within 24
40.253(3 )(b)(2) : " 3 . A notice served pursuant to subsection 1 or 2 must: . . . (b) Advise the tenant:
. . . . (2) That if the court determines that the tenant is guilty of an unlawful detainer, the court may
and,
sheriff or constable of the county to remove the tenant within 24 hours after receipt of the order."
11
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02995
-""",",
","",#
.....,,;
"pronounced", is absent here, and this "receipt of the order" language is something rarely found
which follows NRCP 5(b), and NRCP 6(e) in imputing receipt of such a letter, when actual receipt
Institute, 553 F.3d 1 1 4 ( 1 st Cir. 2009), the record did not reflect when the plaintiff received his
Saturdays and Sundays. In order to bring a claim under either Title VII or the ADA, a plaintiff must
U.S.C. 2000e-5(f)( 1 ). See Baldwin County Welcome Center v. Brown, 466 U.S. 147, 148 n. 1 ,
1 04 S.Ct. 1 723, 80 L.Ed.2d 1 96 (1 984)(granting plaintiff an additional three days for mailing
pursuant to Rule 6).
Further, despite what the inaccurate handouts of Nevada Legal Services may say about this "24
hours" and the applicability of the JCRCP to cases like these, NRS 40.400 Rules of practice, holds
that :"The provisions ofNRS, Nevada Rules of Civil Procedure and Nevada Rules of Appellate
Procedure relative to civil actions, appeals and new trials, so far as they are not inconsistent with
the provisions ofNRS 40.220 to 40.420, inclusive, apply to the proceedings mentioned in those
sections. As such NRCP 6(a),(e) applies to the Order of Summary Eviction that WCSO Deputy
Machem alleged, under penalty of perjury, that he "personally served" upon me on November 1 ,
20 1 1 . That is a lie by Mr. Machem, unless "personally served" i s def
med in a rather impersonal
way and or Machem and I have totally different understanding of the def
mition of "personally
served", which may be the case. Or, perhaps the Sheriffs Office is busy and doesn't want to wait
around to "personally serve" every tenant it wishes to evict. Fine, then just use the "mail it and
allow three days" rule in NRCP 6(e) ...the landlord's might not like it, but they can use that
frustration as an incentive not to jump to litigating every disagreement about habitability that a
tenant brings to them. You may not realize how ridiculous some landlord's get. In my case, I
offered to fix basic things that clearly implicated the habitability rules in NRS 1 1 8A.290 and the
Californian neurosurgeon, Beverly Hill High School graduate landlord balked and complained then
hired and attorney four days into a dispute .....at which point the rules against contacting represented
parties prevented much in the way of real settlement discussion, particularly where opposing
counsel has continuously demonstrated a complete indifference to pursuing settlement (why would
he at the rates he bills hours at?). I just don't think the Sheriffs Office needs to sully its image or
damage the citizen tenants of Washoe County in the name of pleasing people like Dr. Matt Merliss
or Richard G. Hill, Esq.
I AM REQUESTING, IN WRITING, THAT BOTH OF YOUR OFFICES INVESTIGATE THIS
AND PROVIDE A SWORN AFFIDAVIT FROM MR. MACHEM THAT ADMITS THAT I WAS
NOT PERSONALLY PRESENT WHEN HE SERVED THE ORDER FOR SUMMARY
EVICTION IN RIC REV20 1 1 -001 708 ON 1 111112 AT 4:30 PM (ACCORDING TO HIS
12
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02996
AFFIDAVIT OF SERVICE). YOU NEVER KNOW, I MIGHT HAVE IRREFUTABLE PROOF

THAT I WAS SOMEWHERE ELSE AT THAT TIME, SO, BE CAREFUL. There simply is not
anything specific in Nevada law addressing how such Summary Eviction Orders are to be served
and carried out. The sections dealing with
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and exclusion of tenant
for default in payment of rent. ...
6. Upon the filing by the tenant of the affidavit permitted in subsection 3, regardless of the
information contained in the affidavit, and the filing by the landlord of the affidavit permitted by
subsection 5, the justice court or the district court shall hold a hearing, after service of notice of the
hearing upon the parties, to determine the truthfulness and sufficiency of any affidavit or notice
provided for in this section. If the court determines that there is no legal defense as to the alleged
unlawful detainer and the tenant is guilty of an unlawful detainer, the court may issue a summary
order for removal of the tenant or an order providing for the nonadmittance of the tenant.. ..
7. The tenant may, upon payment of the appropriate fees relating to the filing and service of a
motion, file a motion with the court, on a form provided by the clerk of the court, to dispute the
amount of the costs, if any, claimed by the landlord pursuant to NRS 1 1 8A.460 or 1 1 8C .23 0 for the
inventory, moving and storage of personal property left on the premises. The motion must be filed
within 20 days after the summary order for removal of the tenant or the abandonment of the
premises by the tenant, or within 20 days after:
(a) The tenant has vacated or been removed from the premises; and
(b) A copy of those charges has been requested by or provided to the tenant,
E whichever is later.
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 1 0 days after the filing of the motion. The court shall affix
the date ofthe 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 1 1 8A.460 or 1 1 8C.230
and any accumulating daily costs; and
(b) Order the release of the tenant's property upon the payment of the charges determined to be due
or if no charges are determined to be due.... "
I also want to know why NRS 40. 253(8) was not followed with respect to my November 1 7th,
201 1 filing of a Motion to Contest Personal Property Lien. Why didn't the WCSO serve notice, as
required by NRS 40.253(8) upon the landlord's attorney Richard Hill? Why didn't I get a hearing
within the 1 0 days called called for by that section (to get back my client's files no less), but rather,
I had to wait a full 33 days to get a hearing, and service of notice of the hearing was not
effectuated, as required by NRS 40.235(8), by the WCSO. Why?
Please provide an indication, in writing, of the names and case numbers for the last 20 incidences
when the WCSO has served notice of a hearing set pursuant to NRS 40.253(8). What's that? The
WCSO has NEVER served such notice? Yet the WCSO is there with bells on (or Machem is) to lie
in Affidavits of Service to lock out the citizen tenants of Washoe County impermissilby early vis a
vis NRCP 5(b)(2) and NRCP 6(e)? Why is that? Is it a conspiracy? Does money talk? When I was
arrested for trespassing on November 1 2th, 20 1 1 by RPD Officer Chris Carter and Sargent Lopez,
Carter admitted to me that "Richard Hill pays him a lot of money and therefore he arrests whom
Richard Hill says to and does what Richard Hill says to do .... " Both Carter and Sargent Lopez
13
02997
02997
refused to investigate, despite prompting, whether Richard Hill has sent the tenant/arrestee a bill or
demand letter in bill for the full rental value of the property,
$900 per month, under some
interpretation of the "reasonable storage, moving, and inventorying expenses" collectable by a

landlord under a personal property line set forth in NRS
1 1 8A.460 (one could also interpret such a
bill as Hill's withdrawing or eradicating the Order of Summary Eviction itself, which was not
"personally served" by the Washoe Coun Sheriff (despite what their Affidavit of Service says
ty
.. .
wasn't even there at the time they changed the locks. . .and so the Summary Eviction Order was not
properly served under NRCP
6, and despite the Reno Justice Court impermissibly converting $2300
of my money under a "rent escrow" Order its required I comply with in order to litigate habitability
issues in a summary eviction proceeding under NRS 40.253, despite NRS 40.253(6)'s express
dicate against such an Order (unless, pursuant t o JCRCP 83, a justice court gets such a rule, like
Justice Court Rule of Las Vegas (JCRLV) Rule 44, published and approved by the Nevada
Supreme Court, which the RJC has not, rather, the RJC applies all these insidious secret "house
rules" (like f
orcing tenants to deliver themselves to the filing office to submit to personal service
notice of a summary eviction hearing within, like,
1 2 hours of the Tenant filing a Tenant's Answer
or
Affidavit in response to an eviction Notice, rather than the service requirements of such notice
fol lowing NRCP 6 (days for mailing, etc., etc., in other words, in the RJC everything is sped up
imperissilby to help landlord's out, and the NV. S . Ct ruling in Glazier and Lippis clearly
contemplate personal liability against the Court and or Judges themselves for so doing) ....A Qui
Tam action or something a la Mausert's in Solano County, I believe, in Calif
ornia, would be very
interesting . . . Still haven't heard anything from the Reno PD about the various complaints I have
filed with them in writing related to the wrongful arrests, excessive force and other misconduct
committed against me, though they did arrest me the other day for calling 9 1 1 incident to some
domestic violence for which I was granted to Extended Protection Orders against my former
housemates . ... old Sargent Sigfree ordered that arrest, as he did two days prior when he ordered a
custodial arrest of me for "jaywalking".
Funny thing, I never heard anything back from the RPD about complaints like the following one:
"From :
NvRenoPd@coplogic.com
Sent:
Wed 9/07/1 1 1 0:5 1 PM
* * * *DO NOT RESPOND TO THIS
E-MAIL****
We're sorry the following problem was found during review

of your submitted report Tl 1 005956:
THIS IS NOT THE FORUM FOR TillS TYPE OF COMPLAINT HOWEVER THIS REPORT
WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT WILL BE
ADDRESSED.
Thank you,
Officer WOZNIAK,
Reno Police Department"
14
02998
02998
What is interesting there is that at least I was provided the name of an officer, a "Wozniak" (though
I have been unable to confinn the existence of
such an RPD Officer...
or whether " TIllS IS NOT THE FORUM FOR THIS TYPE OF COMPLAINT HOWEVER THIS
REPORT WAS PRINTED AND PASSED ON TO THE OFFICER'S SUPERVISOR AND IT
WILL BE
ADDRESSED. "
What is more strange is that I submitted several online police reports to the Reno PD (a couple of
which asserted complaints against various Reno PD officers, or asked why RDP Officer Carter,
whom admitted taking bribes from Richard G. Hill, Esq. at the time of my custodial arrest for
trespassing (the one where Richard Hill signed a Criminal Complaint for trespass, then Officer
Carter and Sargent Lopez refused to follow up on my imploring them to ask Hill whether he has
recently sent me a bill for the "full rental value" of the property, the same amount that had been
charged for the "use and enjoyment" of the premises, $900, in comparision to what NRS 1 1 8A.460
may deem "reasonable storage" expenses for which a lien is available to a landlord, though NRS
1 1 8A.520 has outlawed rent distraints upon tenant's personal property .... Regardless, between
January 8 - 1 2th, 20 1 2, and was arrested twice by the Reno PD shortly after submitting these
written complaints to the Reno PD.
Actually, upon being released from jail on November 1 5th, 20 1 1 , incident to the custodial trespass
arrest, I went to Richard HIll's office to get my wallet and driver's license. He refused to provide it
to me until late November 22nd, 20 1 1 . Hill called the Reno PD on the 1 5th (or maybe I did because
he was withholding my state issued ID, the one I would need to rent a room, drive my car, and my
wallet, which is kind of useful in such situations .... ) Anyways, Sargent Tarter of the Reno PD
showed up, he went inside Hill's office with Hill for quite some time and the result was Tarter
telling me to leave. I did, but while driving down St. Laurence towards S. Virginia (Hill's office is
at 652 Forrest St. 89503 and would have required turning down the wrong way of a one way street,
Forrest, to go back to Hill's Office (so clearly I was not headed to Hill's office) Sargent Tarter
began tailing me, then he pulled me over, then he gave me a ticket, in retaliation if you ask me for
reporting RPD Officer Carter admitting that he takes bribes from Hill to Sargent Tarter minutes
earl ier Uh, well, anyways, another Sargent calls me later that night, taking the "good cop" role. But
upon informing him of what RPD Officer Carter told me about Hill paying him money to arrest
people during the 1 11 1 2/1 1 trespassing arrest, that Sargent immediately infonned me that, despite
this being the first he heard ofthat, he was sure that was not happening ... .1 guess RPD Officer
Carter is trying to explain away his comments about Richard Hill paying him money to arrest
people by dismissing them as sarcasm, a j oke, said in jest, whatever....but I don't see how that
situation (a license attorney getting arrested for a crime, a conviction for which would result in that
attorney being required to report said conviction to the State Bar of Nevada under SCR 1 1 1 , etc.,
and possibly resulting in a suspension of that attorney's license to practice law, or worse ... ) is all
that jocular of a situation. Combine that with the too quick to dismiss my reports of bribery by
Richard Hill to officer Carter to the RPD Sargent who called me on 1 111 5/1 1 regarding the
retaliation by Sargent Tarter that I complained of, and I don't think it is all that unreasonable for
anyone to take RPD Officer Carter at his word regarding Richard G. Hill, Esq. paying him money
to arrest whom Hill says to arrest. Add to that Sargent Sigfree ordering my arrest for jaywalking
.
15
02999
02999
...."
.........
(by a trainee RPD Officer) on January 1 2th, 20 1 1 (custodial arrest, bail of $ 1 60 emptied my bank
account out, or pretty close to it) while
I was peacefully filming from a public spot Richard G. Hill,
Esq's contractor Phil Howard, whom had submitted bills in courts records and filings under the lien
ound in NRS 1 1 8A.460, even where old Phil
for "reasonable storage moving and inventorying" f
used my own plywood at the property to board up the back porch (curiously leaving the screws
holding up the plywood exposed to exterior of the property where anyone could easily unscrew
them, and also leaving in a window unit ac secured only by ducttape in a window facing a sidewalk
by the LakeMill Lodge . . . .which resulted in $8,000 at least of my personal property being
burglarized from my former home law office on Decmeber 1 2th, 20 1 1 while Hill was asserting a
lien on all my personal property found therein (and my client's files, which arguably are not even
my property, but rather, the client's property). Hill went on to place what he believes to be my
social security number in court records, on purpose, despite his signing an Affirmation pursuant to
NRS 239B.03 0 that that was not the case (attaching a two page report to the RPD as an Exhibit).
Then Hill and his contractor Phil Howard both committed perjury when the signed Declarations
attesting that 1 had climbed on the contractors truck or ever touched Hill. Hill lies constantly,
whether under penalty of perjury or now, so 1 don't have time to rebut every little lie he makes (he
makes me out to comes across as a Yosemite Sam caricature of a human being in his filings when
he describes me . . . ).
Further, why am 1 arrested for trespassing and not those from Nevada Court Services where they
fice and banged on window extremely
went behind closed gate the the backyard of my home law of
loudly for 40 minutes at a time 3 times a day, one guy ringing the doorbell, one guy moving around
ecting a
all other sides of the property banging on the windows, peering in closed blinds, and aff
phony "color of law" tone, resemblance, and verbal communications, misleadingly announcing that
they were "Court Services, come out now ! ", wearing their pretend Sheriff outfits, big equipment
saddled belts (including firearms,
I believe, and radios),
etc. ,etc.
http ://www.youtube.com!watch?v=jQ 1 32q207DY

Add to that that Nevada Court S ervices Jeff Chandler drives by in his Monster Truck baring his
personalized "NCS" license plate while 1 am in the RPD squad car, handcuff
ormer
ed, outside my f
law office at 1 2 1 River Rock, at the time of the 1112/ 1 2 jaywalking arrest and the appearances are
trOUbling. Now, add to that that Lew Taitel, Esq. was my court appointed public defender in the
Reno Municipal Court in the trespass case, and that Judge Gardner had refused to provide me the
names of prospective appointed defense counsel
(I wanted to run a conflicts check) at my
arraignment (where Marshal Mentzel barked at me in a threatening tone, using menacing

ense attorney and filed a notice of
language), whereupon Taitel was appointed as my def
appearance, and received my confidential file, pc sheet, arrest reports, ssn, etc .... only its turns out
that Taitel shares and o ffice and a receptionist with Nevada Court Services and they list him and his
picture on their website as "associated with" their Process Server corporation, despite the
prohibition lawyers face against fee sharing with non-lawyers. Then, Taitel somehow manages to
ending my case without filing a Motion to Withdraw as Counsel, despite that being
get out of def
required by the Reno Municipal Court Rule 3(B):
RMCR Rule 3(B): Authorization to Represent (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.
16
03000
03000
"wtI'
\""",
But, perhaps most troubling of all is the implication that the Reno City Attorney's Office, which
defends actions against the City of Reno Police Department and its Officers, has a vested interest in
ul
discrediting me in advance of the wrongf arrest lawsuit that the Reno City Attorney's office knew
was imminent at the time of all of the above incidents, relating to the following August 20th, 2 0 1 1
wrongful arrest by RPD Officer's Duralde and Rosa.
http ://www .youtube.com!watch?v=5PR7q4015bO So, that's what attempting to coerce a suspect's
consent to an impermissible search sounds like? Add to that that the trespassing case is before
Judge Gardner, whom most recently was employed with the Reno City Attorney's Office.
And, you know what is funny? Officer Del Vecchio cuffed me and placed me in his squad car last
summer after he terrified me and another gentleman who had bicycles. He veered across the road
and screeched his squad car to a halt, jumped out, and did some other stuff, then demanded my
name and ID . . . and the lawyer in me didn't like that that much, and he didn't like me not wanting to
give it to him. This occurred right in front of my home law office in the summer of 20 1 1 . He cuffed
me and told me I was going to jail for something about a light on the front of my bicycle (the one
NY Energy likely stole when the shut off my power, unnoticed, on October 4, 2 0 1 1 ) despite my
bike actually having such a light. . . .but then Del Vecchio's partner did him a solid and talked some
sense into him, and I humbled it up for Del Vecchio and we both let it go, and I didn't go to
jail. . . . Until Del Vecchio was present supervising some Officer's training at the scene of my
custodial (9 hour) jaywalking arrest) on 1 1 1 21 1 2. But Del Vecchio, I guess either didn't want to or
wasn't able to talk some sense into Sargent Sigfree . . . . . and then S argent S igfree (the spelling is
likely off) had me arrested and charged with a gross misdemeanor, "Misuse of 9 1 1 " just two days
later, on January 1 4th, 201 1 when I called 9 1 1 to report that my roommates were laughing
menacingly when I asked them why my dog was missing
(I had
also been chased up to my room
numerous times since moving in with these people, something I had to do because so much of my
money had been taken up with bail or lost earnings due to all these wrongful arrests and abuse of
processes mentioned above . . . also these housemates had chased me with a ten inch butcher knife,
two of my tires were slashed, I was locked out all night on New Years Even when these changed
the locks at around midnight, had my furniture thrown in the street, property stolen, coffee thrown
on me, destroying my smart phone in the process, etc. , etc... And despite the housemate having an
outstanding arrest warrant, and animal abuse being listed amongst the elements of domestic
violence, Sargent S igfree told me he was arresting me because I "keep putting yourself in these
situations", like, where I am a victim, and that he was "trying to help you", he said with a smirk and
a laugh to his fellow RPD Officers, whom then proceeded to use excessive force against me. I
guess he was helping me by saddling me with a gross misdemeanor with a $ 1 ,500 bail, especially
where its been arranged for Court Services, or pre-Trial S ervices to forever deny me an OR, despite
actors for such set forth in statute (30 year resident, entire immediate family lives
my meeting the f
here, licensed to practice law in Nevada, etc., etc) . .! guess it should not be too much of a surprise
to me that Reno City Attorney Pam Roberts failed to address the perjury of all three of her
.
witnesses or that her fellow Reno City Attorney Christopher Hazlett-Stevens lied to me about
whether or not the Reno City Attorney's Office even had any documentation related to my arrest or
ore my arraignment, despite that fact that subsequent productions
whether it would in the month bef
of discovery tend to indicate that the Reno City Attorney's Office did have those materials at the
time. I could be wrong about some of this . . . But that would require and awful lot of coincidences.
Sincerely,
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03001
03001
Zach Coughlin, Esq.

1 422 E. 9th St. #2
RENO, NV 895 1 2
tel: 775 338 8 1 1 8
fax: 949 667 7402
Nevada Bar No: 9473
* * Notice* * This message and accompanying documents are covered by the electronic
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18
03002
03002
Page 1 of 1
State Bar of CA : : William Sten Tilton

.,;
Monday, February 1 3, 2012
1 ' -:
ATTORNEY SEARCH
William Stephen Tilton
#1 70814
Current Status: Active

This member is active and may practice law in California.
See below for more details.
Profile Information
he
ollowing information is from the official records of T State Bar of California.
The f
1 7081 4
Bar
Number:
Phone Number:
(909) 825-331 0
Fax Number:
(909) 825-3 165
e-mail:
Law Office of William S.
Address:
wstilton@earthlink.net
Tilton
2627 S Waterman Ave
Ste E
San Bernardino, CA
92408
Map it
County:
San Bernardino
District:
None
Westem State Univ; Fullerto n CA
District 4
Sections:
Undergraduate
School:
Law School:
Western State Univ COL; Fullerton

CA
Status History
Effective Date
Status Change
Present
Active
61711994
Admitted to The State Bar of California
Explanation of member status
Actions Affecting Eligibility to Practice Law

Disciplinary and Related Actions
Overview of the attorney discipline system.
This member has no public record of discipline.
Administrative Actions
This member has no publ ic record of administrative actions.
Start New Search
http://members.calbar.ca.gov/fallMemberlDetailI1 708 1 4
2/1 3 120 1 2
03003
03003
FI LED
Electronically
0 1 -1 4-201 2:1 2:00: 1 5 AM

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Clerk of the Court

Transation L?700422
Document Code:
Zach Coughlin, Esq.
Nevada Bar No: 9473
1 422 E . 9th St. #2
Reno, NV 895 1 2
Tele: 775-338-8 1 1 8
ZachCoughl in @hotmail .com

Attorney for Appellant
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9
)
)
) CASE NO: CV1 1 -03628
) DEPT: D7
)
)
)
)
) Opposition to Motion for Attorney's Fees
)
)
)
)
ACHARY COUGHLIN;
Appel lant,
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ATTHEW MERLlSS
Respondent.
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Opposition to Motion for Attorney's Fees
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Th is undersigned hereby fi les th is

for Appellant, Zach Coughlin.
Opposition to Motion for Attorney's Fees, as Attorney of Record
The undersigned has been a victim of domestic violence, beginning
with his move, on or about December 27th, 2 0 1 1 until the present, with the Reno Police needed to
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v isit the 1 422 E. 9th St.
25
Further, for NRCP
26
is purports to find that the undersigned made any agreement to waive his security deposit in exchange
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#2 address the undersigned is currently stationed at o n at least 6 occasions.
59 and NRCP 60 basis, this Court's recent Order is clearly inaccurate to the extent
for additional access to the property. Hill and Baker have an established practice in this case
,
- 1
Opposition to Motion f Attorney's Fees

or
03004
03004
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3
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especially of moving for attorney's fees where n o basis in fact o r law exists, See RJC 20 1 1 -00 1 70 8
Memorandum o f Fees for some $20,000 based upon a controlled substance manufacture statute that
clearly was completely inapplicable to this matter, then a similar motion they fi led under NRS 69.030
despite "summary eviction proceedings" not being "civil actions" under N JCRCP 3, which identifies
tour types of cases in j ustice courts, an only one, "civil actions" come within the purview of NRS
69.03 0. To the extent the attorneys fees issue is not made moot by this Court's recent order, it is
hereby opposed.
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PLEASE NOTE THAT THE UNDERSIGNED COUNSEL APOLOGIZES FOR THE

SOMEWHA T
SLAPDASH NATURE OF TH I S FILING, HOWEVER, IT MUST BE EXCUSED
TO SOME EXTENT CONSID ERING T H E U N DERSIGNED JUST SPENT 1 2 HOURS IN JAIL
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AFTER THE RENO POLICE DEPARTMENT (WITH THE HELP OF OPPOSING COUNSEL IN
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THE UNDERSIGNED EVICTION FROM HIS LAW OFFICE CA SE, RICHARD G. HILL, ESQ)
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ARRESTED THE UNDERSIGNED FOR "JAYWALKING" OR "FAILURE TO USE A
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SIDEWALK WHERE PRESENT" OR SOME OTHER SUCH CHARGE WHILE THE

COURSE OF FILMING TH E O r..;;STRUCTION OF ITEMS OF
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UNDERSIGNED WAS IN
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PERSONAL PROPERTY (LIKE THE LAST THING THE UNDERSIGNED'S GRANDMOTHER
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GA VE
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HIM
THE
BEFORE SHE DIED, LIKE THE CARTCTURE ORA WING OF THE
UNDERSIGNEDS GIRLFRIEND AND DOMESTIC PARTNER FOR FIVE YEARS WHOSE 22

YEAR OLD COUSIN JUST DIED IN A CAR ACCIDENT DAYS AGO) PEACEABLY AND ON
PUBLIC PROPERTY AND AFTER A RENO PO OFFICER WHO ACTUALLY HAS SOME
25
CLASS INFORMED RICHARD HILL THAT THE UNDERSIGNED WAS NOT DOING
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ANYTHING ILLEGAL.
27
BUT
THEN IN COMES OFFICER DEL VECHIO WHO ACTUALLY
"DREW DOWN" AFTER SCREACHING TO A HALT AND VEERING ACROSS THE LANE OF
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- 2
Opposition toMotion for Attorney's Fees
03005
03005
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ONCOMING TRAFFIC ON THE UNDERSIGNED THIS SUMMER IN FRONT OF THE SAME

LA W OFFICE AT NIGHT D U E TO THE UNDERSIGNED'S MOUNTAIN BIKE, ALLEGEDLY
LACKING A PROPER LIGHT, AND NOTHING ELSE.
TODAY, WHILE BEING ARRES TED
FOR JAYWA L K JN G ( DE S PITE THE FACT THA T RIC HARD

HAD THEIR TR U CK PARKED IN TH E
HILL'S CREW OF MOVERS
MIDDLE OF THE SIDEWALK THE UNDERS IGN ED
"J
WAS ON) RICHARD HILL WENT B ACK TO A PLACE HE REALLY, REALLY LIKES, THE
RENO JU STICE CO U RT , AND APPARENTLY GOT HIMSELF
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THEN DROVE OFF IN ONE OF HIS
A PROTECTI ON ORDER,
APPROXIMATELY I I PORCH ES WEARING A SHIRT
WITH FLAMING SKULLS ON IT IN A REPEA TING E D HARDY INSPIRED DESIGN. THE

UNDERSIGNED W A S DENIED ANY PHONE CALLS A T THE
WASHOE COUNTY J A I L FOR
l3
A T LEAST 6 HOUR S , IMMEDIATELY PLACED I N A SOLTTARY CON FINEMENT STYLE
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ICE LOCKER DESPITE H AVJNG MADE N O DEMON S TRA TI ON O R RESISTENCE O R
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DEMONSTRATING ANY INAPPROPRIATE CON DUCT
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SEVERAL JAIL NURSE REFUS ED
TO THE JA IL S TA FF, WHEREUPON
TO PROVIDE MEDICAL CARE (E XC E S S IVE FORCE
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WAS USED DURING THE ARRE S T, WHICH APPARENTLY , WAS CONDUCTED R Y AN
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O FFICER
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STOLEN FROM THE UNDER S IGN ED B Y THE JAIL STAFF, A DEPUTY A DA MS, IN FRONT
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LEEDY THA T OFFICER DEL VECHIO WAS "TRAINING", THEN MONEY WAS
OF DEPU TY DOCIO INFORMED THE UNDERSIGNED THAT HE
"
DIDN'T GIVE A SHIT IF A
D rPSHIT LIKE YOU HAS LIFE THREATENING MEDICAL I SSUES" AND REFUSED TO
IT APPROPRlA TE TO
24
S UMMON A NURSE. THE WASHOE COUNTY JAIL FOUND
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FINALLY RELEASE THE UNDERSIGNED FROM JAIL AFTER MAKING HIM PAY SOME OF
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THE LAST MONEY HE HAD FOR "BAIL", TAKING MOST O F THE REST O F THE MON E Y
THE UNDERSIGNED H A D AND CLAIMING IT WAS EITHER "LOST" O R THAT "THEY
03006
03006
'.
WERE WRONG EARLIER W HEN THE SWORE THAT THAT AMOUNT WAS
WOULD N EED TO BAIL
OUT" WHEREUPON THE JAIL STAFF
CASH FROM THE UNDERS I GNED,
JAIL
FOR THE NI G HT
DRESS ONLY IN A THIN
DEGR EE S , AND TH E
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MINUTES AFTER THE LA S T
SHIRT AND J EAN S ,
UNDERSIGNED HAVING $2 IN HIS POCKET, WHEREUPON THE

BY
S U P ERVI S OR "KARl" WHO
THE U NDE RS I GNE D THAT SHE KNE W EVERYTHING THE RENO PD COULD
WOULD DO AND THAT THEY WOULDN'T DO AN YTHING
W R O N G, AN D
OR
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REF U SED TO DIV U L GE
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UNDERSIGNED THAT HYPTHERMIA OR EXPOSURE TO COLD WE A THER
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CONS ITU TE
O F EMERGENCY. FINALLY THE
20
OFFICERS
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SOMEONE RISE
TO THE LEVEL
HI S VEHICLE, NEAR TH E
ONLY TO PROMPTLY BE PULLED OVER B Y 5-6 ARMED RENO PO
WHOM C I TED
THE FACT THAT THE UND E R S I GN E D LICENSE PL ATE WAS
GONE (IT HA D , APPARENTLY, MYSTERIOUSLY DISAPPEARED WHILE THE
UNDERSIGNED WAS IN JAIL
FOR A C U S TO DIA L
ARREST FOR
"J
AY WALKING " ,
SOMETHING RICHARD HILL, E SQ . DID IN FRONT OF THESE VERY SAME OFFICER S

WHILE THE UNDERSIGNED WAS IN THE PATROL CAR), IN C LUDING
SEVERAL TrMES
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ONE WHOM THE UNDERSIGNED HAS
28
DID NOT
SITUA TION WHERE POLICE OR
UNDERSIGNED G OT TO
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THEN KARl
9 1 1 OPERATORS WHO IN FORMED THE
SI IERIFF PE RS ONNE L WERE CONSPIRING TO MURD E R
S IENN A H OTEL,
22
THE IDENTITY OF THE
AN EMERGENCY, NEITHER WOULD A
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21
BU S
THE TEMPERATURE A FREEZING 25
12
THE
LEFT PARR BLVD, AND AT 1 ] :00 AT N I GHT, WITH THE UNDER S I GNED
UNDE RS I GNED CALLED 9 1 1 AND WAS HUNG UP ON

INFORMED
D EC I DED TO POCKET
WITHOUT HIS C ONS ENT, PRIOR TO RELEASE.
SAW FIT TO RELEASE THE UNDERSIGNED ONLY
ALL YOU
SUB MITTED A
COMPLAINT REGARDING TO THE
RENO PD JU ST DAYS BEFORE, OFFICER NICHOLAS DURALDE, WHOM WAS PRE SENT
03007
03007
WHEN OFFICER RON ROSA AITEMPTED TO EXTORT A CONFESSION OR CONSENT TO
SEARCH FROM THE UNDERSIGNE D DURING AN INCIDENT IN A U GUST BY, IN ROSA'S
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6
WORDS "CALLING THE STATE BAR" AND DEFAMING THE UNDERSIGNED,

WHEREUPON OFFICER DURALDE COMMITTED EGREGIOUS POLICE MISCONDUCT. IT
IS IMPORTANT TO NOTE THAT RENO PO OFFICER CA RTER PREVIOUSLY INFORMED
THE UNDERSIGNED THAT "RICHARD HILL PAYS HIM A LOT
THEREFORE HE WILL ARREST WHO RICHARD HILL SAYS TO AND HE WILL DO WHA T
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OF
MONEY AND
RICHARD HILLS SA YS". PREVIOUSLY, RENO PO SARGEN T TARTER HAS TICKETED

THE UNDERSIGNED FOR F ATLURE TO STOP COMPLETELY BEFORE THE WHITE LINE
A T A STOP STGN, IN A RETALIATORY FASHION, AFTER THE UNDERSIGNED LEFT
13
RICHARD HILL, ES Q .S OFFICE, WHERE RICHARD H ILL HAD BEEN REFUSING TO TURN
14
OVER
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THE UNDERSIGNED STATE OF NEVADA DRIVER'S LICENSE
FOR
WEEK. FURTHER, RICHARD HILL'S LICENSED CONTRACTOR (WHOM HAD

PREVIOUSLY SUBMITTED WHAT APPEARS TO BE A FRAUDULENT BILL FOR $ 1 060 TO
BOARD U P AND
"FIX
A LEAK I N T H E BASEMENT" (THE LEAK, H E INFORMED TH E
ACTUALLY JUST FIXED OUT OF THE "GOODNESS OF HIS HEART")
19
UNDE RS IGN ED, HE
20
AS, SOMEHOW, QUALIFYING A S "REASONABLE STORAGE, MOVING,
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OVER ONE
AND
INVENTORYING EXPENSES" LANDLORD LIEN UNDER NRS 1 1 8A.490, DESPITE THE

FACT TlIAT THE CONTRACTOR USED THE UNDERSIGNED'S OWN WOOD AND
PLY WOOD TO BOARD U P THE PROPERTY DESPITE CHARGING $ 1 060 FOR DOING SO
25
AND WHOM TODAY WAS THROWING A WAY THE CALIFORNIA NUEROSURGEON,
26
MATTHEW JOEL MERLISS, MD.'S CARPET, WHILE RICHARD HILL WAS APPARENTLY
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REA DY ING HIMSELF
TO SUE THE UNDERSIGNED
BOTH F O R THE
COST O F DISPOSING
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- 5
jon for Attorney's Fees

Oppositjon to Mot
03008
03008
IT AND FOR COST OF IT AS PROPERTY, AND BOTH OF THESE DISCOVERIES SEEMED
TO VEX THE CONTRACTOR SO COMPLETELY THAT HE FELT IS NECESSARY TO CALL

UP RICHARD HILL RIGHT A WAY AND HAVE RICHARD DO HIS THING WITH THE RENO
4
5
PO (LIKE WHEN OFFICER CARTER AND OFFICER LOPEZ ARRESTED THE
UNDERSIGNED FOR TRESPASSING DESP ITE NOT ONCE IDENTYING THEMSELVES
PRIOR TO ARREST AS OFFICER AND NO ONE HAVING ASKED THE UNDERSIGNED TO
LEA VE THE PREMTSES, AND WHERE THESE OFFICERS, AGATN, STRANGELY, FOUND
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THE UNDERSIGNED NOT "CANDIDA TE FOR A CITATION". THE ARREST TODAY WAS
PARTICULARLY CONVENIENT FOR RICHARD HILL CONSIDERING IT PREVENTED ANY
FILMING OF THE DESTRUCTION OF PROPERTY HE WAS ENGAGING IN. RICHARD HILL
13
PREVIOUSLY GAVE THE UNDERSIGNED A BAG OF T RA SH IN RESPONSE TO THE
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UNDERSIGNED'S DEMAND THAT HILL CEASE APPLYING AN UNLA WFUL RENT
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DTSTRAINT TO THE UNDERSI GNED' S CLIENT'S FILE S . FURTHER, WHEN THE

UNDERSIGNED REFERENCE THE DAMAGE RICHARD HILL WAS DOING TO CLIENT'S
INTERESTS IN CASES JUST LIKE THE CARPENTI ER'S, RICHARD HILL, IN JUDGE
SFERRAZZAS COURT ROOM WATCHING
THE PROCEEDTNGS AND PERIODICALLY
CROSSING THE BAR TO PASS POST IT NOTES TO CASEY BAKER (DESPITE JUDGE
SFERRAZZA DIRECTING HILL AND OTHER WITNESSES TO LEAVE THE COURTROOM
UNTIL CALLED TO TESTIFY) MADE A MASTURBATORY JESTURE AND EXTREMELY
D ISMIS SIVE AND CRUDE FACIAL EXPRESSION AS IF TO S I G N A L HOW UTILE HE
25
CARED ABOUT THE FORECLOSURE DEFENSE OF MIDDLE CLASS A MERICANS AND
26
CITIZENS OF WASHOE COUNTY LIKE the undersigned's foreclosure defense clients.
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03009
03009
D ated this January 1 3th, 20 1 2
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3
4
/s/ Zach
couh\jRY.// --
Zach CoughlIn
NV Bar No.
5
6
pjsq.
94n
1 422 E. 9th St. #2-
Reno, NY 895 1 2
Tele: 775-3 3 8-8 1 1 8
Fax: 949-667-7402
Attorney for Appellant
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0301 0
03010
.-
AFFIRMATION Pursuant to NRS 239B .03 0
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3
Also, th is document does not contain any social security number or other inappropriate material
pursuant to NRS 239B.030.
DATED th is January 1 3th, 20 1 2
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- .---.--".- - - -
)ki;h 20ghiin
iZach Coughlin
Appellant
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Opposition toMotioo for Attorney'S Fees
0301 1
03011
PROOF OF SERVICE
T, Zach Cough lin, declare:
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6
7
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9
On January 1 3th, 20 1 2, T, Mr. Zach Coughlin served the foregoing Opposition to Motion
for Attorney's Fees by faxing and serving upon registered eftlers and depositing a true and correct
copy in the US Mai l addressed to:
Richard G. Hill, Esq. and
Casey Baker, Esq.
652 Forest St.
Reno, NV 89503
Attorneys for Respondent Matt Merliss, MD
10
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I
.
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- __,_ ./-......,.
...-------.,.;..-.... ----------------
Zach COughlin
13
AGENT OF APPELLANT
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- 9
0301 2
03012
(775) 348-0888
FAX (775) 348-0858
652 Forest Street
RICHARD G. HILL
Reno. Nevada 89509
rhill@richardhillaw.com
CASEY D. BAKER
cdbaker@richardhillaw.com

Reno. Nevada 89505
www. richardhillaw. com
SALL Y S. UALLAUHER. Legal Assistant

sgallagher@richardhillaw.com
SHERRI L. HILL. Legal Assistant

shill@richardhiJlaw.com
KAREN A. NIELSEN. Legal Assisrant

knielsen@richardhillaw.com
January 14, 2012
VIA EMAIL ONLY patrickk@nvbar.org

Patrick King, Esq.
State B ar of Nevada
9456 Doubl e R. Blvd.

Reno, Nevada 89 521
Re:

Nevada Bar No. 9473
Mr. King:
You and I have previously discussed Mr. Coughlin. Mr. Coughlin, due to
his mental instab ility, lack of integrity, and complete incompetence, constitutes a danger
to the public if he is allowed to continue to p racti ce law. This letter is written to
discharge my and my associate's reporting obligations under RPC 8.3. Please consider
the following:
1. Rissone v. Gessin, CVlO-01341. Although not among Mr. Coughlin' s

most significant ethical violations, it presents a good microcosm of his derelictions. Mr.
Gessin was a client of our office. He defrauded the plaintiff, as is his modus operandi in
dealing with women. Approximately one year after judgment was entered and the case
concluded, Mr. Coughlin interjected himself in the case on behalf of Gessin, trying to
collect on a sanction award against opposing counsel. It turns out that be cau se he had
filed bankruptcy, Gessin no longer owns this claim. If you look at the file, you will see
that Coughlin appeared and then filed a bizarre " partial withdrawal" docu me n t on
December 8, 2011.
030 1 3
03013
Letter to Patrick King, Esq.

January 14, 2012
Page 2
Subsequent to that time, Coughlin has been ghostwriting documents that

purport to be from Gessin, individually, and e-filing them for Gessin. He is using the
"/s/" for Gessin's signature. These are clearly not documents that are signed or
prepared by Mr. Gessin, and the fact that somebody (Coughlin) e-files them confirms he
is ghostwriting without the required disclosure. In addition, it appears that Coughlin
has facilitated the filing of what may be a fraudulent bankruptcy on behalf of Gessin.
Coughlin's lack of competence is demonstrated in the Gessin case by the fact that he
does not understand the effect on the ownership of Gessin's potential claims from
Gessin having filed a bankruptcy, (i.e., the claims now belong to the bankruptcy trustee,
not Gessin.)
As with all of the matters referenced below, I strongly suggest that you
contact the Second Judicial District Court and get e-filing access to the cases mentioned
so you can look at the documents yourself. Glade Hall, Esq., is opposing counsel in that
case and may be of help to you.
2. I am informed and believe that Mr. Coughlin was recently convicted of a
theft crime in Reno Municipal Court. I am further informed that the matter arises out of
shoplifting at Walmart. That case is presently on appeal to the district court in case
number CRU-2064. Mr. Coughlin is representing himself.
3. Mr Coughlin is presently facing criminal charges regarding the theft of

an iPod. That is pending in Reno Justice Court as case number RCR20U-063341. I
have reviewed the file. Mr. Coughlin got into some sort of argument with his public
defender. As a result, he was referred out for a competency evaluation.
.
4. We represent Dr. Matthew Merliss, a physician from Chico, California.

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-girlfriend. The lease
expired in February 2011. The girlfriend left the community in approximately May 2011.
Dr. MerIiss 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 justified his withholding rent. All of his
claims were decided adversely to his position at the eviction hearing. Justice of the
Peace Peter Sferazza ordered Coughlin evicted from the premises effective November 1,
2011. On that date, the Washoe County Sheriffs Department performed their normal
eviction procedure: locks were changed and the eviction notice was posted on the front
door. We videotaped the home and its contents at that time. Upon inspection over the
next few 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
0301 4
03014

January 14, 2012
Page 3
someone had been in there since I had last been in several days before. Dr. Merliss
discovered that the basement door was barricaded (not locked) from the inside. The
Reno Police Department was summoned. They tried to coax whoever was in the
basement out, without success. After Dr. Merliss had to kick the door down, it was
discovered that Mr. Coughlin had broken in and was living in the basement. He was
arrested and is presently facing criminal trespass charges in Reno Municipal Court. See
case no. 11 CR 26405 2 1 . He is also facing a contempt motion in front of Judge Sferazza
in the eviction case. Judge Sferazza has stayed that matter pending the resolution of the
criminal trial. That trial was scheduled for January 10, 2012, but was continued at the
request of Mr. Coughlin's new attorney.
5. The eviction order is now on appeal to the Second Judicial District

Court. See case CVll-03628, pending in Department 7. As part of the eviction process,
a lien was asserted against the personal property that Coughlin left behind at the home.
On November 16, 2011, Coughlin filed a motion to contest the l andlord's lien in the Reno
Justice Court. The court tried to promptly set a hearing, but Coughlin refused to
cooperate in setting the matter, and the court took it off calendar. Coughlin then re
initiated that process and a hearing was held in December, at which time the court heard
evidence of Coughlin's lack of cooperation in setting the November hearing. You may
also want to contact Reno Justice Court staff, and in particular, chief clerk Karen Stancil,
about Mr. Coughlin's abusive treatment of her and her staff. After the hearing, the court
issued an Order granting Coughlin a two-day time window to remove his personal
property. The first day was Thursday, December 22 2011. After Coughlin was allowed
into the home that first day, he sent out an e-mail to the effect that because he had
appealed Judge Sferazza's order, he was entitled to a stay of proceedings and was going
to resume living in the home. As a result, he did very little to remove any of his personal
property that day. On Friday, December 23, 2011, after he learned, again, that his stay
had been denied, Coughlin assembled a small crew and they were able to remove a
substantial amount of his personal property. (You need to understand that Mr.
Coughlin is a hoarder. We have the photos and videos if you would like to see them.)
However, Mr. Coughlin did not get all of his property out. For example, I counted 13 car
seats that he had somehow managed to get down into the basement.
,
Having failed to remove all of his belongings, Mr. Coughlin then moved
before Judge Flanagan for a temporary restraining order to prevent the disposal of his
abandoned property in accordance with Judge Sferazza's order. Attached is Mr.
Coughlin's motion, my office'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 for a
temporary restraining order. On January 12, 2011, the contractor hired to clean the
house commenced work. Mr. Coughlin flagged the contractor down in traffic when he
(the contractor) was on his way to the dump with the abandoned property from the
home. Coughlin called the police, who arrived at the transfer station . Coughlin was
falsely asserting that the contractor had tried to run him over. He also told the police
0301 5
03015

January 14, 2012
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that the contractor had stolen his possessions. After I presented the court orders to the
police, the contractor was allowed to proceed. At their instruction, I have now had a TPO
issued against Coughlin by Reno Justice Court.
However, before the contractor could get back to the River Rock house,
Coughlin was there. He had his video camera and was walking up and down the street
screaming and yelling at the police, at the contractor, and at me, when I arrived. Mr.
Coughlin ended up being arrested and taken to jail. The police informed me that
because of the number and types of contacts they have had with him, he is no longer
eligible for citations in the event of infractions.
Enclosed you will find a copy of a supplemental document filed by Mr.
Coughlin on January 13, 2012, and sent to my staff and I by email from Coughlin that
morning. Please note that the attorney designation on the first page indicates that it is
being filed by Coughlin as appellant. You will note that the caption is from a different
case. It is unclear in which case Mr. Coughlin intended to file this document, although,
because of the case number and the caption, it appears to have ultimately been routed to
the Carpentier case (CVOS-OI709) and not the eviction appeal case (CVll-0362S). I am
told that counsel in the captioned case may also be in the process of filing a bar
complaint against Coughlin.
6. When the house was secured after Coughlin's arrest, we found a crack
pipe and a bag of what appeared to be marijuana. The contractor also reported finding a
box of pills and a vial of some sort. We understand Coughlin has unsuccessfully tried
the Lawyers Concerned for Lawyers program, and that he has a history of substance
problems.
7. Mr. Coughlin has filed two lawsuits against his former employer,
Washoe Legal Services. He has sued all ofthe board of directors and the management of
the company. Both cases have now been dismissed. Both cases demonstrate his lack of
competence. I suggest you contact Joseph Garin, Esq., in Las Vegas, as he was counsel
for the defendants in that case. You may want to contact Paul Elcano, Esq., the director
of Washoe Legal Services.
S. Mr. Coughlin has a habit of initiating cases and asking to proceed in
He has done so in cases against me, my office, my client, and Washoe
Legal Services. You will find them if you run a search for Coughlin Z on the Second
Judicial District Court website. The courts that have reviewed the documents have
generally denied his requests. What is of note is that his representations in the
applications to proceed inf
ormapauperis are inconsistent with and contrary to the
representations that he has made to Judge Flanagan in the context of seeking a
temporary restraining order. On the one hand, he tells the court he is broke and has no
property, and on the other hand, he is telling the court that he has a great deal of
valuable property at the home that needs to be protected. This demonstrates a gross
lack of candor with the tribunals with which he deals.
forma pauperis.
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9. Coughlin has also tried to file a case against me, my associate, my client,
and others, including the Reno Justice Court. It is also to be found on the website.
Judge Steinheimer has ruled that he did not comply with NRCP 8 .
10. Coughlin's behavior was unusual t o start, and has become more and
more bizarre during the time we have been dealing with him. He serves papers he does
not file, and files papers he does not serve. He consistently signs certificates of service
that he has mailed to us, but we have received an
ything from him by mail. He has
posted videos of the eviction service attempts and parts ofthe trial on YouTube,
including some recordings he secretly made in court with his cellphone.
11. Another example of his incompetence is that he does not understand
what orders are, and are not, appealable. He does not understand that filing a notice of
appeal divests the lower court of jurisdiction.
I am confident that once you look into this matter, you will agree that Mr.
Coughlin should not be practicing law. He is a danger to the community.
Sincerely,
lSI
Richard G. Hill
RGH:kn
Enclosures:
-Coughlin Amended Emergency Motion for Restraining Order
-MerIiss Opposition to Motion for TRO
-Coughlin Reply to Opposition to Motion for TRO
-Supplemental Reply to Opposition dated 1/13/12
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FYI
Unfrozen Caveman La\\.'yer practicing in Reno and beyond in Nevada
About
Zach Coughlin Esg . . ...Attorney focusing on Prosecutorial and

Police Misconduct cases and lawsuits a2ainst the Public
Defender for Malpractice Nevada
Police, Prosecutorial
and Judicial
Misconduct
"There is no crueler tyranny than that which is exercised under cover of law, and with the colors of
justice .. ,"
- U,S. v, Jannotti, 673 F,2d 578,614 (3d Cir. 1982)
Note: We add links to updates with the original news articles reporting police and/or prosecutor
misconduct, so be sure to scroll down to check for "new news".
LIVE CRIMINAL LAW INFORMATION
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The Justice Project's Recommendations to Ensure Prosecutorial Accountability
States should require that prosecutors' offices adopt and enforce clearly defined official policies and
procedures.
States should require open-file discovery in criminal cases.
States should require that prosecutors document all agreements with witnesses and jailhouse
informants concerning conferment of benefits of any kind.
States should require trial and appellate judges to report all cases of prosccutorial misconduct,
including cases where the misconduct is ruled to be harmless error.
States should establish a prosecutor review board with the power to investigate allegations of
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misconduct and impose sanctions.

States should require that prosecutors participate in training and continuing education programs.
Click HERE to read The Justice Project's policy review (pdt). Click HERE to visit The Justice Project
website.
Justice in the Balance (Link)
AUSA TODAY investigation documented 201 criminal cases across the nation in which federal
judges found that prosecutors broke the rules. The abuses put innocent people injail, set guilty people
free.
Both Sides of the Law A Special Report from the Milwaukee Journal-Sentinel
Both Sides of the Law
How the system allows Milwaukee Police officers to keep their jobs despite run-ins with the law
Prosecutor Oversight
A Thumbnail Sketch ofUSDOJ"s "Public Integrity" Unit
On October 27, 2008, Alaska Senator Ted Stevens, a pillar of the Senate for 40 years, was convicted
of a seven-felony string of corruption charges - found guilty of accepting a bonanza of home
renovations and fancy trimmings from an oil executive and then lying about it. The conviction came
just in time to cost him re-election. After all, who has more credibility, a convicted felon or an elite
team of prosecutors brought together to ensure that elected officials maintain the highest level of
integrity? As it turns out, it's the felon who is more credible. The hot-shot "Public Integrity"
prosecutors hid evidence of Sen. Stevens' innocence in order to get a conviction. They acted no .more
honorably than cheating prosecutors all over the country, the kind that distraught citizens turn to the
"Public Integrity"Unit to rein in.
Sentor Stevens was exonerated more than a year before he died in a plane crash on August 9, 2010.
Six weeks later, Nicholas Marsh, one of the "Public Integrity" prosecutors, committed suicide. The
official investigation of theUSDOJ prosecutors continued at a snail's pace, and appears to be
wrapping up with evidence of criminal misconduct that will go unpunished. Below are some
highlights of the investigation, food for thought that leads inexorably to the question, If they can do
this to a rankingU.S. Senator, what do they do to regular citizens?
December 23, 2008. A special agent with the FBI is accusing government prosecutors in the Ted
Stevens case of intentionally withholding exculpatory evidence from Stevens' lawyers and scheming
to conceal a witness from the defense team. Did the government cheat to convict the Senator?
February 14, 2009. An angry fcderal judgc held Justiec Department lawyers in contempt yestcrday for
failing to deliver documents to former senator Ted Stevens's legal team, as he had ordered. "That was
a court order,"U.S. District Judge Emmet
G. Sullivan bellowed. "That wasn't a request. I didn't ask
for them out of the kindness of your hearts.... Isn't the Department of Justice taking court orders
seriously these days?" Judges rarely hold prosecutors in contempt. They're following in Mike
Nifong's footsteps.
November 21, 2011. The lawyer investigating allegations of misconduct in the investigation and
prosecution of the latc Alaska Senator Ted Stevcns is not recommending that any of the government's
lawyers face criminal charges. Still, the special prosecutor's report, filed in the chambers of
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District Judge Emmet Sullivan, revealed "systemic concealment" of favorable information that would
have corroborated the former Republican senator's defense that he did not knowingly file false Senate
fmancial disclosure forms. They're getting off a lot lighter than their victim did.
Texas. The former prosecutors who tried Michael Morton for murder in 1987 - District Judge Ken
Anderson and Round Rock lawyer Mike Davis - didn't mind hiding exculpatory evidence or
keeping a serial killer on the street to kill again. Getting a conviction was their only goal. Now that
Morton has been cleared, after a quarter century in prison, Anderson and Davis don't want to answer
questions under oath about what they did to him. Ask me no questions, I'll tell you no lies.
California. Seventeen years after he was set up by police and prosecutors and convicted of a murder
he didn't commit, Obie Anthony is free. Attorneys from the Northern California Innocence Project
brought a state habeas petition, which was granted on the basis of the cumulative harm done by
egregious prosecutorial misconduct. And while Mr. Anthony sat in prison, the real killer got away
with murder.
North Carolina. Pity Durham County. First there was the fiasco of publicity hound Mike Nifong,
eventually disbarred for his handling of the infamous "Duke LaCrosse Rape Case." An investigative
series by the Charlotte News & Observer examines evidence that his successor, Tracey Cline, may be
following in Nifong's footsteps, literally.
Twisted Truth
Part 1
Part 2
Part 3
Missouri. Kenny Hulshof once excelled at asking tough questions in Missouri courtrooms. But did
Hulshof push the rules to win? i\nd in doing so, did he convict innocent people?
Maryland. In 1988, the centerpiece of the prosecution's murder case against William Ray - in fact,
the only physical evidence the state had - was a baseball cap worn by the man who killed Baltimore
restaurant owner George Prassos. But when Ray's defense team sought the cap for DNA testing,
prosecutors say it has been lost. How convenient; how unbelievable.
North Carolina. The North Carolina Innocence Inquiry Commission has decided unanimously that a
three-judge panel should review the cases of Kenneth Kagonyera and Robert Wilcoxsin. Both pled
guilty to 2nd degree murder in the death of Walter Bowman of Fairview, NC, even though both
maintained their innocence before and after their pleas. DNA results have excluded both men. Worse,
convenience store surveillance tape that would have supported their alibis was taped over with
footage from a soap opera while in the sheriffs department custody. The ghost of Rosemary Woods
must be haunting the Buncombe County Sheriff's Department.
UPDATE: September 22, 2011 - Kenneth Kagonyera and Robert Wilcoxson walked free when a
panel of judges ruled they didn't kill a man during a home invasion despite their guilty pleas a decade
earlier. They pled to avoid the death penalty.
Illinois. In Zion, IL, on Mother's Day in 2005, 8-year-old Laura Hobbs and her friend, 9-year-old
Krystal Tobias, disappeared while bike riding. After searching all night, Laura's father, Jerry Hobbs,
found them, stabbed to death. There followed a marathon, 48-hour police interrogation, after which it
was announced that Jerry had confessed. It was a classic, coerced, false confession, but the media
went with it. Nancy Grace called him "a monster." When the physical evidence - DNA - proved
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him innocent, the state took another 2 1/2 years to set him free and look for serial killer Jorge Torrez.
How many li ves did the coerced false confession cost?
California. Caramad Conley of San
Francisco spent 18 years in prison for a crime he didn't commit
because then-homi cide inve stig at or Earl Sanders, who would later become police chief, had stood by
in court while the star prosecution witness, a paid snitch, lied under oath. Business as usual.
California. On ly a tiny percentage of
prosecutors who engaged in miscond uct were disciplined by the
State Bar of California d uring a 12 -year period, according to a report released October 4,2010.
Among 707 cases between 1997 and 2009 in which courts explicitly determined that prosecutors had
committed misconduct, only six prosecutors - 0.8% - were disciplined by the State Bar of
California. On ly 10 of the
4,741 disciplina ry actions by the state bar during the same period involved
prosecutors. "Preventable Error: A Report on Prosecutorial Misconduct 1997-2009," issued by the
Innocence Project's Northern California chapter, was written by Kathleen Ridolfi and Maurice
Possley, a visiting research fellow at the project . Possley won a Pulitzer Prize for his reporting at the
Chi cago Tribune. Ridolfi is a professor at Santa Clara Universi ty School of Law. Click HERE to
download the full report (pdf format).

North Carolina. SBI agent Duane Deaver will likely face a judge to explain why he shouldn't be sent
to jail for making shifting expl ana tions about criminal blood tests in the case of Greg Tayl or , found
innocent by the NC Innocence Inquiry Commission. The most likely question a judge will consider in
Taylor's case is simple: Did Deaver lie to the commission in September 2009 abo ut blood tests
performed on Taylor's SUV in 1991. The answer should be obvi o us.

Missouri.
A northwest Missouri judge
has ordered all evidence thrown out in a decade-old murder
case in which a former Kansas City attorney is accused of beating his law partner to death in their
downtown office. This is some of the most egregi ous prosecutorial misconduct documented by a court
in a long time. When the defense says "show me," the prosecution says "n o. "
Texas. Police in Richardson, Texas put a lot of effort into coercing a rape confession from deaf
teenager Stephen Brodie back in 1990. Maybe that's why they continue to insist they had the r ight
guy, even though the physical eviden ce tied the crime - and 15 other rapes in the area - to Robert
Waterfield. Brodie spent 10 years in prison for the crime. He has now bro ught a p etiti on to establish
his innocence, based on Watcrfield's fingerprint on the window of the victim's bedroom. The cops
remain in denial.
UPDATE: Stephen Brodie was exonerated and freed on September 29, 2010.
Wisconsin. In response to the title of an article posted (below) just a few weeks ago, about the rarity
of discipline for Wisconsin prosecutors, we can only add:
"
Yo u ' re darn tootin'!" Both the Office of
Lawyer Regulation and the Wisconsin Department of Justic e detennined in 2009 that it was neither
unethical nor illegal for Calumet County DA Ken Kratz to send sexually charged text messages to the
victim of a vicious domestic abuse case he was prosecuting. His conduct doesn't look so good in
daylight. The rats who covered for him have deserted his sinking ship, but remember: The people now
prosecuting Kratz are the same ones who covered for him.
UPDATE: Kratz resigned from his post a s Calumet County DA on October 1, 2010.
New Yor k. Prosecutors' failure to disclose that hypnosis was used to help a witness recover memories
of alleged sex abuse as a child does not invalidate a defendant's guilty plea, a federal appeals court
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has ruled. The 2nd U.S. Circuit Court of Appeals refused to grant the habeas petition sought by Jesse
Friedman, who was seeking to undo his 1988 guilty plea in a molestation case that rocked Nassau
County, N.Y., and became the subject of the documentary "Capturing the Friedmans." While the
Court denied the appeal, the judges urged the Nassau DA to reopen the case. In the interest of justice.
Wisconsin. The Office of Lawyer Regulation has recommended that only three prosecutors be
reprimanded since 2007 - two public reprimands and one 90-day suspension. DAs rarely disciplined
in Wisconsin.
New York. In vacating a murdcr conviction and barring prosecutors from retrying the case, a fcderal
judge in New York has lashed out at the Brooklyn district attorney's Office for failing to take
responsibility for its prosecutors' alleged misconduct. At a contentious, 90-minute habeas corpus
hearing on June 8, 2010, Eastern District Judge Dora L. Irizarry noted that petitioner Jabbar Collins, a
renowned jailhouse attorney, had uncovered numerous documents while serving his 34-years-to-life
sentence suggesting that prosecutors had withheld evidence, coerced witnesses and lied to the court
and the jury. The DA's wagons are circled.
New York. The trial judge should have caught this, but instead put his seal of approval on a coerced
Alford plea by Rashjeem Richardson and sent him to prison for a knife attack someone else
committed. Rochester prosecutors said four witnesses identified Mr. Richardson, when only one did
so, and she retracted the next day because she had been drunk when she fingered him. When faced
with a choice between a conviction and truth, prosecutors in Rochester choose a conviction.
Florida. Now that Anthony Caravella's conviction for the 1983 rape and murder of Ada Cox
Jankowski has been tossed by DNA, officials there are forced to face the fact that now-retired
Sheriffs Deputy Tony Fantigrassi 's real talent was extracting false confessions from innocent
people. And then there's thc crime lab. A legaey of corruption.
New Jersey. An assistant Camden County prosecutor accused of withholding evidence resigned
yesterday after prosecutors agreed they never turned over all the information required when a Camden
man charged with murder tried to prove his innocence. Harry Collins, who has been with the office
for more than 15 years, resigned after the prosecution of Perman Pitman came under scrutiny. Pitman
was freed last month shortly after officials discovered a handwritten note by Collins that said a
witness had been paid to lie. "Please destroy this note."
Maryland. In Baltimore, Donnie Chestnut's trial was delayed 15 times. Small wonder. The state had
no basis for the drug charges filed against him, and no justification for shooting him four times. He
was acquitted - and filed suit the same day.
North Carolina. State Bureau of Investigation (SBl) agent Michael Deaver stands with a foot in each
camp - junk science and egregious police misconduct. He can take a great deal of credit for Greg
Taylor's conviction for a crime he didn't commit, because Deaver selectively reported - and testified
to - finding blood in Taylor's truck, when he knew that more sophisticated tests showed the
substance wasn't blood at all. SBI Director Robin Pendergraft stands behind Deaver, but there is a
growing call across the state: Re-examine Old Cases.
Colorado. So just what have cops and prosecutors in the Rocky Mountain State learned from the case
of Tim Masters-a vulnerable kid targeted to clear a disturbing murder, railroaded through court and
convicted on speculation and innuendo because there was no evidence against him? Douglas County
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Sheriff David Weaver and DA Carol Chambers give a resounding answer: Nothing, absolutely
nothing.
Massachusetts. Frankly, we never thought we would see it happen. Between 1991 and 1993, Boston
U.S. Attorney Jeffrey Auerhahn concealed evidence that might have cleared Vincent Ferrara and
Pasquale Barone of murder charges. No big deal. Business as usual. In 2005, the USDOJ Office of
Professional Responsibility found Auerhahn acted with "reckless disregard of discovery obligations,"
but all he "suffered" was a private reprimand. But Auerhahn's conduct has been referred to a state
agency, and he'll face a 3-judge disciplinary panel. The Tide is Turning. Click
HERE for the back
story.
Illinois. A case that was about whether a convicted man is innocent has morphed into an increasingly
personal brawl between two heavyweights unwilling to back down-with academics, prosecutors,
freedom of the press advocates, and students hanging on the judge's decision. The Professor and the
Prosecutor.
Iowa. The U.S. Supreme Court announced late on January 4, 2010 that it had dismissed an important
pending case over prosecutorial immunity after being alerted that the dispute had been settled. The
action stops in its tracks a case that could have produced a landmark decision that many believed
would have reined in the longstanding tradition that prosecutors cannot be held liable for their actions
as prosecutors. Close call for crooked prosecutors.
More U.S. Federal Court. This time it's the federal court in Columbus, GA, where U.S. District Judge
Clay D. Land issued a 19-page order harshly criticizing the U.S. Attorneys Offices for the Middle and
Southern Districts for offering sweetheart deals to big-time drug dealers in order to fabricate a case
against defense attorney J. Mark Shelnutt - who was acquitted of all charges brought by the feds.
Same song, east coast verse.
U.S. Federal Court. A federal judge on December 15,2009 dismissed the entire criminal stock
options backdating case against two former Broadcom Corp. executives, concluding that the
government's handling of the case "distorted the truth-finding process" and made a "mockery" of the
defendants' due process rights. Before a courtroom packed with observers and other parties in the
case, U.S. District Court Judge Cormac Carney of Santa Ana, Calif., entered a judgment of acquittal
for former Chief Financial Officer William Ruehle, who has been in trial since Oct. 23. Carney's
decision was met at first with stunned silence. These prosecutors aren't used to losing or getting
caught.
California. Ed Jagels, renowned as one of California's toughest district attorneys, built his career on
the Kern County child molestation cases of the 1980s, putting more than two dozen men and women
behind bars to serve decades-long sentences for abusing children. Appellate judges now say most of
those crimes never happened. Since the late 1980s, all but one of26 convictions Jagels secured have
been reversed. Kern County has paid $9.56 million to settle state and federal suits brought by fonner
defendants and their children. But he's retiring, leaving on his own terms, not held accountable for his
actions. Why not? Because Kern County voters kept re-electing him.
Florida. William Dillon spent 27 years in prison for a murder he didn't commit based on fraudulent
"evidence" from dog handler John Preston (discredited in 1984) and perjured "snitch" testimony from
another jail inmate. Now that the snitch testified at a legislative hearing about how Brevard County
detectives got him to lie under oath, the Brevard County Sheriffs Office reopened the homicide
investigation. Isn't it a bit late?
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Florida. Actually, all over the US, but the latest example of a wolverine prosecutor who gets
convictions regardless of guilt is in Broward County, Florida - Robert Carney. Of course, he's a
judge now, and tha t ' s typical, too. A belt full of scalps qualifies prosecutors to move up to the bench
and apply the same, twisted legal rationales to the cases tried by and before them. Congratulations,
Judge Carney. Strike Four.
Wolverine prosecutors travel in packs. Robert Carncy's successor, Carolyn McCann, launched a full
court (no pun i nt ended) effort to assault the credibility of Edward Blake and his lab, Forensic Science
Associates. Why? Blake not only found DNA in the Anthony Caravella case, but his tests cleared
Caravella of rape and murder charges. In
2001, th e Broward County Sheriff's crime lab "couldn't
find" any DNA evidence. They travel in the same pack. Seek the truth? No. Protect the conviction.
Mississippi. Former Hinds County Circuit Court Judge Bobby DeLaughter,
55,
has resigned his job
and pled guilty to misleading authorities. His plea means he'll be spending a little over a year- 1 8
months-in a federal prison, and he will lose his law license. He'll not have to answer for what he did
to Cedric Wi llis . D eLau ght er sent an in nocent man to prison for the rest of his natural life. even
though evidence was available to the contrary. DeLaughter is no victim.
California: As Michael Gressett waited for a jury verdict in a molestation trial, the Contra Costa
County sex crimes prosecutor had what he called a "nooner," bringing a felJow prosecutor to his
Martinez home for intercourse. What happened next, on May
8, 2008, is the subject of an explosive
rape case brou ght by the state attorney general. It involves a gun and an ice pick, but rests on a simple
question that Gressett often asks juries to decide: Was the sex consensual or forced? Do as I say, not
as I do.
Illinois: A Cook County judge ordered a new trial for convicted murderer Victor Safforld on May 22,
2009 after finding three
Chicago police detectives once supervised by disgraced former Cmdr. Jon
Burge likely beat him into confessing. " ... I have a more complete history of the behavior of these
detectives," Circuit Judge
Clayton J.
Cranesaid. "That evidence is staggering. That evidence is
damning."
Wisconsin: Records show that over the past four years, Michael Froehlich, the son of Outagamie
County (Appleton) Circuit Judge Harold Froehlich, has been arrested more than a dozen times for
allegedly making threatening phone calls, drunken-drivi ng related offenses, resisting arrest, battery,
false imp risonme nt and threatening a sheriff's deputy. During that time, Froehlich has been criminally
prosecuted just once - in 2008 - after he wa s caught driving drunk for the third time with a 0.361
percent blood-alcohol level, more than four times the legal limit. Is there a quid pro quo here between
the judge and the DA? (See Morphing DNA, Disappearing Evidence.) There's just something fishy
about it.
Virginia : A top state lawyer defending Virginia death sentences has been accused of misconduct by
the Virginia State Bar, an agency of the Virginia Supreme Court. The Virginia State Bar alleges that
Katherine Baldwin Burnett, senior assistant Virginia attorney general and director of the office's
capital litigation unit, made false statements during a bar hearing in April
2006 and interfered with
another lawyer's access to evidence. Scaring jurors into silence after the trial is over.
Illinois: When Johnny Savory was 14, Peoria, IL police and prosecutors used his coerced, false
confessi on to convict him of murdering two of his friends. When he was re-tried, the state trotted out
two prison snitches who claimed Johnny confe ss ed the murders to them, and again got a conviction.
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...,,)
The snitches have recanted, Johnny has been paroled, but he continues to seek his own exoneration
and the real killer's identity. Hoping DNA will do it.
New York: Nineteen years ago, police in Huguenot, NY forced 1 7-year-old Kevin Keller to sign a
confession to the murder of Elaine Ackerman. Kevin spent 1 8 months in jail before the local court
suppressed the confession and threw out the state's shaky case. Then, in early 2009, a DNA cold hit
was made, identifying James Babcock as Ms. Ackerman's rapistlkiller. Will Keller finally clear his
name?
Wisconsin: About 14 years ago, Dane County Assistant District Attorney John Norsetter allegedly got
a call that attorneys for Ralph Armstrong say would've blown the murder case against their client
apart - if only they'd known about it. A proposed rule pending before the Wisconsin Supreme Court
would require prosecutors who receive such explosive informatio n to reveal it to the defense - and
possibly to investigate it. The current Supreme Court rules for prosecutors require only that
exculpatory evidence be turned over to the defense before trial. No more turning a blind eye.
ARMSTRONG UPDATES: 411109 - John Norsetter, the assistant district attorney who prosecuted
Ralph Armstrong for the murder of UW-Madison student Charise Kamps in 1 98 0, testified
Wednesday that he didn't recall until recently that he'd gotten a telephone call in the mid- 1 990s from
a Texas woman who claimed Armstrong was innocent. "The only thing that I clearly remember is
(saying) we convicted the right man," the now-retired prosecutor said. Armstrong Hearing, Day 1 .
4/2/09
The 29-year-old murder case against Ralph Armstrong appeared in jeopardy Thursday after
ajudge found that a Dane County prosecutor failed to notify the defense of a reported confession by
Armstrong's brother in 1 995. Reserve Circuit Court Judge Robert Kinney also found that Assistant
District Attorney John Norsetter violated a court order in 2006, resulting in destruction of key DNA
evidence. Armstrong Hearing, Day 2.
8/ 1/09
Ralph Armstrong' s long wait for freedom, f

our years after his conviction for the 1980 rape
and murder of a UW-Madison student was overturned, came closer to an end Friday after a judge
dismissed the charges against him. Reserve Judge Robert Kinney, of Rhinelander, said a Dane County
prosecutor in 1995 should have told Armstrong's attorneys about a reported confession to the murder
of Charise Kamps by Armstrong's broLhr. He also said a prosecutor-ordered test in 2006 caused the
destruction of a semen stain on a piece of evidence that could have eliminated Armstrong as a suspect
in Kamps' murder. Is it really almost over?
Wisconsin: It was one of the most terrifying crimes ever to hit Kaukauna, WI, a community of
1 3,000. On June 25, 2000, Shanna Van Dyn Hoven, a 19-year-old UW-Madison student, was stabbed
to death as she jogged by a quarry near her home about 6 p.m. Prosecutors said Kenneth Hudson
stabbed Van Dyn Hoven, a stranger, in a fit of misplaced rage, and that they caught him red-handed,
covered in her blood. Newly uncovered evidence, however, appears to support Hudson' s contentions
- and raises more questions about the conduct of the police and the prosecutor, Vince Biskupic.
Morphing DNA, Disappearing Evidence
Related Links
Key Points of Motion Evidence Graphics Sheet
Comprehensive Motion (pdf) DA's Tactics Questioned
Click HERE for full coverage of Wisconsin's Vince Biskupic money-for-leniency scandal.
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'
Click HERE for more on Vince Biskupic's approach to cooking up a case.

California. As part of a criminal justice review unprecedented in county history, the Santa Clara
County public defender's has launched a massive project to revisit 1,500 or more sexual assault
convictions dating back two decades to determine whether innocent people may have been put behind
bars. Members of Valley Medical Center's Sexual Assault Response Team have been videotaping
examinations of patients since 1991, but prosecutors failed to inform defense attorneys in cases
involving those patients that such critical evidence existed. Under pressure to answer for the failure,
District Attorney Dolores Carr has since revealed there are 3,300 such tapes in existence, and this
week she vowed to inform defense attorneys of each case involving a medical-exam videotape where
a defendant was convicted. Better late than never.
Pennsylvania. For years, the juvenile court system in Wilkes-Barre, PA operated like a conveyor belt:
Youngsters were brought before judges without a lawyer, given hearings that lasted only a minute or
two, and then sent off to juvenile prison for months for minor offenses. The explanation, prosecutors
say, was corruption on the bench. In one of the most shocking cases of courtroom graft on record, two
Pennsylvania judges have pled guilty to taking millions of dollars in kickbacks to send teenagers to
two privately run youth detention centers. $2.6 Million in Payoffs.
But that's just the beginning. The two former judges, now admitted felons, are cooperating with
federal law enforcement officials as they continue their probe into corruption at the courthouse
Conahan used to run. The U.S. Attorney's Office is, in fact, investigating possible case fixing in
Luzerne County's uninsured and underinsured motorist cases and has been for some time. So you
think it's just bad kids and adult criminals who were abused? Everybody suffers.
North Carolina. It used to be that all you needed for a conviction was a vague allegation of sexual
abuse by a very young child and a signed confession by a day care worker. But jurors in Franklin, NC
are picky. In Michael Bradley's case, they demanded actual evidence. All that the state could give
them was the word of a detective who thinks he can tell in minutes if someone is guilty and will use
harsh techniques against a timid person to coerce a conviction to a crime that may not have happened
at all. Their verdict: Not G uilty.
California. Herbie Gonzalez of Los Angeles, CA spent 196 days in jail, framed by two sheriff's
investigators, Katherine Gallagher and Randy Seymour, who didn't hesitate to perjure themselves to
make murder, robbery and residential burglary charges stick. When Judge Cary Nishimoto dismissed
the charges because Herbie's "confession" was clearly coerced, Detectives Gallagher and Seymour
implied he got off on a "technicality." And when the real killer, Milton Gallardo, was identified by
DNA, Gallagher and Seymour continued to claim that Herbie was "somehow" involved in the crime.
Once you frame a suspect, never admit you are wrong.
Illinois. DNA evidence has been widely embraced over the last two decades as a powerful forensic
tool to prove a defendant's guilt or innocence. But in Lake County, authorities have sometimes
pressed for convictions even when the DNA doesn't match a suspect. When DNA evidence excluded
a man convicted in the rape and battery of a 68-year-old woman, Mermel suggested the victim had
consensual sex with someone else. When DNA evidence excluded Juan Rivera in the rape and murder
of an l1-year-old girl, Mermel and another prosecutor suggested that the girl may have been sexually
active. The DNA, he said, was a "red herring." And, just recently, when lawyers for the man charged
in the killing of his 8-year-old daughter and her 9-year-old friend said in court that DNA evidence
from semen excluded him as the perpetrator, the Lake prosecutor had another explanation. Never let
scientific facts stand in the way of a conviction.
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Dece mber 10, 2011 - The Illinois Court of Appeals has not only reversed Juan Rivera's
conviction, it has barred prosecutors from trying him aga in. Smelling the coming storm, Asst. State's
Attorney Michael Mermel announced he will retire on January 1,2012. A stinging rebuke to
prosecutors, justice after a quarter century for Juan Rivera.
Illinois. At last, former Chica go Police Lt. Jon Burge has been arrested. Burge or police officers who
were under his command systematically tortured suspects to get confessions. The torture included
suffocation, burns, electric shocks to the genitals, heads slammed with phone books and "games" of
Russian roulette. But it's too late to charg e Burge with torturing people. He's charged with lyin g
about the torture.
Cook C ounty Judge Dennis Dernbach is the last remaining defendant in the multi-million dollar
lawsuits that four alleged torture victims brought against the city and county. The lawsuits claim
murder confessions were coerced by former Chicago Police Cmdr. Jon Burge and his officers. He is
bein g sued by Leroy Orange, a Death Row inmate who was pardoned and freed from prison by Gov.
George Ryan in 2003. Orange accuses Dernbach, who was an assistant Cook County state's attorney
at the time, of coa chi ng Orange's confession. Orange also claims he told Der nbach he was tortured.
Last man stand in g.
It doesn't get much more ironic. On the same day Jon Bur ge was arrested, former Cook County Judge
Thomas Maloney died. He wa s the first-and remains the only-Cook County j u dge to be convicted
of rigging murder cases for cash when he was found guilty in April 1993 of taking thousands of
dollars to fix three sep arate murder trials and a fourth felony case. Not so tough on crime.
California. Contending that a top local prosecutor r ep e atedly sought to subvert justi ce, the state bar is
recommending that Ben Field be s uspended from practicing law for three years - a punishment that
would represent an unheard of public discipline against a Santa Clara County deputy district attorney.
Defense lawyer Jamie Harmon is f a cing trial in late October, 2008 on a 20-count state bar complaint,
accusing her of neglecting the cases of some criminal defendants and mi srep r esentin g what would
happen to other clients if they pleaded gu ilt y without going to trial. And the 6th D istri c t Court of
Appeals has overturned several convictions in recent months after finding errors by Santa Clara
County judges in their conduct of cases - i ncl udin g four cases in the past six months that were
pr esided over by Judge Paul Bernal. Held accountable in Northern California.
UPDATE: A Californ ia State Bar Court appellate panel has up held a four-year suspension for former
Santa Clara County prosecutor B enjamin F ield , desp it e an amicus curiae brief from the California
District Attorneys Association warning of a chilling effect on prosecutions . Not Dissuaded.
Maryland. In at leas t nine homicide, sex assault and burglary c ases, Baltimore police detectives
instructed crime lab te chnicians not to foll ow up on convicted criminals' DNA found on evidence at
crim e scenes because they determined it was not relevant to their investigations. How tunnelvision
works.
North Carolina. An all-white jury in Concord, NC convicted Ronnie Long of the rape of a prominent
white widow - the wife of a Cannon Mills executive - in 1976, a crime Ronnie has always denied
committing. His conviction was based on the victim's eyewitness identification of Ronnie. Now staff
and attorneys with the NC Center on Actual Innocence have uncovered laboratory evidence that clears
Ronnie - evidence the s tate had all along and hid from Ronnie's defense for 32 years. The state
cheated to keep a rapi s t free.
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Maryland. Baltimore crime analysts have been contaminating evidence with their own DNA - a
revelation that led to the dismissal of the city Police Department's crime lab director and prompted
questions from defense attorneys and forensic experts about the professionalism of the state's biggest
and busiest crime lab. Baltimore police are talking out of both sides of their mouths, saying, 'Oh, it's
not a problem at all,' and on the other hand they have fired the crime lab director. How did this lab get
accreditation?
California. In Bakersfield, the crime lab is part of the DA's office. There is no "firewall" between the
prosecution side and the science side of the office. This creates a conflict that recently moved
prosecutor Nick Lackie to tell a jury, "So what?" This conflict issue has come to a head in a recent
case in which a lawyer, Daniel Willsey, stands charged with causing the death of Joe Hudnall, a local
deputy by driving under the influence of methamphetamine and causing Hudnall to crash. Defense
attorneys have learned that testing of the defendant's blood was conducted by a lab analyst who is a
close friend of the dead deputy's family. Cops in lab coats.
But wait - there's more. When Daniel Willsey's defense attorneys went back to court to argue
motions related to mishandling evidence by the DA office's crime lab, everyonc got a big surprise.
The crime lab had "inadvertently" destroyed the sample of Willsey's blood that the lab claimed tested
positive for methamphetamines. Gosh, it's not like the DA wanted to make sure Willsey's defense
attorneys can't have a private lab test the sample. Ooops - Butterfingers.
Maryland. Raymond Jonassen, of Glen Burnie, Maryland, spent four months in jail based on
information that turned out to be false. In charging documents related to a burglary from earlier in
2008, county police Detective Tate, wrote in an application for arrest warrant that Raymond H.
Jonassen's fingerprints matched a set discovered at the crime scene. In fact, there was no match, and
the county crime lab never indicated a match. It took another two weeks to dismiss the charge against
Raymond. Neither the county police nor the chief prosecutor see a problem in what happened.
Business as usual.
Prince Edward Island, Canada. In 1989, prosecutors wedged Anthony Hanemaayer between a rock
and a hard place, convincing that despite his imlocence, he needed to plead guilty to a rape he did not
commit in order to avoid spending the rest of his life in prison. He took the deal, spent 2 years in
prison, and has endured the stigma of a rapist since then. And when notorious rapistlkiller Paul
Bernardo confessed to police and prosecutors in 2006 that he, not Anthony, had committed the crime,
they didn't bother to tell Anthony. Defense counsel in another case stumbled on it.
I llinois: I n 1995, Alan Beaman of Normal, I L was convicted of murdering his former girlfriend,
Jennifer Lockmiller, in 1993. The prosecutor, James Souk, didn't tell the jury about evidence that
showed Alan was 140 miles away when Jennifer died, or that forensic evidence linked another man,
not Alan, to the murder scene. Thirteen years later , the Illinois Supreme Court has reversed Alan's
conviction, calling the evidence against him "tenuous." James Souk was rewarded for his misconduct
in the usual way - he's ajudge now. The current county prosecutor, Bill Yoder, says he is "saddened
for the family of Jennifer Lockmiller." Apparently Mr. Yoder thinks it is okay to let a killer go free,
so long as somebody does the time. Career advancement at its typical
Ohio: In 1998, when he was 12 years old, Anthony Harris of New Philadelphia, OH was subjected to
a brutal interrogation, then charged and convicted of the murder of Devan Duniver, who lived near
Anthony. Two years later, an Ohio appeals court threw out the conviction, ruling that the interrogation
was so coercive that Harris "had no choice but ... to confess." Prosecutor Amanda Spies got mad and
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got even; when Anthony tried to enlist in the Marines, she told military officials he was a murderer.
But vindictive conduct is not protected conduct. The 6th US Circuit Court has ruled that Anthony can
sue the prosecutor.
Nevada: Roundly denouncing a Las Vegas federal prosecutor for withholding 650 pages of evidence
potentially helpful to two lawyers charged in a stock fraud case, the 9th U.S. Circuit Court of Appeals
upheld dismissal of all 64 charges and refused to allow a retrial. The Justice Department's Office of
Professional Responsibility, not surprisingly, cleared Assistant U. S . Attorney J . Greg Damm of any
misconduct, and did so without contacting defense attorneys. Conduct in flagrant disregard of the
United States Constitution
Texas: The Dallas County di strict attorney who has built a national reputation on freeing the
wrongfully convicted says prosecutors who intentionally withhold evidence should themselves face
harsh sanctions - possibly even jail time. "Something should be done," said Craig Watkins, whose
jurisdiction leads the nation in the number of DNA exonerations. "If the harm is a great harm, yes, it
should be criminalized." Punish Unethical Prosecutors
Mississippi: The exonerations of Kennedy Brewer and Levon Brooks exposed the corrupt underbelly
of rural and sparsely populated Noxubee County. But the corruption isn't limited to small towns with
little outside oversight. Take a look at Jackson, where j udges take money from prosecutors to
guarantee "justice" and consider exonerations bad publicity. The Mississippi system.
Ohio: A judge dismissed aggravated murder charges against Arian S. O' Connor after S ummit County
prosecutors asserted that Youngstown police "compromised" ballistic evidence in the 2002 slaying for
which O' Connor was charged. When they say "compromised," they mean "planted" evidence. That' s
fraud.
Pennsylvania: It took a Fayette County, PA jury j ust 25 minutes to figure out Bret Shallenberger was
innocent of hiting a former employee to burn down Shallenberger's profitable business. It's the local
prosecutor, who promised the actual arsoni st immunity in exchange for framing Shallenberger, who
should be on trial. Wrong Defendant
North Carolina: A day after Glen Edward Chapman was freed from death row, the State Bureau of
Investigation agreed to review allegations of perjury and obstruction ofjustice against Dennis
Rhoney. The former Hickory police detective led the 1 992 double-murder investigation that resulted
in Chapman's convictions. Ex-Cop Who Led Discredited Case Probed
California: A federal appeals court removed a controversial judge, U.S. District Judge Manuel 1. Real
of Los Angeles, from another case, accusing him this time of "excessive and biased interventions"
that denied two defendants a fair trial. B iased Judge
California: The Orange County case against James Ochoa for robbing three restaurant workers was
tainted at every level: police misconduct in manipulating the victims' identification of James and
misrepresenting the responses of a police tracking dog; efforts by the DA ' s office to bully crime lab
scientists into lying about the DNA exclusion of James as the robber; and the inexcusable conduct of
Judge Robert Fitzgerald in extorting a gUilty plea from James by threatening him with life in prison.
In a rare series of real-time reports about the prosecution of James Ochoa, R. Scott Moxley told
readers of the Orange County Weekly exactly which public servants were perverting justice and how
they were doing it. As you read these, keep in mind that for the police, prosecutors and judge,
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business goes on as usual. Moreover, the DA is starting up his own crime lab, so he won' t have to put
up with scientists who refuse to lie about their findings.
The Case of the Dog Who Couldn't Sniff Straight
There Once was a Judge from Nantucket
Oops. Quiet Admission They got the Wrong Guy
If Evidence Doesn't Fit, Alter It
Also see how the California Attorney General played games with James Ochoa' s compensation:
Making a Chew Toy of Justice
Alabama and the U . S . : Don Siegelman, former Democratic Governor of Alabama, has a lot in
common with Georgia Thompson. Both were prosecuted for acts that were not crimes, by politically
motivated U.S. Attorneys, at the behest of vengeful politicos highly placed in the Bush administration.
The Seventh Circuit Court of Appeals tossed Thompson' s conviction at the conclusion of oral
argument, ordering her immediate release f
rom prison. It has taken longer, but the foundation of lies
and corruption underlying Siegelman ' s conviction is starting to crumble. Sadly, Bush and his cronies
have turned the U . S . Department of Justice into a cadre of political operatives. Justice in Amerika.
South Dakota: Start with a 20-year-old cold case, two missing teenagers, and call their disappearance
murder. Pick a suspect, a rapist serving a long prison term. Use a state psychologist to "help" the
suspect' s sister come up with "recovered memories" of seeing the missing teens at her family' s farm.
Recruit a seasoned snitch to get a confession on tape. Voila! You've got a conviction - almost. Then
someone noticed it wasn't the suspect' s voice on the taped confession . . .
Texas : After he was snared in a net of swirling controversies including an e-mail scandal and the high
-profile indictment of a sitting Supreme Court justice followed by an immediate move to dismiss that
case, Harris County (Houston), Texas, District Attorney Chuck Rosenthal resigned from office. It was
a stunning reversal of fortunes.
In a press release, Rosenthal said prescription drugs had impaired his judgment. But it was what
happened inside a southeast Houston home six years earlier that led to events in a federal courtroom
and to Rosenthal 's resignation. Erik and Sean Ibarra - the power of common men.
Mississippi: The Innocence Project has asked the state to fill the long-vacant position of State Medical
Examiner, and to stop using state pathologist Dr. Steven Hayne. Dr. Hayne' s work lies at the heart of
the wrongful convictions of Kennedy B rewer and Levon Brooks. His credentials and the results of his
work have been solidly discredited for several years, but he is under no oversight because the State
Medical Examiner position has been vacant for more than a decade. How many more wrongful
convictions before the state acts responsibly?
But Dr. Steven Hayne is only half of the despicable duo . Forensic odontologist Dr. Michael West
found "bite marks" no one else could see on the bodies of the little victims in both cases, and in both
cases, testified that Kennedy Brewer and Levon Brooks were each guilty. "If you fabricate evidence
in a capital murder case, where you know that if the person' s convicted they are going to be executed
- as far as I ' m concerned that ' s the crime of attempted murder," says Peter Neufeld. "He's a
criminal. "
Massachusetts: Stephan Cowans spent nearly seven of his 37 years of life behind bars, locked up for a
crime he did not commit. Exonerated in January 2004, Cowans sued and ultimately received a $3.2
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million settlement from the city of Boston in 2006. This past October (2007), he was shot dead in his
Randolph horne. Cowans never learned how, or why, he came to be blamed for the non-fatal shooting
of Boston police officer Gregory Gallaghcr in 1 997. Now, the Boston Phoenix has uncovered
substantial new information about the Cowans case. These revelations are troubling, as they suggest
that key members of the Boston Police Department (BPD) knew that Cowans was innocent, even as
they forged the case to prosecute him. Incompetent-or Corrupt?
New York: New York state investigators are probing how police and prosecutors handled the 1 98 8
bludgeoning and stabbing deaths of Seymour and Arlene Tankleff, whose son, Marty Tankleff, served
1 7 years in prison for their murders before being released in December, 2007. What Took So Long?
New York: A teen shooting suspect' s quick decision to record his interrogation with a hidden MP3
device has played out as a perjury case against a veteran detective. Testifying at the trial of Erik
Crespo in April, Detective Christopher Perino, 42, emphatically stated that he hadn' t questioned the
then- 1 7-year-old about a Christmas Day 2005 shooting in The Bronx before the kid' s mother and aunt
showed up at the 44th Precinct station. But Crespo had secretly pressed record on his MP3 player - a
small device used to download music from the Internet - hidden in his pocket and captured the
bullying interrogation. "Testilying" vs. Tape.
Link:
Texas Math
What do you get when you take one ambitious prosecutor, four cold cases, a couple of cooperative
snitches and four defendants with compelling innocence claims? You get three death sentences and
one life without parole.
Hawaii : A hard-won victory for the common man: Pinkerton v. KPD (Link)
Arizona: In a breathtaking ahuse of the United States Constitution, Sheriff Joe Arpaio, Maricopa
County Attorney Andrew Thomas, and special prosecutor Dennis Wilenchik, used the grand jury to
subpoena "all documents related to articles and other content published by Phoenix New Times
newspaper in print and on the Phoenix New Times website, regarding Sheriff Joe Arpaio from
January 1 , 2004 to the present." More alarming still, Arpaio, Thomas, and Wilenchik subpoenaed
detailed information on anyone who has looked at the New Times Web site since 2004. Taking a
Sledgehammer to the Constitution
Within hours of the Phoenix New Times blowing the whistle on Sheriff Arpaio, County Attorney
Thomas and special prosecutor Wilenchik, the two top executives of the newspaper were arrested. By
the next day, public outcry was such that the charges were dropped and Wilenchik was fired. Which
leads to our question: Why are Sheriff Arpaio and County Attorney Thomas still in office?
North Carolina: A Durham, NC judge on October 8, 2007 dismissed murder and robbery charges first
filed in 1 993 against a mentally retarded defendant, ordering his release from a state hospital after 1 4
years in custody without a trial. Floyd Brown, a 43-year-old Anson County man with an I Q of 50, was
charged in the robhery and beating death of 80-year-old Katherine Lynch in 1 993 . He was found at
the time to be incompetent to stand trial, and has remained in state custody at Dorothea Dix Hospital
ever since as prosecutors refused to drop the case against him. (Hey, wasn't Mike Nif
ong the Durham
County DA?) The System Failed Him at Every Level.
Canada: The Supreme Court of Canada, in a 6-3 decision, has broken new legal ground by ruling
suspects can sue police investigators for negligence in cases of shoddy detective work. In a judgment
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that said police officers are not immune from civil l iability, the court set its eyes squarely on
combating wrongful convictions and institutional racism, requiring police to face the same legal
consequences as other prof
essionals who f
ail in their public duties. Ruling Applies Across Canada.
Illinois: Not since club-swinging cops in baby-blue helmets chased demonstrators through clouds of
pepper gas at the 1 968 Democratic National Convention have Chicago police been so awash in
trouble. Federal prosecutors have charged special operations officer Jerome Finnigan with planning
the murder of another member of the unit to keep him from talking to the government. U.S. Attorney
Patrick 1. Fitzgerald has announced the federal government was stepping into the torture case, saying
it would seek evidence of "pet:iury, false statements and obstruction of justice by members of the
Chicago police department." It's political, it's cultural, it' s systemic.
Wisconsin: Award-winning journalist Dee Hall of Madison, WI ' s Wisconsin State Journal has filed a
stunning series on the prosecutorial misconduct of Dane County Asst. DA Paul Humphrey, as well as
the response - or lack of response - of Wisconsin's Office of L awyer Regulation to Humphrey ' s
conduct i n particular and prosecutorial misconduct i n general.
A Prosecutor Accused
Homicide . . . or Tragic Accident?
Ignoring Police, Humphrey Leaves Teen in Jail
Charging Bankrupt Man was Wrong
Not told she had to appear, woman charged after she's tardy
Questionable Handling of Horse Cases
A Vendetta against Defense Witnesses
Some of Humphrey' s Questionable Cases

3 0% Longer to Handle Felonies
Justice Demands Higher Standards
Wisconsin State Journal Editorial
Related
Devastating Consequences
25 Prosecutors Disciplined since 1 98 1
A 1 999 Classic - and Nothing has Changed
A Shocking Expose of Prosecutorial Misconduct
Michigan: Now that evidence points to serial rapist/killer Matthew Macon as the man who brutally
raped and murdered Lansing (Michigan) Community College Prof. Carolyn Kronenberg, experts are
taking a careful look at what police and prosecutors called Claude McCollum' s "conf
ession" to that
murder. "It's shocking to me that this was enough to charge, and ultimately convict somebody," said
Prof. Steve Drizin, one of the false confession experts who reviewed transcripts of the two-hour
interview. Read it for yourself. Keep in mind that McCollum was excluded by DNA, and the state still
called him a killer. McCollum Police Interview Questioned.
UPDATE: 9/22/07 - Ingham County DA Stuart Dunnings, III has j oined Claude McCollum's lawyer
in asking the Michigan Court of Appeals to grant Claude a new trial. According to the joint motion,
Lansing Community College Police turned over a videotape which apparently showed that Claude
was somewhere else on campus at the time of Carolyn Kronenburg ' s murder. Dunnings said if he
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knew in 2005 what he knows now, he would still prosecute Claude. Why wasn't the videotape turned
over before trial?
UPDATE: 9124/07 - The Michigan Court of Appeals has granted Claude McCollum a new trial.
UPDATE: 1 0/1 6/07 - Claude McCollum released on bail. State says he poses no danger to public.
Translation: He's innocent.
UPDATE: 1 0/24/07 - Charges against McCollum dismissed
Pennsylvania: Sometimes justice happens in spite of the justice system. Sometimes it only happens
when the people in the justice system get their noses rubbed in their messes. On 9/1 1 /07, Lancaster
County District Attorney Donald R. Totaro did the right thing by freeing Charles T. "Ted" Dubbs
from a 1 2- to 40-year prison term in two sexual attacks he probably did not commit. Dubbs was
sentenced in May 2002. Wilbur Cyrus Brown, a serial rapist who confessed to 1 3 other rapes,
including one on the same jogging trail where Dubbs supposedly committed his crimes, conf
essed to
those attacks in November. But Totaro had to spin things to portray his office as a well-oiled machine
that immediately turned to fix an honest error when it came to their attention. That's not what
happened.
Wisconsin: In a three-year span, Milwaukee Police Department Sgt. Jason Mucha was accused at least
1 0 times of beating suspects, planting drugs or both - claims so similar that judges took notice.
Mucha' s record shows how an individual can be the subject of numerous misconduct allegations and
continue to advance his career inside a department that lacks a reliable way to track problematic
behavior. His story also shows how a single officer was instrumental in changing the way Wisconsin
courts consider claims of police misconduct. Forceful Impact
Mississippi: Kennedy Brewer of Macon, Mississippi, a mildly retarded, Black defendant, was
convicted of raping and killing a 3-year-old girl and sentenced to death in 1 992. In 2002, he was
cleared by DNA, but he wasn't released. He has spent the past 5 years in the local jail, awaiting
retrial. Because you can bet, the local authorities plan to get another conviction and another death
sentence. The Sheriff says he can't look for a DNA match because Mississippi doesn't have a DNA
database - which is news to the state' s crime lab director. The prosecutor will bring back his star
witness, dentist Dr. Michael West, whose bite mark testimony has been disproven by DNA in other
cases, and who resigned from professional forensic dentistry groups to avoid expulsion. Prosecutors
are so sure they're right about Kennedy' s guilt that they ' re Willing to Bet His Life on It.
UPDATE: 2/9/08 - Kennedy Brewer and Levon Brooks, both convicted of killing 3 -year-old girls in
Noxubee County, Mississippi, and both cleared by DNA, are slated to be released. What did it take to
reach this point? Mississippi Attorney General Jim Hood had to take the prosecutions of these
murders away from the Noxubee County DA, something almost unheard of in the state' s history. The
Attorney General has charged Albert Johnson with the murders of both children.
California: A coalition of national nonprofit groups has asked the Justice Department to investigate
and suspend FBI employee Danny Miller, who was found by a jury to have falsified evidence against
Herman Atkins, a man who served 1 2 years in prison before being exonerated by DNA evidence.
Miller is in a position to continue doing harm to the innocent.
Wisconsin: Wisconsin Dept. of Justice special agent Greg Eggum put away a lot of people during the
time he worked as an arson investigator for the state. It was the means he sometimes used that caused
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the problems - forensic fraud, hiding and tampering with evidence, committing perjury - and state
agencies that should have investigated his conduct refused to do so. In 2006, Milwaukee investigative
consultant Ira Robins asked the state supreme court to appoint a special prosecutor to investigate
Eggum' s conduct. The state high court instead converted Robins' petition to an appeal in John
Maloney ' S criminal case and dismissed it. Robins is back with a federal lawsuit detailing Eggum' s
misconduct and asking for a federal investigation. Click HERE to read the Complaint (pdf format) .
Ohio. Lee Lucas has had an extraordinary career as a DEA agent in Miami, in Bolivia, and now in his
hometown of C leveland. He's gotten a lot of convictions, but with "issues" like evidence tampering,
beating informants, suborning perjury and lying under oath himself. Lucas dodged all the
invetigative bullet, until May of 2007. That ' s when one of his informants, Jerrell Bray, told federal
public defenders: "I could fill a room with the innocent people I ' ve helped Lucas put away ."
Jerrell Bray said he wanted to come clean. But would anyone believe him?
Joshawa Webb won't answer the door. Joe Ward won't leave his room. Lowestco Ballard ' s wife had a
miscarriage. And Geneva France is a ghost. Collateral damage when police become criminals.
Wisconsin. A judge on July 25, 2007 threw out an Oshkosh man ' s 1 995 conviction for threatening to
kill disgraced former Winnebago County District Attorney Joseph Paulus after authorities agreed that
a prosecutor withheld important evidence and solicited false testimony from a key witness. The
prosecution of the case by former Outagamie County District Attorney Vince B iskupic "is an example
of really egregious conduct " by a prosecutor, said an attorney for the man, Mark Price. Vindication.
United States. The power, if not the arrogance, of prosecutors grated on Ange la Davis throughout her
1 2 years at the D.C. Public Defender Service, three as its director. Now a law professor at American
University, she has made a mission of exposing that power-on radio and TV and in a new book,
Arbitrary Justice-with hopes of reining it in. Her beef is not so much with prosecutors breaking the
rules, although plenty do. Davis' greater worry is al I the behavior considered within bounds but
outside any reasonable notion of fair play. Abuse at the early stages.
Massachusetts. In what appears to be the largest sum of money ever awarded to people who were
wrongfully convi cted, a judge today ordered the federal government to pay $ 1 0 1 . 8 million to make
amends for framing four men for a murder they did not commit. Two of the men died in prison after
being falsely convicted in the 1 965 gangland murder. Another, Peter Limone, spent 3 3 years in jail
before he was exonerated in 200 1 . The fourth, Joseph Salvati, spent 29 years in prison. Justice Better Late than Never.
Colorado. Somewhere between the spot Peggy Hettrick was abducted and the Fort Collins field where
her p artially clad body was dumped, her killer would have shed pieces of himself, mothlike. As he
pulled her through the grass that dark morning on Feb. 1 1 , 1 987, his skin cells could have sloughed
off onto her black coat. A strand of his hair could have hooked onto her shoes. A sneeze could have
dampened her blouse. This is the law of forensic science: When two people come into contact, they
leave cells on each other. But in the Hettrick murder case, authorities strayed from this law by losing
some of these biological relies and destro y ing evidence linked to a prominent doctor they never
investigated for the crime. In doing so, they may have covered the killer' s genetic tracks. This
happened in Fort Collins, where a detective clung to his belief that a I 5-year-old boy committed the
crime, despite no physical evidence. In a county where prosecutors opposed saving DNA, let alone
testing it. In a state where the law doesn' t c reate a duty to preserve forensic evidence. The result: An
innocent man goes to prison for life, and the real killer moves on. Tim Masters is the i nnocent man.
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UPDATE: January 3, 200 8 : Innocence Bid Gets Boost. Fort Collins, CO authorities violated evidence
-discovery rules when they withheld expert opinions that conflicted with their theory that a 1 5-year
old Tim Masters murdered Peggy Hettrick in 1 987, according to special prosecutors.
UPDATE: January 22, 200 8 : Tim Masters released and his conviction vacated. DNA excludes
Masters and points to another suspect.
UPDATE: September 9, 2008 : Prosecutors in Tim Masters case get public censure for their
misconduct. Both Terry Gilmore and Jolene Blair are judges now, and this isn't Gilmore' s first
censure for prosecutor misconduct. Nonetheless, they are expected to be easily re-elected in 2 0 1 0 assuming anyone runs against either of them - because the public has such a short span of attention,
and the voters don't really care.
UPDATE: July 30, 20 1 0 : Murder conviction was built on cop ' s lies. Lt. Jim Broderick, one of the
lead investigators in the case against Masters, appeared before specially appointed Judge James
Hartmann in a hearing that l asted about 1 2 minutes. Broderick listened to the perjury charges against
him but waived his right to hear a formal reading of the indictment. He did not enter a plea. He is
scheduled to be back in court for a status conference September 28, 20 1 0.
Massachusetts Chief US District Judge Mark L. Wolf, in a rare rebuke to the US Justice Department,
has asked the Massachusetts Board of Bar Overseers to launch disciplinary proceedings against a
veteran federal prosecutor, Jeffrey Auerhahn, who withheld key evidence in a New England Mafia
case from the early 1 990s. His Victim Wants Auerhahn Disbarred. Click HERE for the back story.
Manitoba, Canada There has been intense scrutiny of cases handled by George Dangerfield, who until
his retirement was considered the most formidable prosecutor toiling for Manitoba Justice. Since his
retirement, however, he has been dogged by allegations that some of his most famous cases were
miscarriages of j ustice. He was at the helm of two confirmed wrongful convictions : James Driskell
and Thomas Sophonow. In both cases, judicial inquiries determined that Dangerfield committed
errors, and failed in his duty to disclose relevant evidence to the defence. The Hon. Roger Salhany,
former justice of the Ontario Court, has been retained to review the cases of former top Manitoba
prosecutor George Dangerfield. Prosecutorial Misconduct Knows No Borders
Michigan After a house burned down on Bay-Arenac County Line Road near Bay City, MI,
Pinconning-Fraser Fire officials called Michigan State Police fire investigator Jeffrey Wallace to the
scene. They suspected arson, they told him. And when Wallace showed up with his arson dog named
Cops and produced evidence that accelerants fueled the blaze, they had all the evidence needed to
bring charges - against Wallace. That's bccause local firefighters intentionally ignited the abandoned
structure - without using any accelerant - in a "sting" on Wallace executed in conjunction with
Michigan State Police and other agencies. Faking Your Way to Glory.
Wisconsin: The trend of prosecuting non-criminal conduct has spread from New York, where former
U .S . Attorney Rudy Giuliani initiated it, to the heartland. In Wisconsin, Georgia Thompson was a
civil service employee when she was convicted of f
raud, after being accused of steering a state travel
contract to a firm whose top officials were major campaign contributors to Gov. Doyle. Never mind
that shc knew nothing about the campaign contributions and was just trying to save the state money.
In a stunning and extremely rare move, a 3 -judge panel of the 7th Circuit Court of Appeals acquitted
Thompson at the conclusion of oral arguments on April S , 2007, and ordered her immediate release
from prison.
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Not a politically motivated prosecution? Not a thinly vcilcd attempt by U.S. Attorney Steve Biskupic
to wound a sitting (Democrat) governor in the heat of an election? If not, then why was Thompson
repeatedly o f
fered deals, even after she was convicted, if she would "talk about higher-ups." Of
course it was. And an innocent woman was Caught in a Political Squeeze Play.
UPDATE: 9/1 2/07 - The federal case against Georgia Thompson is long dead, and she is back to
work in her state job. But questions about the feds' failed prosecution of Thompson just won't go
away. And with good reason. Questions on Thompson case won ' t quit.
from Liestoppers Blog
"An amazing performance of journalism on the fly."

Nifonging Seminar
Click the "ad" for details.
Wisconsin: Prosecutors retrying a 1 980 murder charge against Ralph Armstrong in Madison, WI
cannot use the results of a DNA test on a key piece of evidence because the results were obtained in
violation of a court order, a judge has ruled. Dane County Circuit Judge Daniel Moeser said the state
acted in "bad faith" when it went ahead with the testing without notifying the defense and, in the
process, used up the material - in violation of the judge's order. Bad Faith.
UPDA TE - 4/25/08: Now we know why the state violated a court order to test - and use up - key
evidence. The state, and specifically, Assistant DA John Norsetter, has known for 1 3 years that Ralph
Armstrong's brother confessed to the crime of which Ralph was convicted. Norsetter, who retired
from the office last year, allegedly not only failed to investigate or notify Armstrong' s defense
attorneys of this confession, he subsequently ordered a test that destroyed evidence that could have
established Steve Armstrong ' s guilt. Worse Than Bad Faith
North Carolina: Durham County DA Mike Nifong has made himself the national poster boy for
prosecutorial misconduct by his handling of rape allegations against Duke University lacrosse players.
Nifong made inflammatory comments about the accused to the media, withheld exculpatory evidence,
and continucd to pursuc convictions long after it was obvious thc dcfendants are innocent. Why did he
do it? He was running for election, and as Nifong himself said, ' I 'm getting a million dollars of free
advertisements. '
Texas: In deciding Ex Parte James S. Masonheimer, the Texas Court of Criminal Appeals found that
Taylor County prosecutors (including now Judge Robert Harper) intentionally withheld exculpatory
evidence with the specific intent to avoid an acquittal on three separate occasions. The CCA granted
Mr. Masonheimer double jeopardy relief stating this prosecutorial misconduct met the Oregon v.
Kennedy standard. Third Trial Barred.
New York: Bruce Mason was convicted of arson and other charges in a federal bench trial in
Binghamton, New York before the Hon. Thomas J. McAvoy. Although government and insurance
fire investigators found no evidence of arson at the fire scene (i.e., no accelerant, no incendiary
device), the record shows these experts devised a physically impossible arson scenario, and ignored,
destroyed, suppressed, or lied about evidence which disproved it. When this wasn't enough to win the
conviction, authorities fabricated a witness. Link:: Bruce Mason
Texas: The Dallas County, TX district attorney' s office has acknowledged that prosecutors illegally
withheld evidence that might have saved a man from a 1 983 rape conviction and 1 0 years in prison.
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Newly discovered evidence amassed by attorneys for James Curtis Giles "strongly suggests" that he
was misidentified as one of three men involved in the gang rape, prosecutors said. They said his
conviction should be overturned, but stopped short of declaring Mr. Giles innocent. Instead, they
asked state District Judge Robert Francis for additional time to investigate Mr. Giles' claim that a man
with a nearly identical name was the true rapist. What ' s in a Name?
Similar: Kerry Sanders was whisked from Los Angeles, CA to prison in Stormville, NY when he was
mistaken for fugitive Robert Sanders. For 2 years, no one would listen when he insisted, "My Name is
Not Robert."
New York: Following a "trend" begun by former US Attorney (now a presidential hopeful) Rudy
Giuliani, criminalizing non-criminal conduct, US Attorney for the Southern District of New York
Michael J. Garcia went after David Finnerty and 1 4 other NY Stock Exchange floor specialists for
"interpositioning." Interpositioning means that instead of matching pending buy and sell orders, the
specialists repeatedly trade for their company' s proprietary account, making a profit from the slight
differences in pricing. The government said Finnerty cheated customers out of$4.5 million. Judge
Denny Chin overturned a jury' s guilty verdict, however, concluding that no one was defrauded of any
money and that interpositioning is not a crime. A Page from The Tyranny of Good Intentions
Minnesota: Minnesota prosecutors, the people accustomed to dishing out punishment, have found
themselves on the receiving end of two recent state Supreme Court decisions that targeted improper
closing arguments and other out-of-bounds trial behavior. Prosecutors are bristling over the decisions,
but many defense lawyers and legal experts think it' s about time that courts stop warning prosecutors
about misconduct and start doing something to stop it. Crackdown on Prosecutor Misconduct
Nebraska: Matt Livers of Murdoch, Nebraska, the latest false confessor to a murder, was set free after
evidence that two other persons committed the crime surfaced. The State' s own expert agreed with the
findings of the defense expcrt that Livers was mentally retarded, vulnerable to the tactics used by the
police, and the confession was almost certainly false. Still to be explained are findings in the car
police said Matt drove the night of the murders. Interestingly, no DNA is found in the car on first
inspection. It is only on second inspection, using a wet swab, that the DNA is found, in the only area
searched. Meet Matt Livers.
Vermont: In Burlington, VT, District Court Judge Michael Kupersmith has had it with police who
violate suspects' rights willingly and repeatedly by ignoring the precept of reciting a Miranda
warning. "It's unfortunate that in this country there are people who believe that the rules do not apply
to the executive branch, and they do; and the courts are here to enforce that," says Judge Kupersmith.
"At least," he continued, his voiee rising, "these courts are. " Sidestepping Miranda.
ornia: A Huntington Beach police officer's exoneration for planting a loaded gun in a suspect' s
Calif
car has led to the revelation that police routinely plant evidence in unsuspecting civilians' vehicles for
training exercises. Police admit planting evidence.
I llinois: In Chicago in 1 997, June Siler mistakenly identified Robert Wilson as the man who slashed
her wish a razor blade, after viewing a suggestive photo line up and being told he had confessed. This
is a chilling reminder of how easy it is for police and prosecutors to manipulate a witness' testimony.
Now, June says, "I have to make this right."
Michigan: It took egregious misconduct by both police and prosecutors to hold together a case against
tcacher James Perry long enough for a jury to convict him of molesting 2 kindergarteners in suburban
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Detroit's Oakland County. Well, it was either deliberate misconduct or these folks really believe that
"Harry Potter" and "The Lion King" are "nonerotic pornography. " If you need your hair curled, read
the following news reports:
Lawyer seeks new trial or dismissal of charges
Conviction in sex case doesn' t pass the smell test
Judge reviews assault case
Judge frees teacher in sex abuse case
Perry ' s j ury, too, was railroaded
But Wait!
Oakland County Prosecutor David Gorcyca is no stranger to prosecutorial m isconduct
North Carolina: The Robeson County District Attorney has had to dismiss 1 80 drug cases because a
state and federal investigation has led to corruption charges against former drug enforcement deputies.
Three of those deputies - Roger Taylor, C.T. Strickland and Steven Lovin - have been charged in a
1 0-count federal indictment. The indictment alleges that they burned two homes and a business,
assaulted people, paid informants with drugs, and stole and laundered public money . Power Corrupts
South Carolina: An investigation by The Post and Courier (Charleston) uncovered endemic failures in
the state' s system for tracking police officers that allow problem eops to keep their badges despite
histories of misconduct and even criminal behavior. Systemic Failure
New Jersey : Superior Court Judge Wilbur Mathesius thinks two N.J. Supreme Court justices are too
prejudiced against him to be objective when they review the 6-month suspension Mathesius caught
for, among other things, berating a jury for acquitting a defendant of illegal handgun possession;
talking ex parte to jurors in the midst of deliberations in a murder case; making derogatory comments,
some in public, about appellate judges; and gratuitous remarks that show bias about cases or
defendants. Can't They Take a Joke?
Texas: The Bexar County district attorney's investigation into the possibly wrongful execution of
Ruben Cantu had barely started early in 2006, but already DA investigators were scoffing at the three
witnesses who contend Texas sent an innocent man named Ruben Cantu to his death. The DA denies
bias.
Ohio: According to appeals court decisions, at least three men could be on death row because
Cleveland' s former star prosecutor Carmen Marino hid evidence. Three others had murder
convictions set aside, one because of what an appeals court called Marino ' s "highly improper and
highly prejudicial" conduct. The others, because he hid key evidence or lied about secret deals with
jailed witnesses. Cuyahoga County Common Pleas Judge Daniel Gaul said Marino should be
criminally prosecuted for the abuses. How Many Other Marinos are out there?
Missouri: Sandra Kemper, a suspect in an alleged arson that took the life of her son, denied nine times
that she had anything to do with the fire. Then the St. Louis County police detective resorted to one of
the oldest tricks in the book - he told Kemper that she had failed a lie detector test. Later that day,
Kemper admitted that she set the fire to get out f
rom under the burden of being the sole provider to
hcr family and to collect insurance proceeds. But the confession did not fit the facts of the crime, the
motive evidence was weak, and Sandra had passed the lie detector test with flying colors. The trial
judge declared a mistrial on issues related to the polygraph, and Missouri' s high court has now ruled
that Sandra cannot be retried. Police Lies Backfired.
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Florida: Florida correctional officials - already facing a surge of unwelcome scrutiny in the wake of
the forced resignation of former commissioner James Crosby, nine firings of high ranking officials by
Crosby' s successor, and the release of a videotapc showing the fatal beating of a fourteen year old boy
- have been put on notice by former inmate Thomas Craig: I know where the bodies are buried.
Payback Time.
Wisconsin: Two years after Winnebago County DA Joe Paulus pled gUilty to taking bribes to fix
cases, his iron-fisted approach is still practiced by local politicos. The Legacy of Joe Paulus Lives On.
G et the straight skinny on corruption in the Wisconsin legal system.

Full of Bologna
Illinois: In 1 994, Chicago cops used a "reverse lineup" (in which a suspect is asked to identify his
victims), along with threats and physical abuse, to coerce 1 7-year-old Lafonso Rollins into confessing
to the rape of an elderly woman. He was convicted and sentenced to 75 years prison, but he was freed
in 2004 when DNA proved his innocence. He sued. Discovery in his civil suit disclosed that the
police crime lab had excluded him based on blood type before Rollins was ever tried. Oops. The great
teamwork cost the city $9 mil lion. Cops & Crime Lab, Working Together
Florida: With the help of testimony f
rom convicted murderer Clarence Zacke, Brevard County
prosecutors sent Wilton Dedge to prison for 22 years f a crime he did not commit. In December,
or
2005, Zacke was sentenced to life in prison for raping his adopted daughter 30 years earlier. Now,
Dedge's attorneys are calling for an investigation of the state attorney ' s office after learning during
Zacke ' s rap e trial that the child-rape allegations were the subject of a grand jury investigation before
Dedge' s trial in 1 984. Hidden Dirt, Hidden Deals
New York: A former FBI agent helped set up the 1 992 shotgun murder of a Brooklyn mobster, a
federal civil suit filed by the gangster' s widow charges . The agent, Lindley DeVecchio, pulled a
surveillance team shortly before the rubout of Nicholas Grancio as a favor to Mafia capo Gregory
S carpa Sr. - DeVecchio's secret informant, the suit contends. It' s Nothing Personal; It' s Just Business
New York : A Long Island, N. Y . , judge has been
arre sted and charged by federal prosecutors with
participating in a money laundering and fencing scheme with a suspected organized crime associate.
According to a 7 1 -page complaint unsealed Tuesday by the Eastern District of New York u.s.
Attorney ' s Office, Nassau County District Court Judge David Gross helped an undercover Federal
D ureau of Investigation agent posing as a stolen diamond trafficker unload merchandise as well as
launder about $ 1 3 0,000 in illicit funds. A Cut in the Action
Tennessee : Two more former Campbell County sheriff' s officers have been sentenced to prison for
the beating and torture of a suspected drug dealer. The ofticers claimed they went to Lester Siler's
home to serve a probation violation warrant, but in fact they tortured him, demanding drugs and
money . And Siler ' s wife tape recorded it. Taped Interrogation
I l l inois : In October, 2004, Kevin Fox of Wilmington, Illinos was arrested following a 1 4-hour
illlerrogation in which investigators said he conf
essed to molesting and murdering his 3 -year-old
d a ughter Riley in June of the same year. The prosecutor, just days away from a hotly contested re
election bid that he ended up losing, vowed to seek the death penalty. A sheriff' s officer called the
F i H Lab at Quantico, Virginia in November and told them to stop working on DNA evidence sent
t) :cre for analysis. Kevin' s attorney convinced the new prosecutor to send the evidence to a private lab
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f(l[ testing, and the DNA test results "absolutely" exclude Kevin. Charges that could have led to his
execution have been dropped. Riley's killer remains free. Political Overkill
UPDATE: 5/28/ 1 0 - Riley Fox's killer, identified by DNA as Scott Wayne Eby, has been charged
with abducting the 3-year-old from her own bed, raping and murdering her. After putting the Fox
family through hell with the bogus charges against Kevin, then losing a $ 1 5 . 5 Million lawsuit for
m alicious prosecution, Will County Sheriff Paul Kaupas has apologized to the Foxes. Well, sort of.
He had a spokesman do it on his behalf. So Little, So Late.
V irginia: Cisco A. Olavarria was almost 1 ,000 miles away when 1 4-year-old LaBrian Harris was shot
d : ad in South Richmond in the fal l of 2004. Eleven days after the Oct. 1 6 shooting, Richmond police
publicly named Olavarria, then 1 9, as a suspected accomplice in the killing and distributed his
d ; iver's license photo to the news media. Early the next month, a special grand jury began meeting
o','er an intensive investigation by Virginia State Police into the killing of Olavarria's older brother,
S : mtanna, by two Richmond police officers the preceding spring. It' s Time to Set the Record Straight
{ ' PDATE: Patrolman, ex-partner indicted in Santanna Olavarria's murder.
California: Kern County DA Ed Jagels put two dozen innocent people behind bars on charges that
t1 cy molested their own kids - while ignoring evidence that his friends were throwing orgies with
teenage boys. So why is one of America's most reckless prosecutors still in power? Mean Justice's
r i[ty Secrets
I ' I inois: A lawsuit was predictable in the case of two teenagers who were wrongly charged in the
february slaying of a Machesney Park, Illinois man. The l aws uit was brought by mothers of the two
y r 1 uths who were wrongly charged, and it names Winnebago County Sheriff Dick Meyers, his
department, detectives and deputies. It's time for Safeguards to Protect Accused Kids.
\' ' i sconsin : Suspicions about a 1 998 4th offense drunken-driving case dismissed by former prosecutor
12 rad Priebe have prompted Winnebago County DA Bill Lennon to refer the matter to the state
r partment of Justice for review of the case. Lennon said he did so in response to "red flags" that
a;lpeared as prosecutors prepared a new drunken driving case against the same man, whose 1 998 case
" IS dismissed as a result of a motion by Priebe, then a Winnebago County assistant district attorney.
l ie be , appointed judge in Outagamie County Circuit Court and running for election in his own right,
s , i d he was ordered to dismiss the charge by then-DA Joe Paulus, now in prison for taking bribes to
fi x cases, and "had no choice". The Paulus Legacy Shines On
c ick HERE for full coverage of Wisconsin's Joe Paulus bribery scandal, from initial allegations to
s
' ntencing.
C ' lio : Derrick Jamison has been released from Ohio's Death Row. His 1 98 5 murder conviction was
(' crturned by two federal courts, which ruled he was denied a fair trial by prosecutors who withheld
c idence that might have cleared him. 1 1 9th Innocent Person Released from Death Row
1 SA: The popularity of "CSI : Crime Scene Investigation" and its increasingly numerous progeny has
spawned what some folks are calling the "CSI Effect." That is, most people who might end up on a
j i ' !'Y know,
or think they know, a great deal about forensic science and the kind of evidence needed to
s lve crimes. All this has been widely noted. What hasn't been noted is how years of cop shows have
a! rcady formed our background ideas about the criminal justice system. What this suggests is that we
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o ll ght to be a good deal more suspicious of prosecutorial infallibility than television shows suggest.
Cop Show Ef
fect
Wisconsin: A Milwaukee police officer has been charged with a criminal civil rights violation for
trving to shake down a parolee for money and gtillS, according to a criminal complaint filed in federal
C l ltrrt in Milwaukee. The officer, Ala W. Awadallah, 26, also threatened to plant drugs on the man and
tt have him sent back to prison, according to an FBI agent ' s af

fidavit filed in support of the
complaint. If convicted, Awadallah faces a maximum penalty of two years in prison and $200,000 in
fines. The Price of Staying Out on Parole
O 'le day before Milwaukee cop Ala Awadallah was busted this week by the FBI on charges of
sllaking down a parolee, he was in the most unlikely of places: Sitting in the witness stand testifying
r federal prosecutors in a drug/illegal immigration case. Can you say "appeal"?
I ! ' inois: An Illinois State Police l ieutenant says he was stopped from investigating the possible
i l : volvement of a Downstate businessman in a double homicide because the man had made significant
p olitical donations. The l ieutenant does not allege wrongdoing by the politician, former Gov. George
Ryan, whose campaign fund received the businessman' s donations. But he alleges that state police
brass were guided by fear of political reprisals, even in an investigation with the highest possible
sl ' lkes-a death penalty murder case. Demote the Messenger
r-. ' ake
no mistake. Nearly 1 9 years after the fact, this case is now a bigger mess
than it's ever been.
S ' ate police officials are the subject of very serious allegations of misconduct, and the attorney
g neral' s office is representing the state police against the man leveling those allegations. Who will
s :p in to clean it up?
\" iseonsin: Dale Chu's conviction is proof that, in Wisconsin, you can convict someone of arson even
W ' len the cause of a fire cannot be determined. All it takes is a win-at-all-costs prosecutor like Vince
B : .;kupic, perjured testimony from state "arson experts", the lies of a paid-off snitch and a dummied
d. lwn jury. Fixing It Up

T1C current DA in Winnebago County is conducting a secret John Doe investigation into the conduct
the prosecutor' s
0 ' Vince Biskupic and his friend and mentor, Joe Paulus, when they controlled
c
i ces i n Winnebago and Outagamie Counties, H e calls their actions i n the cases they made against
r-. , ilrk Price "an abuse of the justice system of the worst kind."
C ick HERE for full coverage of Wisconsin's Joe Paulus bribery scandal, from initial allegations to
sc ' : tencing.
C i ek HERE for full coverage of Wisconsin's Vince Biskupic money-for-Ieniency scandal.
r-. " I ssachusetts: Eighteen years ago, three Boston-area men were convicted of fat a l ly shooting a
J
I ll1field couple in the basement of their Main Street home as their two young ch i ldren slept upstairs,
a 'razen crime that sent shock waves through the quiet, prosperous suburb. Richard Costa, Dennis
D lye, and Michael DeNictolis are each serving two consecutive life sentences without the possibility
.
0 : parole for the 1 985 slaying of Robert Paglia and his wife, Patricia, in a robbery at the couple' s
h ' lise. But now a retired FBI agent says i n an affidavit that a former colleague gave false and
m : sleading forensic testimony - deemed crucial to the prosecution's case - at the trial. B S Bullet
r-. ' atching
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Fl orida: The Florida Department of Law Enforcement is joining the investigation of Broward
Sheriff s Office detectives suspected of falsifying crime reports. Prosecutors recently filed criminal
ch:lrges against two deputies who are charged with falsifying documents and mak i ng up confessions
to clear cases in Weston and Southwest Ranches. Dozens more deputies have been informed that they
are under invcstigation or havc been asked to give statements to prosecutors. Exceptional Clearance
Fl orida (but could be anywhere in the US): .Tames Faller claimed innocence in a complicated loan
fr: l lld from the time he reported it to Florida regulators more than 1 0 years ago, when he tried to
explain it to an FBI Agent, when he was indicted, tried, convicted and sentenced to prison. Along the
way he infuriated federal prosecutors by making hundreds of allegations of misconduct at virtually
evny stage of his prosecution in the
$3.6 million fraud because, he claims, they go t the wrong guy.
1l.:.:y' l l Get You if You Tick Them Off

UPDATE: Faller's federal lawsuit has made it through the initial (and inevitable) barrage of motions
to dismiss and motions for summary judgment. Federal Judge Allows Suit to Stand
l ] ' i !1ois: Cook County, Illinois prosecutors have dropped murder charges against Dan Young, Jr. and
Ib'old Hill, who have spent more than 1 2 years behind bars, after DNA test results undermined their
rom a dentist who implicated the two through a bite mark and a
(c(.:rced) confessions and testimony f
hi4 ,ey. A Chicago Tradition

I llinois and Missouri : A federal jury has awarded nearly $6.6 million in damages to former Chicago
police Officer Steven Manning, finding two veteran FBI agents framed him for a Cook County
murder that put him on Death Row. The jury also held that one of the FBI agents also framed
ore both convictions
M anning in a Missouri kidnapping case. Manning spent 1 4 years in prison bef
w 're ovcrturnc d and the prosecutions were dropped. Framed by FBI
}\ I- ; zona: Last year, former Pima County DA Kenneth Peasley was disbarred for intentionally
ore happened to an
alse evidence in death-penalty cases-something that had never bef
pr; <;cnting f
i\ 1 ' lcrican prosecutor. In a 1 992 triple-murder case, Peasley introduced testimony that he knew to be
faLe; three men were convicted and sentenced to die. Peasley was convinced that the three were
guilty, but he al s o believed that the evidence needed a push. According to the Death Penalty
1 11 ('ormation Center, since the mid-nineteen-seventies a hundred and seventeen death-row inmates
h, \'c been released. Defense lawyers, often relying on DNA testing, have shown rcpeatedly how
sl' Jdy crime-lab work, lying inf
ormants, and mistaken eyewitness identifications, among other
fadors, led to unjust convictions. But DNA tests don't reveal how innocent people Come to be
pr. secuted in the first place. The career of Kenneth Peasley - and the case of Martin Soto-Fong
( ,. K ill er Instincts [pdf format]

J' ... vada: Police and prosecutors in the Las Vegas Valley routinely try to keep essential information
fru m defense laVl.yers, violating the constitutional rights of those accused of crimej, defense attorneys
an ' ! the county public defender say. Putting Away the Innocent
Wi sconsin: Everything was hunky-dory at the Department of Corrections when thc TV show "Lie
De ector" proposed filming a polygraph exam of prisoner Mark Price. But when Penny Brummer and
At:drey Edmonds were added to the slate, Deputy Corrections Secretary Rick Rael l l i sch pulled the
ph g, claiming the show is "entertainment", not news. Why the 1 80 degree switch? Perhaps it' s
bet..:ause Raemisch was Dane County Sheriff and at the helm of the Brummer and Edmonds
inyestigations. Conflict of Interest
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Laura Peters
From:
Patrick King
Sent:
Tuesday, September 25, 2012 11:34 AM

lach Coughlin
To:
Cc
David Clark,: laura Peters
RE: citat io n to legal authority?
Subjett
9-25-2012
Dear Mr. CoughHn,

Please be advised that the State Bar of Nevada will not accept or file any documents submitted by you via e
mail. Further, if you intend to send or serve me with a copy of a document it will not be accepted if sent via e-mail.
Since re ly,
Patrick King, Assistant Bar Counsel.
lach Coughlin [maitto:zad'lc.oughlin@hotJnail.com]

Monday. September 24,2012 5:13 PM
To: Patrfck King
SUbJect: alation to legal authority?
From:
Sent:
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 atation for your
oontentions.
Thanks,
lath Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCouahlin@hotmall.CQfD
03045
03045
------- .. _--- - ---
------------- ---- - ---. - - _..

--
---
- --
--.
--
'""
--

ONE SOUTH SIERRA STREET, RENO, NY 89505

Malllni: P.O. 801. 1900, Reno., NY 89505 PHONE (773)334.1290 FAX (775)334-3824
YO_
DEFENDANT: COUGHLIN, ZACHARY BARKER
Court Caseli: II CR 22176 21
AgencyN:
RSICPIICl10617
Status: OPEN
Language: ENGLISH
DOB: 0911711976
Aceidentl#:
Booking#: 15953
Jail Days:
Offense 01::
PIC'&:
10(1011011
Arrest DI:
Suspended Days:
09109/l0lJ
09!091l011
NOT GUILTY
40.00
Supcr.'ilion Fcc Subtotal:
--
40.00
540.00
Additionlll Fees
$40_00
$I)
Supv Fcc(s) Due:
Dt.
Sep 9, 2011
--- - -- --- -- - - - - --,

-
Next ProofDI:
"'leKyll; IClI0617
Ddendlnt Initltols:
PrlntDlte: 100IOlWlI
______
----
---
COURT CASE If: 11CRll176 11

Data Date: 1011011011
P'le I ofl
03046
03046
Balance: _-
=======;]
Completed Dt:
FAILURE TO COMPLY WITII mE CONOmONS OF BAlL AS DESCRIBED IN 11IIS ORDER WIll RESULT IN THE ISSUANCE OF A
FAILURE TO COMPLY W ARRANT OR IMMEDIATE ARREST AND INCARCERATION FOR CONTEMPT OF COURT ANDIOR BAIL
REVOCATION. FOR FURTHER INFORMATION, COAcrTHE SENTENCE COMPLIANCE WlNDOW LOCATEDQN TIlE FIRST
FLOOR OF TIlE RENO MUNICIPAL COURT. ONE sotml StERRA ST, RENO, NY (775) ))4-22!X).
EFENDANT
\)
REVlES
{!J,"'--
THE DEFENDANT SHAll APPEAR AS ORDERED FOR ALL

BAlLIFFSIMARSHALSAND ALLCOURT STAFFtt. .I,W
.
THE D
SHALL ATTEND ALL REVIEWS, CO
.Ai.C0y6tANDDRUG F
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'I;; It;'''; '6l1.f'c..
AND SHALL COQPE {U,TE FULLY WITH THE
'
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o...r
I I
AP
S AND COUT.ORDE PROGRAM ON TI
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AN&' ''''
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'==
mE DEFENDANT SHALL KNOW HlSIHER COURT DATE AND MAlNTAlN CONTACT WITH HlSIHER ATTORNEY.
....
PRIOR TO CHAl"GING HIS/HER ADDRESS OR PHONE NUMBER, THE DEFENDANT SHALL NOTIFJY THE COURT OF SUCH
CHANGE.
OBEY ALL LAWS.
THE HONORABLE WILLIAM GARDNER
JUDGE'S
D ATE:
You ar ordered br the to arrive drug/alcohol free and on time for aU Court hearings and Court related progams. Failure
to
appear
Court win reult In the suance f warrant for your arrest Any violation of this instant order may result
.
proceedmgs and the fihng of ddltlonal crlmmal charges. In accordancc with NRS 22.010, il
refuse or neiled 10 comply With the tcnns of any order issued by the Municipal
.
Court ISSUes another order superseding it.
in contempt
is e misdemeanor for any perscn to fail,

.
"jF1f1!:f::=====::-:; <;:====
_
UNDERSTAND AND PROMISE TO OBEY THIS ORDER. DErENIOAl<To'

'
I, THE SWORN INTPRETER HAVE FULLY INTERPRETED TIllS ORDE
DEFENDANT:
'iM
TlME:
O/rOTHE
__
_
DATE:,____ TIME: ___

_
RECEIVED BY DEPUTY:
TIME:
---
1I
TIME:
BY
Dtftndant Initi.lI:
remain in effect until the
Print D.le:
to/IOllOll
Dd. O.tt:
10/1012011
03047
03047

--- --- ._-
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- - -- - . --
" . s. .
- - - -_._---_._
.....
- - -------- - -- - -
--

COUNTY OF WASHOE,
OF
ADA
'
.. ..
NE"
COLIR
BENO MUNICIPAL
DEPT. NO.1
___
DEPT. NO. 2 _-,:DEPT. NO.3
City, S-, Zip (Ci""'-i, r..wio, Co<ligo "",tal)
33'D/_tf
IV
'
<In76
,I :
'JJ5
Pho Nwnb" (l'd"o"o),/
Dale of Birth (Fecha NKimikto)
DEPT. NO.4-_
E..rmil address (D
6n c1ectr6mca)
_!'
_ -
<eqUCS"
Trial Date (Nueva Fecha deJuicio)
Ncw Am.iJnmcntDate(Nucvarechadc dc Cargos)
This motion is based on the following: .Esta petici6n es basada en 10 siguiente)
AFFIRMATIONIA'IEITAgON .
I, (pnnt name/unpnma su nomb
AP'FlANri
ORD
(PJRMA DEL DECLUtANTl'J
IORDEN
{<:; 1
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(Gun
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de DeClaraci6nl)
ci
sJ-
, "'-{j" J,V
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dcclan: under penalty
- - -'ii72./! I
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the motion be:
(HMJieridojwQ JUdo, et;
J I
I
.
Z-,c"-Covy\L I (./) I\,.<tw\Qi(-(<A/'
iiJ:ci
MOTIONIPE71CIONA LA CORTE:;'
,
Comowthe undcni&nedand here make. Ibe following
VIU.D .v-:r",,.Q""
e",
__
of peljUJ)'
DATEri
Granted
(Otorpth) ..,::-rre-nicd (Nep:h)
Oaobu.s.2011
03048
03048
------_ ._-_._.
1
2
---------_..
..
_--_ _ . - _
.
_ - -_
.
...
_-
_.
Case No. IICR22176

Dept. 4
3
4
5
IN THE MUNIc[PAL COURT OF THE CITY OF RENO
6
7
8
9
10
11
12
13
14
15
16
17

CITY OF RENO,
Plaintiff,
ORDER DENYING LEGAL DEFENDER
VS.
I:OOp.m.
COURT DATE: November 14,2011 @
Department Four
Courtroom B
Zachary Barker Coughlin,

Defendant.
,1
---_____
--
An Application for appointment of a Legal Defender having been filed with this Court,
and having been reviewed by this Court, therefore;
This Court does hereby DENY said appointment for the reason that ifconvicted of this
charge, the standard sentence carries no jail time.
18
It is so ORDERED.
19
DATED this 27 day o[October, 201l
20
21
22
pl!:
W
KENNETH R. HOWARD, JUDGE
23
24
25
26
27
28
03049
03049
.---.
. . ---
- --. .
...
'--'-'--
.
---
..
-- _.-.-_
, '
,.,
..__.. _-
, ,\,'; 't, i
, ...'
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.-.-------------
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CASE NO.: 11 CR22176

DEPT. NO.: 4
In! 1 DEC 21
Ail C: 38
3
4
5
IN THE MUNICIPAL COURT OF THE CITY OF RENO,
7
8
9
ClTYOF RENO
Plaintiff,
10
11
12
OPPOSITION TO
MOTION FOR NEW TRIAL
vs.
ZACHARYBARKER COUGHLIN,
13
14
17
18
The City of Reno, by and through John Kadlic, Reno City Attorney and Pamela Roberts,
Deputy City Attorney, oppos es what appears to be Defendant Zachery Barker Coughlin's Motion
for New Trial. This Opposition is made pursuant to Reno Municipal Court Rule 4 and based on
the following Points and Authorities.
19
20
21
22
23
24
25
26
27
28
_
_
_
__
______
15
16
Defendant
1+-
I.
POINTS AND AUTHORITIES

FACTS
:
On December IS,2011 at approximately' 346 PM, the City received a two page fax
(hereinafter "First Fax") from Defendant Zachary Barker Coughlin (hereinafter 'Defendant").
See Declaration of Pamela Roberts. It appears to be a copy of an email Defendant sent to Deputy
City Attorney Chris Hazlett-Stevens, Deputy City Attorney Pamela Roberts and City Attorney
John Kadlic on Monday, December 12,2011 at9:52 PM. [d. At the top of the First Fax is the
heading Here'is service of the Motion for a New Trial, Set Aside, Va [sic)." Id at Exhibit A-I
and A-2.
03050
03050
..
...
------ "------
.
_
-'-- .
--. - --.
--
.-
On December 15,2011 at approximately 4:01 PM, the City received a three page fax
2
3
4
5
(hereinafter "Second Fax") from Defendant.
Id. This Second Fax has a one page "FAX COVER
SHEET' which indicates "RE: City of reno [sic] v Coughlin RMC II CR 22176 21 Motion for
New Trial." [d. at Exhibit B-1, 8-2 and B-3. The second and third pages of the Second Fax are
Y identical to the First Fax received at approximately 3:46 PM.
Id
On December 19,2011 at approximately 5:21 PM, the City received a 92-page fax from
6
7
Defendant. [d. The first page thereof has a court and cause of this case and is entitled ''Notice of
Denia] of Service; Opposition City of Reno's Notice of Denial of Service; Request for
Clarification Regarding Deadline for Filing Motion For New Trial, Other Tolling Motions,etc.;
10
APPLICAnON FOR DEFERRAL OR WAIVER OF COURT FEES AND COST' (hereinafter
II
"Notice-Opposition-Request-Application"). ld. The City presumes this has been filed with the
12
Court.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
Contained therein is a "DECLARAnON OF ZACH COUGHLIN" which contains two

references to a "Motion for a New Trial" and a "Motion for New TriaL" See Notice-Opposition
RequestApplication at "DECLARAnON OF ZACH COUGHLIN" 13 and '15.
At ,3. Defendant writes "I .. . have faxed [Ms. Roberts] the December 13111 Motion for a
New Trial. etc. to Ms. Roberts at her fax number." Id The City did not receive such a fax or
Motion for a New Trial. See Declaration of Pamela Roberts.
At 15. Defendant writes "He did indicate that 'they' said the Motion for New Trial that I
had recently filed was timely
" See Notice-Opposition-Request-Application at
"DECLARATION OF ZACH COUGHLIN" at 115. The City has not received proper service of
any filed Motion for New Trial. See Declaration of Pamela Roberts.
n.
ARGUMENT
A.
The City Was Not Served With Any Motion for New Trial via the First Fax.
The First Fax is merely a copy of an alleged email. &e Declaration of Pamela Roberts
27
and Exhibits A-I and A-2 thereto. There is no Motion for New Trial attached thereto. Id There
28
is no affidavit or affidavits and no points and authorities as is required by R.M.C.R. 4.
Id
03051
03051
,.-
B.
2
3
4
5
10
11
12
13
14
15
16
17
.-.-.--.....-..---.-.--,",-.--"----
The City Was Not Served With Any Motion for New Trial via the Second
Fax.
There is no Motion for New Trial attached thereto. ld There is no affidavit or affidavits and no
points and authorities as is required by R.M.C.R. 4. Jd
c.
.... .
The Second Fax has a Fax Cover Sheet and then is merely a copy of an alleged email. Jd.
.
. .. .
- -. --_. . _. . - .. .
.. .
.' -, _ ..- - _ .
The City Has Not Been Properly Served -Indeed Has Not Received Any
Motion For New Trlal.
Defendant alleges in his Notice.Opposition-Request-Application
that he filed with the
Court and served via fax a Motion for New Trial upon Deputy City Attorney Roberts and the
City. The City is unaware if Defendant has in fact filed a Motion for New Trial with the Court.
The City denies it was served via fax and denies that it was served at all with any Motion for
New Trial filed on or about De=nber 13 or IS, 201 L
ID.
CONCLUSION
Any Motion for New Trial filed by Defendant on or about December 13 or 15. 2011
should be denied for failure to serve the City.
J,01l,
day of December, 201 L

JOHN J. KADLIC
Reno City Attorney
18
19
20
21
22
23
B y:--
---------PAMELA RO BERTS
Deputy City Attorney
Reno City Attorney's Office
P.O. Box 1900
Reno,NY 89505
(775) 3342050
24
25
26
27
28
03052
03052
.".;:..
DECLARATION OF PAMELA ROBERTS
1
2
STATE OF NEVADA
:ss
COUNTY OF WASHOE
4
I, Pamela Roberts, declare under penalty of peury pursuant to NRS 53.045 that
the following it true and correct:
1.
I am the Deputy City Attorney for the City of Reno and the Reno City Attorney's
Office.
2.
'
On December 15, 2011 at approximately 3:46 PM , the City received a two page
10
fax (hereinafter "First Fax") from Defendant Zachary Barker Coughlin (hereinafter
11
"Defendant"). An accurate copy thereof is attached hereto as Exhibit A1 and A
12
2. It appears to be a copy of an email Defendant sent to Deputy City Attorney
13
Chris HazlettStevens, Deputy City Attorney Pamela Roberts and City Attorney
14
John Kadlic on Monday, December 12, 2011 at 9:52 PM. At the top of the First
15
Fax is the heading MHere is service of the Motion for a New Trial, Set Aside, Va
16
[sicl.' See Exhibit A1 and A2 hereto.
17
3.
2
On December 15, 2011 at approximately 4:01 PM , the City received a three
18
page fax (hereinafter "Second Fax") from Defendant. An accurate copy thereof is
19
attached hereto as Exhibit B1, B2 and B3. This Second Fax has a one page
20
"FAX COVER SHEET" which indicates "RE: City of reno [sic] v Coughlin RMC 11
21
CR 22176 21 Motion for New Trial." See Exhibit B'. The second and third
22
pages of the Second Fax are virtually identical to the First Fax received at
23
24
25
26
27
28
approximately 3:46 PM.
11
See Exhibit B-2 and B3.
------
I The RECEIVED TIME stamp indicates 4:46 PM. However, on cmber 19,2011 at 2:4!1 PM, it was discovered
that the time stamp on the fax machine was offby one hour i.e., it stamped 3:45 PM when the time was actually 2:45
PM. Apparently. when Daylight Savings Time reverted 10 Standard Time on November 6, 201 I, the time function
was not changed to reflect the reversion to Standard Time. The time stamp feature was corrected on December 19,
2011 at approximately 3:35 PM.

1
Su Footnote 1 above.
03053
03053
....
..",-
'.7/11
-___
4.
On December 19, 2011 at approximately 5:21 PM, the City received a 92-page
,
fax from Defendant. The first page thereof has a court and cause of this case
and is entitled "Notice of Denial of Service; Opposion City of Reno's Notice of
Denial of Service; Request for Clarification Regarding Deadline for Filing Motion
For New Trial, Other Tolling Motions, etc.; APPLICATION FOR DEFERRAL OR
WAIVER OF COURT FEES AND COST" (hereinafter "Notice-Opposition
Request-Application"). The City presumes this has been filed wnh the Court.
Contained therein is a "DECLARATION OF ZACH COUGHLIN' which contains
two references to a "Motion for a New Trial" and a Motion for New Trial.- See
10
Notice-Opposition-Request-Application at "DECLARATION OF ZACH
II
12
COUGHLIN" 113 and 1115.

5.
13
Motion for a New Trial, etc, to Ms. Roberts at her fax number." The City did not
14
15
receive such a fax or Motion for a New Trial.

6.
16
Application at "DECLARATION OF ZACH COUGHLIN' at1l15, The City has not
18
20
21
22
23
24
At 1115, Defendant writes "He did indicate that 'they' said the Motion for New Trial
that I had recently filed was timely, .. .' See Notice-Opposition-Request
17
19
At 113, Defendant writes "I . .. have faxed [Ms. Roberts] the December 13"'
received proper service of any filed Motion for New Trial.

7.
Pursuant to NRS 53.045, I dec/are under penatly of peury that the foregoing is
true and correct. Executed on December 20, 2011.
p.
PAMELA ROBERTS
25
26
27
28
03054
03054
---- ---- ----......---
-,- ~.-- .,
------,
EXHIBIT 1
EXflIBIT
I
,, j~il.I'
,,, 111
. ____
'
..RI........__ _____
,
,
:0
;
]
03055
03055
-,..-----.----.-- .-
------------ -_._--
IN THE
_ ._---_.----
HCIPAL COURT OF THE C
F RENO
ONE SOUTH SIERRA STREET, RENO, NY 89505

PHONE (115)334-1190 FAX (775)33"
Mtiling: P.O. DOl: 1900, Reno, NY .9505

DOB: 0912711976
Aecident#:
Court CaseN: 11 CR 2640521

RPD
A&encyN:
II-llIBS
-- - -, .
,,' '"
';l( .
Status: OPEN
8ookingN: 19876
'}
JUDGE GARDNER.
.11 "
. 1"
'"
MOIl, Nov 14,2011
JUOOE GARDNER
Tile, Dec U, 2<111
JUOOE GARD,\lER
--
-
--
.
f
i:
" <JIIjJI'''It! . l . "';-Ur.); \(,' l!l ( . )';:
Tuc,J.. IO,2011
- -- ------- -
,,/''!:I).)'llfcl).... 1'
---
-(,I) ,-11
_ .
1:30 am
Language: ENGLISH
,.
AAItAlGNMENT HEAJUNQ HELD
1:00am
1:00pm
REQUEST OF CITY
8Y REQUEST OF DEFENSE
--- ------- --- ---.r",)" ,; " .. , ,I'
ra" 'H"I";'I<
1I/IJ12011
FORMAL COMPLAINT FILED WITH THE COURT
.1111412011
LEGAL DEFENDER APPOINTED: LEW TAITEL; 415 S. ARLINGTON AVENUE. SUm: IA RENO, NEVADA 19501
PHONE (775) JlZlln
PLEASE ALLOW APPROXIMATlLY J WEEKS BEfORE CONTACTING YOUR A'M'ORNEY SO TIlAT HFJSII
WILL HAVE ALL or THE NECESSARY INFORMA-TlOI"! FROM TIIB COURT TO ASSIST YOU WITH YOUR CASE.
IT IS HEREBY ORDERED THAT THE ABOVE-NAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TO
REPRESENT HIMttt: E R IN ANY AND ALL PROCEEDINGS ON THIS MATTER IN THE RENO MUNICIPAL COURT.
IT IS FURTHER ORDERED TRAT THE DEFENDANT COMPLETE A FiNANCIAL INQUIRV APPUCATION AND
MAYBE REQUIRED TO PA Y FEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILL
REMAIN IN EFFECT FOR SIX MONTHS FROM TODAY'S DATE. IN TIlE EVENT TJIAT THIS ORDER EXPIRES.
THX DEFENDANT MUST SUBMIT AN UPDATED FINANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.
11/1411011
IIIJMOI.I
IF THE DEFENDANT HAS WITNESSES THAT REISHE WOULD UKE TO HAV& WITNESSES PRESENT, OR
WOULD LIKE TO DISCUSS THE DEFENSE OF ",MllR CASE, THE DEFENDANT MUST CONTACT HISIIIER
AITORNEY.
THE DEFENDANT APPEARED, WAS EXPLAINED HISIHER RIGHTS 8Y THE JUDGE AND INDICATED TIIA T
HElSH! UNDERSTOOD THEM COMPLETELY,
LEGAL DEFENDER APPOINTED: ROBERTO PV[NTESI416 RlDG STREET (P.O. BOX 2421) RENO. NEVADA
19505 PHONE (175) 18'*7676
PLUSE ALLOW APPROXIMATELY J WEEKS BEFORt CONTACTING YOUR ATTORNlEY SO THAT HFJSIIE
WILL HAVE ALL Ofl'THE NECESSARY INFORMATION fROM THE COURT TO ASSIST YOU WITH YOUR CASI.
IT IS HEREBY ORDERED TJlAT TUt ABOVENAMED DEFENDANT 8E APPOINTED A LEGAL DtFl:NDER TO
REPRESENT HIMIHER IN ANY AND ALL PROCEEDINGS ON THIS MATTER IN THE RENO MUNICrPAL COURT.
IT IS FURTHER ORDERED T1lAT TilE DEPENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION AND
MAY 8E REQUIRED TO PA Y FEES fOR REPR[sENTATION BY THE LEGAL DEFENDER. THfS ORDER WILL
REMAIN IN EfnCT FOR SIX MONTHS FROM TOOAY'S DATE.. IN TIlE EVENT THAT THIS ORDER EXPIRES,
THE DEFENDANT MUST SUBMIT AN UPDATED F1I"!ANCIAL INQUIRY APPLICATION FOR RECONSIDERATION.
IF TilE DUENDANT lIAS WITNESSES THAT lIElSHE WOuLD LIKE TO HAVE WITNESSES PRESENT, OR
WOULD LIKE TO DISClISS TilE DEFENSE OF IfISIIIF.R CASE. Til! DFF.DANT MUST cn,'TACT 1IIS1i1R
D,rmd.n! lnltill.:
Prill! Dltt:
6JIMOll
n.1I Dale: 6/1811011
03056
03056
,-.---".,-.-- -'
-----
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. . . . .,_.
. ..__ ......
---- ---. _
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.
. r._ ========"'j
.
____': LEWIS TAITEL
':':: EF ;";::
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f
rr=11"=O 07 I1 "':' GAL ND
IT IS HEREBY ORDERED THAT THE LEGAL DEFENDER BE RELIEVED FROM IllS/HER ASSIGNMENT TO THIS
CASL
LEGAL DEFENDER APPOINTED; KEITH LOOMISI9461 DOUBLE R BLVD SUITE A, RENO, NEVADA 89511
2.111101%
PHONI (775) 1531%11
PLEASE ALLOW APPROXIMATELY 3 WEEKI BEFORE CONTACfINC VOUR ATTORNEY SO THAT II[1SHE
WILL HAVI ALL OF THE NECESSARY INFORMATION FROM THE COURT TO ASSIST VOU WITH YOUR CASE.
IT IS
HEREBY ORDERED ntA.T THE ABOVENAMED DEFENDANT BE APPOINTED A LEGAL DEFENDER TO
REPRESENT HlI\o1IHER IN ANY AND ALL PROCEEDINGS ON TillS MAITER IN THE RO MUNICIPAL COURT.
IT rs FURTHER ORDERED THAT 11fE DEFENDANT COMPLETE A FINANCIAL INQUIRY APPLICATION AND
MAYBE REQUIRED TO PAY rEES FOR REPRESENTATION BY THE LEGAL DEFENDER. THIS ORDER WILL
REMAIN IN EFFtCf FOR SIX MONlllS FROM TOOA V'S DATE. rN TilE EVENT THAT THIS ORDER EXPIRES.
THE DEFI.NJ)ANT MUST SUBMIT AN UPDATED Fll'fANClAL INQUlRY APPUCATION FOR RECONSIDERATION.
IF THE DEFENDANT HAS WITNESSES THAT Hl.ISHE WOuLD LIKE TO HAVE WITNESSES PRESENT, OR
WOULD LIKE TO DISCUSS THE DEFENSE 01 81SllItR CASE, THE DEFENDANT MUST CONTACT H1S1HER
ATTORNEY.
LEGAL DEFENDER RELiEVED; PER GRANTED MOTION HEARING
IT IS HEREBY ORDERED THAT THE LEGAL DEFENDER BE RELIEVED FROM HlSIHER ASSIGNMENT TO THIS
CASE.
PRESENT IN COURT FOR THE CITY OF RENO. nLL DRAKE FOR THE DEFENSE: ROBERTO PUENTES
lIlI2.on
1Il/2012
PRESENT IN COURT FOR THE CITY 0' Rl.N01 CHRIITOPUER HAZL1T-STEVENS FOR THE DEFENSE:
KEITH LOOMIS
ClUJllOl2
LECAL DEFENDER RELIEVED: KEITH LOOMIS

IT IS HEREBY ORDERED THAT THE LEGAL OlUNDER BE RELIEVED FROM HlSIHER ASSIGNMENT TO THIS
CASE.
PRESENT IN COURT FOR TlfE CITY OF RENOI CHRISTOPHER HAZLETT-STEVENS FOR THE DEFENSE: KEITH
LOOM.IS
!JI)lOl2
5Il11011
CrrY'S EXHIBIT MARKED/ADMITTED; EXHIBIT 1 EVICfION ORDER; EXHIBIT 2 FINDINC OF FACT AND
CONCLUSION OF LAW (DOCUMENT)! EXHIBIT 3 NOTICE OF ENTRY OF ORDER (DOCUMENT),
6IIIIlOll
PRESENT IN COURT FOR THE CITY OF RENOI CHRISTOPHER HAZLETT-STEVENS FOR THE DEFENSE; PRO
PER
6Il1/2:0U
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Chl.l'Je I: 01.10.010 TRESPASSING
06111112012
Plu:
NOT CVILTY
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0611812012.
..
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\:I:";J.1'IJt I:ll"-' II:'. t'r;1_I1(")."
ACfIVE BOND
CASH BAIL CONV[RTED TO PAY FINES

811141)
DEFENDANT!COUCHLIN. ZACH"RY BARKER

Iltrtndf Inltt.ll:
$JIO.OO
$1]0.00
TOTAL OWING AS OF THIS DATE: S310.00
Supw e(s) Due:
Fine Sublctal:
Cb"C J;
Ftc ( HEM.DV.OF,HIv,LDF.TIP.WITF) Sublotal:
1111512011
--
$40.00
Supcn-isiOil y", Subtotal;
CREDIT FOR JAIL TIME SERVED GIVEN_
'J j
!
"
WRTJ:
0
O6IJIIIlOI1. BENCH TRIAL: CONVICTION
"
Suspended DIYS:
IInJllOll
Dilpolition:
I.
PCN': 1101911
Jail 0.,.,:
1111312011
OffcnxDt:
AmstDt:
', r
AI.nt), I!.UU!
PrJ"r naif:
611111011
"
. , ."
S 310.00
S 310.00
'
'.
CASH ONLY
CASH ONLY
COURT CASE If: II CR 1640511
03057
03057
-_._-...-----.--
.. _-_....
_
._- ------------ --- - --- - _ . -
'
I
.
i
Next Proo(Dt:
SlIenee:
Compl eted Dc
FAILURE TO COMPLY WInI THE CONDITIONS OF BAIL AS DESCRIBED IN THIS ORDER WILL RESULT IN mE ISSUANCE OF A
fAILURE TO COMPLY WARRANT OR lMMEDiATEARREST AND INCARCERATION FOR CONTEMPT OF COURT AND/OR BAIL
REVOCATION. FOR FUR1HER INFORMATION, CONTACT nm SENTENCE COMPLIANCE WINDOW LOCATED ON mE FIRST
FLOOR Of mE RENO MUNICIPAL COURT, ONE SOUTH SIERRA ST, RENO, NV (715) 334-2290.
TIlE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SHALL COOPERATE FULLY WITH THE
BA1UFFSIMARSHALS AND ALL COURT STAFF.
THE DEFENDANT'SHALL AITEND ALL REVIEWS, COURT APPEARANCES AND COURT-ORDERED PROGRAMS ON TIME AND
TIlE DEFENDANT SHALL KNOW H1SIHER COURT DATE AND MAINTAIN CONTACT WITH HISJHER A1TORNEY.
PRIOR TO CHANGING HISIHER ADDRESS O R PHONE NUMBER. THE DEfENDANT SHALL NOTIFIY 1liE COURT OF SUCH
CHANOE.
OBEY ALL LAWS.
0510111011 ADOmONAL CASE rNFORMATION: NO MOTIONS WILL BE NOT ACCEPTED BY FAX FROM DEFENDANT OR CITY
ATIORNEY_ ALL PRE TRIAL MOTIONS MUST BE FILED 15 DAYS PRIOR TO TRIAL DATE Of 6-1&.11 IN PERSON BY ALL
PARTIES.
05lOlllOIl ADOmONAL CASE INFORMATION: PROCEEDINGS NO WNGER SUSPENDED, DEFENSE A1TORNEY TO OBTAIN
WRIIn:N ORDER FROM DISlRlCT COURT FINDINO DEFENDANT COMPETENT PRIOR TO TRIAL DATE
O$JIOflOll Mise NOTES:
011 nIB SECOND JUDICIAL DISTRICT COURT OF nlE STATE OF NEVADA IN AND FOR THE COUNTY OF WASHOE
ORDER TRANSFERRINO JURlSDICT10N TO MENTAL HEALnt COURT ON CASE RCR 2011-061526 TRESPASSING AFrnR
WARNING SIONED BY JUSTICE OF 11iE PEACE PETER 1. 50001
03J05Ilon MISC NOTES: SENDINO MonDt-' UP TO 02 VlA BLACK FOLDER. THIS IS HIS 2ND REQUEST FOR SAME MonON
TODAY.
04l1M012 ADCmONAL CASE INFORMATION: PROCEEDINQS SUSPENDED UNTIL COMPETENCY EV AL HAS BEEN COMPLETED
IN DISTRICT COURT MAlTER
03lO5ll011 MIse NOTES: 02 HAS FILE. SENDING MO
N UP TO DEPT VIA BLACK FOLDER.
THE HONORABLE
JUDGE'S SIGNATURE:
DATE;
As a condldon ofreleue from aatody (bail, bond or own rccopizance) and punuant to NRS 178.4114. the defendant mUlt sign this
document before being released from cwtody. By signing below, the defendant promises to appear at all tUnes and places ordered by
the Court, by way oftbls document. The defendant it ordered by the Court to appear in Court alcohol and dru& frtc or will be subject
to anut for contempt of coun. Failure to appear in court wi ll T'C!ull in forfeiture of bail and a warrant will be issued for the defendant'!
arrest.
Any violation ofthis instant order may result in contempt proceedinp and the filing of additional criminal charges. (n accordance with
NRS 22,010, it I. I misdemeanor for any pcBOD to (ail, refu5e or neglecl to comply with the tenns orany order iS5UCd by the
Municipal Court Judge. This
order will remain itt effect until the Court iSSUe! another order superseding it.
This order is to accompany a receipt of bail pOSled, which shall be used to satisfY any fLlle or cost imposed by the Court. Upon
adjudication of this case, any cash bail posted wilt be applied to outstandin, fmes andlor fees and any surety oonds will be exonerated
unless the judge orders otherwise.
l)[fI[NDANT: COCCIiLlN, ZACHARV DARKER
Altnc),": iI-llllS
D,f,ndanl Inltlall:
Print Dale: 61111101Z
COURTCASEII: l1CRl6-'0511
0.,.0.,,: 611111011
03058
03058
. +... ....- .
"
"
-.-.
...-----------.
"
Any law cnfom:mcnt officer who has

am:st himlbcr.
--'-- '~----- -.~

= - ---.--------
. - ..---
--.-,---.-----,--"----
,~
Ua. _.cawe to believe that the defendant huI 8t.ly condition of this order i, ordc to
---
I UNDERSTAND AND PROMISE TO OBEY THIS ORDER. DEFENDANT:
TIME:
DATE:
J, THE SWORN INTPRETER HAVE FULLY INTERPRETED THIS ORDER TO TilE
DERNDANT:
DATE:
TIM!::
RECEIVED BY DEPUTY:
DATE:
TIME:
ISSUED BY MARSHAL:
DATE:
TIME:
--"
,"
OEFENDANT:
OEFENDANT: COUGHLIN, ZACUARV HARKER
'\I'"C:)"I tI..t1lU
O.ftndlftt rnitt.la:
Print D.t,: 6I11I10n
COURT CASE': II CR 1640':z1

Oat. OUt: 611&12011
r'It" of ..
03059
03059
.~
....
.
.
'
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';,
EXHIBIT 2
-,
'j
EXHIBIT 2
...J,D&tW&
. &
03060
03060
_._-------_._
.. -
..
-- ------
._ .
_--- ------
---------_._.-
F I LED
Electronically
O!J...27-2012:10:10:50 AM
Clerk of the Court
Transaction # 3176051
1
2
3
4
5
IN THE SECOND JUDICIAL DI5TlUCT COURT OF THE STATE OF NEVADA
7
8
9
10
ZACHARY BAKER COUGHUN,
11
Case No.:
Appellant,
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Dept No.:
vs.
CR12-1262
10
CITY OF RENO, a munldpal

eo<paratlon,
Respondent
II--------I
ORDER
GRANDNGRESPONDCNl'SMonON TODISMISS
APPEAL
Presently before the Court, Is a MotIon to Dismiss Appeal filed by Respondent CITY
OF RENO (,Respondentj on Jufy 31,2012. follOWing, on August 14,2012, Respondent
filed a Request for Submission, thereby submitting the matter for the Court's consideration.
On August IS, 2012, Appellant ZACHARY BAKER COUGHUN (,Appellantj med an
Opposition to Motlon to Dismiss.
On November 13, 2011,Appellant was charged wit!) Trespassing under Reno
Munldpal Code, SectIon 8.10.010 by way of Criminal Complaint upon arrest. On June 18,
2012,Appellant was found guilty of trespassing by the Honorable William Gardner of the
Reno Municipal Court. On July 18,2012,Appellant filed a Notice of Appeal In this matter.
-1-
03061
03061
Respondent flies this Instant Motion to Dismiss Appeal based on Appellanrs untimely
filing pursuant to NRS 189.010. NRS 189.010 establishes the time within which an appeal
from a Municipal Court must be flied. In relevant part, NRS 189.010 states that a
4
5
6
7
8
9
10
11
12
13
Defendant In a aimlnal action tried before a Justice of the peace may appeal from the flnal
Judgment therein to the district court.
, at any time within 10 days from the Ume of the
rendition of the Judgment
Alter considering the papers and pleadings 0'; file herein, this Court has determined
that Appellant would have to have flied his Appeal on or before June 28, 2012. Appellant
did not flle his NoHce of Appeal until July 18, 2012, after the deadline had passed.
Accordingly, Respondenrs motion Is granted.
NOW, THEREFORE, IT IS HEREBY ORDERED that Respondenrs Motion to
Dismiss Is GRANTED.
14
15
DATED this
dlj
16
17
District Judge
18
19
20
21
22
23
24
25
26
27
28
03062
03062
_
_u
_ _- -.....
_
---.
____
-
...
.._-_ .._-_ ....
CERDFJCATEOF"!lUNG
1
2
3
4
5
6
I hereby certify that I electronically "led the foregoing with the Cieri< of the Court by
using the ECF system which seM!d the following
9
10
11
parties eiectrorjcally:
ZACHARY COUGHUN, ESQ. for ZACHARY COUGHUN

OiRlS HAZLETT-STEVENS, ESQ. for 0iY OF RENO
JILL DRAKE for 0iY OF RENO
7
B
.
-'.'-. ' _._
..
__ .
.
'
.-," ---_ . -' _ - - -.
_
.
DATED this
.,;.7
HEIDI HO
Judicial Assistant
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
03063
03063
_ .. __. _ - -- - - - -- --- - - -_
.
_ _. __._ _.... _-----_._
._"
, - -- - - , - _ . _---- - - -,, - - - _.. _--,-

OFFICE OF THE CLERK
IN THE MATTER OF DISCIPLINE OF

ZACHARY B, COUGHLIN, ESQ" BAR NO,
9473,
Supreme Court No, 61901
RECEIPT FOR DOCUMENTS
TO:
State Bar o f NevadaiRenolPatriek 0, King, Ass!. Bar Counsel

Zachary B, Coughlin
You are hereby notified that the Clerk of the Supreme Court has received and/or filed
the following:
10/1512012
Filing Fee Waived: Bar matter.
10/1512012
Filed Petition pursuan to SCR 111.
DATE: October 15, 2012

Tracie Lindeman, Clerk of Court
Ie
03064
03064
- - ---. . ,._ - _.- - ---- - - - - - - - ----
- - --- ..-.-----..
.
- -.-.- .--------.
--.-
'.

,
In Re: Matter of
Nevada Bar No. 9473
6
7
8
9
10
"
12
IJ
14
"
16
17
18
"
Case No.
6 1 9/
U
PETITION PURS ANT TO SCR 1 1 1
FILED
OCT 1 5 2012
......
w
".
5WaCif_
In accordance with the requirements set forth in Supreme Court Rule (SCR) 1 11(4), the
State Bar of Nevada rStale Bar). by and Ihrough ils Assistant Bar counsel. Patrick O. King.
hereby files this petition notifying the Supreme Court that attorney Zachary 8. Coughlin, Esq.,
has been convicted of a crime, other than a misdemeanor traffic violation not involving the use
of alcohol or a controlled substance.
On June 1 S, 201 2 , Zachary B. Coughlin, Esq. was found Guilty of Trespassing by the
Honorable William Gardner, of the Reno Municipal Court after a trial, under Reno Municipal
Code, Section 8.10.010. The Judgment of Conviction and Court Order is attached hereto as
Exhibit 1 . On July 18. 2012, Coughlin filed a Notice of Appeal. Dislrict Judge Seven P Elliott
dismissed the appeal. by Order filed on August 27. 2012. attached hereto as Exhibit 2.
Zachary B. Coughlin i s currenlly suspended following the conviction of a separate crime
by this Court. pending a disciplinary hearing pursuant to the Order of Temporary Suspension
and Referral to Disciplinary Board filed June 7, 2012.
,.
"
)
)
)
)
)
)
STATEMENT OF FACTS
1.
Respondent was admitted to practice law in the State of Nevada in 2005 and is
subject to the disciplinary jurisdiction of the Slate Bar of Nevada.

MEMORANDUM OF POINTS AND AUTHORITIES
2.
In accordance with SCR 1 1 1 (4), upon receipt of a Judgment of Conviction of an
l M' '' ;;' UNOt:MM
tl.IAII 01' I UPl1lWl COv,n

DflPVTYCUflI(
03065
03065
.,
o r a controlled substance. Bar Counsel shall file a petition with the Supreme Court.
2
)
3.
As evidenced by the documentation submitted herein, Respondent has been
convicted of a crime which triggers the reporting requirements of Bar Counsel under SCR
1 1 1(4).
CONCLUSION
7
8
WHEREFORE, the State Bar respectfully brings this matter to this Court's attention in
accordance with SCR 111(4).
II-..
STATE BAR OF NEVADA

DAVI D A. CLARK, Bar Counsel
9
10
"
By
12
7
lSl
..d
-;2 o
ant Bar Counsel

Patrick O. King,
Nevada Bar No. 5035
9456 Double R Blvd . . Suite B
Reno, Nevada 89521
IJ
PH: (775) 328-1384
"
I.
17
U 5 Post;li SerViCe
CERTI FIED !VlAIL
RE CE IPT
ProVldeO )
No In<UN/nee Co ve/iJr.)f'
(Domes" e MiJll Only
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03066
03066
-------
--- --
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--- _. _
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EXHIBIT
E '( I I HUT I
. . . -;m::a,=-----.
. .~~.1. ~.-=
03067
03067
----- ._.
-.------
..
IN T1
._------,-,
.-
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_. .-.
_._-----
QM._ IICIPAL COURT OF TIIEOr'-'F RENO
ONE SOUTH
SIERRA STREET, RENO. NY 89505

PHONI (175)334--1190 rAX (775)JJ....
:Vllmnl: P.O, Bos 19tJO. Reno, NY 89505
DEFENDANT: COUGHLIN, ZACHARY DARKER

Court Casd: II CR 16405 ]J
A&cnc:y.: RID I I-UII5
VIDEO
DOR: 09m/1976
Bookina': 1917'
AccidentM:
JUDOE OAADNEA
Mon. NCI'f 14,1011
,:)01",
11/131101 1
1 111..,,0 11
StaNa: OPEr'
lancuaa ENGLln
ARaAJONMEH1' H'EARlNO Hil..O
pm
FORMAL COMPLAINT nLlD Wrnf TIfE COURT
LEGAL DEFENDER APPOINTED: LEW TArrELs 4" s. ,ULlI'(GTON AVENUI.. SUITE IA RENO. NEVADA 19501
PHONE (115) J22.1111
PLUSK ALLOW APPROXIMATILY J WEEKS IEFORE CONTACTING YOUR ATTORNEY SO TIMT IfElSH&
WILL HA.VI ALL 0,. THIE NECESSARV INfORMATION FROM Till COURT TO ASSLST YOV WITIf YOUR CAS&'
IT IS HIR.I8Y ORDERED TIIAT Tn& ABOVE-NAMED DEFENDANT BE APPOINTED A LIGAL DEFENDER TO
REPRESENT IIIMnU:R IN ANV AND ALL PROCEEDINGS ON THIS MATTER IN THI RENO I\.UNICJPALCOVRT.
IT IS ruRTHER ORDEREDTlIAT TIlE DEFENDANT COMPLETE A FINANCIAL INQUIRY A'.LlCATION AND
MAY BI REQUIRED TO 'AY nItS rOR RE.RlSINTATION" BV TII& LEGAL DEI'END!1l- TillS ORDIR WILL
UIAES,
REMAIN IN EF'ECT FOR SIX MONTHS FROM TODAY'S OAT!. IN TUE EVl.NT THAT TIfI! OADER L
THE DEJ"UiDANT ,\-tun SUBMIT AN UPDATtD FlNA"ClAL INQUIRY ,\"L1eATlON fOR RlCONSJDERATlON.
1 " .-n011
1 1/300011
t,. Till DE"ENDANT liAS WITNESSES THAT 1111;111 WOULD UKI TO ItAVI WITNi!!lSU PRIUI.Nr, OR
WOULD LJKI TO DISCUSS TIll DEF[NSEO,. lIIlIffER CASE. TUE DEFENDANT MUST CONTACT 1115IIIU
AnORNEY.
THI DEFENDANT APPEARID. WAS EX'LAINED IIIWER RIGHTS BV. Till JVDCI AND (NDICATED THAT
III'.1SJlIl U;'(DERSTOOD THEM COMPLETELY.
Tr31 416 RIDGE STREIT ('.0_ BO:< 2411) Ri.O, , IV.ADA

L!.GAL DEFLD[R APPOINTED: ROIlRTO PU[.
39505 PHONI (115) 1117676
/,Ul;.\jl ,U.tOW .\f'f'ROXIMA n':LV J WEEKS 81:10RI (Oi'HACf/."iG VOI;R ,\ rrOMNltY so ritA r II.iSHIt
_
IVII.L IIAVE ,\!.L 0' ritE ,... J;C1'05ARY lfORMAnON fRO:", Till r.OIiRr ro .\SSIST YOU WITII YOUR CASE.
DANT HE .\'POINTED A tEeAL DEFENDER 'ro
I r IS IIUEBY ORDf.REO rII.\ r TIfI .\80VE_NAMED DEFr..
MEPRUENT 1IIM/IiE R IN .\,V ,\ND ,\LL PROCIEDINCS ON TillS t.\rn:R IN 'ruE RLO MUNICIPAL COURT.
IT [S fURTIIER OROF-RED nlATT1I1 DEFE1'IIDANT COMI"UTC A flN"NCM.L INQUIJU' AI"'UCATION AND
fAr BE RQUIREDTO P,\ Y FEU FOR R[PRUt. T"TION 8Y Till: UG.\L DEFloDER. fins ORDER WILL
'tt
RE. .\JN IN FrECT fOR SIX IONTlfS fROM TODAY', OATI_ IN rilE EVli'llT TRAT TllfS ORDER r.xPlRU.
U "CI.\L I:'4QUIRY .\P.lIC.\TION FOR RECON!iIDJ:RA no.....
rifF. DEFlNnA:U .\lIl5r seBMIT .\/'11 !lpn,ur.D Fll .
."
I' ruE D[Io'[....O.\.....T 11.\5 W"ITNf.SSES filAr IIt1SIfE WOULD tll(E ro 11-" VI WIT:"I' IIIF'1 PRFtjF.NT.
.
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om f) I IX[ TO r"n''\ nT[ flUE'''C ,,, ;11""', c , '; ' I I I ' IIf . ,." , r n "r 1 II" r 'I r til'\. 1I
,
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.
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i" "e)':: i i Ii It'I Ol! H I' " r. t: 1 \ t It 'I""IC :J
03068
03068
r =
=' l =''=
LEWIS TAITEL
-"
_
=
-
fllAT TilE LEGAL DEFEDER DE RELIEVED fROM 1IIS/lltR ASSIG,
\INT to TIII- .
IT I! IIEREBY
CA.SL
Zi1I101J
LEGAL D,.t.DER APPOINTED; KEITH LOOMI!I N6' DOUBLE R OLVD SUITIE A. RENO. NEVADA a921
PHONE (1'5) S5J..7222
PLIASK AUOW APPROXIMATILY J WElD BEFORI CONTACTING YOUR A tTORNEV SO nlAT 110HI
WILL KAVI A LL 0' nil NlC[s'SARY II't'OR. lATION 'ROM Till caVRTTO ASSIST YOU WITH YOUR CAS[.
\
IT IS
IltllllY OJUJIRID THAT Till ABOV"!"fAMID DlfVfDANT BI APPOINTED A LEGAL DEnNDR TO
Rl,USlNT IIIM1HER II'f ANY AND ALL PROCEEDING! ON TillS MATTER I N nil Rt.O MVtCl'AL COURT.
IT IS FtJRnlER ORDIRID THAT THI DlnNDANT COMPLETI A fiNANCIAL IQUIRY APPLICA nON AND
IAY 81 REQUIRED TO PAY 'US FOR RUR"L
"fTATION n THI tiCAL DEPL""IDI.R. TUISOMDER WILL
REMAIN IN EfFECT FOR S 't MONTIIS ,.OM TODAY'SDATL IN nlE EVENT THAT TJIIS ORDER UPIRt.s.
L
THE DEfIL"(DANT MUST SUBMIT AN UPDATED fiNANCIAL I, QUIRY APPLICATION fOR RECONSID&RATlON.
"(
11 nil DEnNDANT HAS WITNESSIS THAT III'J!HE WOULD LlKI TO HA.VE WITNESSES PRESEl'n'. OR
WOULD LlK& TO DISCUSS TII& DEfENSE 0' HISlH1R CAS&, Till DIJ'ENDANT MVST COl"fTACT 11151111:.
ATTORNEY.
tiCAL DEnNDER A1LiIlVED: PER GRA1"TtD MOTION IlEARING
IT IS IIluav ORDERED TIIAT THE LEGAL DEPENDE. BE RELIEVED FROM illS/HER ASSIGN.\tENT TO TillS
CAJI.
PRUlNT IN COURT rOR THI CITY or RINOI JILL DRAKE fOR Till DEFENSE: ROBERTO PUENTES
lIlIlon
l/lIlOU:
411012012
PR[!IINT IN COURT FOR nlE CITY or RINOI CIIRIITOPIIER HAZLETTSTEVINS FOR nil DEFENSE:
KErrH LOOMIS
LEGAL DEPENDER RELlEVID: KEITH LOOMIS

IT IS HEREBY ORDIRED THAT THE LEGAL DEFINDER BE RELIEVED FROM JlTSIHER ASSIGNMENT TO TillS
CAS&'
PRUINT IN COURT rOR TilE CITY 0' RENal CllRI.!JTopnER HAZLETTSTEVENS 'OR nlE D.I'ENSE: KEITII
LOOMIS
.5III20U
SII/lOU
611111111
611111012
CITY'S EXHIBIT I\fARKID/ADMmIDI U.H180' I EVICTION ORD[A; EXHIBIT 1 FINDINC 01 UCf AND
CONCLUSION or LAW (DOCUMlNT)I IX..I1I81T oJ NOTICE or ENTRY or ORDER (DOCU"INT),

,RUIN'T IN COURT FOR TilE CITY or RIl'tOI CIIRISTOPIIER IIAZLETr-STEVI.NS FOR nlE DEnNSE: PRO
PER
0..... 1: 01.10.01' TRUPASSING
PCN': 1 1'1921
JaiI O.YI:
IIIIJI101 1
0611111012
0611&'1011
SUJP'Cndcd o.:
IUIJIlOIl
PIes.:
WRT.If: :
8
CREDIT FOR JAIL TIME SERYED CIVE:'t.
NOT CVILTY
BINCH TRIAL:
Addition.! Ftc.
UO.ot
Chlr . I : DV. I ;F.!lIV.l Of. ITI'.'.IIIFiliI Sl,IbIOf":
( "E.
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03069
_
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:
Oalance:
ComplC'lCd Dc
FA(lUR.E TO COMPLY wmI mE CONOmONS OF 8AJL AS DESCRIBEC rN nns ORDER WILL RESULT IN TIJE ISSUANCB OP A
FAILURE TO COMPLY WAJUlAN'T OR IMMEDlAn ARREST AND INCARCERATION FOR CON1C.MPT OF COURT ANDIOR BAIL
REVOCATION. FOR FUR.1lfER rNFORMAnON, CONTACT rnE SENTENCE COMPlIANCE WrNOOW LOCATED ON nm FIRST
FLOOR OF ruE RNO MUNIClPALCOURT. ONE soum SIERltA ST. RENO. NY {n$} U(.229O.
rnE DEFENDANT SHALL APPEAR AS ORDERED fOR ALL R.,VlEW5 A."lD SKALL COOPERATE F\JLLY Wlnl lllE
BAILIffWARSHALS AND ALL COURT STAFF.
nrE OEFENDA1'(f SHALL ATTEND ALL RVTEWS. COURT APPEARANCES AND COURT.oRDERED PROGRAMS ON TIME AND
ALCOHOL AND ORUO FREB.
nlE DEFENDAl'n' SHALL KNOW HT$/HER COURT DATE AND MAINTAIN CONTACT wlrn "ISIlIER AlTORNEY.
PRIOR TO CHANGfNO HISIHER ADDRESS OR PHONE NUMBER. THE DEfENDANT SHALL NOTIFIV 111 COURT OF SUCH
CHANGE.
OBEY AU. LAWS.
0510112012 ADDmo
NAL CASE rNFORMAnON: NO MOTIONS WILL BB NOT ACCEPTED BY FAX FROM' DEFENDANT OR CITY
AneRNEY. ALL PRE TRIAL MOTIONS MUST DE FILED 1$ DAYS PRIOR TO TRlAL DATE OF 6-II-T2 IN PERSQN BY ALL
PARTID.
05lOtnOlJ ADDmONAL CASE INFORMATION: PROCEEDINGS NO LONOER SUSPENDED. DEFENSE ATTORREY TO OBTAIN
WRm'EN ORDER FROM DIS1'RICT COURT FINDlNO DEFENDANT COMPETENT PRIOR TO TRIAL DATE
05JIOIlOTJ MISC NOTES:
IN THE SECOND JUDICIAL DISTRlCT COURT OF ntE STATE OF NEVADA rN AND FOR 11IE COIMrV OF WASHOE
ORDER TRANSFERRINO lURJSOICTION TO MENTAL HEAL:rn COURT ON CASE RCR 201 1..()61$16 TRESPASSrNO AFTER
wt\RNfNO 510NED BY romCE OF THE PEACE PETER 1. 50001
Oll05l2011 MISC N0TE5: SENDINO MOTIO!", UP TO [)'2 VIA SLACK FOLDER. nus IS HIS 2ND REQUEST FOR SAME MonON
TODAY.
0411012012 ADOmONAL CASE INFORMAnON: PROCEEDfN09 SUSPENDED UNTIL COMPEttNCY EYAL HAS BEEN COMPLETED
TN DISTRICT COURT MAlTER
0310511011 Mise NOTES: D1 HAS FILE. SENDING .
rF:N::i:UP:::TO=D:iE:PT=V:I::A:OLA=C::K:F:;O::":iD=E=R.=====
THE HONOllA8U
DATI:
roDGE'S SIGNATURE:
AI . condldOCI oIrelHH Itom custody (bail, bond or own recopizanc:.) and punuanl to NRS I7SA .... lh. defendant mUll slID chi.
Jocument be(
ora belna releued from custody. By lignin, below. 1M derendant promises 10 appear at .11 limes and plac o,dORd by
Ih. Court. by '/IIIY orth;, d(Kumenc.
01, defendant il ordertd by th. C..,ul1 to .Itlpear in Cuurl ilcohol and ,Jr!11 free or will he subjeci
ift filrli:ifl.ue ..,{h..il .U\d Nun.n1 wi!! he inun.! rur the Jcr
cnJanfl
!o ,UTest ft)r cllntemp' u( CQu(1. Flilure to .ppear in coun will rCJui1
IITtsC.
.-\n)' vioiJtion ofthis instolnt order mlly result
;"flU
ift contempt proccdinll' anJ the lilins of addilion.1 crimi al !;hOllln.

n
1ft :accordance with
11.010. if Is. misdemeanor ( lI'Iy penon 10 (

or
Olil, rel\l,. or nedcC1 10 comply with Ihe lerml or3111 order iuued by tho
Mwtlcip.1 Court ludge.
Thil order \11'/11 r(m3in in effect uncil the Coult iuucs anolher order ,upervdinJ it.
Tl1i. order ill0 .1( ompilJ1Y a receipt of bail posled, which
shalt b. used 10 1Ilis/'y.11l)' line or cost: imposed by the CoW1. Upoo

JJjudicOlioll oflhis (.nc, any (;u)) bail posted will be applied 10 oUIlranJinl finn Jnd/or feCI and .my IUlety hOl'ub will be exonerated
'Inlu.the juJg. orden otherwis.
-------
" '"
- --
;1011:
... It. 'H r
".. I .( '
03070
03070
".- ~ "'.'~--"-''''''''---~ --------''''''----'''''- .
___
Q;
A~y cnfortemtnt O n " h "

,."'f'Q;;;
ic:w- .:.nl .,ho ''''': - 10 boliev. Ihac the Jllfendllf1t h3S "'., .,"yC"==============
AnY Ilaw '-:, " '
-. -n! m otTIur who houcr._ c"'"' '~----------""'h
o"
I
ausl
.IY ..:ondition !)f thi' urder is urdcrcd IQ ,':
.lITes! himlher.
_
_ _ DAn,,_____
I UNDERSTAND AND PROMlS TO OBEY TillS ORDER. OEFENDA:"'fTI
-=
--: =-
--:
-=-
_
_
_
_
_
_
_
_
_
_
_
TI ...,
DAT!'_____ TI...,
,
I. nlE SWORN lNTPR&TER JlAV FULLY INTERPRETED Till! ORDER TO nle

DU'l/'tDA/'IIT,
DAT.E:______ TIME:
RECEIVD BYDEPUTY:
'rlM&:
ISSUED BY MARSKAL:
"
DATE:
DATIE:
TIII:
'I"
f "I r " . "
' . ' . .
- t-,,i fT: \ , f-i
'-. j ,
: )1 1
_ _ __
_
_
_
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___
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___
__
11 ,
. . ,.-;-, : 1
'.f '
-,
03071
03071
..
--- _.-_ .,
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---.--.--'--.--~-
-,
-------------- --------------------. --------~
-- -_ _
. ---
.')
EXHIBIT 2
F. X I I I 11 IT
03072
_ ... .\
03072
- -
..
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.
,
-..-. . . -.-.. -.... --.. - --. .
- ...- .
.
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- -
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FIlE0
Electronically
08-272012: 10:10:50 AM
Joey Orduna Hasting_
elm of lhe Court

Transaction , 3176051
2
3
4
5
IN THE SECOND JUDIClAI. DI5TRICT COURT OF THE STATE OF NEVADA
9
10
ZACHARY SAKER COUGHlIN,
11
Case No.:
Appellan
12
13
14
15
vs.
Dept. No.:
10
CITY OF RENO, a munldpal

corporation,
Respondent.
16
CR12-1262
17
O D RG NU GR S N NT' M O TODIS
R E RA N E PO DE S OD N
MISSAPP A
EL
18
Presently before the COUrt, Is a Motion to Dismiss Appeal flied by Respondent cm
19
20
OF RENO ,Respondent") on July 31, 2012. following, on August 14, 2012, Respondent
.
21
med a Request tor StJbmlsslon, thereby submlttlng the matter for the Court', conslderatlon.
22
On August 15, 2012, Appellant ZAOiARY BAKER COUGHUN ,Appellant") med an
23
Opposition to Motion to Dlsmfss.
24
On _be< 13, 2011, Appellant was charged witIJ Trespassing under Reno
25
Municipal Code, SectIon 8.10.010 by WdY of Criminal Complaint upon arrest. On June 18,
26
2012, Appeftant was found guilty ot trespassing by the Honorable WIlliam Gardner of lI1e
27
Reno Municipal Court. On July 18, 2012. Appellant med a Notice of Appeal In this matter.
28
1 .
il
- - - . -------
03073
03073
.'
1
2
..
Respondent flies this Instant MoHon to Dismiss Appeal based on Appellanrs unHmely
flilng pur;uant to NRS 189.010. NRS 189.010 establishes the Hme within which an appeal
from a Municipal Court must be flied. In relevant part, NRS 189.010 states that a
Defendant In a criminal action bied before a jusHee of the peace may appeal from the flnal
judgment therein to the dlsbict court.
at any Hme within 10 days from the Hmo of the
rendiHon of the judgment
After considering the paper; and pleadings on flIe herein, this Court has determined
that Appellant would have to have flied his Appeal on or before June 28, 2012. Appellant
did not flle his NoHee of Appeal unHI July 18, 2012, alter the deadline had passed.
10
Aooordingly, Respondent's moHon Is granted.
11
NOW, THEREFORE, IT IS HEREBY ORDERED that Respondent's MoHon to
12
DismiSS Is GRANTED.
13
14
DATED this
IS
dif
("
16
17
Disbict Judge
18
19
20
21
22
23
24
25
16
27
28
1
. .!.
03074
03074
. .---..._ ...--._---_._- ..-
-.
-.-- ---
3
4
5
6
7
8
- -_._--
C BD
E flCA EO M LI G
T f AI N
1
2
. -
I hereby certify that I electronically ftled the fon!golng with the aerie of the Court by
using the ECF system which served the followtng parties electronically:
ZACHARY COUGHUN, ESQ. for ZAQtARY COUGHUN
(}iRIS HAZlETT-STCVEN5, ESQ. for CITY OF RENO

JIll. DRAKE for CITY OF RENO
DATED this
day or August. 2012.
&J-
HEIDI HOW
Judicial Assistant
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
l6
27
28
. J----- ---_..
--
03075
03075
1
2
CF.RTIFIC,HE O F SERVIC
E
The undersigned hereby ccrtitics that a. true and correct copy of the f
oregoing PETITION
Punuant to SCR I t I was deposited in the United States Mail at Reno, Nevada. postage f
ully pre-
paid thereon for certified and first class mail addressed to the f
ollowing:
Reno. NY 89505
Post Ollicc Box
3961
DA rED this Ith day of Oclober. 2012.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
lS ' I
II
03076
03076
An unpublish
order shall not arded 8S precedent and shall nt beVd as Jagal authority. SCR 123.
IN THE MATfER OF DISCIPLINE OF

ZACHARY B. COUGHLIN, ESQ., BAR
NO. 9473.
No. 60838
FILeD
JUN U 7 201l
Bar counsel for the State Bar of Nevada has med a petition
pursuant
SCR
1 1 1 seeking an order from this court temporarily
suspending attorney Zachary B. Coughlin, Bar Number 9473, from the

practice of law and referring him for disciplinary proceedings.
The
petition alleges that on September 9, 2011, Coughlin shoplifted a eandy

bar and oough drops from a WalMart storc.
It is supported by
documentation indicating that on November 30, 2011, in the Municip,l

Court of the City of Reno. Coughlin was found guilty, f
ollowing a bench.
trial. of one count of petit larcenyltheft in violation of Reno Municipal
Code 8.10.040.
He was ordered to pay $400 in [

mes and f
ees.
Coughlin
appealed his conviction to the Second Judicial District Court. and on
March 15, 2012, the judgment was affirmed.l
. lThe petition does not indicate whether Coughlin informed bar
counsel of the conviction .Bs required by SCR 1 11(2).
/ -/7176
. ..
03077
03077
___ _
_
__ E " '
_
,_ _
'
_ '_
_ ._
d
_
_ ___.___ _ _ _ ._.._
_
_ _. ..,_ _ _
__
_
__
.
_
___ _ _ _-..-....
"
Pursuant to SCR 1 1 1 , temporary suspension and referral to

the appropriate disciplinary board are mandatory when an attorney has
been convicted of a "serious" crime, which includes theft. SCR 1 1 1 (6)-(8).
Accordingly,
pursuant to SCR
1 1 1(8),
we refer this matter to the
appropriate disciplinary board for the institution of a formal hearing

before a hearing panel in which the sale issue to be determined shall be
the extent of the discipline to be imposed. Furthermore, pursuant to SCR
1 1 1(7), we hereby temporarily suspend attorney Zachary B. Coughlin from

the practice of law in Nevada, pending final disposition of the disciplinary
proceedings.
It is so ORDERED,'
.cu
SaItta
Pickering
J.
Hardesty
cc;
J,
<
J,
J. Thomas Susich, Chair, Northern Nevada Disciplinary Board
David A Clark, Bar Counsel
Kimberly K. Farmer, Executive Director, State Bar of Nevada

Zachary B. Coughlin
Perry Thompson, Admissions Office, United States Supreme Court
2'J'his order constitutes our final :disposition of this matter.
Should
there be any f
urther proceedings regarding Coughlin, they shall be
docketed as a new matter.
..
".
2
' ., . . "
03078
03078
._.------------_.__._------_ . ._ ---_
- . - -.------

OFFICE OF THE CLERK
IN THE MADER OF DISCIPLINE OF

ZACHARY B COUGHLIN, ESQ., BAR NO.
.
Supreme Court No. 60838
9473.
RP
-!=I\!Cr,
"-'l-
<: ;L.. ,"
RECEIPT FOR DOCUMENTS
TO:
Zachary B. Coughlin
State Bar of NevadaiRenolPatrick O. King, Ass!. Bar Counsel
STAT: BAf Of NEvADA

RENO CFFiC
You are hereby notified that the Cieri< of the Supreme Court has received andlor filed
the following:
051101201 2
Filing fee waived: Bar discipline matter.
05/10/2012
Filed Petition of Bar Counsel for Temporary Suspension from the

Practice of Law pursuant to SCR 1 1 1 .
DATE: May 1 0, 2012

Tracie Lindeman, Clerk of Court
Ie
03079
03079
--- --_..._-----
------------_ ... _---
_
- -_._-- - _ .
.
- - - -- - -
_--- ----
I
1
2
3
4

In Re: Matter of
)
)
ZACHARY B. COUGHLIN. ESQ_ )
N vada Bar No. 9473 )
e
Case No.
FILED
"" /J----= 4
0:..:::5 o
""f._
_
_
_
_
1'IAY 1 0 ZOlZ
..-'f"":L
tRW
LQZGii
CIA
6
7
8
In accordance with the requirements set forth in Supreme Court Rule ("SCR") 111 (4).
the State Bar of Nevada, by and through its Bar Counsel, David A. Clark, hereby notifies the
10
Supreme Court of the conviction of attorney ZACHARY B_ COUGHLIN Nevada Bar No. 9473.
11
after a trial and an appeal on a charge of larceny (theft.)
12
13
STATEMENT OF FACTS
Mr. Coughlin is a member of the State Bar of Nevada. Hi. Bar Number is 9473. Mr.
14
Coughlin was admitted to the Bar on March 25. 2005_ Hi. date of birth i. September 27. 1976.
15
and he is 36 yea", old.
16
17
18
Mr. Coughlin was recently convicted of a crime involving theft. On November 30, 2011,
Mr. Coughlin was found guilty, after a trial, of the offense of Petit Larceny, a violation of RMC
8.1 0.040. in Municipal Court for the City of Reno. Se8 Exhibit 1 .
On September 9, 2011, Mr. Coughlin had shoplifted a candy bar and cough drops from
19
20
21
22
23
24
25
a Wal-Mart store wh a value of approximately f

ourteen dollars ($14.00). Mr. Coughlin
appealed the judgment of conviction. The judgment of conviction was affirmed on appeal. Sae
Exhibit 2.
As evidenced by the documentation submitted herein, Respondent has been convicted
of a crime
I
an attorn
"'9geri. ili..-"
-0
..,
ing requirements of Bar Counsel under SCR 1 1 1 (4).
additi",.: 'SQR 1311'(7) and 8). state that upon receipt of a petition demonstrating that
Ci'lO!d-Olf a serious crime, the Court shall enter an order suspending
h<HelJeen.eonvII
.
: :t
.
, ' ..
03080
03080
---- - - -,
_.
,,...- _._- ,_. .

..
,
-
,----_._-,------
the attorney. pending the final disposition of a disciplinary proceeding, in which the sole issue
to be determined shall be the extent of Ihe discipline to be imposed,
3
4
5
6
7
8
9
10
11
As evidenced by the documentation submitted herein, Mr. Coughlin has been convicted
of a misdemeanor crime under the Nevada Revised Statutes.
for "theft."
However, that conviction was
The following language, as set forth in SCR 1 1 1 (6), dictates Ihal Respondent's
crime constitutes a serious crime:

Definition of "serious crime. to The term "serious crime" means ( 1 ) a felony and (2)
any crime less than a felony a necessary element of which is, s determined by
the statutory or common-law definition of the crime, improper conduct as an
attorney, interference with the administration of justice, false swearing.
misrepresentation, fraud. willful failure to file an income tax return, deceit, bribery,
extortion, misappropriation, theft, or an attempt or a conspiracy or solicitation of
another to commit a -sertous crime." [Emphasis added.]
CONCLUSION
12
13
WHEREFORE, Bar Counsel respectfully brings this mailer to the Court's allention and
14
requests that the Court enter an Order temporarily suspending Respondent from the practice
15
of law and referring this matter to the Northern Nevada Disciplinary Board for further
16
disciplinary proceedings, in acoordance with SCR 1 1 1(7) and (8).
17
18
day of May, 2012. .

STATE BAR OF NEVADA
19
20
21
22
23
r
BY
.
n::;
.,.
Patrick o. King, Assl

nl Bar Counsel
Nevada Bar No. 5035
9456 Double R Blvd . , Ste. B
Reno, NV 89521
;b;;d =-.:
'== 'S'
o
24
25
03081
03081
.
_..._----. '--'-'-----_._._...._.._-- --.._----.--.---.-----..
"
.
-----_ ._-" _..
--
Exhibit
03082
03082
..
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.==
==
.
- -------....... -_... -
'-"

ONE SOUTH SIERRA STREET, RENO, NV 8950!
Mailinl: P.O. BOlli 1900. Reno, NY 89!O!i
PHONE (115)3J.4..1290 FAX (775)334-3824
VI.
DEFENDANT: COUGHLIN, ZACHARY
CourtCuc#: 1 1 CR 21176 %I
DOB: 09127/19'76
Agenty#: RSICPI ICI 10627
9

- -
".
"
'
" I
Starus: OPEN
Ac.cidentU:
"
. '
Booking#: 159S3
"\'t f :1
'.
'l f I. (.
'
1 . , ; ' 1 .. .
ARRAIGNMENT HEARING
JUOOE OAAONER
JUOOE HOWARD
BENCHTRJAL
JUDGE HOWARD
9J9nOll
"
1: .'?,'J 1 (1I1 '

I
.
I : , :. ,
"
MOl'\, Oct 10, 201 1
BENCHTRlAL
'
..
Lanauage: ENCLISH
Mon No' '4 2011

WnI.NOl'lO,lOIJ
1:00pm
1:00
ARJlAlONMENT KEARINO HELD
CONTINUEDBY COlIRT
1:00pm
BENCH TRIAL HELD
' fll l j i !, .' , . i i ." .' : - 1 -:f

===-- f . ' , ' " . , . . } ' . " t "'ll , '
- -
- -
fORMAL COMFLAINT FILED WITH nlE COURT
10I101l011
TIlE DEFENDANT APPEARED, WAS EXPLUNED "ISllfER RIGHTS BY Till: JUDGE AND INDICATED THAT
HfJSHf. UNDERSTOOD THEM COMPLETELY.
1 1/J(lIlOJ I
CITY'S EXHIBIT MARKED/ADMITTED I ,
111J0Jl01 1
PRESENT I N COURT FOR THE CITY 0' RENO: PAM ROBERTS AND FOR TilE DEFENSE: PRO PIER
Jail Days:
Offense Dt
stDt:
1l1JOl2011
09109/101 I
Pl ea
:
Suspended Days:
091091l011
GUILTY
V
GU 'LT
-

== ==
==
==

-- - - - - - .
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"
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'
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fine SublOlII:
Ch
e I:
Fee ( HEM,DV,GF,HlV.LDf,lTP,WTlT) Subtotal:
'.
'
J6O,oo
360.00
"
40,00
Supervision Fcc Subtoo:.:
....00
SO
Sup" Fec{.) Due:
Oe(ud...t lrtitlab:
.....
"".00
,\dditional fees
Altftcylf: ICII0611
Prirtt 0.1.:
II/JOIllB I
COURTedtIf: Ile lll" ll

R
0.1. D.le: I I/J0I201 I
PI.e l or J
03083
03083
--
----
----
--
------ --
-- - _
=l!i'Cl
,ENTENCE COMPLIANCE
WINDOW IS LOCATED ON THE fIRST FLOOR OF THE RENO MUNICIPAL
COURT, ONE SOlJllJ SIERRA ST, RENO, NY enS) 3342290.
Or red Dt:
de
Next proorDt:
B.ranc:e:
""
ON TIME AND ALCOHOlJDRUG

HOURS
COMPLY WITH ALL
AND PAY
OR S35
11I1I.I NO
UNIT,
..d
to 8:0a.m (Salurd.,,)
Next ProorOt:
Balance:
ComplCled Dt:
FAILURE TO COMPLY WITH mE CONDmONS OF BAIL AS DESCRlBED IN THIS ORDER WILL RESULT IN TIlE ISSUANCE OF A
FAILURE TO COMPLY WARRANTOR lMMEOIArn ARREST AND INCARCERATION FOR CONTEMPT OF COURT ANDJOR BAIL
REVOCATION. FOR FURTHER INFORMAnON, CONTACT THE SEl'ITENCE COMPLIANCE WINDOW LOCATED ON THE FIRST
FLOOR OF mE RENO MUNICIPAL COURT, ONE SOUTH SIERRA ST, RENO, NV (71'> 3342290.
11iE DEFENDANT SHALL APPEAR AS ORDERED fOR ALL REVIEWS AND Sf-W..L COOPERATE FULLY WITH THE
BAlLIFFSIM"ARSHALS AND ALL CQURT STAfF.
TIlE DEFENDANT SHALL ATrEND ALL REVIEWS, COURT APPEARANCES AND COURr.oRDERED PROGRAMS ON TIME AND
ALCOHOL ANODRUG FRE
ruE DEFENDANT SHALL KNOW HISlJiER COURT DATE AND MAINTAIN CONT
ACT WlTII H1S1HER ATTORNEY.
PRIOR TO CHANGING HTSIHER ADDRESS OR PHONE NUMBER. TIlE DEFENDANT SHALL NOTIFfY TIlE COURT OF SUCH
CHANGE.
Next PToofOt:
Balance:
DANT:C
OUGHLIN,
ZACHARY BARKE
R
""
03084
A,,"crt: ICI I0621

Pri., D.te: II1Jnnlt
03084
- ---------
----._------_
-------_. ------------
..-
.-
St:.rnENCE COMPLIANCE WINDOW

THE DEFENDANT SHALL REPORT 1M c lA , I..Y. OR UPON RELEASE FROM JAIL. TO
FOR ORIENTATION AND THEREAFTER AS OFTEN AS DIRECTED BY TIlE RENO MUNICIPAL COURTMARSHAL DIVISION.
FAILURE TO 00 SO WILL RESULT IN THE ISSUANCE OF A FAILURE TO COMPLY WARRAI'IT AND lNCARCERATION fOR
CONTEMPT OF COURT. mE SENTENCE COMPLIANCE WINDOW IS LOCATED ON THE FIRST FLOOR OF THE RENO MUNICIPAL
COURT. ONE soum SIERRA ST, RENO, NV (77S) 334229a.
THE DEFENDANT SHALL APPEAR AS ORDERED FOR ALL REVIEWS AND SHALL COOPERATE FULLY WITII THE
BAILlFFSIMARSHALS AND ALL COURT STAFf.
THE DEFENDANT SHALL ATTEND ALL REVIEWS, COURT APPEARANCES AND COURTORDERED PROGRAMS ON TIME AND
PRIOR TO CHANGING HISIHER ADDRESS OR PHONE NUMBER, THE DEFENDANT SHALL NOT1FIY nlE COURT OF SUCH
CHANGE.
OBEY ALL LAWS.
1111..11011 ADOmONAL CASE INFORMATION: J city witnesses had (or bent:h trial
1111411011 ADDITIONAL CASE INFORMATION: DEFENDANT WAS IN CUSTODY AT TIME AND DATE OF BENCH TRIAL;
DEFENDANT WAS TRANSPORTED BUTNOT BROUGHT INTO COURT
1111411011 ADDmONAL CASE INFORMATION: BAIL FORFEITURE CANCELLED

lllJOIlOll
ADDITIONAL CASE INFORMATION: CITY REST ITS CASE; DEFENSE BEGfNS HIS CASE, 6::1:1
IIIJMOII ADDITIONAL CASE INFORMATION: DEFENDANT REFUSED TO STATE WlmTIlER OR NOT HE WOULD BE TESTIFIED;
1113MOII ADDITIONAL CASE INFORMATION: CLOSING BY BOTH PARTIES
1011011011 ADDITIONAL CASE fNFORMATION: DEFENDANT DID NOT WANT A COURT APPOINTED ATTORNEY.
THE HONORABLE
JUDGE'S SIGNATURE:
e
J-()
DATE:
I\\I\
i
You are ordered by the Court to arrve dru&laIcohol free and on time for all Coun hearings and Court related progams. Failure to
appear in Coun will result in the issuance of a WalTlllU for your arrest. Any violation ofthi! instant order may result in contempt
ail,
proceedings and the filing of additional criminal charges. In accordance with NRS 11.010. it is a misdemeanor for any person 10 f
refuse or neglect to comply with the lenns ofany order issued by the Municipal Court Judge. This order w
in eff t un l the
Coutt issues anotherorder supersedingil.
I
X'
UNDIRSTANDAND PROMIS!: TO OBEY THIS ORDER. DEFENDAI'n'
-p .
,o.
J..,
I, TilE SWORN INTPRETER HAVE FULLY INTERPRETED THIS ORDER TO TilE
DATE:>S- .
DEFENDANT:
TIM E:
DATE:
RECEIVED BY DEPUTY:
rl
/ .:\. 1/,h..... "j 3D
_E,
DATF.:
I ISSUED 8Y ....
IARSltAL;
TIME:
DATE:
,
DEfENDANT. eOVGHLlN, ZACHARY BARKER
A'tnylf.
O(
endlnl Inilials:
Print DII.:
ICII061,
I I/JOIlOI I
:{
TIME:
COURT
Dill ().t: I IIlO/1Dl I
CASE If. I J eR 111 ,6 1 I

PI'll or J
03085
03085
_ -_._- --- ..
- --------_
.
._ _... . .__..
---~---------- . ~
Exhibit 2
03086
03086
..
- _ __
...... .
_
.
,
,... ----. ..'..... .
.
-
.
'
....... - -
--,-.----.----.-
.
.
- -- --_ .
_-- - --
FILED
EJectronicaUy
03-15-2012:06:21:48 PM
Joey Orduna Hastlngs
Clerk of the Court
!nsaction # 2829785
1
2
3
1
5
IN n-tE SECOND JUDICIAL DISTRICT COURT OF lliE STATE OF NEVADA
ZACHARY BAKER COUGHLIN,
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case No.:
Appellant,
vs.
CRl1-2061
Dept. No.:
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CTTY OF RENO, a munldpal corporation,

Respondent.
II--------I
O D R F R I G U N O T e e OM N CI
R E A fI MN R LI G F H R N
U I PALC U
O RT
Presently before the Court Is an Appeal from a ruling ot the Reno MunJclpal COurt,
nled by Appellant ZACHARY BAKER COUGHLIN (hereafter "Appellant) on December 23,
201 1 . FollOWing, on February 7, 2012, Appellant flied his Opening Brtef on Appeal.
Thereafter, on February 23, 2012, Respondent CITY OF RENO (hereinafter "Respondent")
nled Its Answering Brief. The matter Is now before the COurt for Its consideration.
This matter comes before the Court on a criminal appeal from the Reno Municipal
Court. On November 30, 2011, Appellant was convicted of Petit Larceny, a vlolaHon of
RMC 8.10.010. Thereafter, on December 13, 2011, Appellant flied a NoHce of Appeal with
the Court.
AlthOlJ9h Appeflant's arguments on appeal are undear, Appellant raises a wide
variety of issues, Including, inter all.J: that he was dented his Sixth Amendment Right to
Counsel, that the Murnclpal Court erred In failing to grant him a continuance, that the
prosecution engaged In misconduct, that he was refused an opportunity to testify on his
, h.,.,.. &enIfy I" .. a 'lUI and COWed COAl 0If me Of

!he rGOOnit of IIIe RM) MunIeipaI Court. R W
uhoe
N....sa, III'Id ItIaI 1M Cleric 01 !he Cm t. th C(Js1odiM
e
1 .lIII ""
"lrlgln_ /OWlOtd
!o"'a"'I;;;;"'
o;.;:
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03087
03087
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own behalf, that certain evidence should have been suppressed pursuant to the Foo
rth
Amendment of the United States Constitution, that his conviction Is not supported by
suflldent evidence, and that "[f]urther Impropetles and due process deftdendes"
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occurred.
Unfortunately, Appellant neither supports his arguments with relevant authority nor
dtatlons to relevant portions of the record. Most Importantly, Appellant has failed to
provide this Court with a copy of the trapt of releva nt proceedings In the Reno
[aJppellant has the ultima
Munldpal Court. The Nevada Supreme Cou has held that an
responsibility to provtde this court with 'portions of the record essenUal to determination of
"
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Issues raised In appellanrs appeal: " 71Iomu v Stale, 120 Nev. 37 n. 4, B3 P.3d BIB
.
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(2004) ( dlf NAAP 30(bX3). Further, NRAP 28(e) provides that "[eJvery assertion In
ng
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IS
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IB
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briefs regarding matters In the record shall be supported by a reference to the page of the
transcript or appendbc where the matter relied on Is to be found."
While Appellant did provide this Court with a Compact Disc containing a recording of
the Munldpal Court proceedings, Appellant did not cite to the portions of the Compact Disc
that he felt supported his arguments, and It Is not the responsibility of this Court to guess
which portions of the Compact Disc might support Appellant's arguments. In short,
Appellant did not soUsfy his responsibility to supply and die 10 relevant portions of the
record merely by producing a Compact Disc recording of the entire Munldpal Court
proceeding.
In light at Appdlant's failure to provide this Court with an adequate appellate
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record, and Appellant's correspondent failure to cite to such a record, this COurt is unable
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to conduct a meaningful review or Appell.nrs appeal Thus, Appellant has railed to meet
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III
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11/
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03088
03088

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hiS burden In providing an adequate appellate rll(Ord, and this COurt must affirm the ruling
of the Reno Munldpal Court. 1
NOW, THER!FORE, IT IS HEREBY ORDERED that the ruling of the Reno
Municipal COurt Is AFFIRMED.
Munldpal COurt for all further proceedings.
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IT IS FURTHER ORDERED that this matter Is remanded back to the Reno
DATED
thls K
dav of March,
2012.
#
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P. EWO'TT
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DIstrict Judge
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]
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11 I_ Is worth notfnQ_ pursuant to NRS 4.410(2), -CtJhe fe@$ for transcripts and Cot munlda* court
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that,
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proceedings] must be paid by the party ordering them. In a eMl case the preparation Of the tnlnsafpt need
not convnenc:e until the fees kave been deposlt.t with the dty derll of the court,- Accordlngty, NRS
189.03Q, which requires the municipal court to transmJ( varIOUs papers to the dl5trk:t CDlIrt upon appeal, does
not require action untO such fees have been paid. Here, it appears that AppeI&ant never p.Id the requisite
fees to secvre the transo1ptlon of the proceedings. For thll reason, the appellate record Is Incomplete.
. J.
03089
03089
C R I !OFM I N
mCAI
AU G
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I hereby certify that I eJectronlca lly nled the foregoing with the Qer1< of the Court by
using the ECF system Which selVed the ro/lowlng parties electronically:
ZACHARY COUGHUN, ESQ. for ZACHARY COUGHUN
PAMELA ROBERTS, ESQ. for ClTV OF RENO
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DATED this
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daY d Ma
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E I HO
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Judicial Assistant
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.4-
03090
03090
,. Artk:loto.:
No

P.O.Box 3961
Reno NV 89505
PS Fonn 381 1 . Februa!y 2004
7010 27aO 0 0 0 3 5 4 2 9 6 7 5 2
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03091
UNITE) STATES POSTAL s'O NV
;:.t-'
0(1.: .'1'1AY aClL2; ,pr-! <2 !..
Sender. Please print your name, address, and ZIP+4 In this box
STATE BAR O F N EVADA

9456 Double R Blvd., See. B
no, W 89521-59n
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J
STATE OF NEVADA
COUNTY OF WASHOE
) ss:
)
The undersigned hereby certifies that a true and correct copy of the attached Petition of
Bar Counsel (or Temporary Suspension f

rom the Practice of law Pursuant to SCR 1 1 1 was
deposited in the United States Mail at Reno, Nevada, postage fully pre-paid thereon for first
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class certified mail, addressed to:

P.O.Box 3961
Reno NV 89505
"
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Certified Mail:
7010 2780 0003 5429 6752
Dated this 3"' day of May, 2012
IS
ra Peters, An Employee
of the State Bar of Nevada
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Subscribed and sworn before me

this 3"' day of May, 2012
OJ
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Notary
blie in and for
County and State.
U S PostJi SerVice
CERT IFI E D M A I L RECE IPT
(Oom[!SI/C MiJll Only No I,, IfIn, 'OVI (I.) - I'ro
,
.:i
r AS";
OF F I C li L' 'U' ;E'l
oi l
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(1'>,,;,h(,n
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May 3,
2012
Clerk of the Supreme Court

201 S. Carson St., Suite 201
Carson City, NV 89701
Re:
In re: MaHer of Zachary 8. Couglin, Esq.
Dear Sir or Madam:
600 F.... Charl.non A/Yd.

l.. VtJ: NV III04IS6.1
...
rI-< 702...)12.2200
wll " IUIO.254.2:''fJ
".702JHU878
..
'l-tS6 l)oubk II. Blvd Ste K
.
R.no. NV 1192JSm
r-h,... n5_\2AIOO
, nS.12.On2
Br",m.b"r:'"I
Enclosed please find the original and three (3) copies of the Petition of
Counsel for Temporary Suspension f
rom the Practice of law Pursuant to SCR
1 1 1 for filing in the above-referenced maHer. Kindly return a file-stamped copy to
this office using the self-addressed, stamped envelope.
cooperation.
Thank you for your
Sincerely,
Laura Peters
Paralegal
Enclosed
03094
03094

11 7 12 0204 62337 Bates 2701 To 3,094 Formal Hearing File SBN v. Zachary B. Coughlin SBN Violates SCR 105 (2) (C) With Index Link

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..

Thursday, April 19, 2012 2:35 PM

FW: CORRECTION CHANGE OF ADDRESS ATIORNEY ZACH COUGHUN, ESQ.

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

say "nevermind" .1 am sorry to have had to change my address so much recently, I

know it is probably more work for the Bar.

Nevada Bar No: 9473

That is what we have Zach

From: Zach Coughlin [mailto:zachcoughlin@hotmail.coml

courttech@washoecourtS.YSi joey.hastings@washoecoyrts.ys; joey.orduna@washoecourts.us;

correspondence I made a misstatement based upon my misreading of SCR

Please allow me to correct that. My preferred mailing address and my

SCR 79 address shoula"Oe the same, as listed dire

Zach Coughlin, Esq.

As for any alternate mailing address, please change that to:

Zach Coughlin, Esq.

945 W. 12th St.

I will attempt to make these changes myself at the "portal" found at

fax: 949 667 7402; ZachCoughlin@hotmail.com

Nevada Bar No: 9473

27, 2012 11:19 AM

Update and a Request

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

Sent: Friday, April 27,2012 12:13 AM

I was never afforded an informal meeting or an opportunity to view the materials

submitted in conjunction with the various grievances or other types of complaints

I given a deadline to respond for any such matters outside the

I have had a a legitimate chance to explore them. I

A screening panel of the No

You wanted to know how I learned of or

my request, pursuant to my investigation.

Pat rick King

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

To: Patrick Kingi David Clarki Glenn Machado

Dear Bar Counsel,

on that 3/16/12 letter from

review and inspection the supporting documents and audio recordings."

Y-lO days to tohe processing time.

rocess such a request, but it will add

"iat option given mailign a letter to

9th St. #2.

Zach Coughlin <zachcoughlin@hotmail.com>

Dear Bar Counsel,

months. Below, please find some updates on my progress.

Zach Coughlin, Esq.

Geof and Judge McGee,

Judge McGee, sorry I missed the Thursday group last week.

"I'tt care and mental health

ervices in May of 2009. At both times I was out of my antidepressant,

Wel lbutrin . I n May of }t)09 there was somethi ng l

\,MittJ a degree i n journal ism that I contributed

lots of money a nd sweat to. . . )

am having trouble following this.

to:' geofgiles@hotmail.com; judgemcgee@msn.com; judgemcgee@aol.com; keith@leelawoffice.net; coe@gbis.com

"rent escrow" deposit of $2,300 bein

ZachCoughlin, Esq., PO BOX 3961, RENO, NV, 89505, tel:

775 338 8118, fax: 949 66

ZachCoughlin@hotmail.com Nevada Bar No: 9473

Yom Judge Kosach

FW: lach Coughlin

Sent: Thursday, May 10, 20125:23 PM

To: Patrick King

picture of exactly who Zach Coughlin is.