12 10 12 065630 Ex 1 1651 Motion To Recuse Conflict Out Continuance BZ Tagged

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formal written grievance against Skau, Young, Leslie, Dogan, etc. FW: 911 calls missing from what was produced by City
Attorney Skau
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 12/04/12 2:07 PM
To: HomerJ@reno.gov (homerj@reno.gov); skauc@reno.gov (skauc@reno.gov); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); complaints@nvbar.org (complaints@nvbar.org);
patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org (davidc@nvbar.org); je@eloreno.com (je@eloreno.com); skent@skentlaw.com (skent@skentlaw.com); cvellis@bhfs.com
(cvellis@bhfs.com); mike@tahoelawyer.com (mike@tahoelawyer.com); eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net); rosec@nvbar.org
(rosec@nvbar.org); laurap@nvbar.org (laurap@nvbar.org); philp@nvbar.org (philp@nvbar.org); glennm@nvbar.org (glennm@nvbar.org); fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com); tsusich@nvdetr.org (tsusich@nvdetr.org); schornsby@nvdetr.org (schornsby@nvdetr.org); bdogan@washoecounty.us
(bdogan@washoecounty.us); jleslie@washoecounty.us (jleslie@washoecounty.us)
12 attachments
CR11-2064-2676094 (Opposition to Motion to Dismiss CR11-2064-2676094.pdf).pdf (167.7 KB) , 11 7 12 subpoenas 063341 gricela alvarez and hassett proof of service or waivers.pdf
(10.4 MB) , CR11-2064 MOTION FOR EXTENSION OF TIME (Mtn for Extension of Time).pdf (132.1 KB) , CR11-2064-2655401 (Mtn to Dismiss ...).pdf (117.4 KB) , CR11-20642676094 (Exhibit 2).pdf (133.6 KB) , CR11-2064-2676094 (Exhibit 3).pdf (48.0 KB) , 111912coughlin4.wmv (298.2 KB) , 111912coughlin6.wmv (3.6 MB) , 11 27 12 11 29 12 and 12 3 12
emails to psferrazza@washoecounty.us and zyoung@da.washoecountys.us in response to Order to submit materials regarding Leslie's ineffective assistance 063341 0204.htm (245.1 KB) ,
11 8 12 Homer email and 11 9 12 Skau email 063341 0204.htm (121.3 KB) , 6 7 12 60838 Order temporarily suspended Coughlin's law license scr 111 0204 12-17976.pdf (198.3 KB) , 12 1
30 notice that laura peters affidavit of 10 9 12 is whopper chocked 0204 with index to exhibits needs attachment.pdf (327.9 KB)
Dear Office of Bar Counsel,

This is a formal grievance against City Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and DDA Zach Young.
A portion of a recent email from City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341

From:
Sent:
To:
Cc:
Creighton C. Skau (skauc@reno.gov)

Fri 11/09/12 11:45 AM
zachcoughlin@hotmail.com
Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,

Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly,
authorized service has already been effected.
Since you claim you cannot open the pdf attachments to my secretary's last email, I offer alternatives:
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion.
Unfortunately, I cannot replicate the attachments. However, they consisted mostly of documents you purportedly served, so
you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set
forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th
St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently
not there. Today, Reno Carson Messanger Service again attempted to serve you there at around 11:00 a.m. They called my
office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me
with a photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that
file:///R|/1%20a%20NEW%20temp/12%204%2012%20063341%20formal%20written%20grievance%20against%20dda%20young%20city%20attorney%20skau%20wcpd%20dogan%20and%20leslie%200204.htm[12/10/2012 4:18:43 PM]
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address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick
up at our Office, third floor of City Hall.
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However, they consisted
mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted to
serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a photograph
of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall...."
But, a listen to around the 9:25 am mark on the audio transcript form the RJC Javs recording of the 11/8/12 hearing in rcr2011-063341 reveals Mr. Skau fraudulently procurred Couglin's attendance at
the 11/13/12 Hearing (and considering 11/12/12 was a holiday, Skau would have been prevented from effecting contstructive service prior to the 11/13/12 hearing date set...This prejudiced not only
Coughlin's formal disciplinary hearing but also the petty larceny trial of 11/19 and 11/20 and is a straight scum bag move by Creig Skau.
Judge Sferrazza granted Coughlin a waiver of witness fees for subpoenas and subpoena duces tecums at the 48 minute mark of the second wmv file from the JAVS audio transwcript of the 10/22/12
Hearing in RCR2012-063341.
Regardless, City Attorney Skau not only doesn't know who Jeremy Bosler, Esq. is, but he cites to a JCRCP 45 to challenge a subpoena in a criminal misdemeanor case and he fails to inform the court
of the waiver of service signed by an individual who indicated she had authority to do so, Gricela Alvarez (whom, somehow, Judge Sferrazza was apparently aware of and had opinions on....curiously).
Speaking of scum bag moves, there's is Jim Leslie jumping in at the 9:06 am mark on the 11/20/12 javs recording 112012coughlin1 for rcr2011-063341 (really, everything Jim Leslie did in this case or
any other in "representing" Coughlin is hall of fame sleazy) "I can jump in as stand by counsel if you feels he is dragging his feet, your honor...He's wasting county assets."...Really, Jim, this is a
grievance against you for seeking to coerce a waiver of Coughlin's fifth amendment rights incident to your refusal to utilize any of the exculpatory media Coughlin provided you at either the Supression
Hearing or the Trial..and a greivance against DDA Young for similarly coercing a waiver of Coughlin's Fifth Amendment rights (you really need to listent to the last file for 11/19 and the first for 11/20
to get an idea of the hysterics DDA Young engages in, getting Coughlin taken into custody, wherein the RJC Bailiffs asked if they could keep Coughlin's laptops over night...but there is some really bad
audio on there with Judge Sferrazza and DDA Young getting completely coercive with respect to a waiver of Coughlin's Fifth Amendment rights and "you can't put on anything else or any evidence,
YOU NEED TO TESTIFY!" and Young "you Honor, it was my understanding that you let mr. Coughlin out of custody on the condition that he testify! If he won't do it TAKE HIM BACK INTO
CUSTODY!"
add to the grievance against young the fraudulent testimony and argument he put on where he knows or should have know that the rpd duralde did not receive any reports from dispatch of "a possible
fight" where Duralde had left his vehicle and the text screen therein prior to the 11:27:11 pm text from dispatch, and therefore, such allegations of a report from dispatch of "a possible fight" did not
bare on Duralde's probable cause/reasonable suspicion analysis. further young put on perured testimony by Zarate about how Zarate "personally eye witnessed Coughlin receiving the phone" when
Young was provide a video wherein Zarate admits he only inferred that. Oh, and Coughlin hereby swears he never received any such 11/7/12 motion, faxed or otherwise from Dogan or his assitant
Tibbals or anyone with the WCPD.
And then there is Jim Leslie failing to make a hearsay objection when DDA Young asks Officer Duralde what some unnamed bystanders told him upon arriving...yet, every bit of video evidence and or
testimony that Coughlin sought to have Leslie introduce regarding Nicole Watson admitting to hearing "the man with the six pack" threaten to throw the iPhone "in the river if someone doesn't claim it
right now" was continually excluded as "hearsay"....
A recent email to Judge Sferrazza and DDA Young (which Judge Sferrazza ordered Coughlin to send him):
Dear Judge Sferrazza and DDA Young,

This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial directed to my issues with Mr.
Leslie's representation (I am too tired to fully set those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young on
this just because it seems like the right thing to do).
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SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot receive
from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Perhaps one of my biggest complaints about the ineffective assistance of counsel by Mr. Leslie (and to a much, much lesser extent that of Mr. Goodnight) relates to Leslie's failure to utilize any of the
work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and Rosa could not have received the dispatch text of 11:27:11 pm
reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could "hear" on the
Dispatch recordings (and those provided by City Attorney Skau provide a basis for mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is suspiciously devoid of anything for
the 6 minutes in which the detaining and arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena which required production
of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main justification for the pat down
and search incident to arrest and led to a justification for not excluding anything "discerned incident to the pat down"...the only problem is is that Duralde and Rosa already are marked as on the scene
by 11:26:00 pm, and therefore could not have read the text screens in their vehicles to recieved the text only 11:27:11 pm dispatch entry about "someone just socked a minor". Further, the extent to
which Coughlin's 911 call is not reported accurately at all further underscores the unfairness of depriving Coughlin the right to cross examine Duralde and the dispatchers.
A review of the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to Judge Sferrazza ordering him to produce in
response to my subpoena duces tecum to Kelley Odom and ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct. Two
of the 911 calls are missing. There is no audio of any RPD-ECOMM/Dispatch communications between the 11:28:17 pm mark and the 11:36:27 pm
mark...which is disturbing, considering the RPD and Ecomm did not know I was filming/recording the arrest. Had I not captured a recording of the
arrest, how little would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many things revealed by the arrest recording
contradict what Officer Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further, where Zarate does not
allege to have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on 8/29/12 does testify to seeing the phone light up
in Coughlin's pocket...but wait...yeah, that's it...he saw it light up from all the way across the skate park...but wait...come November 19th, 2012 he changes
his story and decides he saw it light up from "2 to 3 feet away from Coughlin"....There a movie floating around somewhere out there that does a timeline
of all these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to sworn testimony by these witnesses...etc.
And one problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5, wherein Young writes: "In the instant case, the
pat-down search of the Defendant was proper under the totality of the circumstances. Prior to arriving, Officer Duralde learned that the scene involved a
loud disturbance with possible fight, thereby immediately raising the concern of weapons and the safety of all those present." And, of course, Officer
Duralde responded splendidly to Coach Young's, er, DDA Young's training regime and sang the "possible fight...report from dispatch of a possible fight"
tune all the live long day...which was the basis for the reasonable suspicion for the pat-down (and Judge Sferrazza did change his Suppression Motion
Ruling at the Trial somewhat...altering it to make less obvious the extent to which Young was repeatedly allowed to enter hearsay into the record, both in
the Suppression Motion Hearing and at Trial, whereas Coughin never could get that darn Nicole Watson admitting to hearing the "man with a six pack
threaten to throw the iPhone into the river" capture on video and audio recordings into the record...despite Duralde testifying to a multitude of double
hearsay (and not even capture on a recording so close in time to the arrest and at the very same location, involving the majority of the players in the arrest
itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed on"
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date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more specific, particularized facts in
support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney whom dared to answer one of the officer's questions by asking a question
seeking clarification as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the
Officer's did not receive the text from dispatch reporting Goble's second 911 call wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year old
Austin Lichty (who is captured on the video of the moments(file named: VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to
RPD rcr.3gp 46 seconds in length) lying in asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition to Goodnights 2/14/12 Motion to Suppress, both
Goble, Lichty, and Zarate all have motivations apparent which preclude them from being deemed "reliable citizen witnesses" and Officer Duralde indeed did have, and admitted to in his testimony
at trial to being aware of, the "gross inconsistencies" Goodnight pointed out between the hearsay and double hearsay Duralde testified to at trial after "refreshing his recollection" upon a review of
either his "Supplemental Declaration" (an attachment to the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the question....how was it not misconduct by the
State and prejudicial to the point of declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to (the password for the phone)...and when Goble alleges Duralde gave him back the
phone...and the call into the iPhone at 11:33 pm from Officer Duralde's phone...and the call from the iPhone b
Perhaps the worst thing for the State and the RPD here is that two hostile witnesses (in addition to Coughlin's various statements related thereto, during his
testimony and on the media admitted into evidence) testified that RPD Officer Duralde committed misconduct by lying about the purported order or
point in time in relation to the arrest and search of Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralde
removed the phone from Coughlin's pocket and that Duralde had the phone with him when he first presented to Goble to ask question related to the phone
and to verify ownership of the phone (which would include gathering the phone number for the iPhone, which necessarily would mean that Duralde's
allegation of only searching Coughlin after performing some call to the iPhone and hearsaying it vibrate (even though multiple witness (Templeton,
Zarate, Goble, Lichty testified that they heard no such buzzing or vibrating of the phone, hostile witnesses all) Goble testified that Duralde already had
the iPhone prior to Goble conferring with Duralde or otherwise giving Duralde any phone number to call in an attempt to verify the phone revealing an
incoming call LED display scree light up alert (Goble's statements that the phone would "light up" and that he, as Duralde quotes him in the Narrative,
"could not hear the phone
I have 30 days from the date of conviction to report a conviction to the State Bar of Nevada and the United States Patent and Trademark Office (USPTO)
for these two convictions "possessing or receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
I note that WCPD Jim Leslie, while still attorney of record for me on this cases RCR2011-063341, had served (see attached) a subpoena on ECOMM and
Kelley Odom on 10/03/12. Given that Mr. Leslie was not relieved as my counsel until at the earliest 10/22/12 (so Judge Sferrazza's contention that
Coughlin "has had forever to get his defense ready in this case" and that "no continuance will be granted on account of the formal disciplinary hearing
before the State Bar of Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-063341 (and despite Judge Sferrazza
indicated some canon preventing him from testifying at the formal disciplinary proceeding...that didn't stop 063341 being specifically pled in the SBN
NG12-0204 SCR 105 Complaint in SBN v. Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial Secretary Lori
Townsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the SBN Coughlin's
2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally released them o October
30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a defense in his formal
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disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of the hearing on 11/14/12
after service of the Complaint and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and SCR 105(4)...But the point is,
if the RJC and both of you want to be associate with a Schaeffer style Mirch-ing, then this may be your chance. But you won't be able to say you
didn't have plenty of opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure to turn over anything
to me in the "hand off transmittal" he insisted upon (despite a digital transmission being required per the Order of Judge Sferrazza, I believe) requires
some explanation.
So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faith attempt to comply with Judge Sferrazza
ordering him to comply with the subpoena duces tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events surround it of
8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin Lichty's cellular phone, 775 233 8593, which
Goble is seen in the attached still frame picture culled from a video Coughlin took of the moments prior to the arrival of the RPD, being handed by the
"man with the gauged ears" Lichty referred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton testifying that they do not know that man and did
not know him prior to that night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they gather the identify of the
"man with the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having attacked him and attempting to
steal his bike and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge were "unsubstantiated"). Oddly, in
the attached still frame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty that Goble utilized to make his two 911
calls that evening, the first (if the file name time stamping on the ECOMM recordings is accurate...) taking place beginning at 11:22:52 pm (though the
ECOMM text logs reveal an E911 entry of 11:23:36 pm (its unknown whether the exact time a 911 call comes in is designated on the "Calls for Service
Inquiry Response" Coughlin was provided recently). The EComm text logs reveals a second E911 entry for the 775 233 8593 number (belonging to
Austin Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking my law license away from me for at least 5 years, if
not forever....and DDA Young...over some alleged "skater sets his iPhone down on the concrete in the middle of the ice rink plaza downtown on 8/20/11
at 11:20 pm ish in Reno, "man with a six pack of beer" picks it up, offers it up, receiving no response threatens to "throw it in the river if someone
doesn't claim it immediately" whereupon Goble's friend Nate Zarate apparently (according to RPD Duralde's Narrative of unknown origin date") told
Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in his Narrative)
contain
the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on him" one can hear Officer Duralde
indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in the video Coughlin filmed of the arrest, title:
Then, Officer Rosa is proven to be on the bridge and not in his squad car reading texts from dispatch n the following time stamped file: "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396
on the other end"
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Further, Officer Duralde's arrival on the scene is notated in the dispatch log at the
Its not at all clear why Goodnight only apparently received then forwarded to his client on November 30th, 2011 the "Original Supplemental" containing Officer Duralde's Narrative, that is still of indeterminate date of origin (there are a number of "date of
printing" variations...).
That I know of, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc of phone susps os left on post lighting up in sups pock RP screaming at susp
2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone just socked a minor, waive that cop down 10 10 with open line
3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call from phone with open line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD arriving (and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm mark as indicated by the Ecomm
recordings and dispatch logs...
1. VID_20110820_232413 your all on tape now goble and friends.3gp 8 seconds long
2. VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds
3. VID_20110820_232801 officer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records for the iPhone reveal only four calls occurred in or out during the relevant time frame:
Goble's AT&T records:

44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
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Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..." Previous to that, DDA Young had successfully kept every single witness from specifically
identifying who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps his fingers "Oh, that's Colton" 8 feet
from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seek admission of the misconduct of a prosecution witness....Goble, batterying Coughlin with a lit cigarette, that
Coughlin capture on tape, on June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later by a 3
Justice Panel (including Justice Hardesty, whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you look at the
circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 for Paul Elcano, and had a Trial before
Judge Linda Gardner in a divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty of research beforehand...I just had some issues printing it out and bringing it with me (my
legal assistant couldn't figure that out...WLS took 6 weeks to cut a check for subpoena fees....the usual)...
Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence exclusively hearsay testimony (often unattributed to anyone in particular) to support his win on the "sufficient probable cause to support a search incident to arrest"
despite NRS 171.136 forbidding such an arrest (where Duralde obviously overcharged the alleged crime as a "felony grand larceny"...even making smug commentary about the "certain benefits of charging this as a felony" and saying "oooh, that's a felony", both
matters that Leslie insisted refraining from getting into while he was attorney of record, and further, despite Coughlin complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail for Duralde) Coughlin was
denied the right to cross examine the arresting officer...which is too bad considering his Narrative alternately claims that Goble told him they
DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing stolen property charge.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation of NRS 205.275, a misdemeanor, in the manner following, to wit:
That the said defendant on or about the 20th day of August, 2011, at Reno Township, within the County of Washoe, State of Nevada, did willfully and unlawfully possess or withhold stolen goods having a value less than Two Hundred Fifty Dollars ($250.00), to
wit: an iPhone, at or near 1 North Center Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, for his own gain or to prevent the true owner from again possessing said property, knowing that the property was obtained by means
of larceny or under such circumstances as should have caused a reasonable man to know that such goods were so obtained.
POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that the property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574. Must allege the good were received from someone other than the defendant: Gaddis, 424 U.S.
544, Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a), (b), and (d) cannot also be convicted of receiving or possessing the robbery
proceeds in violation of 2113(c). Heflin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than plaintiff in error, a...The next assignment of error is that the State failed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show (1)
that the property has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one charged with receiving it has actually received the property stolen or aided in
concealing it; (3) that the receiver knew the property was stolen at the time he received it and (4) that he received the property for his own gain or to prevent the owner from possessing it. (People v.
Piszczek,404 Ill. 465.) Proof of these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186." PEOPLE v. ALLEN.
407 Ill. 596 (1950). 96 N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that if a criminal conviction is to be upheld,
[ 21 Ill. App.3d 980 ]
000012
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394 Ill. 325, 327 (1946)), and must contain the nature and elements of the offense in order that the
defendant may fully prepare a defense and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the
indictment, drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this omission,
creates the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from himself, the fact that
the property received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446, 448-449 (1929); People v.
Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the indictment failed to charge the
offense of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490 (1950).
The judgment is, therefore, reversed....
I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does not
create the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances that
would reasonably induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question (in any
manner whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what may be implied from the clear phrasing of the indictment. At trial it is
not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the offense
of theft under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property soon after a
theft is evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971), 1 Ill.App.3d
860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the necessary elements
of the offense, i.e., that the property was already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition of these words would only be grammatically redundant and mere
surplusage legally.
The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the defendant guilty beyond a reasonable doubt. For this reason I, too, would
reverse the defendant's conviction."
Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in "larceny" and "theft" cases. He erroneously urges that the state failed to meet that
standard under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the time
and place it was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
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SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot receive
from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4 Cal.App.2d 214, 40
P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v. United States,
418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and later acknowledged by the court
to be such when it set aside the receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner of handling the error effectively cured it. The error was not cured
by the setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant guilty of burglary, Count 2, or receiving, Count 3.
Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an essential element of the crime of receiving stolen goods..17. Criminal Law. In prosecution for
receiving stolen goods, where instruction given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner from again possessing
property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession thereof. Comp.
Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for possession of
stolen property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish probable cause that
she had committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
Bernier does not deny having possessed the property; rather, she argues the proof did not show that she knew the property was stolen and that such knowledge cannot be inferred from mere possession.
We agree that mere possession is insufficient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a conviction for possessing stolen property on the ground that the legislature did
not intend to compound the punishment for larceny or robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property. Point v. State,
102 Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that for a charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests with
the
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attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d 607.
Can't join in same proceeding a disbarment and contempt proceeding: Dickerson v. State 179 SW 324.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see Gilman
275 V. Comm 474, 657 SE 2d 474.
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2 378.
triem 929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re Cobb,
838 NE 2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).
26405 and 03628 trespass case:
unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,

Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Iorio, 410 NYS 2d 195
Russell v Kalian, 414 A.2d 462: expired warrant for eviction no good
Leese v Horne, 47 P.2d 316
Burhams, 89 P.3d 629
Between the following two timestamped recordings finally provided by City Attorney Skau (WCPD Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the youths
prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest, incident to the
theft of a purse, and Lelise prefers to spend his time chiming in, unprompted, on the regard, arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet" incident to the
inappropriat placement by Judge Sferrazza of Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to further his stated goal of
avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin, as he, in fact did, deposit a
"rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer action...until rich man's opposing counsel Casey Baker, Esq. coached Judge
Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your Honor..." whereupon Judge Sferrazza . You are to his constituency by remixing is previous order regardless of the extent
to which Coughlin was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they are and where only those aspects of a summary proceeding that in year to the
landlords benefit were adhered to where is all of the procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to bring counterclaims were matters Coughlin was
precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner in which service was affected on November 3 in
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violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same bailiff Plamondon managed to take the filings
Coughlin submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let them in her position well prior to the 5 PM closing of
that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public defender applying good nicely peers
deciding that the night was doing too much to assist Coughlin in defending himself and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy session while Coughlin was in
custody on July Friday, July 13 at approximately 430 man and you good night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial on July 16, 2012 Monday morning
at 9 AM and it was only upon Coughlin arriving and being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's December 19, 2011 file
stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and
through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295, inclusive. 1. Inspect and receive copies or
photograph any written or recorded statements or confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of the State, the existence of which is known or by
the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including those preserved on pocket recording devices, 9-1-1
emergency calls, and any dispatch logs, written or recorded, generated in connection with this case." It is telling the extent to which on the record at that July 16 trial date Washoe County public defender
Jeremy Bosler indicated that Jim Leslie would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And that Leslie would be prepared to try the case by Friday and that the
court could step matter for trial on Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have completed all the trial prep Jim Leslie would be doing on this case by Friday,
and that that would be the case whether or not that evinced any sort of concern for his client, ability to zealously advocate on his client behalf or willingness to do so, or indication that Jim Leslie felt that the
judges of the Reno Justice Court would hold him to a standard of care at all tending to indicate that Mr. Leslie has any skin in this game whatsoever.
Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing disregard for the
rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe County District Attorney's Office and therein secure added boys from local law enforcement District
Attorney's Office and perhaps the Reno justice court itself. Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders office in connection with
February 27, 2012 clandestine status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted whether they they have been sworn prior thereto or not an especially where
Dogan's coworker down the hall civil division deputy Dist. Atty. Mary has been involved throughout the confiscation without a search warrant or court order of any kind (or at least one ever served on Coughlin in
any manner) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the clandestine status conference between Dogan young
on February 27, 2012 in RMC case 11 TR 26800 for which Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling conflict between that traffic citation trial in the Reno Muni
court which stemmed from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30 highest-paid city of Reno employees of and admission to taking
bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest based upon a criminal complaint for trespass find by Richard Hill on
November 13, 2011. That criminal trespass conviction has now become the subject of a Nevada Supreme Court case in 61901 wherein Coughlin detailed the video tape admission by RPD Sargent Marcia Lopez of
the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord client, and a summary eviction matter that judge Sferrazza presided over wherein judge Sferrazza purportedly controlled the
civil division of the Reno justice court to the extent that Coughlin's notice of appeal on December 26 submitted for filing December 26, 2011 was not file stamped by the civil division staff of the Reno justice
court. This impropriety is further problematic where Coughlin had served upon the Reno justice court's custodian of records and she civil clerk Karen Stancil (whom Richard Hill references in his January 12, 2012
letter her grievance against Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against Coughlin to the State Bar of Nevada, which ultimately became one of the three grievances depicted
numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State Bar stamped August 23, 2012 (in addition to the NG 12 0434 grievance by judge Nash Holmes incident
to the February 27, 2012 trial in 11 TR 26800 held in violation of NRS 178.405 by way of NRS 5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being
held with other RMC judges including then Administrativ Judge William Gardner, who refused to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at
Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD
Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor Hill meritless or her partner officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial
arrest on that day in where Lopez also admits none of those individuals or anyone present that day identified themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace about
5 feet high underneath the former home law office wherein Coughlin was found at a time when Coughlin still had not receive back from the Reno justice court the impermissible $2275 rent escrow deposit judge
Sferrazza ordered in violation of Nevada law considering judge Sferrazza's admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was correct and his assertion that the
Reno justice court had no then corollary to Las Vegas justice court rule 44 that may support the secret quote house rules been fact in the civil division of the Reno justice court wherein tenants were in summary
eviction matters were subject to forced rent escrow deposit in violation of justice court rules civil procedure 83 and that the Reno justice court had neither published nor had approved by the Nevada Supreme Court
000016
any sort of corollary to justice court rule Las Vegas rule 44 (JCRLV 44). Further that criminal trespass conviction and the wrongful arrest connected thereto occurred even where the Washoe County Sheriff's office
deputy Machen filed a false affidavit on November 7, 2011 alleging to have personally served Coughlin with both the October 25 Eviction Decision and Order and the October 27th Findings of Fact, Conclusion of
Law, and Order of Summary Eviction (which Casey D. Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the fact
that his sister judge Linda Gardner is listed as the grievant (and him goes to Pat King's awkward assertions that the "Clerk of Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order
sanctioning Coughlin incident to a divorce matter where and he was representing a victim of domestic violence on behalf of our Washoe legal services (a rather interesting approach by former prosecutor judge
Linda Gardner in comparison to the extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice court incident to deputy district attorney Young's repeated malfeasance misconduct
violations stays pending competency or evaluations failure to turn over exculpatory materials failure to propound discovery failure to respond reasonable discovery requests demonstration a retaliatory animus in
conjunction with scattershot three, count them three prosecutions of Coughlin this year for charges which young either amended to in advance implicating Supreme Court Rule (SCR) 111(6) (in 065630 young
amended the criminal complaint from a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the
January 14, 2012 arrest in the matter to a charge that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good faith effort to achieve a plea-bargain and resolve what is a messy case
the city of Reno Police Department and emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-000375 run the rental at which the domestic violence resulted in
Coughlin's calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against
Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false
statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth in alleging that Coughlin had already lost his appeal of
summary eviction matter in 1708 Barber which judge Sferrazza presided and which was then on appeal before judge Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney fee award
against Pro per appellant Coughlin in the appeal of the summary eviction order issued by Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's
office on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty. young fastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom "randomly" was
assigned to Coughlin appeal of the petty larceny conviction of a candy bar and some cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license
incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law where tribal police officers affected a custodial arrest for a misdemeanor
(much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS 171.1255 should especially where Walmarts sole witness testifying at the petty
larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar and some cough
drops in connection with Coughlin's selecting heard just seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact that that Walmart alleges to have
had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and where French you admit that his supervisors had previously
indicated to hand a desire to retaliate against Coughlin in connection with Coughlin's questioning some of Walmarts policies and where John Ellis of the W. 7th St., Walmart in any as yet unknown loss prevention
associate specifically and expressly threatening abuse of process against Coughlin on July 7, 2012 incident to Coughlin pointing out the extent to which Walmarts assistant store managers and customer service
managers many of whom have had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from the policy which Walmart holds out to the
public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy as stated at Walmart.com no matter what the convenient for getting in
misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011 affected a citizen"s arrest of Coughlin on that
date in connection with the alleged petty larceny by Coughlin of a candy bar and some cough drops which conveniently for the Reno Police Department just days after Coughlin filed a written complaint detailing
the police misconduct by Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on August 20, 2011 in 063341 a justice court criminal petty larceny and
receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint throughout American jurisprudence that one cannot be charged with both petty larceny and receiving stolen property of
the same item particularly where the receiving of the item is alleged to have been from oneself after one had larceny is the item lending an inference that Joe Sferrazza seeking to sink his jurisdictional hucksters
deeply into Coughlin's light as possible to affect the leverage over Coughlin to mitigate the liability Reno justice court may face in connection with its numerous since is violating about law respecting the manner in
which evictions are carried out and or the misconduct of local law enforcement and prosecutors in carrying out retaliatory arrest and prosecution of Coughlin where the judiciary in Washoe County is off criticizes
being overly influenced by the District Attorney's Office. That Walmart petty larceny conviction stemmed from a trial before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school of
law whom Coughlin's twice former Reno Municipal Court appointed public defender Keith Loomis (not in the Wal-Mart case, as judge Kenneth Howard denied Coughlin a court appointed defender there despite
his express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin
established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin extends further the extent that he early on in that November 30 trial on it in 2011 reviews Coughlin for causing
the November 14 trial setting to have been continued only to in a 3 min. add-on at the conclusion of the hearing which are trial which judge Howard down such a matter of public concern that he Five city of Reno
employees at the courthouse until nine o'clock at night to get it done that in fact judge Howard admitted he was wrong with respect to the cause of the continuance of the 14th 2012 trial that was not Coughlin fault
that all and where the Reno Municipal Court had previously granted a continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin stemming from Richard G Hill Esquire's
criminal trespass complaint (connected to the summary eviction matter over which judge Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a
continuance in light of Richard G Hill's need to take a six-week vacation beginning early November 2011 and it was that same six-week vacation by Richard G Hill that Hill alleges enabled him to commander the
Reno justice court judge Sferrazza to denying Coughlin a hearing on his motion to contest personal property lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to contest
personal property lien on November 17, 2011 even where is extremely suspect that the justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set the hearing on November
17 as Janice admitted when judge Sferrazza called her is of his own witness at the December 20, 2012 hearing that was finally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be able to
control the justice court in his desired to prevent such a hearing been set until he returned from his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to contest
personal property lien judge Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed to allow
the justice court to setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently without Coughlin's permission serve
Coughlin a violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office for
something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate McGeorge school law along with wash County Dist.
Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whom recently granted 2004 graduate McGeorge school of law deputy district attorney Zach young in order taking
away the ability to file by fax from Coughlin a privilege that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27, 2012 hearing at
which Coughlin's then attorney public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the motion young alleged who filed on November
26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had merely comply with judge
Clifton's request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort whatsoever incident to his quote
representation of Coughlin" in 065630).
000017
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he and
his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at www.nvbar.org)
(former law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed Coughlin's work before him
and in Nevada Bankruptcy Court at Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to the hearing and in violation of Supreme
Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of judge Beesley in any matters relative to the ultimate Supreme Court rule 105 complaint
against Coughlin for over six months at least and so in no way can be said to just stuff I his last-minute supplementing judge Beesley and milquetoast attempts to provide Coughlin S supplemental designation of
witness and summary of evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY at the hearing (both of those gentlemen attended
McGeorge school of law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions disapproving of Coughlin's competency as an attorney at the hearing
despite the fact that neither of them could provide anything in the way of specificity with regard to what issues they would take with any of the work they reviewed of Coughlin's or judge Beesley's case filings in
judge before judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting to note the judge Beesley test by both Coughlin formal
disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating some $755,000 from his clients and using it on hookers and
luxury designer goods. Apparently creditors rights specialist bankruptcy judge Beesley sees competency in Mr. Harris and could overlook the $755,000 for my client where it be $14 worth of candy bars and cough
drops from Coughlin and Coughlin's March 30, 2012 filing in Cadle Co. v. Keller (an adversary proceeding in the NVB wherein Coughlin had a hearing on March 15, 2012 at 2:30 pm in representing Mr. Keller
that was affected by the fraudulently procured order for summary eviction in the Reno justice court RJC Rev2011-000374 that morning obtained by Gail Kern Esquire Brown judge Schroeder of the Reno justice
court wherein the audio record from that proceeding indicates a Reno justice court clerk imploring judge Schroeder to hurriedly move the case summary eviction case against Coughlin through despite Judge
Schroeder admittedly having had a different order of hearing the cases planned for that morning docket and despite the fact that the fax header on the summary eviction order that was hurriedly moved through
indicates a time stamping of a 8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime
shortly after 1 PM that same day, 3/15/12, without announcing themselves as law enforcement and where they entered with their guns and/or pagers drawn in and immediately placed Coughlin in handcuffs and told
him he was detained in contrast to the typical procedures carried out by the Sheriff's office incident to evictions in Washoe County. Incident to that summary eviction (where the docket, at least, more review is
necessary, indicates that Kern and Western Nevada Management's Sue King switched up their basis for an eviction all the sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for
seeking an eviction to one for non-payment of rent (seemingly in response to Coughlin Pre Hearing Brief pointing out the difficulties they would face under Glazer in pursuing a No Cause, particularly against
Coughlin, whom at that point was, again, arguably a commercial tenant, especially where the Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably sublessors to
Coughlin). in the third grievance against Coughlin forming SCR 105 complaint for which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw Coughlin under the bus at Coughlin's 11/14/12
formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy bar
conviction that resulted in the current now 5 month long suspension of Coughlin's license to practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104

Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of SAMANTHA L. HALL,
ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of
Opposition# (2) Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email
to WCSO Haley regarding excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record on appeal# (7) Exhibit 11 TR
26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR 26800 whereby she Order Coughlin's
property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately admitted to
having released to the City of Reno Marshals on 2/28/12, denied having the micro sd card, denied the micro sd ever being booked into property, alleged to have given Judge Sferrazza's former tribal court Bailiff
and former Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the jail at Coughlin's request to get Coughlin's keys so Eastman could arrange for Coughlin's dog Jackson Pawluck to be fed and
cared for during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card confiscating without a warrant/5
000018
day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about the Richard G. Hill, Esq. retaliatory issuance of three traffic citations outside Hill's law office,
where RPD Sargent John Tarter told Coughlin to leave after Coughlin presented upon being released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department officers and
managing caught to get Coughlin subject to custodial trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and Coughlin reporting to Sargent
John Tarter at that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him as he too was on Richard Hill's payroll that
RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer Carter and Sargent Marcia
Lopez refused to undertake any diligent inquiry response to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value of the 121 River rock property for the
month of November that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query Hill with any diligence by both
officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told Coughlin at an April 10, 2012 trial
date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact that at that time he had filed a
grievance with the State Bar of Nevada against Coughlin by way of the NG 12 0434 grievance that his fellow RMC judge Dorothy Nash Holmes filed
Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes confiscating Coughlin's
smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of a search incident to arrest given Coughlin property had been booked into his personal property at
the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily sentencing Coughlin to 5 days in jail for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS 22.100,
but characterizing her Order as finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt statute, which is not summary in nature, and
therefore requires more due process, and despite Judge Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even said what Holme's alleged he did in rendering her
"second bit at the apple" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In Nevada, a Summary Contempt Order under NRS 22.030 (which is civil in
nature) for conduct not committed in the immediate presence of the Court (such as the alleged conduct involving a restroom and disassembling a smart phone or recording device and hiding some component part
thereof in the restroom that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 formal disciplinary hearing, and which she included in the Order she rendered in that traffic
citation case stemming from Coughlin being told to leave Hill's law office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly after being released from a 3 day custodial
arrest stay in jail incident to Hill's criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, the eviction matter presided over by Judge Sferrazza). Like the Order
Judge Linda Gardner claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis FV11-03383 (see attached in Exhibit 1), Judge Sferrazza attempted to characterize the
Order he entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th, 2011 filed stamped Motion to Contest Personal Property Lien as an "Order Resolving Tenant's Motion to
Contest Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was certainly not "agreeing" to anything, nor was he waiving his right to appeal any Order Judge Sferrazza
may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice court bailiffs radius in chief bailiff Sexton as to
the fact that he to quote would like to stick some things up Coughlin's ass" in reference to multiple incidents where Reno justice court bailiffs had either as bailiff arrested told Coughlin that he would put his foot
of Coughlin's ass or made commentary as chief Sexton did to Coughlin respecting Sexton's indication of Coughlin on two different occasions the week of Thanksgiving 2011 that Coughlin indicated that the filing
office and/or not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, 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. Merliss contacted us in approximately
August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that justified his withholding
rent. All of his clahns 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"
One, it is not true for Hill to write "The lease expired in February 2011." The Standard Rental Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in accordance with the
NRS 118A holdover tenant provision. Further, it is not accurate for Hill to write "Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with Coughlin's former co-tenant,
Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment payments to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011 and June
2011 and only sent the landlord Merliss $550 for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in combination with Dr. Merliss's assent to
Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's secretly absconding with
Coughlin's rental contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss). Merliss admitted to assenting to the
repayment plan with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and eviction notices, in violation of NRCP 11)
admitted, under oath, that he had expressly, in writing, assented to an agreement with Coughlin for a rent deduction of $350 going forward in exchange for Coughlin "dealing with the weeds". Coughlin
did "deal with the weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the landlord's landscaper for the other property Merliss owned next door
and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the "$2,000" that Dr. Merliss eventually claimed, under oath, at the 10/25/12
000019
eviction "Trial" that he wound up paying Green Action Lawn Service to "deal with the weeds" at Coughlin's former home law office. "Dealing with the weeds", to Green Action Lawn Service, included
tearing up Coughlin's artificial turf installation leaving Street causing Coughlin's law office substantial losses lost profits time away from work and expenses associated with immediately mitigating the
criminal conduct of green action lawn service where they not only tore up the artificial turf installation even though they knew it was there prior to submitting their bid for services to landlord Merliss,
who apparently did not realize or remember that he had also assented to a $350 rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing with the weeds. Green
action lawn service sought close the artificial turf installation Coughlin put into place of his former law office the week prior to their tearing it up and leaving industry when they were doing the weeds
at the property Merliss owns next-door at 252 Mill St.
Hill's grievance of 1/14/12 to the SBN goes on to allege:
"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 in the basement. He was arrested and is presently facing criminal trespass charges in Reno Municipal Court. See case no. 11 CR 26405 21. He is also facing a
contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That 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 CVl1-o3628, 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 landlord'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 reinitiated 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, 20 11. 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 to resume 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 house. Coughlin called the police, who
arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, finally) can be described thusly:
PHONE CALL Start_Time = Saturday, August 20, 2011 11-22-52 PM Source_ID = 50 Cory Goble's first 911 call from Austin Lichty's 775 378 6673.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-29 PM Source_ID = 43 Duralde saying 153 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-34 PM Source_ID = 46 Rosa saying 396 en route.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-06 PM Source_ID = 13 reporting party advised they are now at first and center.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-25-22 PM Source_ID = 21 probably Duralde saying 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying charles 396 on the other end.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-34 PM Source_ID = 14 unintellible short statement sounds like guilt nexus.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-25 PM Source_ID = 41 probably Duralde saying Reno C153 twenty three.wav
000020
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-27-29 PM Source_ID = 43 probably a dispatcher saying c153.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 Duralde saying Reno C153 I'll be out on him on the Center St. Bridge.wav
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18 Probably a dispatcher saying Charles 153.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-40 AM Source_ID = 17 Dispatcher indicating Reno C153 wagon available for a male.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about 5
minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-21-02 AM Source_ID = 28 odd by somebody c153 seems to split in middle yet still one file.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-03 AM Source_ID = 22 Duralde saying Reno c153 rtf returning.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-10 AM Source_ID = 27 Duralde's wife Dispatch Jessica Duralde c153 10 4 break union 9 to reno.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5 Rosa saying Charles 396.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-31 PM Source_ID = 19 Rosa saying 29 white male.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead
with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
--Forwarded Message Attachment-Print
Close
in compliance with Judge Sferrazza Order of 9/5/12 FW: Zach Coughlin has shared a folder with you
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 11/27/12 8:26 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)
re:rcr2011-063341
I am sending this in compliance with Judge Sferrazza's indication that I should send him materials after the trial the bare on the ineffective assistance of counsel claim and or the coerced waiver
of my Fifth Amendment rights, especially incident to the representation by WCPD Jim Leslie. Please note the email of 11/5/2012 from Court Administrator Mr. Tuttle and the inadvertent
faxing of numerous filings to the wrong fax number by myself.
https://skydrive.live.com/redir?resid=43084638F32F5F28!5141&authkey=!APibWiVXTMSWkw0
000021
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
in compliance with
Judge Sferrazza
Order of 9/5/12
View photos Download all
You are invited to view Zach's album. This album has 43 files.
11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf

4 11 12 063341 RJC Townsend correspondence with SBN 0204 motion for new trial basis.pdf
11 21 12 notice of non service 063341 needs ex 1.pdf
11 21 12 Notice of Irregularities 063341 with ex 1 started revised.pdf
11 30 11 063341 Coughlin_Discovery Received_11.30.11 rotated.pdf
11 16 12 skau grievance materials combined 0204 063341.pdf
11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdf
11 13 12 063341 submission of materials and motion for order dmv and cell records or subpoena.pdf
11 12 12 just 80 pages revised cr11-063341 PRE TRIAL MOTION only pages 1 to 80 just text of motion no exhibits.pdf
2 15 12 rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS compressed pdffactpro more nuance.pdf
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final Motion for Mistrial and Memorandum of Law State v Coughlin rcr2011-063341 - Copy.pdf
pre trial brief state of nevada v coughlin rcr2011-063341 8 29 12 leslie wcpd rpd rjc iphone ocrd and tagged jbig2 lossy.pdf
2 14 12 SBN KING LETTER WITH HILL GRIEVANCE ATTACHED RCR2011-063341 RPD RMC 11 CR 00696 WCSO SUSICH ME.pdf
pre trial brief state of nevada v coughlin rcr2011-063341.pdf
rcr11-063341 notice of appearance coughin file 3 3 2012.pdf
rcr11-063341 affidavit in support of motion to file pre-trail motions late bw - Copy.pdf
11 27 12 complete with ex 1 063341 notice of developments.pdf
11 26 12 0204 Notice of Hill and Baker Malfeasance for Motion for New Disciplinary Hearing or Trial 063341 1708 60331 61383.pdf
6 25 12 Order for Sanctiosn 03628 0204 Flanagan $40K in attorneys fees summary eviction appeal.pdf
10 17 11 email and attached Emergency Motion to Stay, Set Aside, Vacate Eviction Hearing Order to Baker 1708 0204.pdf
From: stuttle@washoecounty.us
To: zachcoughlin@hotmail.com
CC: CWood@washoecounty.us; RBaker@washoecounty.us
Subject: RE: Zach Coughlin has shared a folder with you
Date: Mon, 5 Nov 2012 18:39:02 +0000
Mr. Coughlin:
Reno Justice Court has no record of your attempted filing on 10/18/12. If you choose to pursue this filing action, you will need to bring the documents in because we do not accept filings via email. Any
documents filed with the court will be retained by the court and we will not make copies for you, the DA or PD. Providing the appropriate parties copies of your filing is your responsibility, not the court. You
may also bring in your confirmation of transmission from the 10/18/12 filing attempt and we will retain that receipt as part of the court record. Steve
Steve Tuttle
Court Administrator
Reno Justice Court
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]

Sent: Saturday, November 03, 2012 9:39 PM
To: Tuttle, Steve
Subject: Zach Coughlin has shared a folder with you
Dear Mr. Tuttle,

I perused the file in RCR2011-063341 and noticed that the document I submitted for filing on or about 10 18 12 was not file stamped or even in the file, though I have confirmation of receipt of transmission. Can you
please indicate why it is not appearing in the file and find attached another copy of the exhibit 1 thereto.
https://skydrive.live.com/redir?resid=43084638F32F5F28!3600
000023
Zach has 460 files to share with you on SkyDrive. To view them, click the links below.
102611coughlin2 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy Spencer.wmv
102611coughlin1 CRC 11-063341 Motion Competency Hearing DPD Goodnight and DDA Darcy Spencer.wmv
101211coughlin CRC 11-063341 Competency Evaluation Hearing that got continued.wmv
090512coughlin2 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde.wmv
082712 coughlin2 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082712coughlin3 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
071612coughlin rcr2011-063341 rjc .wmv
082712 coughlin1 plea bargain hearing rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso.wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony - Copy.wmv
082912 coughlin1 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
082912coughlin3 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
000024
090512coughlin1 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde - Copy.wmv
082912 coughlin2 RJC RCR2011-063341 iPhone Trial Leslie Young Bosler rpd rmc wcso Duralde Goble Zarate testimony.wmv
090512coughlin5 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
090512coughlin3 rjc rcr2012-063341 iphone leslie goodnight young rpd rmc wcso duralde 1.wmv
Share your files with
IN COMPLIANE WITH JUDGE SFERRAZZA ORDER REGARDING EMAIL HIM AT CLOSE OF TRIAL AND IN
CASE ANYTHING GOES MISSING AGAIN
Sent: Thu 11/29/12 4:57 PM
stuttle@washoecounty.us (stuttle@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us); psferrazza@washoecounty.us (psferrazza@washoecounty.us);
To:
rjcweb@washoecounty.us (rjcweb@washoecounty.us)
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
11 29 12 063341 MOTION FOR NEW TRIAL FINAL WITH 217 MENTION.pdf
EX1 063341 FINAL.pdf
data-2012-11-24-17-43-52 063341 11 19 12 lichty admits phone did not vibrate.wav
data-2012-11-24-17-44-12.wav
data-2012-11-24-18-40-33.wav
data-2012-11-24-18-40-47.wav
data-2012-11-24-18-43-05.wav
data-2012-11-24-18-45-14.wav
data-2012-11-24-18-49-41.wav
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data-2012-11-24-18-49-41(1).wav
data-2012-11-24-18-53-39.wav
data-2012-11-24-18-53-39(1).wav
data-2012-11-24-19-00-18.wav
data-2012-11-24-19-00-18(1).wav
data-2012-11-24-19-21-24.wav
data-2012-11-24-19-21-24(1).wav
data-2012-11-24-19-26-17.wav
data-2012-11-24-19-31-25.wav
data-2012-11-24-19-37-26.wav
data-2012-11-24-19-40-46.wav
Download all
911 calls missing from what was produced by City Attorney Skau
Sent: Mon 12/03/12 2:53 AM
To: psferrazza@washoecounty.us (psferrazza@washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us)

This correspondence is further in line with Judge Sferrazza's previous instruction to me to send him emails after the trial directed to my issues with Mr.
Leslie's representation (I am too tired to fully set those issues out at this point, but I will to some extent herein at least, and I am copying DDA Young
on this just because it seems like the right thing to do).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot
receive from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both
Perhaps one of my biggest complaints about the ineffective assistance of counsel by Mr. Leslie (and to a much, much lesser extent that of Mr. Goodnight) relates to Leslie's failure to utilize any of
the work I did to prep this case. For instance, Leslie whiffed (perhaps intentionally so) on the extent to which RPD Officer Duralde and Rosa could not have received the dispatch text of
11:27:11 pm reporting Goble's since proven fraudulent "someone just socked a minor" 911 call to Ecomm/Dispatch...so, Officer Duralde and DDA Young are stuck with anything the Officer could
"hear" on the Dispatch recordings (and those provided by City Attorney Skau provide a basis for mistrial where the cd lacks Goble's second 911 call and Coughlin's 911 call and is suspiciously
devoid of anything for the 6 minutes in which the detaining and arrest occurs (and further, DDA Young and the State were served a request for discovery by Goodnight in November and subpoena
which required production of those "dispatch logs or recordings...." Yet DDA failed to. Then he put on testimon and made argument that this "report from dispatch of a possible fight" was the main
justification for the pat down and search incident to arrest and led to a justification for not excluding anything "discerned incident to the pat down"...the only problem is is that Duralde and Rosa
already are marked as on the scene by 11:26:00 pm, and therefore could not have read the text screens in their vehicles to recieved the text only 11:27:11 pm dispatch entry about "someone just
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socked a minor". Further, the extent to which Coughlin's 911 call is not reported accurately at all further underscores the unfairness of depriving Coughlin the right to cross examine Duralde and the
dispatchers.
A review of the Ecomm cd provided by Reno City Attorney Skau, in what I believe was his response to Judge Sferrazza ordering him to produce in
response to my subpoena duces tecum to Kelley Odom and ECOMM (Emergency Dispatch Services) reveals what I believe may be misconduct.
Two of the 911 calls are missing. There is no audio of any RPD-ECOMM/Dispatch communications between the 11:28:17 pm mark and the
11:36:27 pm mark...which is disturbing, considering the RPD and Ecomm did not know I was filming/recording the arrest. Had I not captured a
recording of the arrest, how little would have the dispatch logs, witness testimony, and Ecomm recordings revealed...any how many things revealed by
the arrest recording contradict what Officer Duralde put in his Supplemental Declaration and Narrative and the two witness statements? Further,
where Zarate does not allege to have seen the phone light up to Duralde or in his Witness Statement, come Trial time, Zarate, on 8/29/12 does testify to
seeing the phone light up in Coughlin's pocket...but wait...yeah, that's it...he saw it light up from all the way across the skate park...but wait...come
November 19th, 2012 he changes his story and decides he saw it light up from "2 to 3 feet away from Coughlin"....There a movie floating around
somewhere out there that does a timeline of all these calls, all these videos, superimposes the dispatch logs on the text with quotations and citations to
sworn testimony by these witnesses...etc. And one problem for DDA Young and Duralde is found in the State's 2/21/12 Opposition, on page 5,
wherein Young writes: "In the instant case, the pat-down search of the Defendant was proper under the totality of the circumstances. Prior to
arriving, Officer Duralde learned that the scene involved a loud disturbance with possible fight, thereby immediately raising the concern of weapons
and the safety of all those present." And, of course, Officer Duralde responded splendidly to Coach Young's, er, DDA Young's training regime and
sang the "possible fight...report from dispatch of a possible fight" tune all the live long day...which was the basis for the reasonable suspicion for the
pat-down (and Judge Sferrazza did change his Suppression Motion Ruling at the Trial somewhat...altering it to make less obvious the extent to which
Young was repeatedly allowed to enter hearsay into the record, both in the Suppression Motion Hearing and at Trial, whereas Coughin never could get
that darn Nicole Watson admitting to hearing the "man with a six pack threaten to throw the iPhone into the river" capture on video and audio
recordings into the record...despite Duralde testifying to a multitude of double hearsay (and not even capture on a recording so close in time to the
arrest and at the very same location, involving the majority of the players in the arrest itself...).
It was in the same 11/30/11 email from WCPD Goodnight to Coughlin that included the Narrative by Officer Duralde (which has, in the footer of the 4 page document, a footer indicating a "printed
on" date of 11/28/11
Zarate's testimony respecting the scant statements he actually made to Officer Duralde reveal the extent to which Officer Duralde paints on to witness statement more specific, particularized facts in
support of the objectives he has, which here, were motivate by a retaliatory intent and the "thrill" of "busting" and attorney whom dared to answer one of the officer's questions by asking a question
seeking clarification as to Coughlin's constitutional rights....which clearly is not a permissible basis to support a finding of either "reasonable suspicion" to conduct a "weapons check pat down" (the
Officer's did not receive the text from dispatch reporting Goble's second 911 call wherein he fraudulently alleged that "someone just socked a minor" (referring to the instance where then 18 year
old Austin Lichty (who is captured on the video of the moments(file named: VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt
prior to RPD rcr.3gp 46 seconds in length) lying in asserting that "I'm 17...I'm a minor!", so, contrary to DDA Young's assertion in his 2/21/12 Opposition to Goodnights 2/14/12 Motion to
Suppress, both Goble, Lichty, and Zarate all have motivations apparent which preclude them from being deemed "reliable citizen witnesses" and Officer Duralde indeed did have, and admitted
to in his testimony at trial to being aware of, the "gross inconsistencies" Goodnight pointed out between the hearsay and double hearsay Duralde testified to at trial after "refreshing his
recollection" upon a review of either his "Supplemental Declaration" (an attachment to the probable cause sheet, DDA Young would allege) and or his "Narrative". Which begs the
question....how was it not misconduct by the State and prejudicial to the point of declaring a mistrial or at least not, as Judge Pearson did in a curious recorded hearing on
But here is the biggest problem for the RPD and the State...the screen lock that Goble and Templeton testified to (the password for the phone)...and when Goble alleges Duralde gave him back
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the phone...and the call into the iPhone at 11:33 pm from Officer Duralde's phone...and the call from the iPhone b
Perhaps the worst thing for the State and the RPD here is that two hostile witnesses (in addition to Coughlin's various statements related thereto, during
his testimony and on the media admitted into evidence) testified that RPD Officer Duralde committed misconduct by lying about the purported order
or point in time in relation to the arrest and search of Coughlin and Duralde's first coming into possession of the iPhone. Goble testified that Duralde
removed the phone from Coughlin's pocket and that Duralde had the phone with him when he first presented to Goble to ask question related to the
phone and to verify ownership of the phone (which would include gathering the phone number for the iPhone, which necessarily would mean that
Duralde's allegation of only searching Coughlin after performing some call to the iPhone and hearsaying it vibrate (even though multiple witness
(Templeton, Zarate, Goble, Lichty testified that they heard no such buzzing or vibrating of the phone, hostile witnesses all) Goble testified that
Duralde already had the iPhone prior to Goble conferring with Duralde or otherwise giving Duralde any phone number to call in an attempt to verify
the phone revealing an incoming call LED display scree light up alert (Goble's statements that the phone would "light up" and that he, as Duralde
quotes him in the Narrative, "could not hear the phone
I have 30 days from the date of conviction to report a conviction to the State Bar of Nevada and the United States Patent and Trademark Office
(USPTO) for these two convictions "possessing or receiving stolen property" and "petty larceny" under SCR 111(6) and 37 CFR 11.25(3).
I note that WCPD Jim Leslie, while still attorney of record for me on this cases RCR2011-063341, had served (see attached) a subpoena on ECOMM
and Kelley Odom on 10/03/12. Given that Mr. Leslie was not relieved as my counsel until at the earliest 10/22/12 (so Judge Sferrazza's contention
that Coughlin "has had forever to get his defense ready in this case" and that "no continuance will be granted on account of the formal disciplinary
hearing before the State Bar of Nevada" being scheduled just 5 days prior to the 11/19/12 resumption of trial in rcr2011-063341 (and despite Judge
Sferrazza indicated some canon preventing him from testifying at the formal disciplinary proceeding...that didn't stop 063341 being specifically pled in
the SBN NG12-0204 SCR 105 Complaint in SBN v. Coughlin, as was Judge Clifton's case in RCR2012-065630...and that didn't stop RJC Judicial
Secretary Lori Townsend from sending into the SBN Coughlin's 2/12/12 filing in that Judge Clifton case rcr2012-065630 and offering to send into the
SBN Coughlin's 2/15/12 filing in 063341). Add to that the fact that Coughlin never received from Leslie Goble's call records until Leslie finally
released them o October 30th, 2012...and it really is not accurate to say Coughlin had "forever" to prepare his case. Coughlin had to pull together a
defense in his formal disciplinary hearing before the SBN despite the SBN gipping him out of every aspect of SCR 105(2)(c) (ie, not 30 days notice of
the hearing on 11/14/12 after service of the Complaint and Designation of Witnesses and Summary of Evidence is affected pursuant to SCR 109 and
SCR 105(4)...But the point is, if the RJC and both of you want to be associate with a Schaeffer style Mirch-ing, then this may be your chance.
But you won't be able to say you didn't have plenty of opportunities to put this thing aside, because there are a multitude.
It is my understanding is that ECOMM and Kelley Odom had 15 days to respond to the Subpoena duces tecum....Mr. Leslie's failure to turn over
anything to me in the "hand off transmittal" he insisted upon (despite a digital transmission being required per the Order of Judge Sferrazza, I believe)
requires some explanation.
000028
So to requiring explanation is the fact that the cd provided by Reno City Attorney Skau in an apparent good faith attempt to comply with Judge
Sferrazza ordering him to comply with the subpoena duces tecum and or turn over any relevant dispatch recordings pertinent to the arrest and events
surround it of 8/20/11 leading to rcr2011-063341, does not contain the second 911 call made by Goble (using Austin Lichty's cellular phone, 775 233
8593, which Goble is seen in the attached still frame picture culled from a video Coughlin took of the moments prior to the arrival of the RPD, being
handed by the "man with the gauged ears" Lichty referred to as "Peanut" despite Lichty, Goble, Zarate, and Templeton testifying that they do not know
that man and did not know him prior to that night at all....Coughlin respectfully demanded of the RPD Officers, at the time of his arrest, that they
gather the identify of the "man with the gauged ears", however, Officer Duralde et al refused to (claiming Coughlin's allegations of their having
attacked him and attempting to steal his bike and or dog, reach into his pockets, and push him up against oncoming traffic on the Center Street bridge
were "unsubstantiated"). Oddly, in the attached still frame, it is quite clear that "Peanut" is seen handing Goble the phone belonging to Austin Lichty
that Goble utilized to make his two 911 calls that evening, the first (if the file name time stamping on the ECOMM recordings is accurate...) taking
place beginning at 11:22:52 pm (though the ECOMM text logs reveal an E911 entry of 11:23:36 pm (its unknown whether the exact time a 911 call
comes in is designated on the "Calls for Service Inquiry Response" Coughlin was provided recently). The EComm text logs reveals a second E911
entry for the 775 233 8593 number (belonging to Austin Lichty, but passed to Goble by "Peanut" with the gauged ears...yeah, these are the guys taking
my law license away from me for at least 5 years, if not forever....and DDA Young...over some alleged "skater sets his iPhone down on the concrete in
the middle of the ice rink plaza downtown on 8/20/11 at 11:20 pm ish in Reno, "man with a six pack of beer" picks it up, offers it up, receiving no
response threatens to "throw it in the river if someone doesn't claim it immediately" whereupon Goble's friend Nate Zarate apparently (according to
RPD Duralde's Narrative of unknown origin date") told Goble he saw Coughlin pick it up off the ground (as Duralde recounts hearing from Goble in
his Narrative)
contain
the 911 call by Coughlin
So, in the file named "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-11 PM Source_ID = 17 063341 duralde i'll be out on him" one can hear Officer Duralde
indicating he will "be out on him on the Center Street bridge" after he has left his squad care and is shortly to appear in the video Coughlin filmed of the arrest, title:
Then, Officer Rosa is proven to be on the bridge and not in his squad car reading texts from dispatch n the following time stamped file: "PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-26-30 PM Source_ID = 12 RPD Rosa saying
charles 396 on the other end"
Further, Officer Duralde's arrival on the scene is notated in the dispatch log at the
Its not at all clear why Goodnight only apparently received then forwarded to his client on November 30th, 2011 the "Original Supplemental" containing Officer Duralde's Narrative, that is still of indeterminate date of origin (there are a number of "date of
printing" variations...).
That I know of, there were three 911 calls (two by Goble, one by Coughlin, in that order):
1. 082011 112252pm to 112530pm 911 by Goble dispatch Weese log larc of phone susps os left on post lighting up in sups pock RP screaming at susp
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2. 082011 112620pm to 112740pm 911 by Goble dispatch Montgomery logs rp call back re someone just socked a minor, waive that cop down 10 10 with open line
3. 082011 112645pm to 112752pm 911by Coughlin Dispatch Weese logs call from phone with open line yelling re stealing phone people cheering cops are here then call disconnects
And Coughlin filmed three videos that night of the arrest that are relevant, two just prior to the RPD arriving (and actually, while Rosa and Duralde were already on the scene and out of their vehicles after teh 11:26:00 pm mark as indicated by the
Ecomm recordings and dispatch logs...
1. VID_20110820_232413 your all on tape now goble and friends.3gp 8 seconds long
2. VID_20110820_232423 austin lichty templeton goble zarate chan rpd iphone assaulting and battery Coughlin jusrt prior to RPD rcr.3gp 46 seconds
3. VID_20110820_232801 officer duralde and rosa 8 20 11 arrest.3gp 5 minutes 52 seconds long
And the AT&T call records for the iPhone reveal only four calls occurred in or out during the relevant time frame:
Goble's AT&T records:

44 08/20/11 11: 21P 0:21 17753786673 17755279440 0:00 17755279440
45 08/20/11 11:26P 0:21 17753786673 17755279440 0:00 17755279440
46 08/20/11 11:33P 0:12 17752303726 17755279440 0:00 17755279440
47 08/20/11 11:36P 0:01 17755279440 17752303726 0:00 17752303726
Goble messed up at Trial on 11/19/12 and let slip that "and that's when Tanner called the phone..." Previous to that, DDA Young had successfully kept every single witness from specifically
identifying who made what call and when and where to any extent whatsoever. Nobody could remember nuthin'. But, Goble is a self involved twit, who snaps his fingers "Oh, that's Colton" 8
feet from Judge Sferrazza and swaggers out of the court room. And Leslie refused to seek admission of the misconduct of a prosecution witness....Goble, batterying Coughlin with a lit cigarette,
that Coughlin capture on tape, on June 5th, 2012...and email DA Gammich, DDA Young, and some others about at 11:38 pm on 6/7/12...and had his law license suspended in 60838 four hours later
by a 3 Justice Panel (including Justice Hardesty, whom recused himself from Coughlin's wrongful termination suit against Washoe Legal Services...and you might not like me for that suit, but if you
look at the circumstances of my firing therein (I was hurrying to finish a non-profit gets stuck with the building's private landlord's property taxes appeal due on 3/10/12 for Paul Elcano, and had a
Trial before Judge Linda Gardner in a divorce case on 3/12/12...and the attached materials do demonstrate that I did plenty of research beforehand...I just had some issues printing it out and
bringing it with me (my legal assistant couldn't figure that out...WLS took 6 weeks to cut a check for subpoena fees....the usual)...
Somehow at the Hearing on the Suppression Motion DDA Young was able to get into evidence exclusively hearsay testimony (often unattributed to anyone in particular) to support his win on the "sufficient probable cause to support a search incident to
arrest" despite NRS 171.136 forbidding such an arrest (where Duralde obviously overcharged the alleged crime as a "felony grand larceny"...even making smug commentary about the "certain benefits of charging this as a felony" and saying "oooh, that's a
felony", both matters that Leslie insisted refraining from getting into while he was attorney of record, and further, despite Coughlin complying with NRS 174.345 (even splurging on the return receipt requested to go along with the certified mail for Duralde)
000030
Coughlin was denied the right to cross examine the arresting officer...which is too bad considering his Narrative alternately claims that Goble told him they
DDA Young's complaint fails to alleged someone other than Coughlin stole the property, which it must, to support the receiving or possessing stolen property charge.
COUNT II. POSSESSION OF STOLEN PROPERTY, a violation of NRS 205.275, a misdemeanor, in the manner following, to wit:
That the said defendant on or about the 20th day of August, 2011, at Reno Township, within the County of Washoe, State of Nevada, did willfully and unlawfully possess or withhold stolen goods having a value less than Two Hundred Fifty Dollars ($250.00),
to wit: an iPhone, at or near 1 North Center Street, Reno, Washoe County, Nevada, such property being owned by CORY GOBLE, for his own gain or to prevent the true owner from again possessing said property, knowing that the property was obtained by
means of larceny or under such circumstances as should have caused a reasonable man to know that such goods were so obtained.
POLK v. STATE, 749 S.W.2d 813 (1988): "As previously stated, the State must plead and prove that the property was stolen by another. "
It is: check out West headnotes under Receiving Stolen Property at 324k7(3): Kirby, 19 S. Ct. 574. Must allege the good were received from someone other than the defendant: Gaddis, 424
U.S. 544, Allen , 96 NE 2d 446, Polk, 749 SW 2d 813.
Gaddis, 424 U.S. 544, 96 S.Ct. 1023, 47 L.Ed.2d 222 (1976): " A person convicted of violating 18 U.S.C. 2113(a), (b), and (d) cannot also be convicted of receiving or possessing the
robbery proceeds in violation of 2113(c). Heflin, supra, 358 U.S., at 419-420, 79 S.Ct. 451. Pp. 547-548."
"(2) the State failed to prove beyond a reasonable doubt that the automobile had been stolen by a person other than plaintiff in error, a...The next assignment of error is that the State failed to prove
beyond all reasonable doubt that the automobile in question was stolen by some person other than plaintiff inerror. To sustain a conviction of receiving stolen property the proof must show
(1) that the property has, in fact, been stolen by a person other than the one charged with receiving it; (2) that the one charged with receiving it has actually received the property stolen or
aided in concealing it; (3) that the receiver knew the property was stolen at the time he received it and (4) that he received the property for his own gain or to prevent the owner from possessing it.
(People v. Piszczek,404 Ill. 465.) Proof of these essential elements constituting the crime of receiving stolen property may be made by circumstantial evidence. People v. Ferris, 385 Ill. 186."
PEOPLE v. ALLEN. 407 Ill. 596 (1950). 96 N.E.2d 446.
PEOPLE v. DICKERSON. 21 Ill. App.3d 977 (1974). 316 N.E.2d 519: " It is jurisdictional that if a criminal conviction is to be upheld,
[ 21 Ill. App.3d 980 ]
the indictment must charge a crime (People v. Edge,406 Ill. 490, 494-495 (1950); People v. Harris, 394 Ill. 325, 327 (1946)), and must contain the nature and elements of the offense in order that
the defendant may fully prepare a defense and be afforded the constitutionally intended protection against double jeopardy. (People v. Griffin,36 Ill.2d 430, 432-433 (1967).) In the instant case, the
indictment, drawn upon the conclusional premise that the property was stolen, fails to allege that it was stolen by a person other than the one charged with receiving such property and, by this
omission, creates the presumption that the possessor stole the property himself. Since one person cannot be both the thief and the receiver of stolen property nor receive stolen property from
himself, the fact that the property received was stolen by another was an essential element to be alleged and proved. (People v. Ensor, 310 Ill. 483, 484-485 (1923); People v. Dalke, 336 Ill. 446,
448-449 (1929); People v. Harris, 394 Ill. 325, 329-330 (1946); People v. Devore, 402 Ill. 339, 341-342 (1949); People v. Malone,1 Ill.App.3d 860, 863-864 (1971).) Lacking this element, the
indictment failed to charge the offense of receiving stolen property under section 16-1(d). A conviction under an indictment which does not charge an offense is void. People v. Edge,406 Ill. 490
(1950).
000031
The judgment is, therefore, reversed....

I feel that the majority has misconstrued the efficacy of section 16-1(d) in arriving at a conclusion not urged by the defendant. The omission of the words "stolen by another" in the indictment does
not create the presumption that defendant had himself stolen the property from the owner. The use of the words "* * * knowingly obtain control of stolen property * * * under such circumstances
that would reasonably induce him to believe that the property was stolen * * *" (emphasis added) in the indictment clearly implies that when defendant obtained control of the property in question
(in any manner whatsoever), the property had already been stolen by another. That is the plain and ordinary meaning of the indictment.
I believe the majority may be confusing what can and cannot be reasonably implied from evidence introduced at trial with what may be implied from the clear phrasing of the indictment. At trial it
is not
[ 21 Ill. App.3d 981 ]enough for the prosecution to merely show that the property in question was stolen property and that the defendant was in possession of that property in order to prove the
offense of theft under 16-1(d) (the former offense of receiving stolen property). (People v. Baxa (1972), 50 Ill.2d 111, 277 N.E.2d 876.) The defendant's unexplained possession of stolen property
soon after a theft is evidence that the defendant stole the property himself but is not evidence of defendant's receiving stolen property knowing it to have been stolen. (See People v. Malone (1971),
1 Ill.App.3d 860, 275 N.E.2d 236, and the cases cited therein.) However, the phraseology of the indictment herein permits a reader of the indictment to find, even after only a cursory reading, the
necessary elements of the offense, i.e., that the property was already stolen by another when the defendant received it.
While it may be true that the addition of the words "stolen by another" would make the indictment more explicit, the addition of these words would only be grammatically redundant and mere
surplusage legally.
The indictment, therefore, was sufficient to charge the defendant with an offense under 16-1(d)(1).
After a thorough examination of the record, I do not believe that the evidence produced at trial was sufficient to find the defendant guilty beyond a reasonable doubt. For this reason I, too, would
reverse the defendant's conviction."
Appellant correctly argues that the standard of proving value, for conviction, is the same in "receiving" cases as in "larceny" and "theft" cases. He erroneously urges that the state failed to meet that
standard under our holding in Cleveland v. State, 85 Nev. 635, 461 P.2d 408 (1969), where we said "[t]he true criterion for the value of property taken is the fair market value of the property at the
time and place it was stolen if there be such a standard market." 85 Nev. at 637, 461 P.2d at 409. BAIN v. SHERIFF, CLARK COUNTY 504 P.2d 695 (1972).
SHEPP v. STATE, 484 P.2d 563 (1971): "Count 3 charged Shepp with having received property stolen by him during the commission of the burglary charged in Count 2. Since a thief cannot
receive from himself the fruits of his larceny, the jury must be instructed that it could convict of either burglary or receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4
Cal.App.2d 214, 40 P.2d 870 (Cal. 1935); People v. Morales, 263 Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961);
Thomas v. United States, 418 F.2d 567 (5 Cir.1969); Baker v. United States, 357 F.2d 11 (5 Cir.1966). Such an instruction was requested but the court declined to give it. This was error, and
later acknowledged by the court to be such when it set aside the receiving conviction and ordered a new trial on that charge. The appellate issue is whether that manner of handling the error
effectively cured it. The error was not cured by the setting aside of the receiving conviction since there is no way of knowing whether a properly instructed jury would have found the defendant
000032
guilty of burglary, Count 2, or receiving, Count 3. Milanovich v. United States, supra. Both convictions should have been set aside and a new trial ordered"
State v. Pansey, 61 Nev. 333, 128 P.2d 464 (1942): ". Receiving Stolen Goods. Criminal intent is an essential element of the crime of receiving stolen goods..17. Criminal Law. In prosecution
for receiving stolen goods, where instruction given by court followed language of statute with reference to accused's intention to prevent the [61 Nev. 330, Page 336] owner from again
possessing property, defendant was not entitled to instruction which told jury that goods must have been received with fraudulent intent of depriving owner of the immediate possession
thereof. Comp. Laws, sec. 10335."
BERNIER v. SHERIFF, CLARK COUNTY 569 P.2d 406 (1977) Supreme Court of Nevad: "At the conclusion of a preliminary examination, Henny Bernier was ordered to stand trial for
possession of stolen property, a violation of NRS 205.275.1 Bernier then petitioned for a writ of habeas corpus contending the evidence adduced by the prosecution was insufficient to establish
probable cause that she had committed the charged offense. The district court considered and denied her petition and Bernier here reasserts the same contention.
Bernier does not deny having possessed the property; rather, she argues the proof did not show that she knew the property was stolen and that such knowledge cannot be inferred from mere
possession.
We agree that mere possession is insufficient to establish the requisite knowledge..."
"Under Nevada law, Lane could not be convicted of both robbery and receiving stolen property. This court reversed a conviction for possessing stolen property on the ground that the
legislature did not intend to compound the punishment for larceny or robbery by permitting a conviction for receipt or possession of the stolen property against the person who took the property.
Point v. State, 102 Nev. 143, 146-48, 717 P.2d 38, 40-41 (1986); Lane v. State, 110 Nev. 1156, 881 P.2d 1358 (1994).
State v. Pray, 30 Nev. 206, 94 P. 218 (1908): It is long standing authority that for a charge
of possession of stolen property to stand, there must be a showing of all the elements, and
that if even one element is missing, the charge cannot be maintained. State v. Pray, 30 Nev.
206, 94 P. 218 (1908). Possession of stolen property does not in itself prove guilt of the offense. Staab v. State, 90 Nev. 347, 526 P.2d 338, 341 (1974). Instead, the burden of proof of all three elements rests
with the
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d 607.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order, even though, given the incarceration was served, it is a finally appealable order, see
Gilman 275 V. Comm 474, 657 SE 2d 474.
000033
Bifurcate disciplinary matters: In re Porep (Nev. 1941) 111 P.2d 533. In re Kaemmer, 178 SW 2d 474 Terrell v. Miss. Bar 635 So 2d 1377. Matt of Briggs 502 NE 2d 879 In Re Hines 482 A. 2
378. triem 929 P.2d 634 Smith 85 P. 524 In re Finsh 27 A. 3d 401 In re Character, 950 NE 2 177 Toledo v. Cook 88 NE 2d 973('07) Cohn, 151 SW 3d 477 ('04) In re Crandell, 754 NW 2 501 In re
Cobb, 838 NE 2d 1197 In RE Ginsber 690 NW 2d 539 North Carolina Bar v. Rogers, 596 SE 2d 337 Snyder 792 A. 2d 515 joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d
427 Appeala
Whether Goble had "ownership" in iphone matter 920 P.2d 112
Sheely 102 p.2d 96
Participation in larceny as precluding receiving stolen property charge, 29 alr 5th 59 (1995).

Woods 19 NYS 2d 683
Regan 425 NYS 2d 725
Russell v Kalian, 414 A.2d 462: expired warrant for eviction no good
Leese v Horne, 47 P.2d 316
Between the following two timestamped recordings finally provided by City Attorney Skau (WCPD Jim Leslie is too busy whistling during trail at Coughlin's pointing out how he cautioned the
youths prior to the arrival of the peace to stay peaceful in Coughlin's references the then recent murder of Stephen Gale just blocks away approximately two months prior to the 8/20/11 arrest,
incident to the theft of a purse, and Lelise prefers to spend his time chiming in, unprompted, on the regard, arrogantly enough, that he can assist the court if it feels Coughlin is "draggin' his feet"
incident to the inappropriat placement by Judge Sferrazza of Leslie as "stanby counsel" which really amounted to no more than yet another coercive practice put in place by Judge Sferrazza to
further his stated goal of avenging the criticisms Coughlin levied upon him incident to Judge Sferrazza's incredibly questionable on-the-fly pandering/remixing of his Order of 10/13/11 (if Coughlin,
as he, in fact did, deposit a "rent escrow" of $2,275, Sferrazza ruled and noticed in writing that Coughlin would get a "Trial" on the unlawful detainer action...until rich man's opposing counsel
Casey Baker, Esq. coached Judge Sferrazza on the record that "the use of the term "Trial" was unfortunate, Your Honor..." whereupon Judge Sferrazza . You are to his constituency by remixing is
previous order regardless of the extent to which Coughlin was not noticed thereto with respect to that which would be involved on the October 25, 2011 trial they are and where only those aspects
of a summary proceeding that in year to the landlords benefit were adhered to where is all of the procedural and discovery protections attendant to a plenary unlawful detainer trial and the ability to
bring counterclaims were matters Coughlin was precluded from accessing by judge Sferrazza. Just Rosin is interesting approach to landlord tenant matters continued on with respect to the manner
in which service was affected on November 3 in violation the courthouse sanctuary doctrine by Deputy Plamondon in the Reno justice court civil division filing office no less (and that is the same
bailiff Plamondon managed to take the filings Coughlin submitted online November 15 out of the criminal division filing office of the Reno justice court where Robbin Baker it Mr. Coughlin let
them in her position well prior to the 5 PM closing of that filing office and with DVDs attached to those filings Coughlin swears under penalty of perjury that Ms. Baker admitted this to him
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-28-17 PM Source_ID = 18.mp3
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-36-19 PM Source_ID = 5.mp3
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In RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq (who was removed from representing Coughlin by Jim Leslie and Jeremy Bosler the Washoe County public defender applying good nicely
peers deciding that the night was doing too much to assist Coughlin in defending himself and or otherwise zealously advocating on call Pat good night in Coughlin had a trial prep strategy session while
Coughlin was in custody on July Friday, July 13 at approximately 430 man and you good night reiterating the extent to which he would be appearing on Coughlin's to have to try the case at trial on July 16,
2012 Monday morning at 9 AM and it was only upon Coughlin arriving and being brought to the court in custody seeded Jeremy Bosler was suddenly filling in for Goodnight with and indication Goodnight's
December 19, 2011 file stamp discovery requests served upon the stay and district attorney Zach young reads at page 1 therein: "REQUEST FOR DISCOVERY COMES NOW, the Defendant, ZACHARY
BARKER COUGHLIN, by and through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and hereby requests the following discovery pursuant to NRS 174.235 to NRS 174.295,
inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of
the State, the existence of which is known or by the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including
those preserved on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, written or recorded, generated in connection with this case." It is telling the extent to which on the record at
that July 16 trial date Washoe County public defender Jeremy Bosler indicated that Jim Leslie would immediately be rounding you a replacement role pretty suddenly disappearing Goodnight. And that Leslie
would be prepared to try the case by Friday and that the court could step matter for trial on Friday it is witness. Perhaps what Mr. Bosler meant was that Jim Leslie would, by that Friday, have completed all
the trial prep Jim Leslie would be doing on this case by Friday, and that that would be the case whether or not that evinced any sort of concern for his client, ability to zealously advocate on his client behalf
or willingness to do so, or indication that Jim Leslie felt that the judges of the Reno Justice Court would hold him to a standard of care at all tending to indicate that Mr. Leslie has any skin in this game
whatsoever.
Clearly there is a bases for mistrial here were Jim Leslie's entire contribution to the representation of Mr. Coughlin is dripping in every way with misconduct and malpractice and apparently willing disregard
for the rules of professional conduct an intentional manifestation of Leslie's desire to secure a conviction the Washoe County District Attorney's Office and therein secure added boys from local law
enforcement District Attorney's Office and perhaps the Reno justice court itself. Further Reno Municipal Court judge Nash Holmes's admonition as to communications with the Washoe County public defenders
office in connection with February 27, 2012 clandestine status conference between Biray Dogan and Zach Young which neither Dogan nor Young has ever refuted whether they they have been sworn prior
thereto or not an especially where Dogan's coworker down the hall civil division deputy Dist. Atty. Mary has been involved throughout the confiscation without a search warrant or court order of any kind (or
at least one ever served on Coughlin in any manner) of Coughlin smart phone and micro SD card incident Judy impermissible summary contempt finding by judge Nash Holmes just two hours after the
clandestine status conference between Dogan young on February 27, 2012 in RMC case 11 TR 26800 for which Dogan and Young stipulated to a continuance in 06 RGC 065630 in light of the scheduling
conflict between that traffic citation trial in the Reno Muni court which stemmed from Coughlin's being retaliated against vice RPD Sargent Tarter in connection with Coughlin telling Tarter one of the top 30
highest-paid city of Reno employees of and admission to taking bribes from Richard Hill by RPD officer Chris Carter Junior incident to Carter placing Coughlin in handcuffs pursuant to a custodial arrest
based upon a criminal complaint for trespass find by Richard Hill on November 13, 2011. That criminal trespass conviction has now become the subject of a Nevada Supreme Court case in 61901 wherein
Coughlin detailed the video tape admission by RPD Sargent Marcia Lopez of the misconduct by herself officer Chris Carter, Jr. Richard G. Hill, Esq. and his landlord client, and a summary eviction matter that
judge Sferrazza presided over wherein judge Sferrazza purportedly controlled the civil division of the Reno justice court to the extent that Coughlin's notice of appeal on December 26 submitted for filing
December 26, 2011 was not file stamped by the civil division staff of the Reno justice court. This impropriety is further problematic where Coughlin had served upon the Reno justice court's custodian of
records and she civil clerk Karen Stancil (whom Richard Hill references in his January 12, 2012 letter her grievance against Coughlin to the State Bar of Nevada (see Hill's January 14, 2012 grievance against
Coughlin to the State Bar of Nevada, which ultimately became one of the three grievances depicted numerically in the caption of the SBN v. Zachary Barker Coughlin SCR 105 Complaint filed by the State
Bar stamped August 23, 2012 (in addition to the NG 12 0434 grievance by judge Nash Holmes incident to the February 27, 2012 trial in 11 TR 26800 held in violation of NRS 178.405 by way of NRS
5.071 (RJC and RMC under one roof, Judge Nash Holmes admits to strategy sessions to discredit Coughlin being held with other RMC judges including then Administrativ Judge William Gardner, who refused
to recuse himself from the criminal trespass matter incident to the criminal complaint signed by Richard Hill at Coughlin's former law office upon Coughlin being subject to a custodial arrest by officer Chris
Carter on November 13, 2011, resulting in a criminal trespass conviction of Coughlin in 11 CR 26405 where it RPD Sargent Marcia Lopez ultimately had to admit on videotape to Coughlin that neither she nor
Hill meritless or her partner officer Carter issued caught Coughlin a trespass warning prior to effectuating a custodial arrest on that day in where Lopez also admits none of those individuals or anyone present
that day identified themselves as law enforcement prior to landlord meritless kicking down the door to a crawlspace about 5 feet high underneath the former home law office wherein Coughlin was found at a
time when Coughlin still had not receive back from the Reno justice court the impermissible $2275 rent escrow deposit judge Sferrazza ordered in violation of Nevada law considering judge Sferrazza's
admission that the Reno justice court judges held a meeting wherein they admitted that Coughlin was correct and his assertion that the Reno justice court had no then corollary to Las Vegas justice court rule 44
that may support the secret quote house rules been fact in the civil division of the Reno justice court wherein tenants were in summary eviction matters were subject to forced rent escrow deposit in violation of
justice court rules civil procedure 83 and that the Reno justice court had neither published nor had approved by the Nevada Supreme Court any sort of corollary to justice court rule Las Vegas rule 44 (JCRLV
44). Further that criminal trespass conviction and the wrongful arrest connected thereto occurred even where the Washoe County Sheriff's office deputy Machen filed a false affidavit on November 7, 2011
alleging to have personally served Coughlin with both the October 25 Eviction Decision and Order and the October 27th Findings of Fact, Conclusion of Law, and Order of Summary Eviction (which Casey D.
Baker, Esq. lied about his testimony at the criminal trespass Trial of Coughlin from which Judge William Gardner refused to recuse himself despite the fact that his sister judge Linda Gardner is listed as the
grievant (and him goes to Pat King's awkward assertions that the "Clerk of Court" sent bar counsel Patrick O. King, Esq. Judge Linda Gardner's April 2009 order sanctioning Coughlin incident to a divorce
matter where and he was representing a victim of domestic violence on behalf of our Washoe legal services (a rather interesting approach by former prosecutor judge Linda Gardner in comparison to the
extremely light touch demonstrated by judge Sferrazza and judge Clifton of the Reno justice court incident to deputy district attorney Young's repeated malfeasance misconduct violations stays pending
competency or evaluations failure to turn over exculpatory materials failure to propound discovery failure to respond reasonable discovery requests demonstration a retaliatory animus in conjunction with
scattershot three, count them three prosecutions of Coughlin this year for charges which young either amended to in advance implicating Supreme Court Rule (SCR) 111(6) (in 065630 young amended the
criminal complaint from a misuse of 911 charge to do a charge more deleterious to Coughlin's professional license as a lawyer and/or patent agent by amending the charge nearly a year after the January 14,
2012 arrest in the matter to a charge that young brainstormed the ability to leverage against Coughlin upon Coughlin and a good faith effort to achieve a plea-bargain and resolve what is a messy case the city
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of Reno Police Department and emergency dispatch services and again the Reno justice court incident to the eviction and RJC2012-000375 run the rental at which the domestic violence resulted in Coughlin's
calls to emergency services or 911 stand located at 1422 E. 9th St. (therein implicating the three, count them three extremely suspect rolling this year by judge Schroeder of the Reno justice court against
Coughlin in the extremely quick like 40 min. from filing quick issuance of up temporary protection order to Richard G Hill on January 12, 2012 in connection with Hill's fraudulent abuse of process and false
statements to police officers affecting the arrest custodial arrest of Coughlin on January 12, 2012 will jaywalking (Hill lied to RPD officer Hollingsworth in alleging that Coughlin had already lost his appeal of
summary eviction matter in 1708 Barber which judge Sferrazza presided and which was then on appeal before judge Flanagan (whom subsequently had Coughlin with an outrageous $42,000 attorney fee award
against Pro per appellant Coughlin in the appeal of the summary eviction order issued by Judge Sferrazza and 1708 on March 30, 2012 incident to and motion for attorneys fees filed by Casey D Baker of Hill's
office on April 19, 2012 which just happened to coincide with the same day that deputy Dist. Atty. young fastball he violated the stay required by NRS 178.405 and getting judge Elliot (whom "randomly" was
assigned to Coughlin appeal of the petty larceny conviction of a candy bar and some cough drops from Walmart in 11 CR 22176 (the sole basis for Coughlin's current temporary suspension of his law license
incident to bar counsel's SCR 111(6) Petition in 60838) stemming from an arrest on September 9, 2011 that was violative of Nevada law where tribal police officers affected a custodial arrest for a
misdemeanor (much less one not alleged to have occurred in their presence) in violation of the express dictate against doing so found in NRS 171.1255 should especially where Walmarts sole witness testifying
at the petty larceny trial, would be dentist Thomas Frontino, whom testified on behalf of the 2nd St. Wal-Mart at which Coughlin was subject to a custodial arrest for misdemeanor petty larceny" a candy bar
and some cough drops in connection with Coughlin's selecting heard just seeing $83 worth of groceries allegedly consuming a candy bar and or some cough drops while doing so... Despite the fact that that
Walmart alleges to have had absolutely no video footage supportive of its allegations even where its interior is absolutely dotted with "pupil style" will surveillance cameras and where French you admit that
his supervisors had previously indicated to hand a desire to retaliate against Coughlin in connection with Coughlin's questioning some of Walmarts policies and where John Ellis of the W. 7th St., Walmart in
any as yet unknown loss prevention associate specifically and expressly threatening abuse of process against Coughlin on July 7, 2012 incident to Coughlin pointing out the extent to which Walmarts assistant
store managers and customer service managers many of whom have had that position for over a decade routinely claim do not remember the return policy or restated in a manner that depart substantially from
the policy which Walmart holds out to the public on its website Walmart.com and which on that website specifically makes applicable to in-store purchases that return policy as stated at Walmart.com no
matter what the convenient for getting in misremembering of Walmarts managers may indicate the policy actually is. Wal-Mart's Frontino admitted neiher he nor anyone with Wal-Mart on September 9th, 2011
affected a citizen"s arrest of Coughlin on that date in connection with the alleged petty larceny by Coughlin of a candy bar and some cough drops which conveniently for the Reno Police Department just days
after Coughlin filed a written complaint detailing the police misconduct by Reno Police Department officer Grohl and Rossa incident to the arrest of Coughlin the wrongful arrest of Coughlin on August 20,
2011 in 063341 a justice court criminal petty larceny and receiving stolen property charge against Coughlin (despite the fact that the majority viewpoint throughout American jurisprudence that one cannot be
charged with both petty larceny and receiving stolen property of the same item particularly where the receiving of the item is alleged to have been from oneself after one had larceny is the item lending an
inference that Joe Sferrazza seeking to sink his jurisdictional hucksters deeply into Coughlin's light as possible to affect the leverage over Coughlin to mitigate the liability Reno justice court may face in
connection with its numerous since is violating about law respecting the manner in which evictions are carried out and or the misconduct of local law enforcement and prosecutors in carrying out retaliatory
arrest and prosecution of Coughlin where the judiciary in Washoe County is off criticizes being overly influenced by the District Attorney's Office. That Walmart petty larceny conviction stemmed from a trial
before Reno Municipal Court judge Kenneth Howard (a 1981 graduate McGeorge school of law whom Coughlin's twice former Reno Municipal Court appointed public defender Keith Loomis (not in the WalMart case, as judge Kenneth Howard denied Coughlin a court appointed defender there despite his express failure to rule that jail time was not a possibility in his pretrial order and where mandatory authority
exists requiring that he then appoint Coughlin court appointed counsel particularly where Coughlin established his indigency. Judge Howard's malfeasance in connection with that conviction of Coughlin
extends further the extent that he early on in that November 30 trial on it in 2011 reviews Coughlin for causing the November 14 trial setting to have been continued only to in a 3 min. add-on at the conclusion
of the hearing which are trial which judge Howard down such a matter of public concern that he Five city of Reno employees at the courthouse until nine o'clock at night to get it done that in fact judge
Howard admitted he was wrong with respect to the cause of the continuance of the 14th 2012 trial that was not Coughlin fault that all and where the Reno Municipal Court had previously granted a
continuance to the city of Reno prosecutor's in the very criminal trespass prosecution of Coughlin stemming from Richard G Hill Esquire's criminal trespass complaint (connected to the summary eviction
matter over which judge Sferrazza presided) where the Reno Municipal Court freely granted Richard G are the product the city of Reno prosecutor's a continuance in light of Richard G Hill's need to take a sixweek vacation beginning early November 2011 and it was that same six-week vacation by Richard G Hill that Hill alleges enabled him to commander the Reno justice court judge Sferrazza to denying
Coughlin a hearing on his motion to contest personal property lien in the eviction matter 1708 required by law within 10 days of Coughlin filing his motion to contest personal property lien on November 17,
2011 even where is extremely suspect that the justice court is now alleging Coughlin refused to permit either Joslyn John is or Karen Stancil to set the hearing on November 17 as Janice admitted when judge
Sferrazza called her is of his own witness at the December 20, 2012 hearing that was finally set (as Richard Hill's e-mail wherein he threatened Coughlin that he would be able to control the justice court in his
desired to prevent such a hearing been set until he returned from his six-week vacation in late December 2011.... It incident to that same hearing on Coughlin's motion to contest personal property lien judge
Sferrazza ordered Karen Stancil and Joslyn John is of the filing office of the Reno justice court to file in unsworn statements purporting to prove that Coughlin somehow failed to allow the justice court to
setting hearing on his motion to contest personal property lien however that doesn't explain the extent to which bailiff Plamondon was able to apparently without Coughlin's permission serve Coughlin a
violation of the courthouse century Dr. and a notice of it November 7, 2011 hearing in that same eviction matter upon Coughlin at a time when Coughlin was seeking axis justice court filing office for
something unrelated to bailiff Plamondon's desire to affect service of some notice of the hearing upon Coughlin.
Keith Loomis, Esq., RMC, court appointed defendner, admits to having been close friends with in law school and to this day Loomis himself in 1982 graduate McGeorge school law along with wash County
Dist. Atty. Richard Gammick, both of whom were one year ahead of Reno justice court judge Clifton whom recently granted 2004 graduate McGeorge school of law deputy district attorney Zach young in
order taking away the ability to file by fax from Coughlin a privilege that is accorded any other criminal defendants in the Reno justice court despite the fact that that order was granted at the November 27,
2012 hearing at which Coughlin's then attorney public defender Biray Dogan was relieved as counsel and where at that hearing Dogan himself admitted that he had not received the motion young alleged who
filed on November 26, 2012 seeking such an order from judge Clifton barring Coughlin's ability to fax file or send young it a fax of any sort apparently or perhaps Tom despite the fact that Coughlin had
merely comply with judge Clifton's request that he provide judge Clifton something supportive of Coughlin's contention that Biray Dogan had utterly failed her by the advocacy zealous are not of any sort
whatsoever incident to his quote representation of Coughlin" in 065630).
(again, judge Sferrazza as a formal tribal judge and director of Indian legal services and Coughlin's former client Pete Eastman, recently admitted to Coughlin both of the State Bar of Nevada communicated he
and his wife false assertions respecting a non-existent order against Coughlin by Nevada Bankruptcy Court Judge Beesley (the State Bar of Nevada listed as having a specialization in creditors rights at
www.nvbar.org) (former law practice partners with an individual from Washoe Legal Services whom Coughlin is suing in 60302, Karen Sabo, Esq., formerly of Beesley Peck, LTD and whom trashed
Coughlin's work before him and in Nevada Bankruptcy Court at Coughlin's November 14, 2012 formal disciplinary hearing to which judge Beesley's testifying was not noticed to Coughlin previous to the
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hearing and in violation of Supreme Court rule 109 a violation made all the worse in light of the fact it bar counsel Pat King had known of any involvement of judge Beesley in any matters relative to the
ultimate Supreme Court rule 105 complaint against Coughlin for over six months at least and so in no way can be said to just stuff I his last-minute supplementing judge Beesley and milquetoast attempts to
provide Coughlin S supplemental designation of witness and summary of evidence and regard to both judge Beesley's testimony at the hearing and Washoe legal services Executive Director Paul TESTIMONY
at the hearing (both of those gentlemen attended McGeorge school of law in 1977 along with Reno Municipal Court judge Dorothy Nash Holmes and both of them offered strong opinions disapproving of
Coughlin's competency as an attorney at the hearing despite the fact that neither of them could provide anything in the way of specificity with regard to what issues they would take with any of the work they
reviewed of Coughlin's or judge Beesley's case filings in judge before judge Beesley's department in the NVB.) in early May 2012 in violation Supreme Court Rule 121's confidentiality dictates, it is interesting
to note the judge Beesley test by both Coughlin formal disciplinary hearing him on behalf of recently as of November 8, 2012 reinstated attorney Stephen R/ Harris Esquire whom admitted to misappropriating
some $755,000 from his clients and using it on hookers and luxury designer goods. Apparently creditors rights specialist bankruptcy judge Beesley sees competency in Mr. Harris and could overlook the
$755,000 for my client where it be $14 worth of candy bars and cough drops from Coughlin and Coughlin's March 30, 2012 filing in Cadle Co. v. Keller (an adversary proceeding in the NVB wherein
Coughlin had a hearing on March 15, 2012 at 2:30 pm in representing Mr. Keller that was affected by the fraudulently procured order for summary eviction in the Reno justice court RJC Rev2011-000374 that
morning obtained by Gail Kern Esquire Brown judge Schroeder of the Reno justice court wherein the audio record from that proceeding indicates a Reno justice court clerk imploring judge Schroeder to
hurriedly move the case summary eviction case against Coughlin through despite Judge Schroeder admittedly having had a different order of hearing the cases planned for that morning docket and despite the
fact that the fax header on the summary eviction order that was hurriedly moved through indicates a time stamping of a 8:24 am for a hearing that was noticed at 8:30 am on 3/15/12, and where the Washoe
County Sheriff's office deputies Cannizzaro entered and broke into Coughlin's rental sometime shortly after 1 PM that same day, 3/15/12, without announcing themselves as law enforcement and where they
entered with their guns and/or pagers drawn in and immediately placed Coughlin in handcuffs and told him he was detained in contrast to the typical procedures carried out by the Sheriff's office incident to
evictions in Washoe County. Incident to that summary eviction (where the docket, at least, more review is necessary, indicates that Kern and Western Nevada Management's Sue King switched up their basis
for an eviction all the sudden in their 3/15/12 filing of a Landlord's Affidavit that suddenly changed the basis for seeking an eviction to one for non-payment of rent (seemingly in response to Coughlin Pre
Hearing Brief pointing out the difficulties they would face under Glazer in pursuing a No Cause, particularly against Coughlin, whom at that point was, again, arguably a commercial tenant, especially where
the Park Terrace HOA had expressly approved the arrangement with two individuals whom were arguably sublessors to Coughlin). in the third grievance against Coughlin forming SCR 105 complaint for
which a formal disciplinary hearing, the grievance filed by Judge Dorothy Nash Homes in NG12-0402.
Judge Beesley and Judge Nash Holmes attended McGeorge School of Law together in 1977. Perhaps, the filing that Judge Beesley was referring to when he threw Coughlin under the bus at Coughlin's
11/14/12 formal disciplinary hearing (with one of the three grievance numbers listed in the Complaint, which the SBN and Panel will claim also fulfilled the Hearing required by 60838 for the Wal-Mart candy
bar conviction that resulted in the current now 5 month long suspension of Coughlin's license to practice law in Nevada) is the matter wherein, on March 30th, 2011 Coughlin filed the following:
Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104

Entered: 3/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by ZACH COUGHLIN on behalf of SAMANTHA L. HALL,
ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of
Opposition# (2) Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit
Email to WCSO Haley regarding excusable neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record on appeal# (7)
Exhibit 11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
In submitting that somewhat inflammatory 3/30/12 filing (which curiously seemed to immediately result in Judge Nash Holmes entering an Order of the same date in 11 TR 26800 whereby she Order
Coughlin's property released to him, though DDA Mary Kandaras dragged her feet until April 7th, 2012 before finally "allowing" the Washoe County Jail to release to Coughlin the property that it alternately
admitted to having released to the City of Reno Marshals on 2/28/12, denied having the micro sd card, denied the micro sd ever being booked into property, alleged to have given Judge Sferrazza's former tribal
court Bailiff and former Coughlin client Peter Eastman on 2/29/12 when Eastman appeared at the jail at Coughlin's request to get Coughlin's keys so Eastman could arrange for Coughlin's dog Jackson Pawluck
to be fed and cared for during Coughlin's summary 5 day incarceration).
Coughlin put his client's interest ahead of his own (where Coughlin would arguably be better off letting the 2/27/12 Judge Nash Holmes smart phone, cell phone, and micro sd card confiscating without a
warrant/5 day summary contempt jail sentence for testifying that an RPD Sargent lied in connection with his testimony about the Richard G. Hill, Esq. retaliatory issuance of three traffic citations outside Hill's
law office, where RPD Sargent John Tarter told Coughlin to leave after Coughlin presented upon being released from jail incident to a three-day stay stemming from Hill's line 2 Reno Police Department
officers and managing caught to get Coughlin subject to custodial trespassing arrest (detailed at length in 61901) and Hill refusing to give Coughlin his drivers license law accuser clients files and Coughlin
reporting to Sargent John Tarter at that time that three days prior to that Reno Police Department officer Chris Carter Junior had admitted to Coughlin in response to Coughlin querying him as he too was on
Richard Hill's payroll that RPD Officer Chris Carter, Jr admitted to Coughlin: "Yes, Richard Hill pays me a lot of money so I arrest who he says to arrest and I do what he says to do..." and where both officer
Carter and Sargent Marcia Lopez refused to undertake any diligent inquiry response to Coughlin's imploring them to query Hill as to whether he had just sent Coughlin a Bill for the full rental value of the 121
River rock property for the month of November that was commiserate with the same $900 that Coughlin was previously charged for the full use an occupancy of the premises. The lackluster failure to query
Hill with any diligence by both officer Carter and Sargent Lopez is reminiscent of what Reno Municipal Court Court appointed defender Keith Loomis Esquire in 1982 graduate McGeorge school of law told
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Coughlin at an April 10, 2012 trial date in that criminal trespass matter wherein Reno Municipal Court judge William Gardner refused to recuse himself from hearing that case against Coughlin despite the fact
that at that time he had filed a grievance with the State Bar of Nevada against Coughlin by way of the NG 12 0434 grievance that his fellow RMC judge Dorothy Nash Holmes filed
Judge Beesley formerly partnered with now Washoe Legal Services child advocacy director Karen Sabo, Esq., whom Coughlin is or was suing in 60302. Incident to Judge Nash Holmes confiscating Coughlin's
smart phone and micro sd card, and regular cell phone on 2/28/12, when, outside any permissible interpretation of a search incident to arrest given Coughlin property had been booked into his personal property
at the Washoe County jail on 2/27/12 (upon Judge Nash Holmes summarily sentencing Coughlin to 5 days in jail for contempt, despite citing to a non summary civil contempt statute in NRS 22.010 and NRS
22.100, but characterizing her Order as finding Coughlin guilty of the "misdemeanor of criminal contempt" (despite not invoking NRS 199.340, Nevada's criminal contempt statute, which is not summary in
nature, and therefore requires more due process, and despite Judge Nash Holmes relying upon unsworn hearsay by her Marshal Joel Harley (and its not clear Harley even said what Holme's alleged he did in
rendering her "second bit at the apple" of 3/12/12 in comparision to her 2/28/12 Order Finding Defendant in Contempt and Imposing Sanctions...In Nevada, a Summary Contempt Order under NRS 22.030
(which is civil in nature) for conduct not committed in the immediate presence of the Court (such as the alleged conduct involving a restroom and disassembling a smart phone or recording device and hiding
some component part thereof in the restroom that Judge Nash Holmes murkily, hazily, and vaguely testified to during Coughlin's 11/14/12 formal disciplinary hearing, and which she included in the Order she
rendered in that traffic citation case stemming from Coughlin being told to leave Hill's law office upon appearing their demanding his keys, wallets, driver's license, and client's files shortly after being released
from a 3 day custodial arrest stay in jail incident to Hill's criminal trespass Complaint against Coughlin at Coughlin's former home law office (in RJC2011-001708, the eviction matter presided over by Judge
Sferrazza). Like the Order Judge Linda Gardner claimed the parties "agreed" to incident to a Temporary Protection Hearing in Santiago v. Vaxevanis FV11-03383 (see attached in Exhibit 1), Judge Sferrazza
attempted to characterize the Order he entered on 12/21/12 following a very contentious six hour hearing on Coughlin's November 17th, 2011 filed stamped Motion to Contest Personal Property Lien as an
"Order Resolving Tenant's Motion to Contest Personal Property Lien" despite Coughlin clearly indicating, on the record at that hearing that he was certainly not "agreeing" to anything, nor was he waiving his
right to appeal any Order Judge Sferrazza may enter or render incident to that Hearing...which was conducted in an is coercive atmosphere wherein Richard Hill was permitted to joke along with Reno justice
court bailiffs radius in chief bailiff Sexton as to the fact that he to quote would like to stick some things up Coughlin's ass" in reference to multiple incidents where Reno justice court bailiffs had either as
bailiff arrested told Coughlin that he would put his foot of Coughlin's ass or made commentary as chief Sexton did to Coughlin respecting Sexton's indication of Coughlin on two different occasions the week
of Thanksgiving 2011 that Coughlin indicated that the filing office and/or not attempt to file documents so close to the 5 PM closing time of the filing office. (see attached in Exhibit 1).
and him him him him and him In fact, in Hill's January 14th, 2012 grievance to the SBN, Hill writes, inaccurately:
"4. We represent Dr. Matthew MerIiss, 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. Merliss contacted us in
approximately August 2011 to assist in evicting Mr. Coughlin. Coughlin had not paid rent or utilities since May. He contended that there were habitability issues with the property that
justified his withholding rent. All of his clahns 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"
One, it is not true for Hill to write "The lease expired in February 2011." The Standard Rental Agreement utilized by the parties provided that the Lease renewed upon its terms automatically in accordance with
the NRS 118A holdover tenant provision. Further, it is not accurate for Hill to write "Coughlin had not paid rent or utilities since May." One, the landlord assented to an arrangement with Coughlin's former cotenant, Melissa Ulloa, whereby he agreed to allow Ms. Ulloa to make installment payments to make up for the fact that she took Coughlin's $450 contribution to the $900 for each of the months of May 2011
and June 2011 and only sent the landlord Merliss $550 for May 2011 and nothing for June 2011. Coughlin provided Ms. Ulloa with $450 for each of those months, and therefore, in combination with Dr.
Merliss's assent to Ulloa's repayment plan (which arguably saved Ms. Ulloa from a grand larceny charge of a variety to which the two petty larceny charges Coughlin faced shortly after Ms. Ulloa's
secretly absconding with Coughlin's rental contributions (which Coughlin was only made aware, and the concomitant rent due, upon an August 11th, 2011 email from the landlord Merliss).
Merliss admitted to assenting to the repayment plan with Ms. Ulloa on the record in 1708 before Judge Sferrazza. Further, Merliss (though, originally, not Hill or Baker in their demands and
eviction notices, in violation of NRCP 11) admitted, under oath, that he had expressly, in writing, assented to an agreement with Coughlin for a rent deduction of $350 going forward in
exchange for Coughlin "dealing with the weeds". Coughlin did "deal with the weeds" (see the attached artificial turf installation Coughlin had installed in an enterprising approach which the
landlord's landscaper for the other property Merliss owned next door and his quasi real estate broker property manager Darlene Sharpe quickly grew unhappy with, given it was cutting in to the
"$2,000" that Dr. Merliss eventually claimed, under oath, at the 10/25/12 eviction "Trial" that he wound up paying Green Action Lawn Service to "deal with the weeds" at Coughlin's former
home law office. "Dealing with the weeds", to Green Action Lawn Service, included tearing up Coughlin's artificial turf installation leaving Street causing Coughlin's law office substantial losses
lost profits time away from work and expenses associated with immediately mitigating the criminal conduct of green action lawn service where they not only tore up the artificial turf
installation even though they knew it was there prior to submitting their bid for services to landlord Merliss, who apparently did not realize or remember that he had also assented to a $350
rent deduction with Coughlin on or about May 24th 2011 in exchange for Coughlin quote dealing with the weeds. Green action lawn service sought close the artificial turf installation Coughlin
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put into place of his former law office the week prior to their tearing it up and leaving industry when they were doing the weeds at the property Merliss owns next-door at 252 Mill St.
Hill's grievance of 1/14/12 to the SBN goes on to allege:
"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 in the basement. He was arrested and is presently facing criminal trespass charges in Reno Municipal Court. See case no. 11 CR 26405 21. He is
also facing a contempt motion in front of Judge Sferrazza in the eviction case. Sferazza has stayed that matter pending the resolution of the criminal trial. That 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 CVl1-o3628, 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 landlord'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 reinitiated 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, 20 11. 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 to resume 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 house. Coughlin called the
police, who arrived at the transfer station. Coughlin was falsely asserting that the contractor had tried to run hin1 over. He also told the police "
The ECOMM recordings (at least what Skau decided to divulge, finally) can be described thusly:
000039
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about
5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151
unintelligible.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go
ahead with that.wav
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
PRIMARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-24-11 PM Source_ID = 39 weese 063341 c153 scene 10 N Virginia rink check larceny cell phone susp os also loud verb disturb.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-08-51 AM Source_ID = 26 someone other than Duralde sounds like make that a level b clear that in about 5 minutes.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-16-41 AM Source_ID = 13 Duralde indicated he will be en route to main station to drop off Coughlin's smartphone for copying data prior to
depart.wav
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-19-51 AM Source_ID = 42 probably Duralde saying Reno C153 to main station break 151 unintelligible.wav
000040
PRIMARY RADIO TRAFFIC Start_Time = Sunday, August 21, 2011 12-38-41 AM Source_ID = 6 Duralde's wife Jessica c151 reno, Alaksa can you switch to share some information call please.wav
SECONDARY RADIO TRAFFIC Start_Time = Saturday, August 20, 2011 11-37-23 PM Source_ID = 24 man saying come and split that up then female dispatcher saying go ahead with that.wav
11 30 12 063341 updated motion for new trial with ex 1 attached in 2 pages per format.pdf
Download all
--Forwarded Message Attachment-Print
Close
Case No. RCR2011-063341

From:Jeannie Homer (HomerJ@reno.gov)
Sent: Thu 11/08/12 2:48 PM
3 attachments
Motion for Protective Order toQuash Subpoenas and for Protective Order Regarding Issuance ofSubpoenas.pdf (2.2 MB) , Motion for Protective Order toQuash Subpoenas and
for Protective Order Regarding Issuance of Subpoenas[Part 2].pdf (1442.4 KB) , Ex Parte Emergency Order PendingHearing.pdf (81.0 KB)
Please see attached documents from Creig Skau, Deputy City Attorney:
1) Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding Issuance of Subpoenas (part 1 & 2)
2) Ex Parte Emergency Order Pending Hearing (set for November 13, 2012 at 9:00a.m.)
Thank you.
Jeannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov
ATTORNEY-CLIENT PRIVILEGE
This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a
person responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is
STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
Fwd: FW: Case No. RCR2011-063341

From:Creighton C. Skau (skauc@reno.gov)
Sent: Fri 11/09/12 11:45 AM
000041
To:
Cc:
Jeannie Homer (HomerJ@reno.gov)
1 attachment
photo[1].JPG (181.2 KB)
Dear Mr. Coughlin,
Please be advised that Judge Sferaza authorized service upon you by email in an Order. Accordingly, authorized service has already been effected.
1. Set forth below is the language of Judge Sferaza's Order and the language of the City's Motion. Unfortunately, I cannot replicate the attachments. However, they consisted
mostly of documents you purportedly served, so you should be familiar with them. Also, I am providing alternative means for you to obtain the documents, as set forth hereafter.
2. The Court provided us with an address which you provided to the Court. That address is 1471 E. 9th St.,
Reno, NV 89512. Reno Carson Messanger Service attempted to serve you at that address yestarday, but you were apparently not there. Today, Reno Carson Messanger Service again attempted
to serve you there at around 11:00 a.m. They called my office and were directed to leave the Judges Order and the City's motion at the front of that address. They have provided me with a
photograph of the packet left at the front door. (Attached). Accordingly, you can obtain these items at that address.
3. You may also call our Office at 334-2050 and request a copy from Ms. Homer, which you may pick up at our Office, third floor of City Hall.
The Judge's signed Order, entered November 8, 2012, states:
IN THE JUSTICE COURT OF RENO TOWNSHIP
COUNTYOF WASHOE, STATE OF NEVADA
STATE OF NEVADA,
Plaintiffs,
CASE
vs.
NO.:
RCR2011COUGHLIN, ZACHARY BARKER

063341
Defendant.
DEPT.
NO.: 2
EX PARTE EMERGENCY ORDER PENDING HEARING

This matter has come before the Court based upon the following circumstances:
A. The Reno City Attorneys Office (RCAO) represents a number of City of Reno employees who have been named in subpoenas. The RCAO contacted Court
personnel on November 7, 2012 to request a time to appear for an order shortening time regarding a motion to quash and for protective order. Due to the proximity of the trial date in this matter,
November 19, 2012, the Court directed the RCAO to file and serve its substantive motion and provide notice that the matter would be heard on November 8, 2012 at 9:00 am. The City of Reno
filed its motion on November 7, 2012.
B. At the hearing on this matter on November 8, 2012, Deputy City Attorney Creig Skau appeared on behalf of the RCAO and the City employees requesting protective relief.
Zack Young was present in court. Mr. Coughlin did not appear. Mr. Skau represented that he was under the belief that the Public Defenders office represented Mr. Coughlin, that the Public
Defender was served believing this was service upon Mr. Coughlin, that he learned Mr. Coughlin represented himself this morning and attempted to call and left a voice mail message with a phone
number believed to be Mr. Coughlins at 8:30 this morning.
C. The Court is advised that the Public Defender, Jeremy Bosler and the City of Reno Chief Criminal Deputy City Attorney, Dan Wong, may also have received subpoenas and
filed requests for relief similar to the RCAOs requests.
D. The Court read the RCAOs motion in preparation for the hearing. Due to the absence of notice to Mr. Coughlin, no argument was received on the merits of the motion.
However, the Court finds that the RCAOs motion and supporting materials present a sufficient evidentiary basis to issue this Order.
The Court deeming itself sufficiently informed and good cause appearing therefore,
IT IS HEREBY ORDERED as follows:
1. A hearing on the merits of these matters is hereby set before this Court for 9:00 a.m. on November 13, 2012. Oral presentations shall be limited to 10 minutes each. The
Clerk shall notify Mr. Bosler and Mr. Wong of the hearing.
2. Any subpoena not properly issued by the clerk or otherwise not properly issued in accordance with NRS 174.305 is hereby quashed. Any subpoena not personally served by
a non-party or otherwise properly served in accordance with NRS 174.345 is hereby quashed. The Court reserves its ruling on any other grounds such as relevancy or undue burden until the
hearing on the merits.
3. A protective order is hereby granted pursuant to JCRCP Rule 26(c), effective until the hearing on this matter on November 13, 2012, to the effect that upon service of this
Order on Defendant Zachary Barker Coughlin, Defendant Coughlin shall not thereafter issue or cause to be issued or serve or attempt to serve or cause to be served any subpoena or subpoena duces
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tecum in this case unless he has first presented the proposed subpoena or subpoena duces tecum to the Court for the Courts review regarding adequacy, relevancy and necessity of the subpoena
or subpoena duces tecum, and sufficiency of the proposed method of service.

4. Counsel from the Reno City Attorneys Office is directed to promptly attempt to serve a copy of this Order and the RCAOs motion and any supplements by personal
service upon Zachary Barker Coughlin at the address in the Courts file, 1471 E. 9th Street, Reno, NV 89512, with a copy mailed to said address. Service shall also be attempted by email at
zachcoughlin@hotmail.com.
Dated this _[8]_____ day of November, 2012.
/s/
JUSTICE OF THE PEACE
The City of Reno's Motion states:
JOHN J. KADLIC
RenoCityAttorney
CREIGTON SKAU
Deputy City Attorney
NevadaState Bar No. 34
P.O. Box1900
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneys for City of Reno
IN THE JUSTICE COURT OF RENO TOWNSHIP

COUNTYOF WASHOE, STATE OF NEVADA
STATE OF NEVADA, Case No. RCR2011-063341

Plaintiffs, Dept. No. 2
vs.
COUGHLIN, ZACHARY BARKER,
__________________________________/
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER REGARDING ISSUANCE OF SUBPOENAS
COMES NOW, City of Reno (City), as the employer and on behalf of Reno Police Department Officers Ron Rosa and Thomas Alaksa, and Court Marshall Joel
Harley and Reno Emergency Communication Center employees Savannah Montgomery and Scott Weese (and any other City employees (collectively City employees) whose names were
unreadable in subpoenas), by and through their counsel of record, John J. Kadlic, Reno City Attorney, and Creig Skau, Deputy City Attorney, and hereby moves this Court for an order to quash the
subpoenas claimed to have been served on for these City employees in violation of Justice Court Rules of Civil Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
///
JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the attached Exhibits and any additional or further evidence the Court deems just and proper.
I. Statement of Facts
The following procedural background is relevant to this matter:
1. On October 26, 2012, City of Reno Emergency Communication Center employees (ECOMM) Suzy Rogers and Kelley Odom received emails from Zach Coughlin containing nine (9)
Subpoenas, copies of which are attached as Exhibit 1 and incorporated herein by reference.
2. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail informing him, among other things, the City of Reno Police Report and City of Reno ECOMM materials
regarding Case Number RMC 2011-063341were available for pick-up provided he submit payment to the City of Reno for $108. A copy of the letter is attached as Exhibit 2 and
incorporated herein by reference. On November 5, 2012, this same letter was sent again to Mr. Coughlin by certified mail to the same two addresses.
3. This correspondence also informed Mr. Coughlin that the four (4) subpoenas he claimed to have served regarding the appearance of the City employees Ron Rosa, Thomas Alaksa, Savannah
Montgomery and Scott Weese were ineffective because of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The letter indicated because service of the subpoenas for these four
(4) individuals was ineffective, these individuals would not be appearing on November 19, 2012. (Exhibit 2).
4. On November 1, 2012, Mr. Coughlin delivered twelve (12) subpoenas and a Notice of Errata and Revised Supplemental Motion For a New Trial by sliding them
through the security glass in the front office of the Reno Police Department at approximately 4:50 p.m. after being told the office was closed. Three (3) subpoenas contained in 000043
this packet
are duplicates. As such, this packet appears to contain the same ten (10) subpoenas he previously sent to Reno ECOMM employees Kelley Odom and Suzy Rogers. A copy of this packet
is attached as Exhibit 3 and incorporated herein by reference.

5. On November 3, 2012, Mr. Coughlin e-mailed another subpoena duces tecum to both City ECOMM employees, Kelley Odom and Kariann Beechler, seeking documents previously requested
in earlier subpoenas duces tecum. These subpoenas also contained multiple pages of requests for materials unrelated to Case RMC RCR2011-063341. A copy of these documents is
attached as Exhibit 4 and incorporated herein by reference.
6. On November 5, 2012, Deputy City Attorney Robert Bony received a telephone call from Mr. Coughlin regarding the letter this office mailed on November 2, 2012. Among other things,
Mr. Coughlin did not indicate he would be withdrawing his subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery and Scott Weese. Mr. Coughlin did state to have these
witnesses ready for trial.
7. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena Duces Tecum containing seventeen (17) pages of blended documents regarding matters pending before
Reno Justice Court on November 19, 2012 and the State Bar Of Nevada Northern Nevada Disciplinary Board to the Reno Police Department. The subpoena duces tecum on the first page of
the packet contains many unreadable names. A copy of the packet is attached as Exhibit 5.
1. On November 6, 2012 City employee Marshall Joe Harley was handed a packet of materials from an unidentified person. The cover sheet of the packed is entitled Subpoena Duces
Tecum regarding Case RCR2011-063341. This document also appears to contain names of other individuals but the handwriting is unreadable. It is not known if the other individuals
on this subpoena are City employees. A headnote on the Subpoena indicates that if the requested documents are e-mailed to Mr. Coughlin, personal appearance may not be required. A
copy of the packet is attached as Exhibit 6.
II. Argument :
A. Service
JCRCP 45 addresses subpoenas. In pertinent part it states:
(b) Service.
(1) A subpoena may be served by any person who is not a party and is not less than 18 years of age. Service of a subpoena upon a person named therein shall be made by
delivering a copy thereof to such person and, if the person's attendance is commanded, by tendering to that person the fees for one day's attendance and the mileage allowed by law.
When the subpoena is issued on behalf of the State or an officer or agency thereof, fees and mileage need not be tendered. Prior notice, not less than 15 days, of any commanded
production of documents and things or inspection of premises before trial shall be served on each party in the manner prescribed by Rule 5(b).
The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy Rogers on October 26, 2012 and November 3, 2012 and re-delivered to the Reno
Police Department on November 2, 2012 and November 6, 2012 commanding the appearance of the many different City employees above are deficient and ineffective as they fail to comply with
personal service requirement of JCRCP 45(b). Accordingly, service was ineffective and all of the subpoenas should be quashed.
In addition to the failure of personal service, all of Mr. Coughlins subpoenas referenced in Exhibits 1, 3, 4 and 5, also:
1. Violate JCRCP 45(a)(1)(D) in that they do not set forth the text of subdivisions (c) and (d) of JCRCP 45.
2. Violate JCRCP 45(b)(1) which states that a subpoena may be served by any person who is not a party to the proceeding. All of the subpoenas were e-mailed to City ECOMM
employees Kelley Odom, Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3, 2012 and/or hand delivered to the Reno Police Department on November 2, 2012 and November 6, 2012 by Mr. Coughlin, a party in this matter.
1. Violate JCRCP 45(b)(1) which states that service of a subpoena commanding attendance requires that payment for one days attendance and the mileage allowed by law. No witness fee
or mileage fee has been submitted by Mr. Coughlin for the appearance any named City employee.
2. Violate JCRCP 45(c) which states that a party or attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or expense on a
person subject to the subpoena. Mr. Coughlin is serving a litany of subpoenas on many City departments and City employees regarding this case. However, he is also serving subpoenas
on City departments and City employees on a multitude of other cases and proceedings that are unrelated to the instant action. These subpoenas are unduly burdensome, duplicative,
irrelevant, unintelligible, oppressive, harassing, seek information that is irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the subpoenas for all City employees to appear on November 19, 2012 must be quashed. The City
also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not
relate to the City or to this matter.
B. Protective Order
In accordance with JCRCP 26, the City seeks a protective order in this matter. As described above, Mr. Coughlin, a Nevada attorney with a suspended license, is abusing the subpoena process
granted to him by this Court. He is e-mailing multiple City employees or dropping off the same subpoenas (some of which relate to this matter and many which relate to a State Bar proceeding or
other criminal matters) at multiple City departments. This is creating confusion and leading to a waste of time and resources of public safety employees. As an attorney, Mr. Coughlin should be
aware of the subpoena process. This is not the first matter in which Mr. Coughlin has abused a court procedural matter. For this Courts information, Reno Municipal Court Judge Holmes
issued a Sua Sponte Order Denying Relief Sought in Improper Document on March 13, 2012 finding, among other things, that Mr. Coughlin failed to follow proper legal procedure in preparing and
filing motions in a matter pending before that Court and that Mr. Coughlin blatantly abused that Courts fax filing process. As such, that Court ordered that Mr. Coughlin be prohibited from
faxing any documents to that Court. A copy of this Order is attached as Exhibit 7.
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully seeks an Order from this Court requiring Mr. Coughlin to submit any subpoena he intends to serve in this
000044
matter to this Court for review prior to issuance and service to ensure Mr. Coughlin is seeking relevant information regarding a specific case and is following the appropriate legal process.
III. CONCLUSION
Based on the above, it is respectfully requested that this Court issue an order:
1. To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery, Scott Weese, Joel Harley or any other City employee whose names were unreadable in the subpoenas for
failure to comply with JCRCP Rule 45;
2. To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Department which do not relate
to the City or to this matter because they failed to comply with JCRCP Rule 45.
3. Grant a protective order to the City pursuant to JCRCP 26 requiring Mr. Coughlin to submit any subpoena he intends to serve in this matter to this Court for review prior to issuance and
service to ensure Mr. Coughlins subpoenas are relevant and follow the appropriate legal process.
AFFIRMATION
The undersigned does hereby affirm that the preceding document filed in this court does not contain the social security number of any person.
RESPECTFULLY SUBMITTED this day of November, 2012.
JOHN J. KADLIC
Reno City Attorney
By:

CREIGTON SKAU
Deputy City Attorney
P.O. Box 1900
Reno, NV 89505
Attorneys for City of Reno
As to the other matters addressed by you below, I work in the Civil Division and I have no knowledge or authority to address them. I suggest that you take up those matters with
the attorney(s) assigned to them.
Sincerely,
Creig Skau
Deputy Reno City Attorney
-----Original Message----From: Jeannie Homer <homerj@reno.gov>

To: "'bonyr@reno.gov'" <bonyr@reno.gov>, "'skauc@reno.gov'" <skauc@reno.gov>
Date: Fri, 09 Nov 2012 08:50:18 -0800
Subject: FW: Case No. RCR2011-063341
FYI

Sent: Thursday, November 08, 2012 8:36 PM
To: HomerJ@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov; fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Subject: RE: Case No. RCR2011-063341
couldn't open them, and I don't accept service of anything form you... See Allison Ormaas comments on 3/12/12 in 11 tr 26800 with respect to
your offices violation of the RMC Rules to the extent there is not difference technologically anymore between an email and a fax:
000045
Rule 5: Motions/Pleadings by Facsimile

A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by facsimile, except as otherwise specified in this rule.
B. All motions/pleadings filed by facsimile will only be accepted through the clerk's office (775-334-3824).
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet and exhibits. A document shall not be split into multiple transmissions to avoid the page
limitation.
D. Each transmitted page shall bear sequential numbers in the transmission.
E. All persons are eligible to use motion/pleading-by-facsimile procedures.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and telephone number. In addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when the receiving party is a governmental agency, an attorney, or with the consent of the
receiving party. If service of the motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
I. A defense attorney filing a motion/pleading in the first instance must also file a proper authorization to represent.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the follo wing court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must state the reason therefore and whether or not any continuance has previously been sought or
granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin
was suing in CV11-03015 and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance
in response to Coughlin's request for one in 11 CR 22176, but then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means other than the traditional snail mail, usps, or personal service. And I am not
currently included amongst those who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the 'governmental agency" and "attorney
exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that becuase he has lied numerous times, on the record about not being served where he has been. Take, for instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed to follow RMC Rules in withdrawing from representation:
Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court may rule on the motion or set a hearing.
Further, these RMCR's seem to change out of the blue, is there some record of what changes were made and when?
Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a
confirmation of delivery of his timely under NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination of both asserting, in one way or another, that the
Notice of Appeal was not received in a timely manner. The delivery confirmations say otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please provide to me the grievance number associate with this new grievance that is created upon the
successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000046
utbound fax report

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Date: Thu, 8 Nov 2012 14:48:18 -0800

From: HomerJ@reno.gov
Subject: Case No. RCR2011-063341
Please see attached documents from Creig Skau, Deputy City Attorney:
1) Motion for Protective Order to Quash Subpoenas and for Protective Order Regarding Issuance of Subpoenas (part 1 & 2)
2) Ex Parte Emergency Order Pending Hearing (set for November 13, 2012 at 9:00a.m.)
Thank you.
Jeannie Homer
Legal Secretary
1 East First Street, 3rd Floor
Reno, Nevada 89505
(775)334-2050
(775)334-2420/fax
homerj@reno.gov
ATTORNEY-CLIENT PRIVILEGE
This e-mail message transmission and any documents, files or previous e-mail messages attached to it are confidential, and are protected by the attorney-client privilege and/or work product doctrine. If you are not the intended recipient or a
person responsible for delivering it to the intended recipient you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or attached to this e-mail transmission is
STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and then delete the message and its attachments.
000048
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WLS Let Taitel, conflict, professional misconduct, criminal

misconduct
Sent: Fri 8/24/12 11:31 AM
To: complaints@nvbar.org; complaint@nvbar.org
Dear Bar Counsel,
I would like to file a formal grievance against Lew Taitel, Washoe Legal Services, Joe Garin, and
Nevada Court Services in connection with the matters set forth below, and my case against WLS is
on appeal before the Nevada Supreme Court right now, with Garin moving to dismiss my appeal
based upon a failure to timely file an Opening Brief caused by these two fraudulently procurred
arrests. see N. S. Ct. case 60302.
Also, please add WCPD Jim Leslie to the complaint as he has continually refused to gather the
audio cd from Milan Kreb's Protection Order extension hearing in the July 3rd, 2012 arrest matter
RCR 2012-067980, in addition to failing to gather the July 16th, 2012 audio from the Trial in RCR
2012-063341 to determine whether the August 29th, 2012 court date is a hearing on pre-trial
motions or, in fact, a Trial, in addition to the other misconduct Leslie has committed in my
represenation, and add Biray Dogan, whom, along with Leslie apparently asserted to the RJC that I
filed to show to a hearing in RCR2012-065630 on August 22th, 2012, despite WCPD staff Linda
Gray admitting that she did not mail out the notice of the hearing to me as her office had marked
my PO BOX 3961 Reno 89503 address as "no longer good" and, accordingly, failed to mail the
notice, only to have Dogan assert that is was mailed, and provide a fax of the purported notice,
baring the initials "LG" at the bottom, which Linda Gray confirmed was an indication that she
prepared the letter. Dogan has refused to apprise the Court of his error and undue the prejudice to
me brought by making me appear to be negligent and absentee. Further, Dogan and Leslie continue
to try to combine hearings in these three cases to an impermissible extent.
From: zachcoughlin@hotmail.com
To: jgarin@lipsonneilson.com
Subject: WLS Let Taitel, conflict, professional misconduct, criminal misconduct
Date: Fri, 24 Aug 2012 11:24:39 -0700
"69 a.l.r. 4th 410" "negligence, inattention, or professional incompetence of attorney in criminal defense"
000050
file:///R|/...ainst%20Jim%20Leslie%20and%20WCPD%208%2024%2012%209%205%2012%20and%209%208%2012.htm[12/10/2012 4:18:49 PM]
"Disciplinary Action Against Attorney for Aiding or Assisting Another Person in Unauthorized Practice
of Law," 41 A.L.R.4th 361 (1985).
An attorney who initiates, causes to be initiated, or threatens to initiate a criminal prosecution for the
purpose of influencing a civil matter is violating the rules of ethics. See Model Code of Profl
Responsibility DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or Threatening to
Initiate, Criminal Prosecution as Ground for Disciplining Counsel, 42 A.L.R.4th 1000 (2006). Additionally,
a practitioner may be sanctioned, or even disbarred, for coercing any person connected to the case, for
making false statements of material fact or law, or for frivolous behavior before the immigration courts.
A Plaintiff that has been harassed, intimidated or treated in a bad faith manner by a Defendant has two
recourses: Rule 11(b)(1) and Rule 11(b)(2).
Taitel works for WLS now. Taitel's partners at Nevada Court Services, upon information and
belief, recently had me arrested or contributed thereto (through R. Wray's perjured affidavit of
personal service, attempted breaking and entering and attempted trespass and assault and NCS's and
Jeff Chandlers unauthorized practice of law and other activities) on both June 28th, 2012 and July
3rd, 2012.
I want a written response from you and WLS explaining this to me and what steps have been taken
to ameliorate this misconduct. Oh, Taitel also undertook to be my court appointed public defender
in RMC case 11 cr 26405 for which I received a criminal trespass conviction on June 18th, 2012
and NCS criminally trespassed and assaulted me on numerous occasions through the eviction matter
RJC Rev2011-001708 from which that criminal trespass conviction sprung. Taitel withdrew from
the case without following RMC Rules regarding filign a written motion explaining the reasoning
for seeking an Order granting withdrawal. I was suing NCS at the time Taitel took on my
representation in that matter, while Taitel shared and office, staff, fax number with NCS and was
listed on NCS's website as their "Staff Attorney" and "associated with" NCS. Taitel is now part of
the ECR program run by WLS, in some connection with the WCDA (and the WCSO arrested me
on July 3rd, 2012 with NCS in tow, NCS purporting to criminally trespass me from and entire
Apartment Complex wherein I still had two valid leases and where the one eviction order was
fraudulently procured by those committing the unauthorized practice of law (R. Wray lied about
effecting personal service on my on June 14th, 2012 and the 5 day unlawful detainer notice was
deficient listing Sparks Justice Court, as the appropriate forum to file a Tenant's Answer....then
NCS received a Lockout Order from Reno Justice Court, despite my advance notice to both the
RJC, WCSO, RPD and Sparks Justice Court regarding these jurisdictional defects and due process
deficiencies.
000051
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
August 2rth, 2012 grievance against Jim Leslie, WCPD

Sent: Wed 9/05/12 12:11 PM
To: davidc@nvbar.org; patrickk@nvbar.org; complaint@nvbar.org; complaints@nvbar.org
Dear Bar Counsel,

Please file this as a grievance or formal complaint.
The WCPD has refused many reasonable requests I have made so far. Additionally, I
believe there is a basis for moving for a dismissal in rcr2011-063341 given Mr.
Goble's failure to show up at the last Trial Date in this matter. Mr. Leslie continues
to refuse preserve the issues for appeal.
I am that the WCPD has refused to respond in writing to my inquiries regarding any
February 27th, 2012 communication with the Reno Municipal Court or Judge Nash
Holmes. "...Also, please respond to my inquiries with respect to whether you or
anyone with your office (including Biray Dogan) ever communicated with anyone
with the Reno Municipal Court (including Judge Nash Holmes, especially on February
27th, 2012 at or around 1:00pm, despite the fact that your client, me, was noticed that
the Status Conference previously scheduled for that time was vacated....and despite the
fact that on that very date your associate Biray Dogan and moved for a second
competency evaluation ordered of me, apparently after meeting with DDA Young and
000052
another person or two....and neither you nor anyone with your office has responded to
my inquiries in that regard, vis a vis, whether Judge Nash Holmes (whom could not be
found by her staff in court at that time, which was the time schedule for the traffic trial
in 11 TR 26800 on 2/27/12 at which I was found in criminal contempt and sentenced
to 5 days in jail, and for which I have had to report that conviction to the State Bar of
Nevada and the USPTO). How is it that Mr. Dogan could get an Order signed
requiring me to have a District Court competency hearing, yet I was permitted to stand
trial in RMC 11 TR 26800? Mr. Leslie has continually jumped in on cases assigned to
Joe Goodnight or Biray Dogan and indicated to me that his supervisory capacity
allows him to do so. He has argued to the Court that my behavior in these various
cases precluded a successful Faretta canvas, then argues his behavior for a conflict
analysis is limited to just rcr2-11-0633441. That is not just. Now, if anyone with the
RMC, particularly Judge Nash Holmes or anyone in communication with Her Honor,
was present at or aware of the import of the February 27th, 2012 clandestine Status
Conference between DDA Young and Deputy Public Defender Biray Dogan, I would
like to know about it...
On numerous occasions now I have requested, verbally and in writing, for the WCPD
to provide me whatever part of my file in RCR11-065630 that I am permitted to have.
Mr. Dogan, just recently made inconsistent statements to me regarding whether I was
ever provided such materials. In the WCPD lobby, in person, Mr. Dogan at first
indicated he was sure he himself provided me those materials, then scoffed at the idea
of providing them again, if by chance I never actually received them. Then, Mr.
Dogan shortly thereafter changed his account, and insisted Jim Leslie provided me
those materials, in person no less..."
Please note, I filed a grievance against Mr. Leslie on August 24th, 2012, and Mr.
Leslie has had communication today with the State Bar of Nevada indicating the Bar
is unaware of that, at least to some extent.
That complaint or greivance read, in part:
"Subject:WLS Let Taitel, conflict, professional misconduct, criminal misconduct

8/24/12
Zach Coughlin
To complaints@nvbar.org, complaint@nvbar.org
Sent: Fri 8/24/12 11:31 AM
To: complaints@nvbar.org; complaint@nvbar.org
Dear Bar Counsel, (omitted irrelevant material) ...Also, please add WCPD Jim Leslie to the
complaint as he has continually refused to gather the audio cd from Milan Kreb's Protection Order
extension hearing in the July 3rd, 2012 arrest matter RCR 2012-067980, in addition to failing to
000053
gather the July 16th, 2012 audio from the Trial in RCR 2012-063341 to determine whether the
August 29th, 2012 court date is a hearing on pre-trial motions or, in fact, a Trial, in addition to the
other misconduct Leslie has committed in my represenation, and add Biray Dogan, whom, along
with Leslie apparently asserted to the RJC that I filed to show to a hearing in RCR2012-065630 on
August 22th, 2012, despite WCPD staff Linda Gray admitting that she did not mail out the notice
of the hearing to me as her office had marked my PO BOX 3961 Reno 89503 address as "no longer
good" and, accordingly, failed to mail the notice, only to have Dogan assert that is was mailed, and
provide a fax of the purported notice, baring the initials "LG" at the bottom, which Linda Gray
confirmed was an indication that she prepared the letter. Dogan has refused to apprise the Court of
his error and undue the prejudice to me brought by making me appear to be negligent and absentee.
Further, Dogan and Leslie continue to try to combine hearings in these three cases to an
impermissible extent."
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
grievance and complaint against DDA Young and WCPD

Dogan, Leslie, and Bosler
Sent: Sat 9/08/12 1:50 AM
To: complaints@nvbar.org; complaint@nvbar.org; davidc@nvbar.org; glennm@nvbar.org
1 attachment
9 8 12 grievance against DDA Young Dogan Bosler and Leslie.pdf (88.9 KB)
Zach Coughlin, Esq.

PO Box 3961
Reno, NV 89505
Tel: 775 338 8118
Fax: 949 667 7402
000054
September 9th, 2012
State Bar of Nevada

complaint@nvbar.org
complaints@nvbar.org
DavidC@nvbar.org
Dear Bar Counsel,
Dear Bar Counsel,

Please accept this correspondence as a formal grievance against both Washoe County Deputy District
Attorney Zach Young, Esq. and Washoe County Public Defender Biray Dogan, Esq. for the reasons set
forth herein, with the understanding that I plan to supplement this further in the near future.
Mr. Dogan, despite RPC sections devoted to diligence, competence, and communciations with clients,
you failed to copy me on (or even inform me of) DDA Young's attempt to amend the complaint in
RCR2012-065630 to a misdemeanor that would require, if a conviction is garnered, Bar Counsel to
file Petition seeking suspension of one's law license under SCR 111(6), given "obstructing a public
officer" is specifically delineated as a "serious offense" therein. I have, in the past in writing and
verbally, indicated to Dogan and his supervisors Jim Leslie and Jeremy Bosler, that I demand to be
copied of every filing in any case for which they appear for me. Dogan made contradictory and
untruthfull statements to me with regard to whether he ever gave me a copy of my file in this
matter. At first, Dogan indicated he did himself, and that he was sure of that, then minutes later he
stated he was sure that he was there to witness Jim Leslie give me the one copy the WCPD ever
provided me. WCPD staff has admitted to me that there was a package available for me to pick up,
after the date on which Dogan and Leslie allege they gave me my file, but that because I did not pick
it up soon enough, it was withdrawn from the front desk. Thereafter Dogan and Leslie have
maintained the position that I was provided that package, with varying, contradictory, evasive, and
vague statements (and in Leslie's case, testimony) as to just how and when that occurred.
Additionally, Dogan and Leslie persist in seeking to combine hearings in this case and the two cases
000055
Jim Leslie is attorney of record on (RCR2011-063341 and RCR2012-067980)with the case Dogan is
attorney of record on (RCR2012-065630, and which Leslie alternately, when its convenient to him,
maintains he is allowed to chip in on, or, alternately, maintain that he has not a connection thereto
and thus any misconduct in connection with that case may not provide a basis for a conflict being
found in RCR2011-063341), despite my express indication that Dogan and Leslie must refrain from
doing so.
Further, DDA Young is violating RPC 3.8 and other ethical rules. In seeking to attain some leverage in
RCR2012-065630 by amending the Complaint to a charge that falls wtihin the purview of SCR 111(6)
("serious offense", etc), where the allegations do not provide probable cause for such a charge, DDA
Young is violating RPC 3.8. Further, DDA Young has a duty to divulge to the Court the conflict
inherent in his office's partnering with an entity that I am suing on a wrongful
discharge/discrimination/retaliation basis, Washoe Legal Services, which is partnering with the WCDA
in an Early Case Resolution program that is violative of the Sixth Amendment Right to Counsel.
http://sixthamendment.org/?p=463
Rule 3.8. Special Responsibilities of a Prosecutor. The prosecutor in a criminal case shall:
(a) Refrain from prosecuting a charge that the prosecutor knows is not supported by probable
cause;
(b) Make reasonable efforts to assure that the accused has been advised of the right to, and the
procedure for obtaining, counsel and has been given reasonable opportunity to obtain counsel;
(c) Not seek to obtain from an unrepresented accused a waiver of important pretrial rights, such
as the right to a preliminary hearing;
(d) Make timely disclosure to the defense of all evidence or information known to the prosecutor
that tends to negate the guilt of the accused or mitigates the offense, and, in connection with
sentencing, disclose to the defense and to the tribunal all unprivileged mitigating information known
to the prosecutor, except when the prosecutor is relieved of this responsibility by a protective order of
the tribunal;
(e) Not subpoena a lawyer in a grand jury or other criminal proceeding to present evidence about
a past or present client unless the prosecutor reasonably believes:
(1) The information sought is not protected from disclosure by any applicable privilege;
(2) The evidence sought is essential to the successful completion of an ongoing investigation
or prosecution; and
(3) There is no other feasible alternative to obtain the information;
(f) Except for statements that are necessary to inform the public of the nature and extent of the
prosecutors action and that serve a legitimate law enforcement purpose, refrain from making
extrajudicial comments that have a substantial likelihood of heightening public condemnation of the
accused and exercise reasonable care to prevent investigators, law enforcement personnel, employees
or other persons assisting or associated with the prosecutor in a criminal case from making an
extrajudicial statement that the prosecutor would be prohibited from making under Rule 3.6 or this
Rule.
DDA Young has continually sought to deny Coughlin his right to a legitimate pre-trial hearing in
RCR2012-065630, in fact, Young needs to answer to whether or not RMC Judge Nash Holmes and he
(as well as Dogan or anyone with the WCPD) met, on or about February 27th, 2012, minutes before
Judge Nash Holmes entered her courtroom in 11 TR 26800 and shortly thereafter found Coughlin in
"criminal contempt" in a traffic citation trial, seconds after Coughlin testified that RPD Sargent Carter
lied in his testimony related to the three traffic citations he had issued on Coughlin incident to Richard
Hill, Esq's refusal to return Coughlin his client's files or Coughlin's state issued identifcation.
Additionally, please add to this grievance, Reno City attorney Allison Ormaas, for her lack for Candor
to the Tribunal (RPC 3.3) in asserting that the word "retaliation" and the subject of retaliation did not
appear in the police report for that November 15th, 2011 traffic citation when clearly, the report
reveals that is does. The SCR 117 Petition Coughlin now faces is based in large part on Judge Nash
000056
Holme's Order and subsequent grievance filed with the State Bar in connection with a Trial in 11 TR
26800 on February 27th, 2012, set for 1:30 pm, and DDA Young and Dogan allegedly met on
February 27th, 2012, at or around 1:00 pm, despite having noticed Coughlin that the Status
Conference set for that time in RCR2012-065630 had been vacated. Judge Nash Holmes Judicial
Assitant could not locate Judge Nash Holmes for nearly 45 minutes on that date when the time for
Trial came around. WCPD Bosler and Dogan have refused to confrim or deny whether they had any
communications with Judge Nash Holmes or anyone connected with the RMC on or around that date
regarding Coughlin's alleged "competency" issues. Leslie has been extremely evasive in answering
such questions. Court's have a duty to suspend proceedings if competency issues are raised, across
departments, and arguably across the RJC to the RMC, particularly if Judge Nash Holmes was privy to
the "secret" Status Conference that was held on February 27th, 2012, depsite the RJC having vacated
it and Dogan having communicated as much to Coughlin after Coughlin pointed out the scheduling
conflict with 11 TR 26800. I am formally requesting Bar Counsel to initiate an inquiry into whether
Judge Nash Holmes was privy to the Order for Competency Evaluation orderd on February 27th, 2012
in RCR2012-065630, and if so, whether she violated any RPC's by continuing to hold the Trial in 11
TR 26800, especially in light of her subsequent grievance/Complaint with the SBN and Orders in that
matter.
DDA Young violated RPC 3.8 in seeking to have Coughlin returned to custody in September 5th, 2012.
There was absolutely no basis for Young seeking to do so at that time other than to disadvantage
Coughlin, ego trip, and impermissilby coerce Coughlin out of pursuing any civil remedies that he may
have available given the police and prosecutorial misconduct that Coughlin has systematically been
subjected to in the last year.
On that note, the July 3rd, 2012 arrest in RMC 12 CR 12420 for "distrubing the peace", no "proof of
insurance" and "failure to secure a load on a truck" led to Coughlin spending 21 days in jail after the
RPD, in conjunction with Reno City Attorney Jill Drake advocated for RMC Judge Gardner to raise the
$1,415 bondable bail to $3,000 cash only, on a "public saferty and welfare basis" despite the only
permissilbe rationale for bail under Nevada law being to insure the defendant's appearance at trial.
Please accept this as a grievance against John Kadlic and Jill Drake, Esq. for violating RPC's, including
RPC 3.8. It is telling that the disturbing the peace charge and proof of insurance charge were dropped
on September 4th, 2012, but not before a Reno City Attorney (the signature is illegible) sought to
violate Soldal v. Cook County and Wheeler v. Coss some more by adding a trespass complaint against
Coughlin, whom had, at the time of the arrest, two valid leases at the property in question. If a Reno
City attorney filed a trespass charge, it is a violation of the RPC, and I wish for this to be construedas
a grievance and for further investigation to be undertaken. Certainly, Keith Loomis grievance of
August 28th, 2012 looks more supportable
Rule 3.3. Candor Toward the Tribunal.

(a) A lawyer shall not knowingly:
(1) Make a false statement of fact or law to a tribunal or fail to correct a false statement of
material fact or law previously made to the tribunal by the lawyer;
(2) Fail to disclose to the tribunal legal authority in the controlling jurisdiction known to the
lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or
(3) Offer evidence that the lawyer knows to be false. If a lawyer, the lawyers client, or a
witness called by the lawyer, has offered material evidence and the lawyer comes to know of its
falsity, the lawyer shall take reasonable remedial measures, including, if necessary, disclosure to the
tribunal. A lawyer may refuse to offer evidence, other than the testimony of a defendant in a criminal
matter, that the lawyer reasonably believes is false.
(b) A lawyer who represents a client in an adjudicative proceeding and who knows that a person
intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the
000057
proceeding sGhall take reasonable remedial measures, including, if necessary, disclosure to the
tribunal.
(c) The duties stated in paragraphs (a) and (b) continue to the conclusion of the proceeding, and
apply even if compliance requires disclosure of information otherwise protected by Rule 1.6.
(d) In an ex parte proceeding, a lawyer shall inform the tribunal of all material facts known to the
lawyer that will enable the tribunal to make an informed decision, whether or not the facts are
adverse.
DDA Young violated RPC 3.3 when, at trial in RCR2011-063341 on August 29th, 2012 he asserted to
RJC Judge Sferrazza that Layton v State presented mandatory binding authority in Nevada preventing
Judge Sferrazza from excercising any discretition with regard to whether Coughlin could appear as his
own co-counsel. Certainly, Wheby and other cases prove otherwise. Yet, DDA Young was insistent
and clear in his statements that there was "mandatory, binding authority" preventing any excercise of
such discretion by the court to permit a co-counsel arrangement.
DDA Young has continually sought to deny Coughlin his right to a legitimate pre-trial hearing in
RCR2012-065630, in fact, Young needs to answer to whether or not RMC Judge Nash Holmes and he
(as well as Dogan or anyone with the WCPD) met, on or about February 27th, 2012, minutes before
Judge Nash Holmes entered her courtroom in 11 TR 26800 and shortly thereafter found Coughlin in
"criminal contempt" in a traffic citation trial, seconds after Coughlin testified that RPD Sargent Carter
lied in his testimony related to the three traffic citations he had issued on Coughlin incident to Richard
Hill, Esq's refusal to return Coughlin his client's files or Coughlin's state issued identifcation.
Additionally, please add to this grievance, Reno City attorney Allison Ormass, for her lack fo Candor to
the Tribunal in asserting that the word "retaliation" and the subject of retaliation did not appear in the
police report for that November 15th, 2011 traffic citation when clearly, the report reveals that is
does.
Rule 3.3 (formerly Supreme Court Rule 172) is the same as ABA Model Rule 3.3.
Rule 3.4. Fairness to Opposing Party and Counsel. A lawyer shall not:
(a) Unlawfully obstruct another partys access to evidence or unlawfully alter, destroy or conceal a
document or other material having potential evidentiary value. A lawyer shall not counsel or assist
another person to do any such act;
(b) Falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a
witness that is prohibited by law;
(c) Knowingly disobey an obligation under the rules of a tribunal except for an open refusal based
on an assertion that no valid obligation exists;
(d) In pretrial procedure, make a frivolous discovery request or fail to make reasonably diligent
effort to comply with a legally proper discovery request by an opposing party;
(e) In trial, allude to any matter that the lawyer does not reasonably believe is relevant or that
will not be supported by admissible evidence, assert personal knowledge of facts in issue except when
testifying as a witness, or state a personal opinion as to the justness of a cause, the credibility of a
witness, the culpability of a civil litigant or the guilt or innocence of an accused; or
(f) Request a person other than a client to refrain from voluntarily giving relevant information to
another party unless:
(1) The person is a relative or an employee or other agent of a client; and
(2) The lawyer reasonably believes that the persons interests will not be adversely affected
by refraining from giving such information.
DDA Young, on July 16th, 2012, violated RPC 3.4 when he made the statement to the Court in
RCR2011-063341, at Trial, that Coughlin caused the continuance that was necessitated that day by
Joe Goodnight, Esq. (WCPD) sudden removal from the case. Coughlin pointed out that even he had
000058
not been given any rationale for Goodnight's sudden removal from a Monday Trial when Goodnight
had met with Coughlin for trial prep the Friday before, tending to indicate that either Young was privy
to information from the WCPD that Coughlin was not privy to, or Young was making arguments not
based in fact or law or in line with RPD 3.4(e). DDA Young then sought to backtrack, making mincing
statements about how he "assumed" this or that and how he had not actualy had impermissilbe
communications with WCPD Bosler (who was filling in for Goodnight). RJC Judge Sferrazza
rebuked DDA Young, pointing out that he should not "assume" anything.
DDA Young continues to impermissibly seek to leverage another obstructing/resisting/making a "false"
statement to a public officer charge in RCR2012-067980, despite his having been provided
excuplatory videos and despite a lack of probable cause to support the complaint, the information
pled therein being deficient as well. Additionally, Coughlin's June 26th and July 3rd, 2012 emails (see
below) make clear that the RPD, Reno Justice Court, Washoe County Sheriff, et al were made aware
well in advance of the deficiencies in the 5 day unlawful detainer notice drafted and served by Lew
Taitel, Esq's apparent business partners, Nevada Court Services, who are committing the unauthorized
practice of law in their "eviction consulting services" (please see my recent grievance in that regard).
An attorney who initiates, causes to be initiated, or threatens to initiate a criminal prosecution for the
purpose of influencing a civil matter is violating the rules of ethics. See Model Code of Profl
Responsibility DR 7-105 (1983). See also Gregory G. Sarno, Annotation, Initiating, or Threatening to
Initiate, Criminal Prosecution as Ground for Disciplining Counsel, 42 A.L.R.4th 1000 (2006). DDA
Young and the WCDA may be violating the following: Attorney violated professional conduct rules
prohibiting conduct prejudicial to the administration
of justice and prohibiting a lawyer from threatening to present criminal charges
solely to obtain an advantage in a civil matter, where attorney threatened a complainant with
criminal prosecution and a defamation suit to prevent him from pressing forward with a disciplinary
complaint. State Bar Articles of Incorporation, Art. 16, Rules of Prof.Conduct, Rules
8.4(d, g), LSAR.S. foll. 37:222. In re Robinson, 46 So. 3d 662 (La. 2010). Additionally, a practitioner may
be sanctioned, or even disbarred, for coercing any person connected to the case, for making false
statements of material fact or law, or for frivolous behavior before the immigration courts. A Plaintiff
that has been harassed, intimidated or treated in a bad faith manner by a Defendant has two
recourses: Rule 11(b)(1) and Rule 11(b)(2). However, malicious prosecution actions are necessary to
deter persons from procuring the arrest of another maliciously and without probable cause. Hunt v.
Lawson, 2008 WL 4691052 (Ky. 2008), as corrected, (Oct. 24, 2008). Merlet v. Rizzo, 64 Cal. App. 4th
53, 75 Cal. Rptr. 2d 83 (1st Dist. 1998).
WCPD Jim Leslie has violated RPC 1.2 in RCR2011-063341 in attempting to withdraw from criminal
defendant Coughlin one of the few inviolable rights a criminal defendant has. Leslie has refused to
attempt to procure authentication or foundation for the admission of excuplatory videos of the arrest
of August 20th, 2011 in that case from any of the witnesses in the case. Rather, Leslie has maintained
that he will only put on such videos (whether as evidence or to refresh a witness recollection, and or
for impeachment purposes) if Coughlin himself takes the stand and provides authentication and
foundation for the videos, thereby exposing Coughlin to a waiver of his right to decide whether or not
to testify, and opening the scope of cross examination impermissibly. Further, Leslie has refused to do
or provide any legal research to determine the permissibility of only utilizing portions of any such
video evidence. That is to say, Leslie insists that the videos must be submitted in toto, even portions
that damage Coughlin's case. Leslie has a duty of diligence and competence, and his blase refusal to
provide any legal citation for his contention that Coughlin's defense may not include picking an
choosing which portions of such videos to utilize in Trial is violative of those duties, in addition to
violating RPC 1.2's dictate that a "lawyer shall abide by a clients decision concerning the objectives of
representation and, as required Rule 1.4, shall consult with the client as to the means by which they
000059
are to be pursued" and that "the lawyer shall abide by the clients decision, after consultation with the
lawyer, as to a plea to be entered, whether to waive jury trial and whether the client will
testify...".
Rule 1.2. Scope of Representation and Allocation of Authority Between Client and Lawyer.
(a) Subject to paragraphs (c) and (d), a lawyer shall abide by a clients decision concerning the
objectives of representation and, as required Rule 1.4, shall consult with the client as to the means by
which they are to be pursued. A lawyer may take such action on behalf of the client as is impliedly
authorized to carry out the representation. A lawyer shall abide by a clients decision whether to settle
a matter. In a criminal case, the lawyer shall abide by the clients decision, after consultation with the
lawyer, as to a plea to be entered, whether to waive jury trial and whether the client will testify.
(b) A lawyers representation of a client, including representation by appointment, does not
constitute an endorsement of the clients political, economic, social or moral views or activities.
(c) A lawyer may limit the scope of the representation if the limitation is reasonable under the
circumstances and the client gives informed consent.
(d) A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer
knows is criminal or fraudulent, but a lawyer may discuss the legal consequences of any proposed
course of conduct with a client and may counsel or assist a client to make a good faith effort to
determine the validity, scope, meaning or application of the law.
Further, this grievance seeks to have an investigation undertaken to deterimine whether the
circumstances detailed in the June 7th, 2012 email by Coughlin to davidc@nvbar.org, and the WCDA,
wherein a battery via a lit cigarette projected at Coughlin at close range by Cory Goble was the
subject of a grant of immunity by the WCDA, despite the extent to which such conduct is illegal and
reasonable calculated to dissuade Coughlin from testiying in RCR2011-063341. Further inquiry is
requested as to the permissibility of WCPD Jim Leslie refusing to even bring up the subject on cross
examination of Goble, Zarate or Duralde in that matter.
Compensatory Damages Topic Summary Correlation Table References 117. Injury to reputation
West's Key Number Digest West's Key Number Digest, Malicious Prosecution k67 Compensatory
damages in a malicious prosecution action may include harm to the plaintiff's reputation caused by the
underlying action,[FN1] including the damage to one's reputation from the malicious institution of
administrative proceedings.[FN2] Thus, the plaintiff in an action for malicious prosecution may recover
damages for injury to his or her reputation,[FN3] including injury resulting from the publication of
reports of the proceedings.[ FN4] Caution: Although a malicious prosecution is, at common law,
assumed to be harmful to an individual's reputation, it is nonetheless necessary to make an objective
showing of an individual's reputation before the malicious prosecution versus the damaged condition
of his or her reputation afterwards to support an award of damages for injury to reputation.[FN5] The
plaintiff's own testimony that he or she lost respect due to the malicious prosecution is not enough,
without other objective evidence, to support such an award.[FN6] Evidence of a plaintiff's prior arrests
is properly admitted in a malicious prosecution action if that evidence bears directly on the question of
whether or not the plaintiff's arrest in fact damaged his or her reputation, in view of his or her
previous arrests.[FN7] However, it has also been held that a trial court does not err in excluding such
evidence, because it has no relevancy to the issue of compensatory damages.[FN8] [FN1] Bhatia v.
Debek, 287 Conn. 397, 948 A.2d 1009 (2008); Sikora v. Gibbs, 132 Ohio App. 3d 770, 726 N.E.2d
540, 111 A.L.R.5th 685 (10th Dist. Franklin County 1999); Wecht v. PG Pub. Co., 725 A.2d 788 (Pa.
Super. Ct. 1999). [FN2] Melvin v. Pence, 130 F.2d 423, 143 A.L.R. 149 (App. D.C. 1942). [FN3]
Browning v. Ray, 1968 OK 52, 440 P.2d 721 (Okla. 1968). [FN4] Grimes v. Greenblatt, 47 Colo. 495,
107 P. 1111 (1910). As to proof of publicity given to prosecution, see 119. [FN5] Rodick v. City of
Schenectady, 856 F. Supp. 105 (N.D. N.Y. 1994) (applying New York law). [FN6] Rodick v. City of
Schenectady, 856 F. Supp. 105 (N.D. N.Y. 1994) (applying New York law). [FN7] Delchamps, Inc. v.
Bryant, 738 So. 2d 824 (Ala. 1999). [FN8] Szarejko v. Amerling Volkswagen, Inc., 55 A.D.2d 801, 390
000060
N.Y.S.2d 266 (3d Dep't 1976).
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
000061

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Close
grievance against Keith Loomis, Esq. and Christopher HazlettStevens, Esq., Lew Taitel, Esq., and Henry Sotelo, Esq., and
WCPD Biray Dogan and Jim Leslie
Sent: Mon 10/22/12 12:33 AM
To: complaints@nvbar.org; complaint@nvbar.org; rosec@nvbar.org; davidc@nvbar.org;
patrickk@nvbar.org; glennm@nvbar.org
Dear Bar Counsel,

Please accept this filing of a formal grievance against the attorneys listed and
mentioned herein. The basic import of this grievance is that these public defenders
and prosecutors seek to leverage the benefits of Order for Comptency Evaluations
(buy them some time to do research once they get cornered or exposed) while
avoiding any of the dictates of NRS 178.405 and NRS 5.010 requiring "all
proceedings" be stayed.
There was an Order For Competency Evaluation by Judge Clifton in RCR2012065630 entered February 27th, 2012, and the Order in CR12--0376 adjudging
Coughlin competent and remanding jurisdiction back to the lower court was not
entered until May 9th, 2012, yet Loomis and Hazlett-Stevens persisted in seeking to
ramrod the criminal trespass case in RMC 11 CR 26405 through...and both were well
aware of the February 27th, 2012 Order for Competency Evaluation and the import of
NRS 178.405, requiring the suspension of all proceedings during the pendency of such
an Order. Further, the RMC failed to file the timely Notice of Appeal I submitted for
filing on June 28th, 2012, and which was served by delivering to the City Attorney's
Office on June 27th, 2012 (timely within 10 days under NRS 189.010) resulting in the
dismissal of the appeal.
Further, Loomis and Puentes deprived me of my right to supboena witnesses to defend myself in RMC 11 CR
26405, a criminal trespass matter resulting in a criminal trespass conviction on June 18th, 2012, which I reported
to Bar Counsel in compliance with SCR 111. SBN Bar Counsel King has the audio from two of the pre-trial
hearings and I am attaching the audio of the trial or linking to it herein. It demonstrates the fact that Dr. Merliss
was a percipient, material eye witness (in fact Dr. Merliss lied to the RPD in effectuating this wrongful arrest,
and Sargent Marcia Lopez has admitted to me, contrary to RPD Officer Chris Carter's police report and Richard
Hill's June 18th, 2012 sworn testimony and Casey Baker, Esq's (whom was not even there on November 13th,
2011) NRCP Rule 11 violating (given he possessed the video's taken by Dr. Merliss and his supervisory attorney,
Richard G. Hill, Esq, which were propounded to the Reno City Attorney's Office and which both Loomis and
Puentes had, which further demonstrate their culpability. There is a suggestion that these "contract" court
appointed defenders put their own profit motive above their client's rights to subpoena witnesses and gather
000072
file:///R|/...against%20rmc%20defenders%20etc%20regarding%20violating%20stay%20in%20competency%20matters.htm[12/10/2012 4:18:51 PM]
evidence to defende their cases (similar to the refusals by WCPD Jim Leslie, Loomis refused to procure and
provide the audio of two extremely relevant court proceedings in the RJC, necessary to the defense of RMC
case, which led to 18 days wrongful incarceration of me from July 3, 2012 to July 21st, 2012 in RMC 12 CR
12420. The two RJC matters are the Milan Krebs TPO hearing in RJC RCP2012-000287 (particularly necessary
to the defense of that matter, in addition to the matter Leslie represent me on incident to a wrongful June 28th,
2012 arrest by the WCSO in RCR2012-067980, incident to a fraudulently procurred Summary Eviction Order
(stemming from the fraudulent Declaration of Personal Service by license process server Robert Wray for
Nevada Court Services, which was committing the unauthorized practice of law (deeming themselves an
"eviction consulting and process service company" in RJC rev2012-001048, where Wray lied about "personally
serving" me a June 14th, 2012 5 day unlawful detainer notice (he tried to break and enter my rental #29, which
had not windows and which had a locked front door at the time that he and Northwind Apartments Manager
Duane Jakob attempted to break and enter and committ another trespass (as they had done previously, when they
failed to get the City of Reno Code Enforcement to do their bidding in seeking to subvert the summary eviction
process, and where the RPD, though making threats to arrest me for criminal trespass violative of Soldal v. Cook
County, was taking too long to "help" Northwind out. WCPD Leslie failed to inform me or notify me in any
way as to the fact that the WCDA filed, on August 23rd, 2012, a document listing Jakob as a witness it intends
to call in its prosecution of me in RCR2012-067980. Further, WCPD Biray Dogan failed to inform me in any
way of the fact that, on July 31st, 2012, DDA Young filed a Motion to Amend Criminal Complaint wherein he,
lacking a RPC 3.8 probable cause basis to do so, seeks to amend his charge in RCR2012-065630 to a charge that
would invoke, upon a conviction, the reporting requirements of SCR 111(6), rather than maintain the difficult
task of prosecuting one for "misue of 911" where 911 was allegedly utilized to report police misconduct,
whereupon 911 operators purportedly efused to document such a complaint or report in any way. Additionally,
Henry Sotelo, similar to Loomis, refused to procure and provide to his client, Coughlin (once Loomis received
his second Order granting his withdrawal as court appointed counsel for Coughlin, once in RMC 11 CR 26405
(now a SCR 111(4) petition, filed by Bar Counsel against Coughlin on October 15th, 2012) and again in RMC
12 CR 12420 (Loomis also refused to send a request for discovery or subpoena duces tecum to the City of Reno
or RPD for the various police reports Sargent Dye and Officer Weaver reference during an impermissible,
unnotice, impromptu bail hearing (wherein Jill Drake, Esq. committed professional misconduct) on July 5th,
2012 (at which RMC Judge Gardner again failed to recuse himself despite the pending grievances filed on his
behalf by Judge Nash Holmes, NG12-0434 and NG12-0435, the latter of which resulted from Judge W.
Gardner's sister passing to him, her brother, her April 2009 Order After trial sanction Coughlin, to RMC Judge
Nash Holmes, whom filed it on March 14th, 2012 with Bar Counsel, along with her admission to to
communications with the WCPD's Office, which the WCPD'S Office, including Bosler, Dogan, and Leslie, have
refused to comment on to Coughlin in any way, aside from Leslie's dubious assertion that he is completely
unaware of such.
Regardless, given the import of NRS 178.405 and NRS 5.010, the June 18th, 2012 Trial in RMC 11 CR 26405
should have never taken place, should have never been set on May 8th, 2012 (particularly where the 2/27/12
Order for Competency Evaluation in RCR2012-065630, to which Loomis admits to have been aware of, was not
ruled upon by D10 ("Tiburon" prinout sua sponte gathered by Judge Gardner aside, where Loomis didn't manage
to get one, though he did argue that an unofficial online "docket" was somehow capable of providing judicial
notice of an Order Finding Coughlin competent on May 8th, 2012, which is clearly violative of NRS 178.405
and NRS 5.010). Additionally, it is preposterous to find that Coughlin was able to make the decision to proceed
without Loomis or other court appointed, Sixth Amendment satisfying representation, on May 8th, 2012, given
the Order by D10 in CR12-0376 finding Coughlin competent did not get signed and entered until May 9th,
2012. This is reminiscent of DDA Young filing an Opposition to Coughlin's Motion to Appear as Co-Counsel
in RCR2011-063341 after the entry of the 2/27/12 Order for Competency Evaluation by Judge Clifton in
RCR2012-065630 (though the docket lists Judge Schroeder as presiding over that "clandestine" status
conference, so deemed in light of Coughlin being notice in writing that it had been vacated to March 29th, 2012,
in light of the scheduling conflict presented by the RMC 11 TR 26800 traffic citation trial set for 1:00 pm on
2/27/12 before Judge Nash Holmes, which she held anyways, despite the dictates of NRS 178.405 and NRS
5.010 and the communicatiosn Judge Nash Holmes admits to in the March 14th, 2012 grievance she filed on
behalf of all RMC Judges (including pro tempore ones) on March 14th, 2012, and for which Judge William
Gardner admits to being aware of, as does City Attorney Hazlett-Stevens, whom makes ridiculously mincing
000073
arguments respecting the difference in being "competent" to practice law versus being "competent" to stand trial,
even where he was aware of RCR2012-065630 and CR12-0376. Further, upon information and belief, HazlettStevens demonstrates a lack of candor to tribunals where he argues he was not "served" documents that he
recieved via email and or fax where the RMC Rules allow for such transmissions to constitute service upon
"governmental attorneys". I reserve my right to supplement this grievance further at a later date. Additionally,
Mr. Sotelo violated NRS 178.405 and NRS 5.010 on September 30th, 2012 where he filed a Motion to
Withdraw as Coughlin's Counsel of Record in 12 CR 12420 during a period in which a September 5th, 2012
(though it might be file stamped September 7th, 2012) Order for Competency Evaluation of Coughlin in
RCR2011-063341 was entered (and which the RMC, City Attorney Sooudi, and RMC defender Sotelo
recognized as requiring a stay of a Motion Hearing in 12 CR 12420 on September 18th, 2012...). Sotelo
compounds his misconduct by making spurious and vague allegations against his then client Coughlin in that
Motion alluding to some "repugnant" course he alleges Coughlin wishes to maintain, though, predictably, Sotelo
fails to provide any support for his egregiously prejudicial statement, damaging of his client's interests and
defense, all while violating NRS 178.405 and NRS 5.010.
Further, given the correspondences admitted to between Puentes and Loomis with the Washoe County Public
Defender's Office, and in light of the fact that both Loomis and Puentes are employed by the RMC, the various
Orders for Competency Evaluation filed since the first one of September 8th, 2011 regarding Coughlin, in
RCR2011-063341, vitiate the import of all subsequently void Orders predicated upon any part of any proceeding
not stayed during the pendency of such an Order for Competency Evaluation. That means, the conviction in
RMC 11 CR 22176 underpinning the SCR 111(6) petition in 60838 resulting in Coughlin's current temporary
suspension of his law license, is necessarily void, particularly where the arraignment took place at a time
(October 10th, 2011) when Coughlin's competency was put into question, particularly where RMC defender Lew
Taitel, appointed at Coughlin's court ordered defense counsel beginning on November 19th, 2011, was aware of
the pending Order for Competency Evaluation in RJC RCR2011-063341 at the time of the November 30th, 2011
Trial in RMC 11 CR 22176. resulting in Coughlin's conviction for petty larceny. Please add Pamela Robert,
Esq., City of Reno prosecutor on that matter to this grievance in that regard as well, in addition to her coworker
Allison Ormaas, particularly where she appeared and offered argument both at the 2/27/12 Trial in 11 TR 26800
in the RMC, but as well as the February 12th, 2012 continuation of that Trial. In that regard, all of Judge Nash
Holmes purported Orders, including those finding Coughlin "by clear and convincing evidence" to be guilty of
"summary criminal contempt" and other violations of the Rules of Professional Conduct incident to the traffic
citation trial in 11 TR 26800 on 2/27/12 that Judge Nash Holmes, despite the mandates of NRS 178.405 and
NRS 5.010, transmogrified into a disciplinary proceeding against a pro se attorney indigent criminal defendant
denied his Sixth Amendment Right To Counsel in a proceeding wherein jail time was ultimately ordered, are
also void, to the extent they are not already void given the divesting of her jurisdiction incident to Coughlin
filing, on March 7th, 2012, a Notice of Appeal of that summary contempt order as rendered (especially where
the March 28th,2 2012 written Order by Judge Nash Holmes was mailed to an address for Coughlin that the
RMC knew was no longer good). Most recenlty, WCPD Dogan and Goodnight, in a stipulation with DDA
Young sought to swap an October 15th, 2012 hearing date in RCR2012-063341 with Dogan (though Dogan has
not communicated with me at all in what seems like months, and Leslie appears to be taking ownership of that
case, in RCR2012-065630, though Leslie does not communicate with me much at all either...and most of the
information I glean from this matters is culled from repeated trips to the filing office, where bailiffs have
implemented rules limiting my access to justice to 15 minute installments...). The public defenders (including
Sotelo, whom only sent me a copy of his Motion to Withdraw after the Order granting it was signed...)
repeatedly fail to adhere to the RPC concerning their duty to communicate with clients., particularly where I
have put them on written notice respecting my demands to be copied on any and all filings and correspondence
in any way connected to any of my cases.
To wit:
"CERTIFIED COPY OF DOCKET
000074
13 November 2011: Criminal Complaint issued upon the oath of Reno Police
Department Officer Carter.
Charge I: Trespass, a violation ofR.M.C 08.10.0lD.
14 November 2011: Defendant appeared while in custody before Judge William
Gardner
for arraignment. The defendant was represented by Keith Loomis Esq. and on behalf
of the City
was Christopher Hazlett-Stevens. The defendant was advised of his Constitutional
rights. The
Defendant entered a plea of Not Guilty and a trial date was set for December 13, 2011.
Lewis
Taitel Esq. was appointed to represent defendant. Defendant's request for release on
O.R. was
denied.
15 November 2011: Cash bail in the amount of$3 1 0.00 wa.s posted and the defendant
was
released from the Washoe County Jail.
23 November 2011: Motion To Continue With Supporting Declaration filed by
Deputy City Attorney Christopher Hazlett-Stevens.
28 November 2011: Order Continuing Trial signed by Judge William Gardner.
30 November 2011: Trial date of January 10,2012 set by the court. Legal Defender
Roberto Puentes was appointed as Attorney for defendant for new trial date.
14 December 2011: Motion To Proceed Inforrna Pauperis filed by defendant.
03 January 2012: Motion for New Trial Date filed by Legal Defender Roberto
Puentes.
04 January 2012: Motion for New Trial Date granted by Judge William Gardner.
18 January 2012: Motion For Withdrawal Of Attorney filed by Legal Defender
Roberto Puentes. A motion hearing was set for February 2,2012.
02 February 2012: Motion hearing held before Judge William Gardner. Present at
the hearing on behalf of the City was Deputy City Attorney Jill Drake, for the defense
Roberto
Puentes and defendant Zachary Couglin. Motion To Withdraw was granted. Legal
Defender
Keith Loomis was appointed to represent defendant.
13 February 2012: Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59,
JCRCP 60, Motion for Reconsideration: Motion for Recusal: Motion For Publication
Of
000075
Transcript at Public Expense. Petition for In Forma Pauperis Status filed by defendant.
16 February 2012: Notice of Appeal, Motion to Vacate and or Set Aside, JCRCP 59,
JCRCP 60, Motion for Reconsideration: Motion for Recusal: Motion For Publication
Of
Transcript at Public Expense. Petition for In Forma Pauperis Status filed by defendant.
22 February 2012: Opposition to Defendant's Motion filed February 13,2012, filed
by Deputy City Attorney Jill Drake.
05 March 2012: Trial date set for April 10, 2012 by Court.
05 March 2012: Notice Of Appearace As Co-Counsel And Motion To Dismiss filed
defendant.
20 March 2012: Order #1 denying defendant's motion filed 13, February 2012 signed
by
Judge William Gardner.
21 March 2012: Order #2 denying defendant's motion filed 5, March 2012 signed by
Judge William Gardner.
21 March 2012: Motion To Strike Defendant's Motion To Dismiss Complaint filed by
Deputy City Attorney Christopher Hazlett- Stevens.
10 April 2012: Defendant appeared for trial with counsel Keith Loomis, Judge
William
Gardner presiding. Present on behalf of the City was Christopher Hazlett-Stevens.
Several
pre-trial motions were heard. An Order Suspending Proceedings was signed. All
proceedings suspended until the question of competence is determined. Case Status
Hearing
scheduled for 8, May 2012.
08 May 2012: Case Status hearing held before Judge William Gardner. Present on
behalf of the City was Deputy City Attorney Christopher Hazlett-Stevens, for the
defense
Keith Loomis and defendant Zachary Coughlin. Defendant was found to be
competent.
Defendant's motion to remove Keith Loomis as counsel granted. Trial date set by the
court
for June 18,2012.
OS June 2012: Notice Of Appearance As Counsel ; Motion To Dismiss; Motion To
Suppress; Motion For A Continuance Of Trial And Transfer To Mental Health Court
filed by
defendant.
000076
18 June 2012: Defendant appeared for trial pro-per, Judge William Gardner presiding.
Present on behalf of the City was Christopher Hazlett-Stevens. Several pre-trial
motions
were heard. Motion to Continue filed by defendant denied. Motion to Dismiss filed by
defendant denied. Motion to Suppress denied. Motion to Recuse denied. Motion to
Transfer
to Mental Health Court denied. Case tried on its merits and the Defendant was found
guilty of the
charge of Trespass, a violation of R.M.C 08.10.010.
The Defendant was sentenced as follows:
Trespass, a violation of R.M.C 08.10.0 10. : Time Served and a $310.00 fine.
26 June 2012: Motion for New Trial filed by defendant.
11 July 2012: Order Denying Motion For New Trial & For Other Relief signed by
Judge
William Gardner.
18 July 2012: Notice Of Appeal filed by defendant.
19 July 2012: Notice Of Appeal filed by defendant.
2 3 July 2012: Notice Of Appeal filed by defendant.
25 July 2012: Notice of Appeal, motion to Vacate and or Set Aside, JCRCP 59,
JCRCP 60,
Motion for Reconsideration; Motion for Recusal; Motion For Publication Of
Transcript at
Public Expense, Petition for In Forma Pauperis Status filed by defendant.
Municipal Judge.
Department Two
CERTIFICATE OF TRANSMITTAL OF COMPLETE RECORD ON APPEAL
1, Cassandra Jackson, Court Administrator of the Reno Municipal Court, do hereby
certifY that the attached documents include full, true and correct copies of all papers
relating
to Case Number II CR 26405 21, including a Certified Copy of Docket, Plaintiff's
exhibits 13. Further, said documents have been transmitted to and filed with the clerk of the
Washoe
County District Court. Transcript to follow."
Further, Taitel took on my representation despite a clear conflict existing, ie, I was
suing his business partners, Nevada Court Services (with whom he shares a fax
000077
number, mailing and physical address, receptionist, is listed as "associated with" and
"Staff Attorney" on the Nevada Court Services official web site, etc....all while NCS
was trespassing against me at my former home law office, while being hired by
Richard G. Hill and Casey Baker, Esq.. I submitted an IFP and propsed Complaint in
the District Court on October 19th, 2011 CV11-
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
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Print
Close
bar grievance against Richard Hill, Casey Baker, and Keith

Loomis, Roberto Puentes, Lew Taitel
Sent: Thu 10/18/12 8:02 AM
To: laurap@nvbar.org; patrick@nvbar.org; rosec@nvbar.org; glennm@nvbar.org;
davidc@nvbar.org; tsusich@nvdetr.org; complaint@nvbar.org; complaints@nvbar.org;
shornsby@nvdetr.org
To: laurap@nvbar.org; patrick@nvbar.org; rosec@nvbar.org; glennm@nvbar.org; davidc@nvbar.org;
tsusich@nvdetr.org; complaint@nvbar.org; complaints@nvbar.org; shornsby@nvdetr.org
Subject: LITIGATION HOLD NOTICE rev2011-001708 cv11-03628, 60331 61383, SBN v. Coughlin
CASE NUMBER NG12-0204, NG-0435, NG 0434
Date: Wed, 17 Oct 2012 16:59:57 -0700
Dear Office of Bar Counsel, Investigator Peters, Chairman Susich, et al,

Please find important attachments supporting the assertions herein here:
https://skydrive.live.com/redir?resid=43084638F32F5F28!3587
Please don't try to old "my IT guy said I couldn't open it, because of viruses and stuff".
That is no more plausible an excuse for reviewing materials material to your
investigation than would be suggesting your fear of "anthrax" potentially being mailed
to you prevents you from opening your paper mail...You have my personal guarantee
that there is no virus or other harmful items in any emails I send you or any paper
mail, either, for that matter. I submit these materials respectfully and ask you to
consider how being wrongfully incarcerated ten times in one year following a divorce
of sorts would affect our tone, behavior, or personality.
Loomis refused to advocate at all on my behalf, refused to subpoena material
percipient witness Merliss, and refused to make argument directed to issue I provided
wealth of support on, ie, the invalidity of the eviction order where the lockout
occurred outside of the "within 24 hours of receipt" window in the statue, and where
technical service requirements were not met, vis a vis NRS 40.400, NRCP 6(e), and
NRCP 5(b)(2), and where Loomis acted on matter during pendency of Competency
000246
file:///R|/...%20temp/10%2018%2012%20bar%20grievance%20complaints@nvbar.org%20loomis%20hill%20trespass.htm[12/10/2012 4:19:05 PM]
Evluation in cr12-0376.
Also, will you please have the NG- grievance or case numbers for all of the grievances
and complaints I have filed this year provided to me in writing, including the new
grievances found herein against Richard G. Hill, Casey Baker, and Christopher
Hazlett-Stevens?
note: please forward this written correspondence on to Bar Counsel King and
Investigator/Clerk of Court Peters in light of their apparent and sudden, somewhat
technical "issues" with emails from Coughlin, which in no way is interpreted as
providing indications that they now seek to sully the SBN's image by attempting to
add Coughlin to their blocked sender list or otherwise prevent any further duty
accruing on their part to actually investigate Coughlin's claims, in some manner that at
least a colorable argument can be made that the SBN treats Coughlin's and others
allegation with anywhere near the urgency it treats those of Judge Nash Holmes or
Richard G. Hill, Esq. (in contrast to the whole "attack dog for the rich and powerful"
image, some might say, the SBN has built up....
It is ironic, that Hill and Baker's own writing in their November 21st, 2011 Opposition
to Coughlin's November 16th, 2011 Motion to Contest Personal Property lien may
now be used against them, in light of the staleness, voidness, and invalidity of the
October 25th, 2011 and October 27th, 2011 Eviction Decision and Order and Findings
of Fact, Conclusions of Law and Order for Summary Eviction in RJC Rev2011001708. See Williams v Nagel, 643 N.E. 2d 816 and Wolf-Lillie, 504 F. Supp 1.
Baker wrote on Hill's behalf:
"Here, Coughlin filed his first motion pursuant to NRS 118A-460 on November
16,2011. That motion was timely. However, when the court attempted to set the
hearing, Coughlin refused to cooperate or communicate with the court to get the
hearing on calendar, despite repeated requests from Merliss' counsel that he do so. As
a sole and direct result of Mr. Coughlin's refusal to cooperate with the court to set his
own hearing, that hearing never happened. The 10 days in which to hold the hearing
under NRS 40.253(8) have now expired. Mr. Coughlin's motion is stale, and the relief
he seeks is now time-barred. Because he abandoned that motion, it was, effectively,
denied."
000247
To Baker's November 21st, 2011 Opposition (how clever, Baker writes it so he can
make reckless allegations that aren't true in it that Hill would not be so free to make,
given he was there during the November 12th, 2011 arrest), is attached the signed,
sworn, November 21st, 2011 Declaration of Richard Hill, which reveals at the least an
intent to mislead the tribunal by Hill, and also reveals Hill and Merliss contributed to a
false arrest to a material extent. That Declaration reads:
"4. On October 27, 2011, this court signed a summary eviction order, and on November 1, 2011, the Washoe County
Sheriffs Department served that order. The notice was posted on the door of the home by the Washoe County Sheriffs
Department in the manner customary in Washoe County for evictions. The locks on the front door and back door were
changed, and we retained all keys to the home.
5. After that date, I began to notice that it looked like somebody had been
getting into the home. On approximately November 4,2011, I became concerned about the
home and its contents. I entered it and was able to confirm that "somebody" had been getting in. I
thought I had secured the means of entry being used by whoever it was that
was getting in. However, on later visits to the home, it was clear that the home was still
being surreptitiously accessed.
6. On November 13, 2011, Dr. Merliss came to Reno because he wanted to
inspect the home. Upon entry, it was clear that somebody had again accessed the home.
7. We tried to enter the basement and found the door was barricaded, not locked, from the inside. We
were concerned that whoever had been accessing the home was inside, so we called the police.
8.
When the police arrived, they agreed with us that it was very likely that somebody was barricaded in
the basement. The police tried to coax the person to come out, but without success.
9.
When the police declined to break down the door, Dr. Merliss did so. The police looked inside and
discovered the defendant, Zachary Coughlin, and his dog.
10. Coughlin came out peacefully, went upstairs and was placed under arrest
by the police for trespassing.
11. After Coughlin was taken to jail, Dr. MerHss and I tried to videotape the contents of the basement
where Coughlin had been hiding. It was too dark to effectively videotape, but we were able to
ascertain that Coughlin and his dog have been living in th
basement ofthe home for quite some time, likely even before the lockout. I observed that Coughlin
had a bed set up. He had several computer monitors. He had a store ofhoth food
and water. He had electric space heaters.
12. Since the eviction order was served, my associate, Mr. Baker, and I had sent numerous emails to
Coughlin, in which we both repeatedly made it clear to him that he was not to be at the borne
without our prior permission. No such permission was given.
Mr. Coughlin had no reason to possibly think he was permitted on the property. We had
tried to coax him to cooperate on getting his possessions Qut, without success, or even a response.
13. As a result ofMr. Coughlin's break-ins, Dr. Merliss has incurred a bill of $1,060 with a licensed
contractor to secure the premises. That does not include the cost of the door that was broken in order
to get Coughlin out. That does not include the numerous hours of me and my staff to deal witb Mr.
Coughlin's repeated break-ins at the home.
14. I am no expert, but I believe Mr. Coughlin is wbat is called a "hoarder."
He has many car seats throughout the house. He has many dead televisions. He has a box of car
window servo motors. The attic, which can only be accessed through a very narrow
opening, is full of items, including dead electronic devices.
15. We have found drugs at the home. We found a bag of what looks like
marijuana on the kitchen counter. I found a crack pipe. The contractor found what he said
was a large quantity of pills.
16. Mr. Coughlin has been harassing and stalking me, and possibly, my staff.
000248
On Noyember 15, 2011, he burst into my office and created a scene. Then, he was parading up and
down the sidewalk across the street with a video camera screaming obscenities at
me and my staff. "
Now, if one reads that Declaration by Hill, then watches the videos Hill took of the moments
before, during, and after Coughlin's arrest for criminal trespass on November 13th, 2011...well, one
must conclude Hill and Merliss lied, and broke the law, resulting in profound reputational damage to
Coughlin and vast damage to his family and career. They should do time for this, period. Where, in
that Declaration, so soon after the arrest it is almost an "excited utterance" is Susich or Kings
allegation of "breaking and entering" and the "locks being broken"? Why wouldn't Hill just say that in
the Declaration if it was true? Where is the video of the basement that Hill mentions attempting to
take. There wasn't one provided in the materials Hill gave to the city attorney, which were discovered
to Coughlin. Why doesn't Hill correct his client when he lies, in front of the police, just before the
handcuffing moment, in response to Coughlin's query as to who exactly, in anyone, had told Coughlin
to leave, or issued a "warning". That basement was fixed up to be, basically, a studio apartment
addition to the main floor for over a year before the eviction, and Hill admits this appears to be the
case in another filing. Hill misleads the court above where he fails to mention the numerous times
Coughlin indicated he had added HIll to his "blocked senders list" and or indicated he did not consent
to any form of electronic service or notice of anything, and where Baker was on vacation in early
November. The video's Hill took title Zach's arrest 0007-0014, found at the above link, show
particularly well the fraud and criminal conduct by Merliss and HIll including lying to effectuate a false
arrest and criminal trespass and invasion of privacy.
What is actually stalid, invalid, void, null, expired, or otherwise ineffective is the
October 25th and 27th Summary Eviction Orders by Judge Sferrazza in light of the
WCSO's admission that on November 1st, 2011 (allegedly at 4:30 pm), Deputy
Machen broke into Coughlin's former home law office with Hill or Baker in tow (and
probably one of those lawyers legal assistant/videographers whom drive a new
Mercedes SL-600 convertible coup....the kind with a V-12 engine...that's right, a V12, $130,000 new, three times the engine found in Coughlin's four banger 1996 Honda
Accord LX (at least its not a DX, right?) with 110,000 miles on it):
All the case cited below are relevant, and most are terrible, for Hill, Baker and Merliss, in addition to
making the criminal trespass conviction extremely suspect:

Russell v Kalian, 414 A.2d 462
Roswick, 231 BR 841
Hammond, 515 SE 2d 182
Albert, 490 NYS 2d 951
000249

Woods 19 NYS 2d 683, Regan 425 NYS 2d 725, Iorio, 410 NYS 2d 195, Russell v Kalian, 414 A.2d 462:
expired warrant for eviction no good
Leese v Horne, 47 P.2d 316, Burhams, 89 P.3d 629, Roswick, 231 BR 841, Hammond, 515 SE 2d 182, Albert,
490 NYS 2d 951, O'Brien v. U.S., 444 A.2d 946, State v. MErnar, 786 A.2d 141 (01), Canavan v. State 38 So.
3d 885, Jordan V. State, 802 So. 2d 1180 (01), State v. Ash, 12 SW 3d 800 (TN '99). Jordan v. State 110 P.3d at
47, Williams v. Nagel 643 NE 2d 816, Koenig, 742 P.2d 649,Nelson, 909 NE 2 642, claim of right O'banion 519
SE 2d 819, Bean 465 P.2d 1441
attorney charged with "summary criminal contempt" one reported decision ever, In Re Kunstler. 606 NYS 2d
607.
Judge Nash Holmes continues to refuse to allow Couglin to appeal the "summary criminal contempt" Order,
even though, given the incarceration was served, it is a finally appealable order, see Gilman 275 V. Comm 474,
657 SE 2d 474.
Bifurcate disciplinary matters:
In re Porep (Nev. 1941) 111 P.2d 533, In re Kaemmer, 178 SW 2d 474, Terrell v. Miss. Bar 635 So 2d 1377,
Matt of Briggs 502 NE 2d 879, In Re Hines 482 A. 2 378, triem 929 P.2d 634, Smith 85 P. 524, In re Finsh 27
A. 3d 401, In re Character, 950 NE 2 177, Toledo v. Cook 88 NE 2d 973('07), Cohn, 151 SW 3d 477 ('04), In re
Crandell, 754 NW 2 501, In re Cobb, 838 NE 2d 1197, In RE Ginsberg 690 NW 2d 539, North Carolina Bar v.
Rogers, 596 SE 2d 337. Snyder 792 A. 2d 515
joinder/prejudice to Coughlin, 259 P.2d 7, In Re Richardson 692 A. 2d 427
000250

Woods 19 NYS 2d 683, Regan 425 NYS 2d 725, Iorio, 410 NYS 2d 195, Russell v Kalian, 414 A.2d 462:
expired warrant for eviction no good
Leese v Horne, 47 P.2d 316, Burhams, 89 P.3d 629, Roswick, 231 BR 841, Hammond, 515 SE 2d 182, Albert,
490 NYS 2d 951, O'Brien v. U.S., 444 A.2d 946, State v. MErnar, 786 A.2d 141 (01), Canavan v. State 38 So.
3d 885, Jordan V. State, 802 So. 2d 1180 (01), State v. Ash, 12 SW 3d 800 (TN '99). Jordan v. State 110 P.3d at
47, Williams v. Nagel 643 NE 2d 816, Koenig, 742 P.2d 649,Nelson, 909 NE 2 642, claim of right O'banion 519
SE 2d 819, Bean 465 P.2d 1441
Please indicate in writing what you have done to investigate Richard G. Hill's
allegations, as set forth in his January 14th, 2012 grievance against me, in writing,
including, but not limited to Hill's allegations vis a vis the criminal trespass arrest of
me in on November 13th, 2011, leading to a custodial arrest, and three traffic citations
by RPD Sargent Tarter following my release on November 15th, 2011 when I
ventured to Hill's office to retrieve my state issued driver's license, wallet (credits
card, money), and my client's files and my own files and hard drives and other
materials. This is a formal, written grievance against Richard Hill and Casey Baker,
in compliance with my RPC 8.3 obligations respecting their failure to turn over my
hard drives, driver's license, client's files and my own files, their impermissibly
influencing the RJC to fail to give me a hearing on my November 16th, 2011 filing of
a Motion to Contest Personal Property lien within the 10 days required by NRS
40.253(7)-(8) (hearing only took place after Richard's six week vacation, on
December 20th, 2011, in accord with Richard's written indication to me that he would
be able to get the RJC to wait that long on his account..., an impermissible suggestion
by Richard that he could improperly influence a tribunal, as was Richard threats that
he would have me given the Jordan v. State "vexatious litigant" treatment if I kept up
my opposition to his nefarious aims.
"Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
Date: Tue, 7 Feb 2012 11:40:39 -0800
From: LStuchell@washoecounty.us
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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"
Additionally, this is a grievance against Hill and Baker concerning their lying under oath at the
June 18th, 2011 criminal trespass from my former law office trial in RMC 11 CR 26405. Please review
the Claiborne decision for support for the contention that neither Bar Counsel King, SBN Investigator
Peters, or the SBN will find availing any argument that no investigation was required on their part
respecting those allegations (particularly during the 5 months period between Hill's January 14th,
2012 written, but unsigned, grievance to Pat King and the conviction on June 18th, 2012...certainly,
the SBN has taken an interest in my pending criminal matters...). In Claiborne, the SBN was taken to
task for making such a suggestion that no duty to investigate on their part was present, where the
Court ruled it clearly was...
Please review the sworn Declaration by Hill attached to his November 20th, 2011 Opposition to
Coughlin's Motion to Contest Pesonal Property Lien and that Opposition itself, especially the bit in
Hill's Declaration where he fails to allege the RPD identified themselves as law enforcement or issued
an "lawful order" for Coughlin to "emerge from the" "basement" (which never had an outside lock to
begin with) prior to landlord Merliss kicking the door down (and isn't is interesting that the RPD did
not feel it had authority to kick a door down...suggesting they also felt they did not have authority to
issue a "lawful order" or warning, pursuant to RMC 8.10.010 to Coughlin to leave the premises. I am
complaining of an unlawful trespass and invasion by Hill, Baker, and Merliss, especially where in the
other videos provided to Reno City Attorney Chris Hazlett-Stevens (and this is a formal grievance
against Hazlett-Steven's as well, especially considering the extent to which he put on perjured
testimony, failed to hold Hill to a subpoena, in violation of Coughlin's right to a speedy trial (during
the same 6 week vacation by Hill that resulted in the RJC failing to give Coughlin a timely Hearing on
his November 16th, 2011 filing of a Motion to Contest Personal Property Lien in the eviction matter
from Coughlin's former home law office in the RJC, REV2011-001708...a Motion for Continuance was
filed by city attorneys Hazlett, which Coughlin's then RMC appointed defense Counsel Lew Taitel failed
to timely inform Coughlin of and agree to (despite Coughlin, at that time, having filed a lawsuit
against Nevada Court Services, on October 19th, 2011 in CV-03051, CV11-03051 ZACH COUGHLIN VS.
MATT MERLISS ET AL (D1). 19-OCT-2011.
Further, any writings or filings by Bar Counsel King and or Chairman Susich that suggest or indicate
Coughlin committed a "breaking and entering" of his former law office, or that the "locks were broken"
is totally unsupported and reckless and contradicted explicitly by the videos Hill himself filmed and his
statements therein. Please correct any such filings and alert the Court to your transgressions.
Baker lied and violated NRCP 11 in his NOvember 21st, 2011 Opposition where he alleged the
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RPD identified themselves as law enforcement and issued a lawful order for Coughlin to emerge from
the "basement" or leave the property:
"Even though he had a week to do so, Coughlin did not remove his personal
belongings from the property prior to the lockout. In fact, he did not even remove himself
from the property. Unbeknownst to Merliss or his counsel, Coughlin continued to live in
the basement of the property until he was discovered squatting there on November 13. 2011
- nearly two weeks after he was legally locked out. Coughlin had barricaded himself, his
dog, and some of his presumably more cherished possessions in the basement. 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. Coughlin
was
arrested and charged with trespassing. Due to Coughlin's criminal activities, the security
ofthe house was compromised. As a result, Merliss was forced to incur costs in the amount
of $1,060.00 to secure the property in order to protect it and Coughlin's belongings. A true
and correct copy of the bill from the contractor is attached hereto as EXHIBIT 2."
Bakers NRCP 11 violation in his filing of November 20th, 2011 in RJC Rev2011-001708 occurs at
pages 1-3, where he attempts to mislead the tribunal in suggesting that Coughin failed to cooperate
in setting a Hearing on the Motion to Contest Personal Property Lien, even where Coughlin responded
to Hill's then email informing him of such a hearing, by Coughlin emailing Hill "Rich, you are aware the
files can be on hard drive's, right?" in response to HIll's email of a Hearing (Coughlin subsequently
revoked (and had made express previously written indication that no such acceptance of such
electronic service or notice would be availing respecting communications with Coughlin, and HIll was
added to Coughlin's "blocked sender list" on Coughlin's Hotmail account, as such, Coughlin did not
receive Hill's emails from October any implicit authority Hill may assert to provide Coughlin notice via
electronic means, and therein is vitiated any of Hill's testimony at the trespass trial that the "warning"
against trespass was relayed in Hill's various attempts at emailing Coughlin during the first few weeks
of November, including the period where Baker was on vacation and somethings appear to have
slipped through the cracks at the Hill law firm respecting notifying Coughlin in an accepted means of
service). Coughlin did not receive any emails from Hill's rhill@richardhillaw.com address between Hill's
email of August 16th, 2011 and November 18th, 2011, this Coughlin swears pursuant to NRS 53.045
under penalty of perjury:
Sent: Monday, November 21, 2011 3:15 PM
To: rhill@richardhillaw.com
Subject: RE: River rock
Rich, you are aware that "files" can include things on hard drives, right?
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
> From: rhill@richardhillaw.com

> To: zachcoughlin@hotmail.com
> Subject: River rock
> Date: Mon, 21 Nov 2011 14:53:03 -0800
>
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> Mr coughlin -this confirms a voicemail left for you

> I now have your drivers license & what I think are your client files.
> Don't know, didn't look that closely - your privacy & all.
>
> Will release them to you at the hearing tomorrow.
> Please confirm that the hearing is on calendar
>
> Rgh"
Coughlin appeared at the RJC for the Hearing he was noticed on for November 22nd,
2011 pursuant to the November 16th, 2011 filing by Coughlin of the Motion to Contest Personal
Property lien in RJC REV2011-001708. Hill failed to appeared. Further, Hill continued to lie about his
"offering to provide Coughlin" his client files, including those files on Coughlin's hard drives. Further,
at least one of Coughlin's hard drives, upon their finally being returned to Coughlin on December
22nd, 2011 (with one of the expensive laptop screens completely cracked...) indicated a video card
driver was loaded to the hard drive, including one on December 6th, 2011, during the period from
Coughlin's arrest of November 13th, 2011 to Hill's and Baker's finally returning Coughlin's client's files
and hard drives to him on December 22nd, 2011 (unless you count the instance where Hill playfully
set down a bag of trash and indicated to Coughlin "here is your client's files" at the time when
Hill finally returned Coughlin's state issued driver's license one full week after Coughlin had demanded
it, on November 22nd, 2011, something that Hill lied to the courts and the police about his willingness
to do so up to that time absent a coercive demand that Coughlin sign away his rights, including those
to his damage deposit. Further Hill violated Nevada law in placing demands upon Coughlin that
Coughlin remove his property in the exact manner and order that HIll demanded (Hill required
Coughlin to appear with certain vehicles and a "crew" of movers, and insisted Coughlin must remove
all the property on the former home law office's exterior prior to Coughlin being allowed to "cherry
pick" the items within that were of the most value, requirements for which there exists no support in
Nevada law for Hill to make, including within NRS 118A.460, all to the detriment of Coughlin's client's
concerns and the reputation of the Bar in Nevada and beyond. The RJC never needed Coughlin's
permission previously to set Hearings, including the one on November 7th, 2011 that Coughlin was
served an impromptu notice of while he was at the filing office on November 3rd, 2011, nor did the
RJC need Coughlin's permission to to set the October 13th, 2011 summary eviction proceeding date,
the October 25th, 2011 "Trial", or the December 20th, 2011 Hearing date.
Further 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 an allegation, there were no
"broken locks" ever mentioned by anyone (and if Hill is willing to make up finding a "bag of weed and
crack pipe" along with describing what Hill's own videos show to be vitamins as a "large quantity of
pills", then you know Richard G. Hill, Esq. would have been all over any "broken locks" at the former
home law office, yet, there simply were none, not that that would stop Pat King or J. Thomas Susich
from cobbling together such an allegation in the SCR 117 Petition 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 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 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 16th, 2011 Motion to Contest
Personal Property Lien (the Hearing was not set or conducted with the "10 days" required by NRS
40.253(7)-(8) because Richard G. Hill, Esq. needed to go on a six-week vacation shortly after
Coughlin's November 16th, 2011 filing (in a matter now on appeal in SCR 60331 and 61838, wherein,
somehow, a commercial tenant, Coughlin (whom was both running a law practice and Coughlin
Memory Foam, a foam mattress business from his home, which was previously utilized for commercial
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purposes by a drug and alcohol rehabilitation counseling business and is zone for mixed use purposes)
was summarily evicted based upon a No Cause Eviction Notice only (ie, the non-payment of rent was
neither noticed, pled, nor argued by the landlord) despite the clear dictate against the use of
summary eviction proceedings against commercial tenants not based upon the non-payment of rent
(Bench Book stuff) set forth in NRS 40.253. The December 21st, 2011 Order "Resolving" Coughlin's
Motion to Contest Personal Property Lien actually required Coughlin to pay the exact same amount of
rent for 17 days (November 1 to November 17th, 2011), $480 (ie, pro-rated from the $900 per month
rental agreement) as Coughlin would have under a "fair 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 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 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 Coughlin, Stuchell wrote: "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". The text of NRS 40.253 speaks to service of Lockout Orders:
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, 2011 (though not mailed to Coughlin
until after the November 1, 2011 lockout had allegedly already occured). That language is only found
in situations inapplicable to the one incident that in the summary eviction from Coughlin's former
home law office. NRS 40.253(3)(b)(2), and NRS 40.253(5)(a) are the only sections of NRS 40 where
this within 24 hours language occurs, and those situations only apply where, in: 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 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
and, 40.253(5)(a): 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 thereupon issue an order directing the sheriff or
constable 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 requirements attendant to serving Summary Eviction Orders and conducting lockouts
are found in NRS 40.253 in 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, 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 where one must file a Complaint within 90 days of
receipt of a Right To Sue Letter, a situation which 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 114 (1st 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 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 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.
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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.
However, in his January 20th, 2012 Second Motion for Order to Show Cause, Richard G. Hill, Esq. did
not get all bogged down in legal research and stuff, instead he just pointed out: "FACTS SHOWING
CONTEMPT OF COURT 6. EXHIBIT 1 (the Summary Eviction Lockout 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, thereby ejecting and dispossessing Coughlin of
possession of the Property." Hill went on to lie again in that January 20th, 2012 Motion when he
equated his offer to let Coughlin get some of the 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 to remove his property in exchange for Coughlin
waiving his rights to the $700 damage deposit Coughlin provided upon moving in, where Hill spins it:
"12. On Friday, December 23, 2011, Coughlin had a crew of helpers, and made progress.
Nonetheless, Coughlin failed to remove all of his belongings from the Property. Coughlin failed to
remove his things despite having been given additional time to do so after the time set by the Reno
Justice Court in its order of December 21, 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 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 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 abandoned on the Property. Coughlin's motion was fully briefed, and the Court entered
its order denying the motion on January 11, 2012. A true and correct copy of this Court's January
11,2012 order is attached hereto as EXHIBIT 3. 14. On Thursday, January 12, 2012, in accordance
with EXHIBIT 2 and EXHIBIT 3, a licensed contractor hired by Merliss began cleaning up the Property
and disposing of the abandoned items still remaining there. 15. Early that afternoon, while the
contractor was hauling the first of several loads of abandoned property to the transfer station (dump)
for disposal, Coughlin stopped the contractor in traffic and attempted to prevent him from carrying
out his task. 16. Specifically, Coughlin stood in front of the contractor's vehicle in an effort to prevent
him from proceeding to the transfer station. Coughlin threatened to sue the contractor. Coughlin
climbed up on the contractor's vehicle. Coughlin then called the police and falsely told them that the
contractor had stolen his possessions, and that the contractor had tried to run him over. Coughlin's
acts were specifically calculated to prevent the contractor from disposing of the abandoned property,
and to frustrate and interfere with Merliss' compliance with this Court's January 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 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") against 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."
The thing is, and Coughlin would sure like to get the 911 tapes (or, more likely, with Hill, any
recordings that may exist of Hill calling somebody in particular he may have had in mind with the
RPD) of calls by Coughlin (and if Wal-Mart can call 911 over a candy bar, or a skater board over an
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
unclaimed can call 911 (and make up a bunch of lies on the spot for the purpose of manipulating the
police into assuages the skateboarders own negligence vis a vis the iPhone) is it unreasonable for
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 are
pretty fungible, right? Who needs a TPO for that? And its not like the landlord could just accept rent
in the meantime, or that the property still remains unrented to this day, some 11 months after the
lockout, and apparently, some $60,000 worth of attorney's fees paid to Hill for a two bedroom home
that appraises at around $90,000 currently, if that. And Hill's fantastic legal work ("wrong site 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 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 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 WCSO, in violation of
Soldal v. Cook County where Coughlin was not accorded the "24 hours" cushion after Coughlin's
"receipt" of the lockout order mentioned in this Court's own packets on the service of Lockout Orders,
which Hill himself attached as a subsequent exhibit recently...It gets funnier. The civil division of the
Justice Court and the Sheriff's Office think that whole "within 24 hours" language in NRS 40.253
means "within 24 hours" of the Sheriff's "receipt" of the Order from the Justice Court...While other's
think it is "within 24 hours" of the tenant's receipt of the Order from the Sheriff...and this Court's
official forms and instructions seem to imply that "at least 24 hours" from "receipt" of the lockout
Order must be accorded to a tenant. Who knows? But, it is not clear, as Hill suggests, that the "usual
custom and practice of the Washoe County Sheriff's Office" is black letter law upon which Bar
grievances, custodial criminal trespass arrests, multiple Motion for Order To Show Cause, tens of
thousands of dollars in attorney's fees sanctions against a pro se appellant, etc. are warranted.
Somehow the District Court found a way to sanction Coughlin with $40,050 worth of attorney's fee in
that appeal of the summary eviction without holding a single hearing, well, 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 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 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 climb on Stewart's truck.
Hill needed a little "fact" to spice up his Motion to Show Cause just enough, and "Coughlin climbed up on the truck" was "just
the ticket", and Stewart did not mind going along for the ride, so long as... And none of the many videos from that day
actually show any of the Yosemite Sam cartoon villian type behavior Hill attributes to Coughlin in his wonderfully imaginative
Motion for Order to Show Cause and or Application for Order of Protection concerning the events involved in the jaywalking
custodial arrest Hill had Coughlin subjected to on January 12th, 2012.
Much like Hill's contractor, Phil Stewart, flat out lying in an affidavit when he swore Coughlin "climbed
up on" his truck, Hill similarly lied in an affidavit about Coughlin, apparently while "engraged" making
"physical contact" with Hill. On Page 2 of Hill's Affidavit attach to his Motion for Order to Show Cause,
January 20th, 2012, Hills attests: "5. On Friday, December 23, 2011, we unlocked the house at 9:00
a.m. as ordered. We overlooked the chain on the back gate. There was nobody at the house when we
were there. At approximately noon, my staff informed me 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 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 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
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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. At
least the audio of this incident was captured on tape. 13. Nevertheless, at 5:00 p.m. on Friday,
December 23,2011, counsel granted Coughlin and his agents additional, unfettered, and 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 contact" (which is a
damn lie anyways), in Hill's then associate Casey Baker, Esq.'s NRCP 11 signed January 3rd, 2012
Opposition, HIll's associate Baker will only go so far as to say that Coughlin, "at one point, charged
Mr. Hill and attempted to physically intimidate him." Baker was standing directly next to Hill during the
interacation wherin Hill swore, under penalty of perjury, that Couglhin "made physical contact" with
Hill). Sounds like Casey Baker, Esq. was not quite willing to "spice up" the 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 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 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 Oliver Miller, whom, upon information and belief,
urged Northwind's apartment maintenance man Milan Krebs to sign a fraudulent criminal complaint
against Coughlin for "disturbing the peace" on July 3rd, 2011, and again urged Superior Mini Storage's
Matt Grant to sign a similar baseless "disturbing the peace" criminal Complaint against Coughlin on
approximately September 21st, 2012 then there is more than a little indication that the RPD is out of
control and attempting to incite members of the public to sign fraudulent criminal complaints based
upon a retaliatory animus by the RPD towards Coughlin. Officer Weaver and Sargent Dye showed up
to an unnoticed July 5th, 2012 bail hearing for Coughlin, presided over by Judge Linda Gardner's
brother RMC Judge William Gardner (whom received Coughlin's timely Notice of Appeal of the criminal
trespass conviction, under NRS 189.010, yet failed to forward it on to the District Court, which
somewhat recently dismissed Coughlin's appeal in that matter, wherein Sargent Dye and Officer
Weaver testified under oath, with City Attorney Jill Drake singing backup, the the effectd that, despite
bail only being valid based upon one reason in Nevada (to secure the defendant's attendance at trial)
the "public health and 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 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 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 such misconduct can not, and will not, be tolerated. Such a retaliatory animus
towards Coughlin by the RPD is likely due to his September 7th, 2011 Complaint with respect to a
wrongful, retaliatory, and fraudulent arrest by RPD Officer Nicholas Duralde, which was accompanied
by extortionate threats by RPD Officer Ron Rosa that if Coughlin didn't cooperate they would "call the
Nevada Bar and let them know how you cooperated with our investigation. How's that runnin' for ya?"
While Duralde testified that he did not hear or recall Rosa's coercive threats to Coughlin just prior to
the arrest, the fact that Duralde echoed those threats by saying "Now, I can arrest you for larceny.
Now, I can do a search incident to arrest. How's that?" tends to undermine Duralde's contention that
"he doesn't recall" hearing anything like what Officer Rosa was capture on tape saying to Coughlin
just prior to the arrest. Upon making a Fourth Amendment violating arrest completely lacking in
probable cause, and smugly "joking" to Coughlin about the "benefits" associated with charging
Coughlin with a "felony", (at the time of the August 20th, 2011 arrest, the felony larceny amount limit
was $250 and above) compared to a misdemeanor (under some half baked "grand larceny" of an
allegedly lost or mislaid or abandoned three year old iPhone 3G that the alleged victim testified was
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only then worth "about $80-100" on eBay or Craigslist), ie, search incident to custodial arrest 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 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 during the scant 13
hours Coughlin had to move it. But, when Hill swears, on page 3, that: "Coughlin's access to the
house itself was never hindered.:" he is just "sippin' drank" or something, 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 his agents
additional, unfettered, and unlimited access to the outside of the property to remove any remaining
items. The only condition placed on that access was that Coughlin's helpers agreed to replace the
gate on its hinges as best they could. Coughlin and his agents failed to remove the remainder of
Coughin's property from the yard that night, and failed to put the gate back on the 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?
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 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 filing fee, and its not
really clear whether that date is when the check was cashed by the District Court, or whether the
Justice Court held on to the check for quit4e awhile before shipping it along 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 sneakily
indicating that you are looking at an old docket from the Justice Court from December 19th, 2012,
even though Coughlin made a big deal to you and the Justice Court, in writing, that he was
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
make all this argument based upon some old docket and the extent to which it fails to reveal or
"make clear" matters to which Hill had ready written notice of via his own e-Flex account and service
of filings upon him connected thereto, in addition to Coughlin's faxes, emails, and there might have
even been a service of a Notice of Posting Supersedeas Bond (need to check on that more), etc. in
connection with the depositing on December 22nd 2012, the $250 required for a stay 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 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 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 pay any
money to the court, he had been locked out of the property for six weeks. As such, any request for a
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stay was, and is, moot. At this point, Coughlin does not have any rights in either the real 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
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
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
$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 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 Order, its not an agreement, its not a settlement, etc, etc. and
the audio record clearly reflects that. NRS 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. In an action concerning a lease of commercial property or any other property for which the
monthly rent exceeds $1,000, the court may, upon its own motion or that of a party, and upon a
showing of good cause, order an additional bond to be posted 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 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. 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. 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
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
escaped prosecution that time, over they whole ladder deal. It never was made clear why the
contractor removed the ladder from the property, other than, perhaps, like the applying of a lock to
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.
Also, this is a complaint against Hill and his contractor for petty larceny of the ladder
from Coughlin's former law office, admitted to on tape on December 22nd, 2011 by Hill
(though the issue of whether they intended to "permanently deprive" Coughlin of the use
and enjoyment thereof may be grounds for debate, Hill should get to spend the next 12
months defending himself as Coughlin has from the onslaught of SBN, WCDA, and City of
Reno prosecutor investigation...otherwise...gee, doesn't it kinda being to mind Coughlin's
question to RPD Officer Chris Carter, Jr. while Coughlin was in cuffs during the custodial
arrest of November 13th, 2011 when Coughlin asked Officer Carter: "are you on Richard
Hill's payroll too?". Coughlin has faithfully reported on exactly what Officer Carter's response was,
however ill-advised a sarcastic response he may claim it to have been. Hill has failed to faithfully
report on just what he meant where he filed documents attesting to have found "a crack pipe and a
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bag of weed", a "vial of some sort", and "a large quantity of pills" and "drugs" in Coughlin's former
home law office.
Respecting Coughlin's written communications to HIll's office concerning Coughlin's express refusal to
accept electronic notice or service of anything from HIll's Office, includes the following:
Sent: Monday, November 21, 2011 4:10 PM
To: cdbaker@richardhillaw.com
Subject: RE: Merliss v. Coughlin
Casey, couldn't open them, and even if I could, I don't consent to service by email of pleadings, nor by fax. I have told you
that many times. I will file a Motion for Sanctions if you do not cease attempting to circumvent the procedural protections
accorded tenants. The only matter for which I consent to having you or your office contact me by email, is to tell me if and
when I can get my exigent client/law practice materials/state issued identification, etc. I refuse to accept service of
pleadings and motions you wish to sling through the courts at warp speed while withholding my mail and wallet. Come on!
Your better than this!
Zach Coughlin, Esq.
To: patrickk@nvbar.org; davidc@nvbar.org; nvscclerk@nvcourts.nv.gov
Subject: LITIGATION HOLD NOTICE rev2011-001708 cv11-03628, 60331 61383
Date: Mon, 15 Oct 2012 17:03:34 -0700
Mr. King,
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).
You might want to look at AB226 and the Committee on the Judiciary notes from March 31, 2011.
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
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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
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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 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.
(6) The amount of rent claimed due and delinquent.
40.280.
(7) A statement that the written notice was served on the tenant in accordance with NRS
(8) A copy of the written notice served on the tenant.
(9) A copy of the signed written rental agreement, if any.
(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.
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
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
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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 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
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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:
NRS 118A.242 Security: Limitation on amount or value; surety bond in lieu of security; duties and liability of landlord; damages;
disputing itemized accounting of security; prohibited provisions.
1. The landlord may not demand or receive security or a surety bond, or a combination thereof, including the last months rent, whose
total amount or value exceeds 3 months periodic rent.
2. In lieu of paying all or part of the security required by the landlord, a tenant may, if the landlord consents, purchase a surety bond to
secure the tenants obligation to the landlord under the rental agreement to:
(a) Remedy any default of the tenant in the payment of rent.
(b) Repair damages to the premises other than normal wear and tear.
(c) Clean the dwelling unit.
3. The landlord:
(a) Is not required to accept a surety bond purchased by the tenant in lieu of paying all or part of the security; and
(b) May not require a tenant to purchase a security bond in lieu of paying all or part of the security.
4. Upon termination of the tenancy by either party for any reason, the landlord may claim of the security or surety bond, or a
combination thereof, only such amounts as are reasonably necessary to remedy any default of the tenant in the payment of rent, to repair
damages to the premises caused by the tenant other than normal wear and to pay the reasonable costs of cleaning the premises. The landlord
shall provide the tenant with an itemized written accounting of the disposition of the security or surety bond, or a combination thereof, and
return any remaining portion of the security to the tenant no later than 30 days after the termination of the tenancy by handing it to the
tenant personally at the place where the rent is paid, or by mailing it to the tenant at the tenants present address or, if that address is
unknown, at the tenants last known address.
5. If a tenant disputes an item contained in an itemized written accounting received from a landlord pursuant to subsection 4, the tenant
may send a written response disputing the item to the surety. If the tenant sends the written response within 30 days after receiving the
itemized written accounting, the surety shall not report the claim of the landlord to a credit reporting agency unless the surety obtains a
judgment against the tenant.
6. If the landlord fails or refuses to return the remainder of a security deposit within 30 days after the end of a tenancy, the landlord is
liable to the tenant for damages:
(a) In an amount equal to the entire deposit; and
(b) For a sum to be fixed by the court of not more than the amount of the entire deposit.
7. In determining the sum, if any, to be awarded under paragraph (b) of subsection 6, the court shall consider:
(a) Whether the landlord acted in good faith;
(b) The course of conduct between the landlord and the tenant; and
(c) The degree of harm to the tenant caused by the landlords conduct.
NRS 118A.360 Failure of landlord to comply with rental agreement or maintain dwelling unit in habitable condition where cost of
compliance less than specified amount.
1. If the landlord fails to comply with the rental agreement or his or her obligation to maintain the dwelling unit in a habitable condition
as required by this chapter, and the reasonable cost of compliance or repair is less than $100 or an amount equal to one months periodic
rent, whichever amount is greater, the tenant may recover damages for the breach or notify the landlord of the tenants intention to correct
the condition at the landlords expense. If the landlord fails to use his or her best efforts to comply within 14 days after being notified by the
tenant in writing or more promptly if conditions require in case of emergency, the tenant may cause the work to be done in a workmanlike
manner and after submitting to the landlord an itemized statement, the tenant may deduct from his or her rent the actual and reasonable cost
000265
or the fair or reasonable value of the work, not exceeding the amount specified in this subsection.
2. The landlord may specify in the rental agreement or otherwise that work done under this section and NRS 118A.380must be
performed by a named person or firm or class of persons or firms qualified to do the work and the tenant must comply with the
specifications. If the person qualified to do the work is unavailable or unable to perform the repairs the tenant shall use another qualified
person who performs repairs.
3. A tenant may not repair at the landlords expense if the condition was caused by the deliberate or negligent act or omission of the
tenant, a member of the tenants household or other person on the premises with his or her consent.
4. The landlords liability under this section is limited to $100 or an amount equal to one months periodic rent, whichever amount is
greater, within any 12-month period.
5. A tenant may not proceed under this section unless the tenant has given notice to the landlord that the dwelling is not in a habitable
condition as required by this chapter.
NRS 118A.355 Failure of landlord to maintain dwelling unit in habitable condition.

1. Except as otherwise provided in this chapter, if a landlord fails to maintain a dwelling unit in a habitable condition as
required by this chapter, the tenant shall deliver a written notice to the landlord specifying each failure by the landlord to
maintain the dwelling unit in a habitable condition and requesting that the landlord remedy the failures. If a failure is
remediable and the landlord adequately remedies the failure or uses his or her best efforts to remedy the failure within 14
days after receipt of the notice, the tenant may not proceed under this section. If the landlord fails to remedy a material
failure to maintain the dwelling unit in a habitable condition or to make a reasonable effort to do so within the prescribed
time, the tenant may:
(a) Terminate the rental agreement immediately.
(b) Recover actual damages.
(c) Apply to the court for such relief as the court deems proper under the circumstances.
(d) Withhold any rent that becomes due without incurring late fees, charges for notice or any other charge or fee
authorized by this chapter or the rental agreement until the landlord has remedied, or has attempted in good faith to remedy,
the failure.
2. The tenant may not proceed under this section:
(a) For a condition caused by the tenants own deliberate or negligent act or omission or that of a member of his or her
household or other person on the premises with his or her consent; or
(b) If the landlords inability to adequately remedy the failure or use his or her best efforts to remedy the failure within 14
days is due to the tenants refusal to allow lawful access to the dwelling unit as required by the rental agreement or this
chapter.
3. If the rental agreement is terminated, the landlord shall return all prepaid rent and security recoverable by the tenant
under this chapter.
4. A tenant may not proceed under this section unless the tenant has given notice as required by subsection 1, except
that the tenant may, without giving that notice:
(a) Recover damages under paragraph (b) of subsection 1 if the landlord:
(1) Admits to the court that the landlord had knowledge of the condition constituting the failure to maintain the
dwelling in a habitable condition; or
(2) Has received written notice of that condition from a governmental agency authorized to inspect for violations of
building, housing or health codes.
(b) Withhold rent under paragraph (d) of subsection 1 if the landlord:
(1) Has received written notice of the condition constituting the failure to maintain the dwelling in a habitable
condition from a governmental agency authorized to inspect for violations of building, housing or health codes; and
(2) Fails to remedy or attempt in good faith to remedy the failure within the time prescribed in the written notice of
that condition from the governmental agency.
5. Justice courts shall establish by local rule a mechanism by which tenants may deposit rent withheld
under paragraph (d) of subsection 1 into an escrow account maintained or approved by the court. A tenant
does not have a defense to an eviction under paragraph (d) of subsection 1 unless the tenant has deposited
000266
the withheld rent into an escrow account pursuant to this subsection.
Mr's. Baker and HIll, would you not say it more accurate to characterize the situation in rev2011-001708 as one fitting under the NRS
118A.355 heading, particulary where the RJC, at the time of that summary eviction "Trial" had, according to Judge Sferrazza, no "local
rule" or "mechanism by which tenants may deposit rent withheld under paragraph..." and therfore acknowledging the brilliance in
Coughlin's JCRLV Rule 44 corollary in the RJC argument? Certainly, under the NRS 118A.355 analysis, after one strips away the agreed
to $350 for weeds maintenance (which kind of amounts to a waiver of term in the Standard Rental Agreement that Judge Sferrazza
interprets to require such "care" of the "lawn and surrounding grounds" (which, to the Court, apparently, included "weeds"), doesn't it?),
and the agreed upon credit for fixing the stairs, well, then, and other amounts fit quite nicely into the "fix and deduct" approach set forth in
NRS 118A.360. But, regardless, you proceeded under a No Cause Eviction basis, but against a commercial tenant, a fact you are stuck
with, as the Tenant's Answer, numerous phone calls to Baker, and many, many instances throughout the filings in that matter make clear
thta this was Coughlin's home law office, a commercial lease which the Standard Rental Agreement specifically allows for. And take a look
at that 2008 Winchell v Schiff seafood business goes under because of wrongful eviction case wherein damages accounting for the loss of
one's entire business (and what is a patent attorney's business worth, do you think, Dr. Merliss?) are allowable under Nevada law. Please
remit $450,000 to me within 7 days of this email being sent to you in satisfaction of this dispute against you, Dr. Merliss. Richard and
Casey, I will deal with you later, but your liability is on par with Dr. Merliss's, no doubt, and that is before the FDCPA stuff and the fact
that your office is not licensed as a bill collector.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
000267
Page 1 of 17
RE: cases being randomly assigned in RJC FW: attempt

to file prior to 5pm denied
From: Tuttle, Steve (stuttle@washoecounty.us)
Sent: Fri 2/17/12 10:40 AM
Cc:
Sferrazza, Pete (psferrazza@washoecounty.us)
That is your sole, complex interpretation of a (two) simple meeting requests to discuss court staff
related issues, which you declined both.
Steve Tuttle
Court Administrator
Reno Justice Court

Sent: Friday, February 17, 2012 10:09 AM
To: Tuttle, Steve
Subject: RE: cases being randomly assigned in RJC FW: attempt to file prior to 5pm denied
Oh, you must be referring to when Ms. Stancil called and indicated you told her to tell me I would need
to come in and meet with you and the Bailiff prior to the RJC agreeing to set for the Hearing on Motion
to Contest Personal Property Lien?
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
000268
http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=c9614f81-5996-11e1... 2/22/2012
Page 2 of 17
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521,
and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent
responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review,
dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is
confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work
product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that
any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this
information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s),
please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately.
Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other
applicable privilege.
Date: Fri, 17 Feb 2012 09:46:06 -0800
Mr. Coughlin:
I am in receipt on your six page email, which again is riddle with accusations and unfounded claims. I
do not see any new issues that necessitate a reply. However, I do feel compelled to address one
accusation regarding your perception of my management responsibilities. You claim I did not properly
investigate your allegations of sexual assault because I did not interview you thus being in violation of
U.S. law. Please check your emails on or about 11/30/11 where you were asked twice (once by Karen
Stancil for me and once by me directly) for a meeting to discuss your issues with court staff. You
declined both invitations. Steve
Steve Tuttle
Court Administrator
Reno Justice Court

Sent: Thursday, February 16, 2012 4:58 PM
To: Tuttle, Steve
000269
Page 3 of 17
Dear Court Administrator Tuttle,
I feel that you have misunderstood my import. Please consider that you and
others in the court are only human, whereas Richard G. Hill, Esq. is clearly a
lycan, who has also somehow managed to fashion himself and his brethren
into a sophisticated commercial law firm capable of distorting reality in ways
not commonly seen absent the administration of extremely potent
psychotropic drugs. There were no "assertions regarding "Judges Sferrazza,
Clifton and the Court's integrity" in anything I wrote you. There is a
difference between an "appearance" and a "reality", however, I think you will
find that "appearances of impropriety" are given considerable attention in the
Rules of Professional Responsibility, the Code of Judicial Conduct, and the
Model Code of Conduct for Judicial Employees in the State of Nevada.
Further, I think you will find that, contrary to your retaliatory assertions, my
duty to my client includes making a reasonably diligent effort to attempt to
access justice, and any subsequent excusable neglect analysis may, in fact,
call for making an attempt to inquire with court personnel or Sheriff's
Deputies in an attempt to address my concerns vis a vis the doors locking.
While you indicate the videos are the property of the Sheriff (quite a bit of
power for the Sheriff alone to own those videos) you do not make clear how
it is that you are able to review them, while at the same time, seemingly
disclaiming any liability for the negligent hiring, training, or supervision of the
various Deputies you supervise and or work with at the RJC, especially, vis a
vis their propensity to tell litigants that they will have objects forcibly inserted
into their anuses should such litigants in any way question the cold, hard,
authority of these Sheriff's Deputie's jackboot.
What is not clear is why Judge Clifton would handle all the other cases on the
stacked docket of 2/13/12, beginning at 8:30, but then, after Chief Bailiff
Sexton came into the Court Room with Bailiff Reyes (whom I have been
forced to file for a Protection Order against just recently) and made some
phone calls, Judge Sferrazza replaced Judge Clifton. Further, while Judge
Sferrazza explained the non-appearance of Judge Lynch by indicating that
Judge Lynch was instead scheduled to do traffic court that day, Chief Civil
Clerk Stancil indicated today that, in fact, Judge Lynch was hearing matters
000270
Page 4 of 17
on a criminal calendar.'
Regardless, I certainly have not impugned the credibility of any of the fine
judges of the RJC. However, your jumping to being "insulted" and failing to
ask me anything about these incidents involving threats to insert objects
inside of my anus leaves a bit to be desired, in my humble opinion, from the
perspective of a member of the public appearing in your court as a litigant.
You wrote: "You were not denied by this Court your right to file these
documents yesterday. You were, however, denied by Washoe County Sheriff
Court Security Unit access to the building after closing time; the same as
anyone else would be denied. You were not here before 5:00pm and trying
to gain access into the facility by coming through an exit only door is not
permissible."
I don't agree with your assessment, but I apologize for the annoyance this
seems to have caused. I hope you will consider that the date on which this
occurred was the last day to file a pre-trial motion (under NRS 174.125, such
motions, including a "motion to suppress" the fruits of an unlawful search by
law enforcement) in a matter for which I am a criminal defendant, and for
which a conviction could result in me being disbarred as an attorney, in
addition to fairly substantial criminal penalties, including incarceration. There
are a lot of things that can go wrong on the way to an innocent man being
convicted of a crime. One key area involves the failure to preserve for appeal
important issues. Such were the content of the documents I sought to filed
on February 14th, 2012. Additionally, only yesterday was I finally informed
by the RJC, criminal division, that I may file by fax. I have previously been
told that I may not file by fax. Further, today Ms. Stancil, Chief Civil Clerk,
informed me that I may also file by fax in the Civil Division. I am quite
certain I have requested permission to do this before in both the civil and
criminal divisions and have been told I may not every single time. This
relates to your recent commentary on "favoritism" and applying the rules
evenly to all litigants. I am sure I have heretofore been disallowed from filing
by fax. Indeed, I have spent countless hours of my time travelling out of my
way, down to the Reno Justice Court, to file each and every document that I
have filed in the few cases I have had in your court (and most any lawyer
000271
Page 5 of 17
will tell you that their "time" is the only thing a lawyer is much able to sell to
anyone for the purpose of making a living, something which, I assure, has
been an enormous struggle for me this past few years). You are aware of
just how enormous the file is in RJC Rev2011-001708. I guess some would
say that is my fault, though I would counter that the law is rather clear that
NRS 40.253's summary eviction proceedings are forbidden against
commercial tenants where the non payment of rent is neither alleged nor
Notice of such is posted or served, as here.
Mr. Tuttle, you know as well as I do that there is a turnstile that only turns
one way that would obviously present any such attempt to gain access.
Further, the door you are referring to is not marked "exit only", and your
assertions that I was "trying to gain access to the facility" is so transparent
that it is disturbing considering your position with the court. I clearly knocked
on the window and waived to Deputies in an attempt to ask them my
questions. Surely, the video you reference easily show this. Additionally, you
do not mention exactly what time "after 5 pm" the video showed, and I find
that curious. Further, you do not mention any system in place to assure that
the time stamping on the video is in accord with the official United States
time at www.time.gov. Indeed, the RJC or the Sheriff are not the only one's
in the this world with cameras and clocks, and it might be very interesting to
see a documentary of several days worth of footage of just when exactly the
doors lock, synced to a visual time stamping verified to be accurate vis a vis
www.time.gov. If such a video did exist, you don't sound like you would be
too interested in seeing it. Please correct me if I am wrong.
You further wrote: "Because your actions could be consider trespassing is the
reason why Reno Justice Court Chief Bailiff Michael Sexton again asked you
to leave. Fair and equal access to justice applies not only to discrimination,
but also to favoritism. Allowing one party to file documents after a deadline is
unethical and without question unfair." Your interpretation of the crime of
"trespassing" is interesting. I guess, under your approach, Richard G. Hill,
Esq. would be guilty of trespassing where, at the 12/20/11 Hearin on
Tenant's Motion to Contest Personal Property Lien, after the Tenant invoked
the Rule of Exclusion, and Judge Sferrazza ordered Hill and other prospective
witnesses to leave the court room, where Hill surreptiously snuck back in the
court room, found time during a recess to announce to myself Bailiff Reyes
and Chief Bailiff Sexton that Hill too would like to "put his boot up Coughlin's
ass", and then manage to sneak back into the court room during the
proceeding, and have Bailiff Sexton pass post-it notes from behind the Bar to
000272
Page 6 of 17
a struggling Casey Baker, Esq., whom was attempting to apply and unlawful
rent distraint under the guise of "reasonable storage" expenses.
At $30 a day for "reasonable storage" expenses, Judge Sferrrazza's Order

was more in line with what one gets in a room at the Sand's for a day,
complete with the full use and occupancy of the room, heat, plubming, light,
and premium cable television, and wi-fi access. $30.00 a day for "reasonable
storage" of that which could fit in a 10 by 30 foot storage shed (which
typically cost $125 per month, or about 1/8th of what Judge Sferrazza ruled
would be a reasonable daily storage charge, in the great Reno area). This
$30.00 a day storage charge is made all the more questionable by the fact
that the locations where all these items were being "stored" (and for which a
bill for $1,060 to "secure" this "storage" was filed with the RJC) was actually
burglarized on December 12th, 2011, while under Hill and Baker control, and
many valuable were stolen, though neither Hill nor Baker ever provided
anything close to a reasonable detailed inventory of what was there prior to
the burglary and what remained after the burglary. The did manage to notice
that a 62 inch Television was missing, though.
I agree with your assessment that it would be unethical and without question
unfair for the criminal division filing office to ask a "red headed step child"
litigant "who is calling" on the phone when they inquire with court personnel
as to whether the court will, in fact, remain open, all the way up to the
posted 5pm closing time, and then for the door's to the court to, ever so
curiously, be locked prior to 5 pm when said redhead presents to access
justice, and even more so where a court administrator and Chief Bailiff then
arrange a version of the facts to explain away their actions and decisions,
replete with menacing allusions to retaliatory prosecution, etc., etc. You are
right about that, Sir.
You further wrote "Informing Chief Bailiff Sexton of your intention to wait
outside for Reno Justice Court employees to leave so you could force them to
take your filings is a form of harassment and needs to stop immediately. If
this aggressive behavior continues, the Court will consider a protective order
against you, which will result in your ability or privilege to access Reno
Justice Court." Well, it does seem somewhat untoward that you are now
000273
Page 7 of 17
threatening to file a protective order merely because a litigant asked to speak

with a supervisor regarding the court's doors locking prior to 5 pm. This is
particularly troublesome where you make accusations of such a litigant
engaging in "aggressive behavior" when, in fact, it is your own Chief Bailiff
Sexton and Bailiff Reyes who have both engaged in bullying behavior
towards litigants, replete with the ever so professional threats to forcibly
insert objects into a litigants anus, and other menacing commentary related
to a litigants "ass", particularly where such commentary occurred while said
litigant was attempting to access justice in the most basic way (by presenting
documents to be filed with the filing office, during hours for which the court
holds itself out as open for business).
You further wrote: "In addition, I have looked into your assertions of sexual
assault by the Reno Justice Court Bailiffs and found these allegations to be
without merit." However, in your "looking into" these "assertions of sexual
assault" you have neither met with me nor interviewed me or otherwise
conducted anything close to a reasonably diligent inquiry, something which
you may have a duty to perform with respect to any negligent hiring,
training, or supervision claim or other 42 USC Sec 1983 claim a member, or a
class of members of the public may have. But you seem to suggest that you
do not bare any responsibility for the actions of the WCSO Court Security
Unit's actions. However, if that is the case, one must wonder why you would
have "looked into your assertions of sexual assault by the Reno Justice Court
Bailiff's" or why you refer to said Bailiff's alternatively as "Reno Justice Court
Bailiffs", while elsewhere using the designation Washoe County Sheriff
Court Security Unit.
You went on to write in another recent correspondence: "1) The locking of

the front doors to the Courthouse is the responsibility of the Sheriffs Office,
so all your questions regarding this issue will need to be directed to them.
However, I will state that the surveillance videos, which are dated and time
stamped, clearly shows that you were here after 5:00pm on 2/14/2012."
Well, the videos may technically show I was "here after 5 pm", but it is
curious you do not write that the videos show that I "did not arrive until after
5 pm"...or otherwise get very specific.
000274
Page 8 of 17
Please be aware that this correspondence places you on a LITIGATION HOLD

NOTICE with respect to any and all recordings made in conjunction with this
matter, and further, with regard to any recordings made concerning me
whatsoever. PLEASE PROVIDE ME WITH A COPY OF THE VIDEO YOU
REFERENCE, COMPLETE WITH THE TIME STAMPING AND A WRITTEN
ATTESTATION AS TO THE PRACTICE IN PLACE TO ASSURE THE ACCURACY
OF THE TIMESTAMPING.
You go on to write: "3) I am not sure what your question is regarding your
11/16/11 filing - Motion to Contest Personal Property." By all means, let me
elucidate this matter for you more clearly. Please see the attached 1/5/12
Reply to Opposition in the appeal from this matter, in CV11-03628 wherein
the RJC's liability for failing to appropriately carry out the dictates of black
letter Nevada law found in NRS 40.253(7)-(8) is quite clearly pronounced.
Further, I was never provided or served a copy of (until the filing of the
Record on Appeal, well after the 12/15 and 12/17/11 entries in the docket,
which preceded the 12/20/11 Hearing on Tenant's Motion to Contest
Personal Property Lien) the two statements the RJC seemingly order Deputy
Clerk Jocelyn Jonas and Chief Civil Clerk Karen Stancil to place in the file in
RJC REV2011-001708.
In that Reply, in page 7 of 24, one' finds the following: 4. Funny thing about the
Reno Justice Court: when it comes to setting a hearing within 10 days of my filing Motion to Contest
Personal Property Lien on November 16th, 2011, the RJC is all "oh, we needed your permission, Mr.
Coughlin, to set such a hearing, its your fault that we couldn't get it on within the 10 days required by
statute under NRS 40.253(7-8); however, when Coughlin went in to file something on November 3,
2011 at 4:58pm, RJC filing office Chief Clerk Karen Stancil didn't need no permission to serve personally
on Coughlin Notice of a Hearing to take place on Monday, November 7, 2011. Well, actually,
allegathetically, another clerk (Deputy Clerk Christine Erickson) had to sneak that Notice of the Hearing
on November 7, 2011 into a stack of papers she slipped Coughlin when she was pretending to be helpful
for a change, rather than sullen, and overly opinionated for someone who cares so little of the import of
the Whitman, Donoho, Byrant, and Sullivan decisions of the Nevada Supreme Court with respect to court
employees legislating from the filing office desk and refusing to accept filings because they just aren't
feeling it that day.... You see, somebody at the RJC figured out that it probably was not legal to hold on
to Coughlin last $2,275 on earth if it was not granting him a stay (especially where NRS 40.385 entitles
Coughlin to one, for his posting a bond as little as $250 (instead the RJC kept Coughlin's $2,275, and if
you believe Hill, did not grant a stay) as, in Judge Sferrazza's words, that would be "conversion". So,
how again is it Mr. Hill's outrageous allegations of Coughlin living here or there during this or that period
(something which Hill never bothers to support with anything other than his own bluster, hot air, and
conjecture, and apparent willingness to to incur NRCP Rule 11 sanctions if it means milking a willful
neurosurgeon good and dry in the process) are reasonably based in fact or law and therefore not worthy
000275
Page 9 of 17
of NRCP 11 sanctions?
Regardless, the RJC did set a Hearing on Tenant's Motion to Contest Personal Property Lien, and Tenant
did show up for it, in face, he checked in with Chief Bailiff Sexton prior to that Hearing, which was set
for November 22, 2011. However, Tenant was the only one who showed up. Should that not yield a
default victory?
However, more troubling is the RJC's conduct in forcing two of its filing office personnel to sign
unsworned "statements", one month after some alleged conversation incident to a litigants visit to the
filing office, and further, where Deputy Clerk Jocelyn Jonas was called to testify by Judge Sferrazza,
would conducted a leading examination of the Court's witness, in a matter where the Court was not
even a party. Most troubling of all, however, it the fact that Ms. Jones, on cross-examination had to
admit matters that show here statement of December 15th, 2011 to be misleading, at best, and wholly
deficient in fulfilling the RJC's duty to maintain an appearance of impartiality towards all litigants. It is
simply impermissible for the RJC to have Ms. Jonas sign and unsworn "statement" (truly a new one to
me, being neither a notarized Affidavit, nor a Declaration made under "penalty of perjury" in lieu of an
Affidavit. However, when Ms. Jonas did get sworn in at the 12/20/11 Hearing, a few unpleasant truths
emerged. One, Ms. Jonas was forced to admit that she did recall having a discussion with Tenant
Coughlin in RJC REV2011-001708 about the requirement that the RJC comply with NRS 40.253(8) which
reads:
Upon the filing of a motion pursuant to subsection

7, the court shall schedule a hearing on the motion. The
hearing must be held within 10 days after the filing of
the motion. The court shall affix the date of the hearing to
the motion and order a copy served upon the landlord by
the sheriff, constable or other process server. At the hearing,
the court may:
"NRS 40.253(8):
(a) Determine the costs, if any, claimed by the landlord

pursuant to NRS 118A.460 or 118C.230 and any accumulating
daily costs; and
(b) Order the release of the tenants property upon the
payment of the charges determined to be due or if no charges
are determined to be due.
One thing you may notice about the jurisdiction granted to the Court, above, in NRS 40.253(8), is that
there is decidedly not any language allowing for an Order "Resolving" Motion to Contest Personal
Property Lien like that Judge Sferrazza entered on 12/21/11, and for which the RJC filing office has
refused to allow me to file a Notice of Appeal for, and has further refused to even mark as "received" my
attempts at so filing Such a Notice Appeal and Motion to Proceed on Appeal In Forma Pauperis (to the
extent that would even be necessary considering the previous IFP status given the Tenant in that
000276
Page 10 of 17
matter, RJC REV201-001708). That 12/21/11 Order is included following this corrspondence.
Coughlin is also the Defendant in this criminal matter, which is also before Judge Sferrazza, RCR11063341....Judge Sferrazza is now seemingly being placed onto another landlord tenant matter where
Coughlin is a named party, despite JCRRT 2 calling for a random assignment of cases (Judge Lynch was
randomly assigned to the case originally, RJC2012-074408, Coughlin v. Park Terrace HOA, and, also,
Judge Sferrazza is now set to also take jurisdiction over the unlawful detainer matter that shall soon be
filed upon Coughlin filing a Tenant's Affidavit upon the proper service of a 5 day Unlawful Detainer
Notice to Quit). This is not about impugning Judge Sferrazza as a jurist. Its about criticizing and seeking
redress for the appearance of impropriety created where WCSO Bailiff's engage in conduct that is
impermissible (threatening to forcibly insert objects up a litigants anus) and then create an unduly
suspicious appearance of "judge shopping by Bailiff" (Why these Bailiff's seem to want to insult an
esteemed jurist like Judge Sferrazza, one who has an extraordinary depth and breadth of experience
throughout all three branches of government in Washoe County, is puzzling and unfortunate). It would
not take much for these Bailiff's to gather an opinion on which judges have which approach on landlord
tenant matters. It would be impermissible to allow Bailiff's go grudge based judge shopping to retaliate
against litigants asserting their consitutional rights, as Coughlin clearly does, much to their totalitarian
dismay. Judge Sferrazza has an approach to landlord tenants matters that is his own, as all judges
invariably will. That does not make him and impartial arbiter or imply any impropriety. However, to allow
RJC Bailiff's to "gerrymander" what is supposed to be a random assigning of cases, would clearly be
impermissible. Even if that is not what is occurring here, a reasonable person could concluded that the
appearance of such is evident. This is particularly true where Judge Clifton was on the bench and heard
every other case set for the 8:30 stacked docket in court room "B" on 2/13/12. Mr. Tuttle did not get
where he is by being foolish or dim. He must work day in day out with these Bailiffs. Mr. Coughlin is but
a minor occasional litigant/attorney in the Reno Justice Court. Reasonable minds may feel it would be
foolish for Mr. Tuttle to take any action which would appear to undermine his belief in the
reasonableness and justness of these Bailiff's actions, particularly where these brave men are called to
perform the heroic in truly dangerous circumstances at times. That is where rules get to be the "bad
guy" rather than judges or administrators. JCRRT 2 is the bad guy here, and it is only appropriate for
Judge Lynch to hear both this new Complaint for Unlawful Interruption of Essential Services, in addition
to any Summary Eviction and or Unlawful Detainer matter that may arise between those parties and
within a common nexus of circumstances and facts.
Also: "The justices' judgment obligation to pay attorneys' fees is based (1) on
their having followed a procedural rule (JCRCP 106) enacted by this court
and (2) on their having made several erroneous judicial decisions." Lippis v.
Peters, 112 Nev. 1008, 921 P.2d 1248 (Nev. Aug 16, 1996); G.C. Wallace,
Inc. v. Eighth Judicial Dist. Court of State, ex rel. County of Clark, 262 P.3d
1135, 1140+, 127 Nev. Adv. Op. 64, 64+ (Nev. Oct 06, 2011) (NO. 56773) "
HN: 2,3,4 (P.2d) 2 Schneider v. Elko County Sheriff's Dept., 17 F.Supp.2d
1162, 1165 (D.Nev. Aug 06, 1998) (NO. CV-N-96-548-ECR) Mentioned 3
Cheung v. Eighth Judicial Dist. Court ex rel. County of Clark, 124 P.3d 550,
552, 121 Nev. 867, 869 (Nev. Dec 15, 2005) (NO. 42212) HN: 1 (P.2d); "42
U.S.C. 1988 (1991). This federal statute permits the state courts to award
attorneys fees to successful civil rights litigants in civil rights actions brought
in the state courts under 1983. The cited code provision, section 1988,
000277
Page 11 of 17
allows for an award of fees to the prevailing party when that party has
sued to enforce a provision of ... 42 USCS 19811983. Even if we were
to recognize the tenants as the prevailing party in this litigation, it is more
than clear that this action was in no way designed or pleaded to enforce a
provision of ... 42 USCS 19811983. In their points and authorities in
support of their application for *1015 attorney's fees the tenants agree that
[i]n order to state a claim under 1983, Plaintiffs must allege a person has
deprived him or her of a federal right and the person so depriving acted
under color of state law. In no instance did plaintiff tenants ever allege
[that] a person has deprived him or her of a federal right. Lippis v. Peters
112 Nev. 1008, 921 P.2d 1248.
Sincerely,
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C.
2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended
recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this
document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this
information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain
information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the
intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be
taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in
error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy
any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any
attorney-client, work product, or other applicable privilege.
Date: Thu, 16 Feb 2012 09:46:45 -0800
CC: psferrazza@washoecounty.us
000278
1)
Questions regarding clocks asked and answered.
2)
Page 12 of 17
Assertions of a countywide conspiracy are unfound and insulting.
3)
4)
5)
Case judge assignments are random, but hearing judge assignments are at the discretion
of the court and cases will be moved for a variety of reasons, mostly to ensure continuity
and caseflow efficiency.
Statements regarding your ass asked and answered.
Assertions regarding Judges Sferrazza, Clifton and the Courts integrity are unfound and
insulting.
Steve Tuttle
Court Administrator
Reno Justice Court

Sent: Wednesday, February 15, 2012 10:29 PM
To: Tuttle, Steve; Lynch, Patricia
Subject: cases being randomly assigned in RJC FW: attempt to file prior to 5pm denied
Dear Mr. Tuttle,

Would you please confirm that the clocks in the court are
accurate, and indicate how the doors are locked, and
how they were locked yesterday. It is my position that I
was there prior to 5 pm, further the appearance given by
the fact that the person I spoke with on the telephone
from the criminal division filing office (she made sure to
ask for my name, as though that would affect the content
of her answer to my questions-contrary to your a
ssertions, I am seeking no special privilege, but rather,
seeking to avoid any special prejudice) made sure to ask
000279
Page 13 of 17
my name, and it was provided is troubling when viewed

in conjunction with the events before my 2/13/11
Hearing in the RJC in Coughlin V. Park Terrace
Townhomes HOA. As you know, JCRRT Rule 2 requires
cases be assigned randomly. However, though Judge
Lynch was assigned to hear my Complaint for
Interruption of Essential Services, shortly before the
hearing, the court room was popuplate by two different
Deputies who have both made menacing statements to
me involving my "ass", one of which involved forcible
putting an object up my "ass". Chief Deputy Sexton
entered the court room and made a few calls, and he is
one of the two Deputies to which I refer when
mentioning this "ass" situation. Next thing I know,
Judge Sferrazza is hearing the case, and now I am told
Judge Sferrazza is "attached" to the case instead of
Judge Lynch. While hearing the case, before it was
continued, Judge Sferrazza apparently granted a license
to practice law to a property manager on behalf of
another named party, the Park Terrace Townhomes
HOA. I feel this case should be heard by Judge Lynch.
This is not a statement against Judge Sferrazza, it is a
statement with respect to the appearance created by the
above facts. This, combined with the unexplained
October 19th, 2011 fax to Judge Clifton seeking an ex
parte Order allowing inspection of my law office by Casey
Baker, Esq. of the Law Offices of Richard G. HIll, Esq.,
despite Judge Clifton not being Chief Judge at that time
in consideration of JCRCP 84.
Sincerely,
Zach Coughlin, Esq.
Zach Coughlin, Esq.
1422 E. 9th St. #2
000280
Page 14 of 17
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
To: stuttle@washoecounty.us
Subject: RE: attempt to file prior to 5pm denied
Date: Wed, 15 Feb 2012 22:15:02 -0800
Dear Mr. Tuttle,

Your correspondence contains numerous inaccuracies that I am
too pressed for time to counter at this point. I appreciate your
response though. Can you confirm that the clocks in your court
are correct? Deputy Sexton agreed to get a supervisor and it
was agreed I would wait outside to speak to one. You, of
course, have been informed numerous times previously of WCSO
Court Security efforts to deny the access to justice prior to the
5pm closing time. I am still waiting for some response from you
regarding the various statements concerning my "ass" by those
you have some supervisory position over. Further, can you
please indicate why I was, apparently, provided some demand
whereby I would perform the duty placed upon the WCSO
incident to my 11/16/11 filing of a Motion to Contest Personal
Property Lien vis a vis the service and scheduling dictates found
in NRS 40.253(7)-(8), especially considering the holding in Lippis
and NRS 42.
Sincerely,
Zach Coughlin, Esq.
1422 E. 9th St. #2
000281
Page 15 of 17
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
Subject: RE: attempt to file prior to 5pm denied

Date: Wed, 15 Feb 2012 15:57:32 -0800
CC: JGoodnight@washoecounty.us
Mr. Coughlin:
The documents that you emailed and faxed to Reno Justice Court at 6:40pm on February 14, 2012 were
filed stamp with todays date (February 15, 2012) and placed in the file for the Judges review. It will be
noted that these documents were received by the Court after normal business hours on February 14,
2012.
You were not denied by this Court your right to file these documents yesterday. You were, however,
denied by Washoe County Sherriff Court Security Unit access to the building after closing time; the
same as anyone else would be denied. You were not here before 5:00pm and trying to gain access into
the facility by coming through an exit only door is not permissible. Because your actions could be
consider trespassing is the reason why Reno Justice Court Chief Bailiff Michael Sexton again asked you
to leave. Fair and equal access to justice applies not only to discrimination, but also to favoritism.
Allowing one party to file documents after a deadline is unethical and without question unfair.
000282
Page 16 of 17
Informing Chief Bailiff Sexton of your intention to wait outside for Reno Justice Court employees to
leave so you could force them to take your filings is a form of harassment and needs to stop
immediately. If this aggressive behavior continues, the Court will consider a protective order against
you, which will result in your ability or privilege to access Reno Justice Court.
In addition, I have looked into your assertions of sexual assault by the Reno Justice Court Bailiffs and
found these allegations to be without merit.
Lastly, your practice of filing hundreds of documents on multiple cases and then repeatedly asking for
copies of the case files free of charge will no longer be granted by the Court. Reno Justice Court will
provide you one free copy of your original case files and one free copy of any future filings , but you will
be charged appropriately for all additional copies.
Steve Tuttle
Court Administrator
Reno Justice Court

Sent: Tuesday, February 14, 2012 6:40 PM
To: Tuttle, Steve; Goodnight, Joseph W; Young, Zach; RJCWEB
Subject: attempt to file prior to 5pm denied
Dear Reno Justice Court Administration and Filing Office, DDA Young and DPD Goodnight,
Hello, I am emailing and faxing the document and one exhibit you will find herein as I was denied my
right to file it today. I presented to the court prior to 5pm today but was prevented from filing this
document (and today is the last day to file these pretrial motions absent receiving leave of court to do
so prior to the February 29th, 2012 Trial in Department 2 before Judge Sferrazza. Judge Sferrazza has,
in the past, expressed displeasure with regard to any attempt to file by email, and I do not wish to upset
Judge Sferrazza here, and accordingly am not copying him on this correspondence. However, I believe
the "excusable neglect"/"deprivation of rights under color of law" analysis may dictate that I promptly
attempt to make some record of my attempt to file and in that regard I am submitting this to you now.
Incidentally, I did call the criminal division RJC filing office today shortly before 5pm alerting them to my
imminent attempt to access justice and received confirmation that they would not close prior to 5pm.
HOwver, the doors of the court house were locked prior to 5pm. I have witness timers/clocks in the
court to be set approximately 5 minutes fast in that past. I attempted to ask a supervisor about this by
000283
Page 17 of 17
alerting Chief Deputy Sexton, and while he initially refused to get a supervisor, he then finally indicated
he would, however, no supervisor ever appeared. Chief Deputy Sexton, along with another Deputy has
sexually assaulted me in that past, and as such, of course, the was a very unusual and uncomfortable
situation.
Additionally, I had another landlord tenant hearing involving myself on Monday, 2/3/12. AS per JCRRT
my case was randomly assigned to Judge Lynch. However, just prior to my case being heard, Deputy
Sexton entered the court room, made some calls, and Judge Sferrazza appeared to hear my case.
Judge Sferrazza then proceeded to grant a property manage a license to practice law on behalf of Park
Terrace Homeowners Associations (PTHOA). I, of course, am very uncomfortable having the Deputy
who sexually assaulted me appear in the court room at all my appeances, as Deputy Sexton seems to do
(in fact, he glowered over me at the 12/21/12 Hearing on my Motion to Contest Personal Property lien)
in such a menacing fashion that I was unable to think clearly, much to the detriment of my case.
Further, I am uncomfortable at the appearance given off by the curious changing of the Judge assigned
to my hearing after Deputy Sexton entered the court room and made a few calls. It may be
inappropriate to give off the appearance that Deputy Sexton is able to control the assignment of Judges
to certain cases rather than having cases randomly assigned pursuant to JCRRT. I believe this filing and
one exhibit you find herein should be accorded a filing date for 2/14/12, as I was prevented from
appropriately accessing justice, and in that regard, I don't believe this is a request to "bend" the rules or
allow a special exception, though I do believe one is able to file a motion seeking such an exception for
cause. Deputy SExton has sexually assaulted me in the past in similar situations where I attempt to use
all of the hours available to filing accorded to any other member of the public.
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
000284
000285
One Size Car Garage For Rent
reno craigslist > housing > parking & storage
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Date: 2012-04-02, 10:02AM PDT
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Welcome to Northwind Apartments. We offer storage units to non-Northwind Residents!

If you need more storage, we offer garages to rent for $75 per month. They are a full size single car garage. Most
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Please call us at (775) 747-9200 or come by. We are located at 1680 Sky Mountain Drive in Northwest Reno.
1680 Sky Mountain Dr. (google map) (yahoo map)

000286
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000287
State Bar Of Nevada
Skip to navigation
Member Login
State Bar Of Nevada
image description
FIND A LAWYER
{ Back to Search Results }
Daniel Wong
Company:
Reno City Attorney's Office
Address:
P.O. Box 1900
~
Reno
,
NV
89505
Phone Number:
7753342048
Fax number:
7753344226
Email:
wongd@reno.gov
Website:
No information provided
Admit Date:
9/23/80
Law School:
McGeorge
Specialization:
000288
file:///R|/1%20a%20NEW%20temp/State%20Bar%20Of%20Nevada%20wong%20mcgeorge%20065630%20dogan%200204%200435%2026800.htm[11/23/2012 5:31:59 AM]
000289
000290
000291
000292
12/3/2012
Zachary Barker Coughlin
1471 E. 9th St.
67 7402
949
949 667 7402 tel and fax is the same
rmc judge william gardner

Reno Municipal Court
and 7/5/12 bail hearing in
12 cr 12420 and transfer
ng12-0204, ng12-0435, ng12-0434 (SBN v. Coughlin 11/14/12 formal hearing)
in 12 cr 00696
x
11 CR 26405
arraignment in 11 cr 22176 10/10/11
I recently appealed the denial on 11/14/12 of a Motion for

For New Trial filed a
in late October 2012
will supplement later, but
000293
12/4/12
000294
please see attached materials

incorporate by reference all of Zach Coughlin's documents and exhibits on file before the
nevada supreme court
http://caseinfo.nvsupremecourt.us/public/caseSearch.do
http://sdrv.ms/TQrulW
incorporate all materials found therein as well

in all these links
http://sdrv.ms/TQrEd6
http://sdrv.ms/RyRc0M
http://www.youtube.com/user/NEVADARADICAL/videos?view=0
http://www.youtube.com/user/NevadaGadfly/videos?view=0

and incorporate by reference all materials found at all links herein and
therein
failed to file in my 6/28/12 notice of appeal in 11 cr 26405...judge steven elliot

member of CAAW's board, went to Stanford with washoe legal services paul elcano, whom
i sued along with CAAW, Elcano and WLS in cv11-01955 no 60317 and associated ith 60301
and elliot presided over, did not disclose and was "randomly" assigned my cases in
cr11-2064 (resulted in suspension of my law license) cr12-1262 and cr12-0376 (8 days in jail and
medical records privacy rights raped, 40K attorney fee award against me in cv11-03628
richard g. hill, esq. interspersed throughout...
d
x
oh, and see n s ct case 54844 judge w. gardner's sister I sued Mandamus he passed her order
cited as sole cause for firing me by WLS to RMC Judge Nash Holmes...ghost grievance
in re frank....
failed to forward 11 2 12 Notice of Errate, etc. in 11 cr 26405, cd/dvds missin' (common theme) with
local judges lately, ask rjc sferrazza and clifton in rcr2011-063341 and rcr2012-065630
000295
12/5/12
zach coughlin
1471 e. 9th st
949 667 7402
reno muni court
dorothy nash holmes and kenneth howard

rmc
11 tr 26800 and 11 cr 22176 and 11 cr 00696

i can't tell anymore
x
every last one of them
000296
12/5/12
000297
6/28/12 notice of appeal in 11 cr 26405...judge steven elliot

d
in re frank....
failed to forward 11 2 12 Notice of Errate, etc. in 11 cr 26405, cd/dvds missin' (common theme)
with
local judges lately, ask rjc sferrazza and clifton in rcr2011
http://sdrv.ms/TQrulW incorporate all materials found therein as well
in all these links
x
therein
000298
12/4/12
Zachary Barker Coughlin
1471 E. 9th St., Reno, NV 89512
my telephone and fax is 949 667 7402
STeven Elliot
Second Judicial District Court for Washoe County
cr12-0376, cr12-1262, cr11-2064
cr12-0376 resulted in unlawful 8 day incarceration and coercion of waiver of HIPAA rights
x
x
cr11-2064 and cr12-1262 were fraudulently
denied
most of them, I will supplement this later but he is or was on CAAW's Board while presiding over
cv11-01955, wherein I was suing CAAW, and he has "randomly" managed to sink his hooks into three
criminal matters involving
me this year, wherein ordeal with
Chief Appeals Clerk Lori Matheus has been especially curious. appearance of impropriety
incarcerated me for lies by Lakes Crossing that
were not in an affidavit as required by NRS 22.030...DDA Young violated NRS 178.405 stay
000299
12/4/12
000300
see attached and I will supplement this soon
see attached and I will supplement this soon
cv11-10955 was appealed in 60317...I tried appealing cr11-2064 but apparently that, like Hiibel
will require a Mandamus Petition. Now, my appeal of the denial of my motion for new trial
is being retained as an extension of my initial appeal of rmc 11 cr 26405, in cr12-1262, though I
do not feel Judge Elliot should ever touch another one of my case, ever.
xx
xxx
000301
12/5/12
zach coughlin
1471 e. 9th st
tel and fax 949 667 7402
judge peter j. sferrazza

reno justice court
rev2011-001708 and rcr2011-063341
not sure where either case is exactly
000302
12/5/12
000303

d
in re frank....
with
in all these links
x
therein
didn't file in notice of appeal submitted 12/26/12 as to ORder "Resolving" contest proprty lient
hearing on 12/20/12 (its fraudulent to say I "agreed" to the "orderd" plus didn't give me a hearing
for 6 weeks though NRS 40.253 calls for one within 10 day sof 11/17/12...called jonas and stancil
coerced me out of fifth amenments rights at trial in rcr2011-063341 and ltos else.
x
x
i am not sure
000304
12/5/12
Zach Coughlin
1471 E. 9th St. Reno NV 89512
tel and fax is 949 667 7402

I prefer email to ZachCoughlin@hotmail.com
Judge David Clifton

reno justice court
rcr2012-065630
x
its not entirely clear to me

x
this is mostly done out of an abundance of caution because I sense Judge Clifton being taken over by
per pressure from his fellow Judges and we need good Judges like Judge Clifton and I think its not too
late for him to use his talents for
helping the forces of good, and not
evil, but he may need to help in getting there. pat flanagan hit me we a $42K atty fee award in
cv11-03628 where I was a pro se tenant appealing a summary eviction...motion filed while judge elliot
had me
locked up and deprived of medications...then the order came down shortly after the rpd and
judge gardner had me locked up on a phony charge and he raised the bail 10 times high over
nuthin'
000305
12/5/12
Judge Clifton was shaking with anger and venom when he forced me to admit I had filed grievances
against DDA Zach "Norman Nifong" Young, Esq. for his rampant prosecutorial misconduct, saying "well,
that say's a LOT about YOU as a person" and other disparaging and threatening remarks...1983 McGeorge
Gammick 1982 McGeorge, suspended from practice of law 4 hours after emailing Gammick only time ever
on June 6, 2012...regarding alleged victim battering me with a lit cigarette....McGeorge Mafia:
000306
judge clifton summarily took away my fax filing rights poor little dda young couldn't take it
and I had barely even been inserted as counsel yet when he did that, plus he tried to depose wcpd
dogan to get some rhythmn on denying me a continuance.
d
in re frank....
with
in all these links
x
therein
000307
6WDWH %DU 2I 1HYDGD
3DJH RI
0HPEHU /RJLQ
),1' $ /$:<(5
^ %DFN WR 6HDUFK 5HVXOWV `
please add JOhn Echeverria is he is subject to Judicial Discipline

Commission Jurisdiction in his role as Panel Chair.
-2+1 3(7(5 (&+(9(55,$

&RPSDQ\
(FKHYHUULD /DZ 2IILFH
$GGUHVV
'RXEOH 5 %OYG

a
5HQR 19
3KRQH 1XPEHU

)D[ QXPEHU

&XUUHQW 0HPEHU 6WDWXV

$WWRUQH\ $FWLYH
Tom Susich and Pat King really did a "shake and

bake" on %$5 180%(5 formal disciplinary hearing Panel
the

selection for the 11/14/12 hearing in sbn v
coughlin
(PDLO
:HEVLWH
$GPLW 'DWH

/DZ 6FKRRO
+DVWLQJV
6SHFLDOL]DWLRQ
1RQH
3URIHVVLRQDO /LDELOLW\
,QVXUDQFH
<HV
this guy went to Stanford around 1966 with Washoe Legal Services Paul Elcano, whom he
admits to being "boyhood chums" with (what about the wine business, guys?) and Judge
STeven Elliot, who has "randomly" been assigned three criminal appeals of Coughlin's
since Coughlin upset the brother and sister Judge tandem of Linda and William Garnder
by filing a Petition for Writ of Mandamus GDWDEDVH LQFOXGHV SXEOLF GLVFLSOLQH
'LVFLSOLQDU\ $FWLRQV 'LVFLSOLQDU\ FDVHV DUH DYDLODEOH IURP -DQXDU\ WR WKH SUHVHQW 7KLVin 54844 after her sanctions against him
RQO\ DQG GRHV QRW LQFOXGH SHQGLQJ GLVFLSOLQH FDVHV 7KH GDWDEDVH LV IUHTXHQWO\ XSGDWHG EXW PD\ QRW EH FXUUHQW DW WKH WLPH RI \RXU were cited by Elcano as the
VHDUFK )RU WKH PRVW FXUUHQW LQIRUPDWLRQ UHJDUGLQJ DQ DWWRUQH\V GLVFLSOLQDU\ KLVWRU\ FRQWDFW WKH 2IILFH RI %DU &RXQVHO &OLFN KHUH sole reason he fired
IRU WKH GLVFLSOLQH NH\ Coughlin....then in CV11-01955 Coughlin sued WLS and CAAW and Judge Elliot did
7KH 2IILFH RI %DU &RXQVHO VWULYHV WR HQVXUH WKH GLVVHPLQDWLRQ RI WLPHO\ DFFXUDWH SXEOLF LQIRUPDWLRQ FRQFHUQLQJ DWWRUQH\ GLVFLSOLQH disclose that he was on
7KH LQIRUPDWLRQ FRQWDLQHG LQ WKLV VLWH LV EHOLHYHG WR EH FRUUHFW KRZHYHU LWV DFFXUDF\ FDQQRW EH JXDUDQWHHG )XUWKHU WKH 2IILFH RI %DU CAAW's Board or that he
&RXQVHO LV QRW UHVSRQVLEOH IRU DQ\ HUURUV RU RPLVVLRQV DQG DVVXPHV QR OLDELOLW\ IRU LWV XVH DYDLODELOLW\ RU FRPSDWLELOLW\ ZLWK ZHEVLWH worked at Echeverria and
XVHUV VRIWZDUH RU FRPSXWHU Osborne, and now Echeverria is the Panel Chair for Coughlin formal Discipline
,Q DGGLWLRQ VRPH EDU PHPEHUV VKDUH WKH VDPH QDPH 3OHDVH YHULI\ WKDW \RX KDYH VHOHFWHG WKH FRUUHFW ODZ\HU 7KH 2IILFH RI %DU
&RXQVHO LV QRW UHVSRQVLEOH IRU DQ\ FRLQFLGHQFH LQ WKH QDPHV RI GLVFLSOLQHG DWWRUQH\V DQG RI PHPEHUV LQ JRRG VWDQGLQJ DV D UHVXOW RI
LQGLYLGXDOV KDYLQJ LGHQWLFDO QDPHV
1RWH $Q DWWRUQH\ KDV WKH GXW\ WR PDLQWDLQ D /DZ\HU
V %LRJUDSKLFDO 'DWD )RUP ZKLFK GHWDLOV WKHLU DGGUHVV OLFHQVLQJ LQIRUPDWLRQ
DUHDV RI VSHFLDOL]DWLRQ EDFNJURXQG WUDLQLQJ DQG OHJDO H[SHULHQFH <RX PD\ UHTXHVW WKLV IRUP GLUHFWO\ IURP \RXU DWWRUQH\
hearing and Elcano is added as a witness just a couple days before the hearing along with
most of the other people who graduated from McGeorge School of law between 1977-1982
000308000308
000308
KWWSZZZQYEDURUJODZ\HUGHWDLO
KWWSZZZQYEDURUJODZ\HUGHWDLO
http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=ce3...
RE: Missing property

From: Campbell, Debra (DCampbell@washoecounty.us)
Sent: Tue 3/13/12 10:49 AM
To:
No, a micro sd card is not listed on the evidence envelope.
Debi Campbell, Detention Operations Manager

Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
dcampbell@washoecounty.us
WCSO MISSION STATEMENT
To serve the residents of Washoe County, consistently earning the public's confidence by providing a
safe and secure community using the highest quality law enforcement, detention, and support services
possible within the resources entrusted to us.
CONFIDENTIAL AND PRIVILEGED COMMUNICATION AND WORK PRODUCT: This communication, including
attachments, is for the exclusive use of addressee and may contain proprietary, confidential and/or privileged
information. If you are not the intended recipient, any use, copying, disclosure, dissemination or distribution is
strictly prohibited. If you are not the intended recipient, please notify the sender immediately by return email,
delete this communication and destroy all copies.

Sent: Tuesday, March 13, 2012 10:29 AM
To: Campbell, Debra
Subject: RE: Missing property
Did these items that were placed into evidence include a micro sd card?
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473
1 of 17
3/29/2012 2:18 PM
Subject: Missing property

Date: Tue, 13 Mar 2012 10:14:59 -0700
From: DCampbell@washoecounty.us
FW: missing property from my secured property
Mr. Coughlin:
From: Cummings, Tami (TCummings@washoecounty.us)

Sent: Mon 3/05/12 8:43 AM
Your email regarding your missing secure property was forwarded to me for response. I apologize for the delay
in responding to you but it took me a little while to figure out the issue.
To:
Cc:
Sheriff - Bkg_CC Supervisors (SO-BKG-CC-SUPV@washoecounty.us)
Dear Mr. Coughlin:
Your two cell phones and electric razor were put into evidence at the request of Judge Nash-Holmes on
February 28, 2012. In order for us to release them to you, we will need an order from Judge Nash-Holmes that
the evidence can be released to you.
Thank you for your email. We are forwarding your email to our Detenon Booking Supervisors for their
review and response. Should you need to contact them by phone, you can call Detenon Administraon at
328-2971.
To make this matter smoother for you all documentation should reflect Washoe County Sheriffs Office case
number 12-1805 and evidence number C-47591. The court case number corresponding to this issue is
11TR26800.
Regards,
If you have any questions all of my contact information is listed below.
Community Relations| Washoe County Sheriff's Office
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

Sent: Friday, March 02, 2012 9:40 PM
To: SheriffWeb
Subject: missing property from my secured property
Dear Washoe County Sheriff's Office and Jail,

The secured property returned to me today did not include either of my cell
phones or the micro sd card that were listed on my check in sheet. My agent,
Peter Eastman, did come and retrieve my keys and wallet, etc. (to help make
sure my dog would not starve to death, and I am so thankful to you for letting
him do that as animal control would have likely cost much money and I already
had a $300 towing bill for my car upon being release from jail and I am
literally flat broke, and just had to pay my $450 per year bar dues and pay for
twelve credits of continuing legal education and my yearly CLE dues....so it
000309
2 of 17
3/29/2012 2:18 PM
3 of 17
3/29/2012 2:18 PM
000310
000311
000312
000313
000314
000315
000316
000317
NEVADA COUNCIL FOR THE PREVENTION

OF DOMESTIC VIOLENCE
NOTICE OF PUBLIC MEETING

Thursday, January 24, 2008, at 10:00 a.m.
The Office of the Attorney General
100 North Carson Street
Conference Room
Carson City, Nevada 89701
With
Public Access Via Videoconference Located At:
Grant Sawyer Building
555 East Washington Street, Suite 3900
Room # 3315
Las Vegas, NV 89101
AGENDA
Please Note: The Nevada Council for the Prevention of Domestic Violence (Council) may
address agenda items out of sequence to accommodate persons appearing before the Council
or to aid the efficiency or effectiveness of the meeting. The Council may convene in closed
session to consider the character, alleged misconduct, professional competence or physical or
mental health of a person (NRS 241.030).
At the discretion of the Chairman, public comment is welcomed by the Council. It will take place
at the beginning of the meeting and will be given as much time as is necessary for all of those
interested to be heard. A public comment time will also be available as the last item on the
agenda. The Chairperson may allow additional time to be given a speaker as time allows and in
his/her sole discretion. Once all items on the agenda are completed the meeting will adjourn.
Asterisks (*) denote items on which Council may take action.

Action by the Council on an item may be to approve, deny, amend, or table.
1.
*Call to order, roll call of members (Attorney General Catherine Cortez

Masto).
2.
*Review, amend, and approve minutes from the October 4, 2007, Council
meeting.
3.
*Report, discussion, and possible action on request from Executive

Committee to Review the Death of Children (Dr. Neha Mehta).
000318
Page 3 of 5
Nevada Council for the Prevention of Domestic Violence
c. Secretary
7.
Presentation by David Clifton, Washoe County District Attorneys Office,

regarding the Washoe County Domestic Violence Fatality Review Team.
8.
*Discussion regarding possible development of a Statewide Fatality Review

Team (Catherine Cortez Masto).
9.
*Report from the Domestic Violence Ombudsman (Kareen Prentice).
10.
Report from the Southern Nevada Domestic Violence Task Force (Elynne
Greene).
11.
Report from the Washoe County Domestic Violence Task Force (Dr. Freda).
12.
*Report from the Nevada Network Against Domestic Violence (Sue

Meuschke).
13.
Report from the Nevada Coalition Against Sexual Violence. (Andrea

Sundberg)
14.
Report from the Attorney General Office on Violence Against Women (Dorene
Whitworth).
15.
Report from the Committee on Domestic Violence (Jennifer Kandt).
16.
Update on Best Practices project (Dorene Whitworth).
17.
Report from the Victims of Crime Subcommittee (Attorney General Catherine

Cortez Masto).
18.
*Discussion regarding rural transportation issues along I-80 corridor for

victims of domestic violence.
19.
Comments from the Chair.
20.
*Discussion and scheduling of future meetings and agenda items.
21.
Public Comment.
Note: No vote may be taken upon a matter raised under this item of the agenda until the matter itself has
been specifically included on an agenda as an item upon which action may be taken. (NRS 241.020)
22.
*Adjournment.
000319
STATE OF NEVADA
NEVADA COUNCIL FOR THE
PREVENTION OF DOMESTIC VIOLENCE
Minutes of Meeting
September 8, 2008 at 10:00 a.m.
Office of the Attorney General

100 North Carson Street
Carson City, NV 89701
Committee Members Present
Adriana Botello, Gail Palchikoff, Mike Freda, Mike Sprinkle, Patricia Lynch,
Rebecca Smokey, Russell Smith, Suzanne Ramos, Tammy Whatley, Traci Dory,
Valerie Cooney, Sue Meuschke
Committee Members Present Via Videoconference
Andrea Sundberg, Barbara Aupperle, Robert Zentz
Committee Members Absent
Ellen Ewing, Elynne Greene, Linda Lilleboe, Ron Titus, Brett Kandt
Public Present
Rebecca Ferreira
Toni Downen, New Member
Susan Filon, New Member
Vic Hutchins, New Member
Dave Clifton, Washoe County District Attorneys Office
Robin Sweet, AOC
Misty Allen, Statewide Suicide Prevention Coordinator
Mrs. Sprinkle
Attorney Generals Office staff present
Catherine Cortez Masto, Attorney General
Kareen Prentice, Domestic Violence Ombudsman
Henna Rasul, Deputy Attorney General
Dorene Whitworth, Grants Supervisor
1. *Call to order, roll call of members, and introduction.
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x
x
Jane Boucher not present.

Rebeca Ferreira present in Las Vegas.
Suzanne Ramos explained why these two applicants were

not considered during the application process.
The
applications were not received on time or the application was
not complete. The two applicants have appealed the
Committees decision, so they are coming before the
Council, so the Council can decide if their applications
should be considered. If the Council decides they should be
considered, then they would then go through the application
process their applications would be looked at by the
Committee and then the Committee would decide whether or
not to interview them and make a recommendation for their
approval.
Kareen Prentice explained that Rebeca Ferreiras application
packet was received after the due date of June 30th, 2008. It
was received by FedEx after July 4th. She explained that
Jane Bouchers packet was missing a personal letter of
recommendation. It contained a letter of recommendation
about her book, but not about her personally. Both
applicants were sent letters explaining the reasons they
were not considered. Jane Boucher has since submitted a
personal letter of recommendation.
Gail Palchikoff explained that the Council has had these
types of issues in the past, with missing documents or late
applications and they decided that they needed to stick
strictly to the requirement of timely and complete application
packets. Sue Meuschke explained that the applicants can
ask that their packets be held to be reconsidered during the
next review cycle which begins in January 2009. Mike
Sprinkle said that he didnt feel it was appropriate for the
Committee to start the reviewing process all over this year
for the two applicants, but rather they should wait until the
next review cycle.
General Masto made the recommendation that the two
applicants packets be held until the next cycle and they
would not need to re-apply.
Committee membership and attendance. Suzanne Ramos

explained to the new members about the requirement that all
members belong to one subcommittee. She then spoke
about members whose terms are ending in January. Mike
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Sprinkle reminded members about the commitment it takes

to be on a committee and that most of the work is done
through the committee work. Henna Rasul asked members
who want to be added to or removed from a committee to
contact her or Kareen Prentice.
General Masto asked at this point that the meeting proceed
out of order to Item 7 on the agenda, so that Dave Clifton
could give his presentation.
o Public Information Committee (Brett Kandt) Brett Kandt
submitted a written report. General Masto read his report to the
Council. The Public Information Committee last met on June 17th
and considered several items. The election of a new chair was
discussed. Brett can serve as chair in the interim, but the
Committee would like to get new members and elect a new chair.
The Council Brochure content and design was discussed. The
Statewide DV Hotline number was added along with a purple ribbon
logo and description. It was decided by the Committee that the
website should be updated to include one year of meeting agendas
and minutes in PDF format.
o Underserved Populations Committee (Suzanne Ramos)
Suzanne Ramos explained that due to lack of quorum, there have
been not been any meetings.
6. Report, discussion, and action on reports/updates from the following
Council Officers:
x Vice Chair nothing to report.
x Treasurer - Suzanne Ramos passed out two handouts, the first
handout was the 2008-2009 budget, which she went discussed.
Kareen Prentice explained the second handout which covered
expenditures. Ms. Ramos explained that the Council would need to
be very conservative with their money again this fiscal year due to
budget constraints.
x Secretary nothing to report.
7. *Presentation by David Clifton, Washoe County District Attorneys
Office, regarding the Washoe County Domestic Violence Fatality
Review Team. David Clifton explained how the first Child Death Review
Team came together after a couple of high-profile child death cases in the
late 80s and early 90s to look at systemic problems related to Child
Protective Services. This led to the creation of a Washoe County
Domestic Violence Fatality Review Team. He explained that the two
Teams meet once every two months on the same day the DV Fatality
Review Team meets immediately following the Child Death Review Team.
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He explained that the Child Death Review Team looks at all types of
deaths accidental, murder, etc. whereas the DV Fatality Team only
reviews deaths of adult domestic violence victims. He spoke about the
study the first team completed at the request of the Legislature, from 1994
to 1999.
This first Team dissolved in 2000 as there were not many DV related
deaths in Washoe County to review. In 2007, at a meeting of the Washoe
County Domestic Violence Task Force, it was decided to restart the DV
Fatality Review Team. He discussed that NRS 217.475 (1997) covers the
legislative authority of the Review Team. It requires a court or multiple
governmental agency to organize or sponsor the multi-disciplinary team.
He explains that the first Review Team was sponsored by Judge Berry
and many governmental agencies were part of the team along with
representatives from mental health, medical, social services, and animal
control. Judge Berry is sponsoring the new Task Force as well. As a
sponsor, Judge Berry has the right to refer a case to the Task Force and
they must review it. The previous Team reviewed all domestic violence
deaths as a matter of course. Mr. Clifton discussed the confidentiality
agreements that team members must sign to participate on the Team.
He discussed how others could follow the model they established to set up
their own Fatality Review teams in their area and gave out informational
handouts to the members. He explained for their Team, they decided it
was best to only review adjudicated cases. He feels that through the
Teams efforts they are making the system better. The challenges
surrounding the setting up of a Statewide Team or a Rural Team were
discussed. Sue Meuschke noted that perhaps they would need to take a
look at what other states were doing in this area, and also get local input
on the subject. She stressed the importance of maintaining confidentiality
and that anything that was undertaken would have to be done so
thoughtfully and carefully.
Russell Smith cautioned that any Team would have to realize that its not
a one-size fits all approach the issues in the rural counties are going to
be very different than in either Clark or Washoe County. Sue Meuschke
suggested that the Education Committee bring together some information
about how other states have set up Statewide Fatality Review Teams and
then have the discussion about how to move forward with that in Nevada.
8. *Discussion regarding possible development of a Statewide Fatality
Review Team (Attorney General Catherine Cortez Masto). The
Attorney General advised the Education Committee to discuss
development of a Statewide Fatality Review Team and to bring back their
information to the Council at the next meeting.
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9. *Report from the Domestic Violence Ombudsman (Kareen Prentice).

Kareen Prentice reported that she is participating in the last AOC
standardized forms committee meeting this next week to wrap up the
protection order form changes. She is teaching a POST Victims Rights
class with Traci Dory on September 24th in Carson City and acting as a
panel member for the Nevada Networks Homeless and Runaway Youth
and Intimate Partner Violence the afternoon of the 24th.
She is also attending the National Center for Victims of Crimes Civil
Justice for Victims of Crime training in Las Vegas with Henna Rasul on
September 26th. The Attorney Generals Office is having an information
booth at the Safe and Healthy Homes Run/Walk event on the 28th in
Reno. The Girl Scouts DV Merit Patch Kickoff event is October 4th. Kareen
explained the different activities that would be available that day for the
scouts to complete. She shared that the Junior League of Reno paid for
2,000 patches, so that the girls dont have to buy them. She went over the
program for the day and named the speakers who are attending the event
and shared that lunch will be provided for attendees. General Masto asked
about a similar program in the South. Kareen agreed that she would begin
working on developing contacts to have this happen.
She is attending the Foundations of Victim Services Program by the Joint
Center of Victims Study on October 6th through 10th that the Alliance for
Victims Rights is bringing to Nevada at a reduced cost of $275. It is the
only national certification for victim advocate training. October 23rd will be
the Nevada DV Teen Dating Violence Best Practices and Resources
training provided by the Southern Nevada Domestic Violence Task Force.
She is also participating in the NNADVs Leadership Development
Program.
For Domestic Violence Awareness Month, she is sending out 1,000
RADAR cards in partnership with the NNADV. The AGO is responsible for
the mailing of the cards and the Network will be handling any follow up
calls or questions from the recipients. Kareen will be sending out 2,000
Domestic Violence Purple Ribbon Awareness pins to members of the
Council, members of the Committee on Domestic Violence, Carson City
Health District, State Health Division, Southern NV Health District, and
AGO offices.
10. *Report from the Southern Nevada Domestic Violence Task Force
(Elynne Greene). Not present to report
11. *Report from the Washoe County Domestic Violence Task Force (Dr.
Freda). Dr. Freda reported that they have the Safe and Healthy Homes
event coming up on September 28th. It will be held at Idlewild Park and
9
000324
many government and community agencies will have booths and there will
be free food. Everything at the event is free and there are raffle prizes as
well.
12. *Report from the Nevada Network Against Domestic Violence (Sue
Meuschke). Sue Meuschke reported that the Network was founded in
1980. Their focus is helping communities develop services to help victims
of domestic violence. They are a private non-profit with a board. They
have grown over the last 28 years. They coordinate the Statewide
Domestic Violence Hotline 1-800-500-1556 (Safe Nest actually operates
the line). They do a lot of technical assistance throughout the state. They
do trainings and site visits and have a peer review process to work with
programs.
NNADV coordinates the statewide domestic violence advocacy programs
in the state to help them expand and improve their legal advocacy
services. They are also working on the challenge of non-traditional
transitional housing and rental assistance in rural communities. They are
coordinating a program on Court Monitoring with five other states. She
explained that they used to hold an annual conference but this year they
are having four different regional training sessions instead. They also
operate an advocate certificate achievement program that is a 40-hour
independent study course.
They work with Headstart staff on the statewide Headstart Training
Initiative to try and break the cycle of violence at an early age. She spoke
about their pilot project - Leadership Training that means to train the
next generation of leaders in domestic violence prevention. She explained
that they have resource lending, and give out about 62,000 pieces of
information in the form of brochures, magnets, hotline cards, etc. for free.
You can order posters or other information from their website. They also
put out a newsletter quarterly.
The Network also administers around 1.3 million in pass-through funds for
hotline, shelters, and other services. They also do a lot of policy work and
Sue shared the fact that although the State is asking others to cut their
budgets by 14%, domestic violence programs are being asked to cut their
budgets by 28%. To make up for this cut, they plan to go to the legislature
and ask that the Marriage License fee be raised by $5 and they will be
asking that the Council give them a letter of support. She passed out
information on the Silent Witness project and asked that anyone interested
in displaying the exhibit, please contact them.
13. *Report from the Nevada Coalition Against Sexual Violence (Andrea
Sundberg). Andrea Sundberg reported that their annual conference will
10
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Department 5
1 of 1
http://www.washoecounty.us/rjc/justiceofthepeacedept5.htm
County Home => Reno Justice Court => Divisions => Justices of the Peace => Department 5
Department No. 5
Judge David Clifton
David Clifton serves as Justice of the Peace in Department

5 of the Reno Justice Court, having been elected in 2010.
A resident of the City of Reno since 1964, he attended
local schools, including the University of Nevada, Reno,
where he received a Bachelor of Science Degree in
Business Administration in 1980.
Judge Clifton obtained a Juris Doctor Degree from the
McGeorge School of Law of the University of the Pacific in
Sacramento, California, in 1983. He served as the law
clerk for the Honorable James J. Guinan in the Second
Judicial District Court of the State of Nevada from 1983 to
1984. Upon completion of his clerkship, he secured a
position as an associate attorney in the Reno law firm of
Sala, McAuliffe, White and Long.
In 1986 he was hired by Washoe County District Attorney Mills Lane to prosecute criminal
cases. He was promoted to Chief Deputy Criminal Attorney in 1994 and held that position
until 2009. In 1996 he originated and supervised the offices Domestic Violence Team and
was also in charge of the Sex Crimes Unit for over ten years.
From 1994 to 2009, Judge Clifton was a member of the Washoe County Domestic
Violence Task Force and from 2007 to 2009 was Chairman of the Washoe County Fatality
Review Committee, serving under the direction of that Task Force. He was also Treasurer
of the Washoe County Public Attorneys Association from 1995 to 2009.
In addition to prosecuting many high-profile cases within Washoe County, Judge Clifton
was also heavily involved in teaching and training peace officers, investigators and
prosecutors, as well as members of the judiciary, at various academies, colleges,
seminars and conferences throughout Nevada and at other sites within the United States.
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where to pay and how much

Sent: Fri 12/16/11 10:44 PM
To: plongoni@charter.net
Dear Ms. Longoni,

I have left you several messages. I wish to pay whatever it is I have to pay to get this appeal
transcript going and to preserve all my rights to review of the decision in RMC 11 cr 22176. Further,
I would like a copy of the audio from the hearing as soon as possible. Please provide specific detailed
instructions as to how to pay and how much and anything else I need to do.
Sincerely,
Zach Coughlin, Esq.

817 N. Virginia St. #2
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 25102521, 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.
no reply from Transcriptionist

Sent: Wed 12/21/11 12:02 AM
To: renomunirecords@reno.gov; robertsp@reno.gov
000343
file:///R|/...1%20email%20to%20ballardd@reno.gov%20regarding%20longoni%2022176%2026800%200204%200435.htm[11/16/2012 4:21:20 PM]
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
Dear RMC,
It is my understanding the Judge Howard's order regarding email does not extend to the address to
which I am sending this correspondence: renomunirecords@reno.gov which is the email address filing
office supervisor Donna Ballard indicated to me was acceptable for sending correspondence and
filings to the RMC in lieu of faxes. I am writing because the email address I was provided for RMC
"official transcriptionist" Pam Longoni yielded a "return to sender/failed transmission" message when
I wrote to the email address provided for her: plongoni@charter.net. Further, please see the
forwarded email below that I sent to Ms. Longoni. I have not received a return call from her
regarding my recent messages to her. I was told by a RMC filing office counter employee that I must
get the transcript through Ms. Longoni, as she is the "official transcriptionist" for the RMC. Please
confirm that I am no able to have another certified court reporter or transcriptionist create the official
transcript and indicate by what date this must be done, how it must be done, etc.
I was told by RMC filing office staff, including Ms. Ballard, that the RMC would not accept any
filings fees, bonds, or any other payments from me in relation to the underlying case 11 CR22176 2I
or the appeal of that matter given that the RMC was holding the bail money I paid into the court. If
this is not the case or if I must pay anything into the RMC to ensure that my appeal goes forward,
please indicate as much in writing and with particularity. If I am able to use any other
transcriptionists and or the RMC has a list of such with contact information, please provide such in
writing.
Sincerely,
/s/Zach Coughlin
Zach Coughlin, Defendant/Appellant
000344

Subject: where to pay and how much
Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,

Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
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: Coughlin's
erty
s his
er's
nse
ite RSIC
cer
ford's
imony
1/30/11
1CR22176
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Tribal Police not allowed to arrest for misdemeanors FW:

Case No. RCR2011-063341
Sent: Sun 11/11/12 8:40 AM
To: homerj@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org);
hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov
(robertsp@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); wongd@reno.gov (wongd@reno.gov); ormaasa@reno.gov
(ormaasa@reno.gov); bonyr@reno.gov (bonyr@reno.gov); skauc@reno.gov (skauc@reno.gov);
davidc@nvbar.org (davidc@nvbar.org); drakej@reno.gov (drakej@reno.gov); je@eloreno.com
(je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
skent@skentlaw.com (skent@skentlaw.com)
How exactly is it that both City Attorney Pamela Roberts, Esq. and Chris HazlettStevens, Esq. did not violate RPC 3.8 or otherwise prosecute for arrests that were not
lawful
in RMC 11 CR 22176 (Indian Tribe police custodial arrest for misdemeanor? Not
lawful under NRS 171.1255, and even if they were RPD, which they are not, its not like
they charge Coughlin with something other than petty larceny a la NRS 171.136(2)...
Further, can you provide me an indication of how it was lawful for RSIC Officer's
Kameron Crawford or Donnie Braunworth to arrest me on 9/9/11 (and Wal-Mart's
Thomas Frontino made explicitly clear in his testimony at trial on 11/30/11 that neither
he nor any of Wal-Mart's staff in any way effected a custodial arrest of Coughlin on that
date) for a misdemeanor given the following:
NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian
tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a
person employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant
delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer
or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has
reasonable cause for believing the person arrested to have committed it.
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(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross misdemeanor
by the person arrested.
(e) When a warrant has in fact been issued in this State for the arrest of a named or described person
for a public offense, and the officer or agent has reasonable cause to believe that the person arrested
is the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed
a battery upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that
reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh
pursuit of a person who is reasonably believed by the officer or agent to have committed a felony
within the boundaries of the reservation or colony or has committed, or attempted to commit, any
criminal offense within those boundaries in the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
(Added to NRS by 1985, 452)
While Ormaas made sure to get judicial notice taken of jurisdiction in 11 TR 26800, it doesn't seem
Pamela Roberts, Esq. did in the Indian Colony Wal-Mart matter...Why is that, Pam? Tribal land? Never
determined if Coughlin had even an ounce of tribal blood? RSIC Officers not entitled to make custodial
arrests for misdemeanors, even, apparently, one's committed right in their presence? So, even if
Coughlin did refuse to provide his driver's license (which has been proven to be a lie, and perjury
suborned by Pam Roberts as to the testimony of Wal-Mart's Frontino and the RSIC Officer's Crawford
and Braunworth via police reports, dispatch recordings (AND PLEASE BE ADIVSED, AS ITS WITHIN THE
2 YEARS, THAT THE CITY OF RENO, THE SOUTH DISPATCH CENTER FOR ECOMM OR WASHOE
COUNTY, OR WHOEVER IT IS THAT HANDLES THE RSIC DISPATCH CALLS, IT ON A LITIGATION HOLD
NOTICE. COUGHLIN DEMANDS (AND THE DISPATCH/ECOMM SOUTH DISPATCH CENTER WILL GET
ITS NRS 174.345 SUBPOENA IN THE MAIL FOR A MISDEMEANOR SOON ENOUGH) THAT THE
CUSTODIAN OF RECORDS MAINTAIN ANY AND ALL RECORDINGS, LOGS, OR OTHER DOCUMENTATION
OR MEDIA IN ANY WAY CONNECTED TO ZACHARY B. COUGHLIN IN ANY WAY WHATSOEVER,
ESPECIALLY WITH REGARD TO THE ARREST OF 9/9/11 AT THE RSIC WAL-MART IN RENO NEVADA
NEAR GLENDALE AND W. 2ND ST.
So, all these arrests by the RSIC police of alleged shoplifters at Wal-Mart...Sling Bla...er, Officer
Braunworth testified that there was lots of them (sounds like Wal-Mart and the RSIC have the whole
"find a way to get a search incident to arrest" thing down part, while avoiding any wrongful arrest
liability against the deep pocket tenant Wal-Mart by avoiding any "shopkeeper's privilege" type citizen's
arrests (or trying to use just as much intimidation and coercion as Frontino and the gang can muster,
while seeking to claim not to have effected a citizen's arrest later in court, given setting the RSIC up to
handle those types of lawsuits is arguably a better long term loss mitigation approach for these long
term business partners, Wal-Mart and their partner/landlord the RSIC.
So, please enlighten me. How is it these RSIC Officers are making all these custodial arrests for simple
misdemeanors? And just where in the audio transcript of the Trial (you might want to have RMC house
000357
transcriptionist Pam Longoni finally get around to making a transcript and providing it to Coughlin, as
the handouts the RMC itself provides defendants baring Longoni's and the RMC's "down
payment"/transcript hostage rules are tantamount to extortion in violation of NRS 189.030. Then there
is the bit about the RMC and or other discovering over $700K was "missing", and the attempts to chalk
it up to "data entry" errors. Please get that transcript to me right away, and transcripts of every other
hearing I have ever had in the RMC, including the one on or around February 2nd, 2012 or so where
RMC court appointed defender Roberto Puentes successfully argued for an Order Granting His
Withdrawal (five Withdrawals by court appointed counsel of Coughlin, four via an Order Granting a duly
filed Motion (though these guy's Motions wouldn't pass my 7th grade English Class's bi-weekly writing
assignment in my days at Swope Middle School) and Hon. W. Gardner starts to divulge, only after
Coughlin's prompting, bit by bit some of the patent conflicts that should have prevented him from ever
ruling on a single motion in that case 11 CR 26405. With such lack of vigor from the RMC's court
appointed defense counsel, could a class action lawsuit agains them, the RMC, and or the City of Reno
be a possibility someday? Certainly is a nice lil side gig $7K a month those guys get...and all these
prosecutions and trips to jail this year certainly have afforded an opportunity to see the "operation" up
close.
Also, you know, as to lots of these arrests, like say the July 3rd, 2012 arrest by RPD Officer Alan
Weaver and now Sargent Brian Dye in 12 CR 12420 (wherein two RMC court appointed counsel have
already sought and obtained Orders Granting Their Withdrawal, one, by Keith Loomis, one by Henry
Sotelo, the latter in violation of the stay in NRS 178.405) the legitimacy of effecting a custodial arrest is
completely suspect considering:
ARREST: BY WHOM AND HOW MADE

NRS 171.124 Arrest by peace officer or officer of Drug Enforcement Administration.
1. Except as otherwise provided in subsection 3 and NRS 33.070 and 33.320, a peace officer or an
officer of the Drug Enforcement Administration designated by the Attorney General of the United States
for that purpose may make an arrest in obedience to a warrant delivered to him or her, or may,
without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officers presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officers
presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer has reasonable
cause for believing the person arrested to have committed it.
for a public offense, and the officer has reasonable cause to believe that the person arrested is the
person so named or described.
2. A peace officer or an officer of the Drug Enforcement Administration designated by the Attorney
General of the United States for that purpose may also, at night, without a warrant, arrest any person
whom the officer has reasonable cause for believing to have committed a felony or gross misdemeanor,
and is justified in making the arrest, though it afterward appears that a felony or gross misdemeanor
has not been committed.
000358
So back to the Wal-Mart RSIC arrest...the charge sheet doesn't say Coughlin was arrested for anything
other than petty larceny....but:
NRS 171.136 When arrest may be made.

1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at
any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the
public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting
officer to stop, detain or arrest the person for another alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person
makes an arrest immediately after the offense is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and
the arrest is made in the manner provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against
domestic violence issued pursuant to NRS 33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of
arrest.
So, on exactly what basis was the July 3rd, 2012 arrest made by the RPD? The police report says the
arrest was made for "disturbing the peace", yet the only allegation of anything remotely in the "officer's
presence" relates to the minor traffic citation the City of Reno is clinging to in attempts to mitigate the
Sec. 1983 damages here. However, the RPD admits at least one vehicle was between their's and
Coughlin's and Sooudi et al (besides making an incomprehensibly stupid decision to briefly file an
amended complaint for trespassing where even the RPD was smart enough to realize that was a poor
choice given Coughlin still had lease at Northwind, and thus a pat claim of right defense to any trespass
allegation absent something like the manufactured protection order that RPD Officer Weaver coerced
Milan Krebs into obtaining, just like Weaver attempted to get Superior Storage's Matt Grant to do,
shortly after Weaver, in full view of Welch, Sargent Miller, and other RPD Officer's, on September 21st,
000359
2012, threatened to come up with yet another fraudulent "failure to secure a load on one's vehicle"
arrest of Coughlin). So, even though Weaver and Dye are stuck with their statements in the written
reports, wherein they allege to have arrest Coughlin for "disturbing the peace" only to then tack on
"citations" for the two traffic offenses (and the "proof of insurance" citation, even after Officer Weaver
admits to being provided a high definition pdf picture on a 5 inch smart phone screen with a policy
number, etc., only to be amplified by the July 5th, 2012 bail hearing racket tearing (a tennis reference
for Jill Drake, Esq.,... for shame, really Jill, really, really unimpressed).
Please remit a certified check for $450,000 in satisfaction of these torts committed upon Coughlin,
under color of law.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: homerj@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov;
kadlicj@reno.gov; fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Date: Thu, 8 Nov 2012 20:36:27 -0800
couldn't open them, and I don't accept service of anything form you... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
the RMC Rules to the extent there is not difference technologically anymore between
an email and a fax:
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
facsimile, except as otherwise specified in this rule.
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax
number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
the receiving party is a governmental agency, an attorney, or with the consent of the receiving party. If service of the
motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
000360

No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
state the reason therefore and whether or not any continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
becuase he has lied numerous times, on the record about not being served where he has been. Take, for
instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed
to follow RMC Rules in withdrawing from representation:
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
may rule on the motion or set a hearing.
Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000361
utbound fax report
Inbox
Voxox noreply@voxox.com
Jun 27
to me
Hi zachcoughlin,
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox?
Get Voxox: http://download.voxox.com and adjust your Notifications in the Settings/Preferences window. Voxox by
TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
Jun 27
to me
Hi zachcoughlin,
Jun 28
to me
Hi zachcoughlin,
Jun 28
to me
Hi zachcoughlin,
Jun 28
to me
Hi zachcoughlin,
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Sent: Fri 12/16/11 10:44 PM
Dear Ms. Longoni,

transcript going and to preserve all my rights to review of the decision in RMC 11 cr 22176.
Further, I would like a copy of the audio from the hearing as soon as possible. Please provide
specific detailed instructions as to how to pay and how much and anything else I need to do.
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
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,

000425
Sent: Wed 12/21/11 12:02 AM

Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
Dear RMC,
which I am sending this correspondence: renomunirecords@reno.gov which is the email address
filing office supervisor Donna Ballard indicated to me was acceptable for sending correspondence and
regarding my recent messages to her. I was told by a RMC filing office counter employee that I
must get the transcript through Ms. Longoni, as she is the "official transcriptionist" for the RMC.
Please confirm that I am no able to have another certified court reporter or transcriptionist create the
official transcript and indicate by what date this must be done, how it must be done, etc.
writing.
Sincerely,
/s/Zach Coughlin
000426
Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,

Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
000427
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RE: arraignment
From: Dogan, Biray (BDogan@washoecounty.us)
Sent: Fri 2/24/12 4:29 PM
Your case has been continued. I will send the new court date by mail.

Sent: Wednesday, February 22, 2012 6:36 AM
To: Dogan, Biray
Subject: arraignment
'Sup Biray,
I went and got the arraignment done today....Judge Pearson informed me we have a
mandatory 2/27 1:30 STATUS Conference RJC with in rcr12-065630
However, I already had a "Trial" set in bench trial 11 tr 26800 RMC (ticket number 544281) 1pm feb 27th Judge
Holmes (talk to cashiers) right of way stop sign, can you get a continuanc brokered on the status conference.
Judge Pearson said you are my attorney of record in this matter, though you haven't been communicating with me
much far as I can tell and you guys hung up on me last we spoke.
Hope to hear from you, amigo,
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****** IMPORTANT NOTICE - READ THIS INFORMATION *****

PROOF OF SERVICE OF ELECTRONIC FILING
A filing has been submitted to the court RE:
CV11-03628
Judge:
PATRICK FLANAGAN
Official File Stamp:
02-08-2012:16:34:48
Clerk Accepted:
02-08-2012:16:35:22
Court:
Second Judicial District Court - State of Nevada
Case Title:
ZACHARY COUGHLIN VS. MATTHEW

MERLISS (D7)
Document(s) Submitted:
Ord to Show Cause
Filed By:
Kathryn Sims
You may review this filing by clicking on the
following link to take you to your cases.
This notice was automatically generated by the courts auto-notification system.
If service is not required for this document (e.g., Minutes), please disregard the below language.
The following people were served electronically:
ZACHARY COUGHLIN, ESQ. for ZACH
COUGHLIN
CASEY BAKER, ESQ. for MATTHEW MERLISS
RICHARD HILL, ESQ. for MATTHEW MERLISS
The following people have not been served electronically and must be served by traditional
means (see Nevada electronic filing rules):
000448
FILED
Electronically
02-10-2012:01:49:40 PM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2758134
000449
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FILED
Electronically
02-10-2012:01:49:40 PM
Clerk of the Court
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CV11-03628
Judge:
PATRICK FLANAGAN
02-10-2012:13:49:40
Clerk Accepted:
02-10-2012:13:50:37
Court:
Case Title:

MERLISS (D7)
Notice of Entry of Ord

- **Continuation
Filed By:
RICHARD HILL, ESQ.

COUGHLIN
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Due Process concerns related to the "grievances"

Sent: Sat 3/24/12 1:28 AM
To: patrickk@nvbar.org
4 attachments
3 23 12 FAX TO BAR COUNSEL PATRICK KING NEVADA BAR.pdf (55.3 KB) , 3 19 12 fas to
rmc marshals regarding property wcso.pdf (40.0 KB) , Pages from mary barker rmc 11 tr
26800 order denying motion for return of bond.pdf (508.2 KB) , notice of appeal 11 tr
26800 rmc and Motion for reconsideration set aside etc.pdf (2.6 MB)
Zach Coughlin, Esq.

Nevada Bar No: 9473
PO Box 60952
RENO, NV 89506
tel: 775 338 8118
fax: 949 667 7402
TO: Patrick King, Esq.

State Bar of Nevada Assistant Bar Counsel
sent via email to: PatrickK@nvbar.org
March 23, 2012

Dear Assistant Bar Counsel King,
I have a few question I would like to respectfully submit to you. What have you done to ascertain whether the
Marshal's have a vested interest in discrediting me? I would like you to forward me all communications from
anyone in Department Three. I would like for you to obtain a copy of the hearing today, wherein Judge Flanagan
concluded the hearing by quoting to something I wrote (it was the only thing he mentioned after indicating that he
wished to speak to the attorney's in this matter after dismissing the witness, the lying contractor for Richard G.
Hill, Phil Stewart, who has offered perjured testimony numerous times on Mr. Hill's and his client's behalf. Judge
Flanagan quote something I wrote in a filing in 11 TR 26800, where the Judge, Dorothy Nash Holmes, a lifetime
000497
prosecutor and or warden of a prison (or something along those lines) had me arrested and confiscated my
property, including a smart phone (and a smart phone these days could store the entire contents of a law firm's
files and a law library in one), my less advanced cell phone, my premium electric shaver and other items. My car
was towed during the summary 5 day jail stay Judge Nash Holmes found appropriate, costing me $300 to get it out
of the lot (also lost a client that would have brought in a substantial amoutn of money, by my standards anyway).
A $100 bail was paid to get me out of jail on the fourth day (thus avoiding a fifth day) and accepted by the RMC,
yet, I was not released and the RMC has decided to keep the money anyways.
Yesterday I went to the RMC to pick up a copy of the audio transcript of the 2/27/12 Trial in that matter 11 TR
26800. After asking some questions of filing office supervisor Donna Ballard and a front counter clerk named
Daniel, wherein both agree with me that some of the ways things were done done at the Reno Municipal Court
lacked transparency, a system of checks and balances, and other fundamental notions of due process and fair play,
all of the sudden, two beefy City of Reno Marshals in their mid 20's decided, unilaterally, it seems, to ask me to
leave, as Ms. Ballard certainly had expressed nothing in the way of discontent with our conversation, nor had
Daniel. While I was leaving I could clearly hear Marshal Thompson lying extensively into his radio, trying to
manufacture some sort of report of a scene were there had been none, other than that put on by the City of Reno
Marshals, whom have lied extensively about whether or not they ever took possession of a micro sd card incident
to the full body all pockets, belligerent, accusatory search they performed incident to the summary contempt
finding and arrest of 2/27/12. I request that you ask for a copy of Marshal Harley's employment file from BOTH
the RMC and the City of Reno Marshals Division and see if they put in my letter and complaint in that regard.
Or, do you "find that the burden of proof in the various grievances I have filed with you has not been met, that all
the evidence needed for a conviction has not been presented to your lap with a bow? Did Mr. Hill present such
proof, meeting such a burden. Clearly, the only thing you provided to me from Mr. Hill was an EXCERPT of his
1/14/12 letter to you, which reference numerous shadowy previous phone calls between the two of you (are you
Mr. Hill's hand picked Bar Counsel, or was this case assigned randomly? Does Mr. Hill get to pick which RPD
Sargents and Officers show up for his calls for help? Have you made any inquiry to ascertain this. Why does
Richard Hill constantly file a peremptory challenge anytime he is assigned to Judge Adam's Department 6,
apparently? Did the innuendo and hearsay Richard G. Hill, Esq. Mentioned in his unsigned, unsworn letter to you
of 1/14/12 provide you sufficient proof to meet the clear and convincing evidence stand you indicate that the
grievances I filed did not? How do the copies of electronic correspondences between myself, State Bar of Nevada
Director of Admissions Patrice Eichman, Peter Christiansen, Esq., and Michael Sanft, Esq.,'s legal assistant Kelly
Huff, wherein she explicitly admits to her firm committing malpractice in my case, fail to provoke even a scintilla
of investigation into a grievance from or the State Bar of Nevada?
And the impropriety implicated by Kevin Kelley's conduct, and Mr. Christiansen's later lying under oath at the
June 2002 Character and Fitness Committee hearing for which he feels he satisfied the $5,000 he received in
payment (well, okay, he did file an 8 page pre-hearing brief that rehashed factual recitations from various previous
filings of the Committee, then did manage to cite to the Claiborne case, which concerned a former judge, not an
applicant for admission to the bar, and he did fail to subpoena percipient witness Mark Tratos, or any of the
relevant faculty from Boyd School of Law, and he did screw up the affidavits of the students witnessing me
turning in the hard copy of the paper, and his office did forward a correspondence about alcoholism to the State
Bar despite an express indication by the client atop of it that said not to do so, and his office did mistate whether
they ever turned in the second Consent Agreement send with confirmation to them on September 27th , 2004 in a
November 2004 email, so....wait, are you really saying there isn't enough there for a grievance FROM A CLIENT
FILING ONE AGAINST HE WHO WAS COMPENSATED $5,000 TO REPRESENT HIM (THOUGH
CHRISTIANSEN LIED UNDER OATH AND SAID IT WAS ON A PRO BONO BASIS, IN ACCORD WITH
THE REPRESENTATIONS MADE BY STRIP CLUB SPEARMINT RHINO OWNING CHARACTER AND
FITNESS COMMITTEE MEMBER KEVIN KELLEY, ESQ., WHOSE BEST FRIEND WAS THE
PSYCHOLOGIST THE APPLICANT WAS STEERED TO IN THE ADMISSIONS PROCESS)? BUT, YOU
ARE SAYING PURSUING A GRIEVANCE PROCEDURE AND, APPARENTLY, FORMAL HEARING
INCIDENT TO THE ATTEMPT TO FILE A GRIEVANCE BY A KNOWN SCANDALOUS OPPOSING
ATTORNEY RICHARD G. HILL, ESQ., AGAINST MYSELF, IN A MATTER FOR WHICH I AM NOT AN
ATTORNEY OF RECORD (PRO SE ATTORNEY LITIGATNS, APPARENTLY, CANNOT RECEIVE
ATTORNEY'S FEE AWARDS UNDER THE SELLERS CASE, SO HOW CAN THE RULES OF
PROFESSIONAL CONDUCT BE APPLIED TO ANY OF MY CONDUCT IN A CASE WHERE I AM A PRO
SE LITIGANT?)? It sure is curious how you find sufficient proof to pursue Richard G. Hill, Esq.'s grievance
against me, yet, you claim that all the grievances I filed do not warrant any sort of investigation on your part. Very
curious, indeed...
000498
You wrote: "As Assistant Bar Counsel I would like to help you. However, my primary responsibility is to protect
the public and the administration of justice by insuring that Nevada Lawyers are complying with standards
required of the profession. It appears that you are not."
I would like you to specify in detail exactly what forms the basis of your assertions in those a statements, as
heretofore you seem to rely upon only the unsigned, unsworn, hearsay cited to by Richard G. Hill and some
apparent grievances filed by judges, to which you have not previously informed me of or offered any proof
thereof, despite your incorrect assertion that you have done so. If you, as you wrote that you did, previously
provide any indication or documentation in support of these "grievances" filed by Judges, please provide support
therefor in explicit written detail with supporting documentation and proof service.
You further wrote, and I seek explication and specificity with regard to details and attribution incident to the
allegations therein contained that:
" I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal
research." Would you say, Mr. King, that you would very much prefer it if I had done NO legal research prior to
meeting with you?
You go on to write "You asked if Mr. Hill has standing to file a grievance against you. Not only does he have
standing to file a grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As
I have explained to you, the grievances against you came not only from Mr. Hill but also from Judges from
different Courts."
That statement casts extreme doubt upon everything you have said to me, Mr. King, and everything you will say to
me. Please provide the requested proof of any grievances against me that came from "Judges from different
Courts". You do realize, Sir, that some "Judges in Different Courts" have pulled drivers over recently and
impersonated a highway patrol officer, and that some Clerks of Court have embezzled $250,000 from the public
fisc? And, just to be clear, you truly do not find anything worthy of a grievance per Mr. Taitel's curious
appearance/disappearance as attorney of record, failure to do a conflicts check, failure to subsequently disclose
such a failure and the tangible harm it has done to me vis a vis my suing Nevada Court Services and his sharing
an office, receptionist, and being listed on the Nevada Court Services web site as "associated with" their business
entity? Didn't Mr. Taitel have a recent ethics investigation pursuant to some run for judicial office?
Also, Judge Nash Holmes indicated at trial, and this is a direct quote, that she "doesn't care about corruption, or
bribery, retaliation, or police misconduct"...well, that is as close to a direct quote as I can make given the fact that
the RMC, just yesterday refused to provide me a copy of the audio transcript from the 2/27/12 Trial in 11 TR
26800, presided over by Judge Nash Holmes, after a length disappearance by her immediately before calling my
case, and after hearing all the other matters on that stacked docket, and after denying my request for a continuance
but granting Deputy City Attorney Allison Ormaas's request for one to "speak" with Reno Police Department
Sargent Tarter, whose cross examination formed the basis for my arrest and incarceration incident to the summary
contempt finding. The cross examination focused on whether Sargent Tarter had retaliated against me for reporting
the bribery admission by RPD Officer Chris Carter (he admitted Richard G. Hill, Esq. bribes him) to Sargent
Tarter while at the scene of my attempts to get Richard G. Hill to turn over my client's files and my wallet and
state issued identification. If you want to put your name on the line over this, Mr. King, and you think we still live
in a world with very little transparency, who am I to tell you any different.
You further wrote: "These grievances, and the evidence attached with them, rather clearly puts into question your
competence to practice law." Please narrow down which parts of which grievances you feel so implicate my
competence, in explicit written detail.
You further wrote: "As I have explained to you, I will make the evidence and exhibits available to you when you
come to inspect them at my office." Mr. King, please indicate when it was and in what form or method you
communicated this offer to "make the evidence and exhibits available to you when you come to inspect them at
my office"? Please further explain why on earth I would only be allowed to inspect them at your office and how
that does not create and overly bullying and intimidating scenario departing entirely from fundamental notions of
due process. Please just fax and email (both please) the entire contents of all these materials to me. I am likely
suing the USPS and some of its local postal inspectors and or station supervisors under the Federal Tort Claim Act
and while I have taken every prudent step to ensure the timely delivery of my mail (I have a ton of evidence and
000499
documentation in support of this), I am EXPLICITLY indicating to you that I wish for you to fax and email me all
of these materials rather than send them through the mails (USPS, UPS, Fed-Ex, etc, etc.).
You then wrote: "I will not send you reports or document, especially since you claim your mail is being
compromised. " I am appalled that you would write this, and offended really. Please email and or fax them to me.
I have communicated with the USPS and my change of address has been processed (there was a delay through no
fault of my own) and if you refuse to send these to me via email or fax, the go ahead and mail them to my new PO
BOX, though taking that tact will likely only make your conduct throughout this proceeding further suspect. Such
as when you wrote:
" As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters.
As such, at this time we have not opened any files based on the information you have submitted. " Please indicate
how, exactly, Richard G. Hill's grievance met such a standard of proof where the one's I submitted did not.
Further, while you have indicated that I have not responded to your request to meet with you (which is not the
case), you only just, for the first time, today, even mentioned anything about any judges filing or corresponding
anywith with or to you, and you have failed to provide any documentation of such or copies thereof sufficient to
satisfy my Sixth Amendment Right to Confrontation, etc. Please do so.
Sincerely,
/S/
Zach Coughlin, Esq.
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402;
From: PatrickK@nvbar.org
CC: DavidC@nvbar.org
Subject: RE: does Richard Hill have standing to file a grievance
Date: Fri, 23 Mar 2012 19:10:10 +0000
March 23, 2012
Dear Mr. Coughlin,
Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She
said that you appeared wearing pajamas over your clothes and were demanding and
argumentative. Apparently I will be receiving a report from the Marshals. As Assistant Bar
Counsel I would like to help you. However, my primary responsibility is to protect the public
and the administration of justice by insuring that Nevada Lawyers are complying with standards
required of the profession. It appears that you are not. I believe that there are ways 000500 you
to get
assistance that may protect your license to practice law. I would sure appreciate the
opportunity to talk with you about resources and assistance that may help you through this
difficult time.
Patrick King, Assistant Bar Counsel

Sent: Friday, March 23, 2012 10:39 AM
To: Patrick King
Mr. King,
This is the very first time you allege anyone other than Mr. King filed or alleged a
grievance. Please provide any documentation or proof related to these apparent
communications from judges that you are only now bringing up.
Sincerely,
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
No: 9473
000501
FILED
Electronically
08-28-2012:04:32:12 PM
Clerk of the Court
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FILED
Electronically
03-27-2012:08:56:46 AM
Clerk of the Court
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000540
000541
FILED
Electronically
08-16-2011:01:34:07 PM
Howard W. Conyers
Clerk of the Court
000542
000543
FILED
Electronically
02-08-2012:04:34:48 PM
Clerk of the Court
000544
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Print
Close
RE: WCSO Deputy Machem's "personally served" Affidavit of

11/1/2011
From: Stuchell, Liz (LStuchell@washoecounty.us)
Sent: Tue 2/07/12 11:40 AM
Cc: Kandaras, Mary (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.

WCSO Civil Section

Sent: Monday, February 06, 2012 2:58 AM
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov; fourthestate@gmail.com;
jamesandreboles@msn.com
Subject: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
lstuchell@washoecounty.us mkandara@da.washoecounty.us
Dear IA Supervisor Stuchell and DDA Kandaras,

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 121 River Rock St., Reno 89501 on
November 1, 2011 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.
000565
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
Summary Eviction against 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), 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 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 "served" in
compliance with all time related rules because it was done in 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 , 2011. 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 of NRS 40 where this within 24 hours language occurs, and those
situations only apply where, in:
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 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
000566
county to remove the tenant within 24 hours after receipt of the order
and,
40.253(5)(a): 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 thereupon issue an order directing the
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, 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 where one must file a Complaint
within 90 days of receipt of a Right To Sue Letter, a situation which 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 114 (1st 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 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 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, 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
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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. 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,
2011. That is a lie by Mr. Machem, unless "personally served" is defined in a rather
impersonal way and or Machem and I have totally different understanding of the
definition 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 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 118A.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 Sheriff's 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 RJC REV2011-001708
ON 11/1/12 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 information contained in the affidavit, and the filing by the landlord
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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 118A.460 or 118C.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,
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 10 days after
the filing of the motion. The court shall affix the date of the hearing to the motion
and order a copy served upon the landlord by the sheriff, constable or other
process server. At the hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460
or 118C.230 and any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment of the charges
determined to be due or if no charges are determined to be due...."
I also want to know why NRS 40. 253(8) was not followed with respect to my
November 17th, 2011 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 10 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
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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 12th, 2011 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 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 118A.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 County Sheriff (despite what their Affidavit of
Service 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 40.253(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, 12 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 following 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 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 911incident 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".
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Funny thing, I never heard anything back from the RPD about complaints like the
following one:
From: NvRenoPd@coplogic.com
Sent: Wed 9/07/11 10:51 PM
****DO NOT RESPOND TO THIS E-MAIL****
We're sorry the following problem was found during review
of your submitted report T11005956:
THIS 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.
Thank you,
Officer WOZNIAK,
Reno Police Department
What is interesting there is that at least I was provided the name of an officer, a
"Wozniak" (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 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 118A.460
may deem "reasonable storage" expenses for which a lien is available to a landlord,
though NRS 118A.520 has outlawed rent distraints upon tenant's personal
property....Regardless, between January 8 - 12th, 2012, and was arrested twice by the
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Reno PD shortly after submitting these written complaints to the Reno PD.
Actually, upon being release from jail on November 15th, 2011, 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, 2011. Hill called
the Reno PD on the 15th (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 earlier. 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 11/12/11 trespassing arrest, that Sargent immediately
informed me that, despite this being the first he heard of that, he was sure that was not
happening....I 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 attorney being
required to report said conviction to the State Bar of Nevada under SCR 111, 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 11/15/11 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 12th, 2011 (custodial arrest, bail of $160 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 118A.460, even where old Phil used my own plywood at the property to
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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 12th, 2011 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.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 signed 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.com/watch?v=jQ132q2O7DY
Add to that that Nevada Court Services Jeff Chandler drives by in his Monster Truck
baring his personalized "NCS" license plate while I am in the RPD squad car,
handcuffed, outside my former law office at 121 River Rock, at the time of the
1/12/12 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 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
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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, 2011 wrongful arrest by
RPD Officer's Duralde and Rosa. http://www.youtube.com/watch?v=5PR7q4OI5b0
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 2011. 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, 2011)
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 1/12/12.
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 911" just two days later, on
January 14th, 2011 when I called 911 to report that my roommates were laughing
menacingly when I asked them why my dog was missing (I had also been chased up to
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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 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 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 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)...I
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 of this...But that would
require and awful lot of coincidences.
Sincerely,
Zach Coughlin, Esq.

1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
000575
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
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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
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RE: IFP Coughlin Service of Complaints WLS employment law;

landlord tenant case
Sent: Mon 12/05/11 12:32 PM
Mr. Coughlin,
Per your demand stated in the e-mail received from you on November 7th, all document packets that were provided by
you were assembled and served by November 16 th . Affidavits of Service were sent to your new address that you
provided on November 30 th . Affidavits with case numbers were sent directly to the court. Last week copies of those
were sent to you free of charge. You also will receive original Affidavits of Service of documents that did not have case
numbers.
Any further inquiries should be made to our Civil Attorney, Mary Kandaras at the District Attorneys Office.
Liz Stuchell
WCSO Civil Section

Sent: Sunday, December 04, 2011 2:53 AM
To: Silva, Roxanna; Stuchell, Liz
Subject: RE: IFP Coughlin Service of Complaints WLS employment law; landlord tenant case
Dear Ms. Stuchell and Ms. Silva,

I don't mean to be a jerk, I am under inordinate stress right now (not that that is anybody's problem but mine).
The citation below would tend to indicate that your office might, MIGHT, have a duty to photocopy the
000576
electronic versions I sent and serve them in a manner that the opposing attorneys will not respond to by filing
"Motions to Dismiss" based upon illegibility or bad copying/printing. They object to the 9 pages per page
stuff...In an ideal world your office would serve one page per page of these things, after you print them out,
etc...If you can do that, I would of course be extremely grateful, if you can't, I am of course let to scratch and
claw my way through this lawsuit like every other thing in my life as an IFP who can seemingly be curbstomped
by the older richer attorneys whenever they feel like it (and who have some dubious help in doing so). One
interesting thing is that one of the employment cases, etierh cv11-01955 or cv11-01986 (whichever was filed on
June 27th with an IFP) has to be served within 120 days of WHEN? The docket seems to suggest the Complaint
in that IFP case was only entered on or around August 11th, 2011, which would obvioulsy changed the 120 days
calculation, however, whether the filing date relates back to the IFP is something I have never been able to get a
clear answer on anywhere....
Thank You,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 25102521, 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
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.
Date: Thu, 1 Dec 2011 08:52:29 -0800
From: RSilva@washoecounty.us
You and I are the only ones who got this. Is he asking us to serve more docs?

Sent: Wednesday, November 30, 2011 6:37 AM
Subject: IFP Coughlin Service of Complaints WLS employment law; landlord tenant case
"The defect in service (that the photocopy of the complaint provided was too
faint) was not attributable to the plaintiff, but to court personnel, who are
responsible for making copies of the initial pleadings for IFP litigants".
McKENZIE v. AMTRAK M OF E, 777 F.Supp. 1119.
000577
Please serve a full, one page per page copy of each complaint to each defendant in all of
the matters for which I have provided you IFP proof, summons, and complaints.
PLEASE NOTE I HAVE A NEW ADDRESS.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and
may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you
are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted
to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in
error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client,
work product, or other applicable privilege.
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WLS
From: Paul Elcano (pelcano@washoelegalservices.org) You moved this message to its current
location.
Sent: Wed 5/06/09 9:38 AM
Dear Zach,
You are correct about the letter being delivered on April 20 th , I misread my timeline. My decision is limited to the
hearing conduct. You have proffered nothing that indicates that the way you acted in court is in any way related to any outside
event. Your 50 page motion for reconsideration before Judge Gardner has not linked your conduct in any way to an outside
event. You have refused to give me a time and date to meet once again, and I will issue my determination tomorrow morning
at 9:00 am.
Access to your computer materials, will be made at a convenient time and place with our office manager, executive
director or designee and our computer specialist present. This is a business computer, and without further research I will not
give you access to it privately. You have been given a tape of the two Joshi hearings. To date, you have not agreed to meet
at any time and place to discuss these hearings; and you have not specifically requested any identified items, documents etc.
that were related to your conduct in this hearing. Your series of questions about the Board is irrelevant. The Board delegated
this matter to me to handle as a personnel matter.
-Paul
000589
FILED
Electronically
01-20-2012:02:35:37 PM
Clerk of the Court
000590
000591
000592
000593
000594
000595
000596
000597
FILED
Electronically
01-20-2012:02:35:37 PM
Clerk of the Court
000598
000599
000600
000601
FILED
Electronically
01-20-2012:02:35:37 PM
Clerk of the Court
000602
000603
000604
000605
000606
FILED
Electronically
03-30-2012:04:14:37 PM
Clerk of the Court
000607
000608
000609
000610
000611
000612
000613
000614
60302: Case View
Disclaimer: The information and documents available here should not be relied upon as an
official record of action.
Only filed documents can be viewed. Some documents received in a case may not be
available for viewing.
Some documents originating from a lower court, including records and appendices, may not
be available for viewing.
For official records, please contact the Clerk of the Supreme Court of Nevada at (775) 6841600.
Case Information: 60302
COUGHLIN VS. WASHOE
Civil Appeal - General Short Caption:
Classification:
LEGAL SERVICES
Other
Related
60317, 60838, 60975
Case(s):
Lower Court
Washoe Co. - Second
Case Status: Briefing Reinstated
Case(s):
Judicial District CV1101896
Panel
Disqualifications: Hardesty
Panel
Assigned:
Replacement:
To SP/Judge:
SP Status:
Exempt
Oral
Oral Argument:
Argument
Location:
How
Submission Date:
Submitted:
+ Party Information
+ Due Items
Docket Entries
Date
Type/Subtype
Filing Fee - Filing Fee
02/27/2012
Waived
Description
Pending Document
Appeal Filing fee waived. In
Forma Pauperis.
Filed Notice of Appeal. Appeal
Notice of Appeal
docketed in the Supreme Court
02/27/2012 Documents - Notice of
12-06119
this day. (Docketing statement
Appeal
mailed to counsel for appellant.)
Justice James W. Hardesty
Other - Disqualification of disqualified from participation
02/27/2012
Justice
in this matter. Disqualification
Reason: Voluntary Recusal.
Issued Notice of Referral to
000615
Settlement Program. This
Print
Close
WLS
location.
Sent: Fri 5/01/09 8:52 AM
Cc: Kathy Breckenridge (kathy@kbreckenridgelaw.com)
1 attachment
ltrCoughlin2ndDraft.doc (30.5 KB)
Letter attached.
000616
file:///R|/...0a%20NEW%20temp/5%201%2009%20elcano's%20pelcano@washoelegalservices.org%200435%2060302.htm[11/23/2012 1:16:39 AM]
Dear Zach,
I have been authorized by the Board to handle this matter.
1.
Your current suspension was a result of the order entered by Judge Gardner in
the Joshi matter;
2.
Suspension means that you are no longer to participate as a lawyer in any case
assigned to you by WLS until further notice. You may appear on your own
behalf to litigate the order of sanctions entered by Judge Gardner. If any
lawyer contacts you about a WLS case you must refer them to Caryn
Sternlicht or Marc Ashley;
3.
According to the Courts order, you were sanctioned for arguing incessantly,
being unprepared, making sarcastic and derogatory remarks to the Court, and
for rude and disrespectful conduct. You were personally fined $934 as a result
of this conduct;
4.
I could not evaluate your conduct at trial until I received the tape of the
hearing; this tape was promptly ordered, and was finally received on
Thursday, April 23rd. I have not yet reviewed this tape in its entirety.
5.
You have requested a copy of your personnel file. This has been made
available to you;
6.
We have delivered a copy of the tape of the Joshi matter to you;
7.
You requested a formal response to your complaint concerning Rhonda. This

was investigated by me within 48 hours of your complaint. There is no
question that your office behavior (which included yelling, and calling her a
hall monitor, etc.) upset her, and as a direct result she made a comment to you.
She was counseled as to the type of language she used, and specifically told
that even though she was upset this language (bite me) was not appropriate
for the workplace. I did not realize you wanted a formal response to this
incident. Please consider this your formal response. I am unaware of any
specific written complaints other than the one you made to me about Rhonda.
Please provide me with copies of all other written complaints sent by you to
me prior to the entry of Judge Gardners order. Please make sure they are
dated. I will review them and indicate to you what the disposition of those
matters may be.
000617
8.
Counseling for difficulties in office interaction had already been scheduled

when I received Judge Gardners order. You did not appear for the mandatory
meeting at which I announced this counseling;
9.
We have received a copy of a 50 page motion for reconsideration you filed in

the Joshi matter. I will review this in its entirety. If there is any other written
material you want me to review in determining whether or not your
employment should continue with WLS you must provide it to me by 5:00 pm
Monday, May 4th. I will be happy to pick up any such material at a reasonable
time and place if you are not comfortable emailing it to me.
Based on the forgoing I will be taking the following action:

1. I will review the tape in the Joshi matter, your fifty page motion for
reconsideration and any other written material you provide to me. If your conduct
was as represented by Judge Gardner you will be terminated. This termination
will be based exclusively on the manner in which you conducted this hearing, and
will not be related to any ultimate outcome regarding the sanctions order. WLS
can not maintain an employment relationship with a lawyer who argues
incessantly, appears unprepared and makes sarcastic and derogatory remarks to
the court, and otherwise conducts his or her case in a rude and disrespectful
manner. This determination will be made by me by 10:00 am Wednesday
morning, May 6, 2009.
2. If the hearing tape does not justify Judge Gardners order WLS will require you to
participate in the previously referred to employee counseling pursuant to the
directives of our industrial psychologist. This counseling is currently going on
with other employees at WLS. The counselor will determine the extent to which
you will participate and maintain a case load. You will maintain your employment
status, and will receive pay and benefits throughout this course of counseling.
3. If you wish to discuss any resolution of this matter between now and Wednesday
morning at 10 am I will be available to meet with you at any convenient time and
place, including this weekend. You may bring any person you would like to a
resolution discussion. I will come alone unless you request otherwise.
This has been sent to you by email. Please advise me as to the address to which a hard
copy of this transmittal should be delivered.
Sincerely,
Paul Elcano
000618
60302: Case View
Notice/Outgoing - Notice
appeal may be assigned to the
02/27/2012 of Referral to Settlement
settlement program. Timelines
Program
for requesting transcripts and
filing briefs are stayed.
Notice/Outgoing - Notice Issued Notice to File Case
02/27/2012 to File Case Appeal
Appeal Statement/Civil. Due
Statement/Civil
date: 10 days.
Issued Notice: Exemption from
Settlement Program. It has been
determined that this appeal will
Settlement Notice not be assigned to the
02/27/2012 Notice: Exemption from
settlement program.
Settlement Program
Appellant(s) 15 days transcript
request form; 120 days opening
brief:
Case Search
Filed District court order. Copy
Participant Search
of Order Denying Motion to
Proceed In Forma Pauperis filed
Order/Incoming - District in district court on 3/8/2012 and
03/09/2012
Case Appeal Statement or, Pled
Court Order
in the alternative, Motion for
Extension of Time to Correct
Deficiencies in Appeal Papers.
Motion - Motion to
Filed Motion to Dismiss
03/26/2012
Dismiss Appeal
Appeal.
Filed Notice of Appearance
Notice/Incoming - Notice (Brian A. Gonsalves appearing
03/26/2012
of Appearance
on behalf of respondent Crisis
Intervention Services).
Motion - Response to
Filed Opposition to Motion to
04/09/2012
Motion
Dismiss.
Notice of Appeal
04/13/2012 Documents - Case Appeal Filed Case Appeal Statement.
Statement
Motion - Reply to
Filed Reply in Support of
04/16/2012
Response
Motion to Dismiss Appeal.
Filed Order Dismissing Appeal
in Part. We dismiss this appeal
as to CIS, only. Appellant shall
have 11 days from the date of
05/31/2012 Order/Procedural - Order this order to file and serve his
(1) transcript request form or
certificate that no transcript will
be requested, and (2) docketing
statement.
Transcript Request Filed Certificate of No
06/14/2012 Certificate of No
Transcript Request.
Transcript Request
Docketing Statement 06/14/2012
Filed Docketing Statement.
Docketing Statement
12-06121
12-06126
12-06222
12-07769
12-09480
12-09496
12-11097
12-11962
12-12020
12-17190
12-18622
12-18740
000619
60302: Case View
Notice/Outgoing - Notice Issued Notice to File Opening

06/27/2012 to File Opening Brief and Brief and Appendix. Due Date:
Appendix
15 days.
(Joseph Garin and Shannon
Notice/Incoming - Notice
07/13/2012
Nordstrom of Lipson Neilson
of Appearance
Cole Seltzer & Garin appearing
on behalf of respondents).
Motion - Motion to
Filed Respondents' Motion to
07/13/2012
Dismiss Appeal
Dismiss Appeal.
Filed Motion for Permission to
File Opening Brief After
07/25/2012 Motion - Motion
Deadline has run and
Opposition to Motion to
Dismiss.
Dismiss (and request for 15
07/26/2012
Motion
days extension to file opening
brief and appendix).
Filed Response to Plaintiff's
Motion for Permission to File
07/31/2012
Opening Brief After Deadline
Motion
Has Run and Opposition to
Motion to Dismiss.
Motion - Reply to
08/03/2012
Respondents' Motion to Dismiss
Response
Appeal.
12-20249
12-22194
12-22195
12-23543
12-23572
12-24165
12-24569
000620
000621
000622
000623
000624
000625
000626
000627
000628
000629
000630
000631
000632
000633
000634
000635
000636
000637
000638
000639
000640
000641
000642
000643
Case Summary
Case Summary for Case: CV11-03628

ZACHARY COUGHLIN VS. MATTHEW MERLISS (D7)
Case Number CV11-03628
JUSTICE COURT CIVIL
Case Type
APPEAL
Opened 12-21-2011
Status DISPOSED
Plaintiff ZACHARY COUGHLIN

Defendant MATTHEW MERLISS
PATRICK FLANAGAN Judge
Division D7
Show/Hide Participants
File Date
Case History
09-17-2012
Court
Proof of Electronic Service

Filed by or in behalf of: Court
09-15-2012
Plaintiff
Motion ...
Filed by or in behalf of: ZACHARY COUGHLIN, ESQ.
Motion ...
09-06-2012
Plaintiff
$Notice/Appeal Supreme Court

Filed by or in behalf of: ZACHARY COUGHLIN
08-31-2012
Court

08-31-2012
Plaintiff
Reply to/in Opposition

- Exhibit 1
08-29-2012
Court

08-29-2012
Defendant

Filed by or in behalf of: RICHARD HILL, ESQ.
- Continuation
08-28-2012
Court

08-28-2012
Court
Order ...
Order ...
08-22-2012

000644
file:///R|/...NEW%20temp/cv11-03628%20DTA%20as%20of%2010%2028%2012/cmsFullHistory%20(Show%20Hide%20Participants).html[11/4/2012 3:52:01 PM]
Case Summary
Court
08-22-2012
Defendant
Request for Submission

08-21-2012
Court

08-21-2012
Court
Order ...
Order ...
08-13-2012
Court

08-10-2012
Defendant

08-10-2012
Court

08-10-2012
Defendant
Opposition to Mtn ...

- Exhibit 1
08-02-2012
Court

08-02-2012
Court
Supreme Court Receipt for Doc

08-01-2012
Court

07-31-2012
Plaintiff
Mtn to Set Aside Decree

- Exhibit 1
07-31-2012
Court

07-31-2012

000645
Case Summary
Defendant

07-31-2012
Court

07-31-2012
Court
Case Appeal Statement

07-31-2012
Court
Supreme Ct Deficiency Notice

07-31-2012
Court
Certificate of Clerk
07-30-2012
Plaintiff
Notice of Appeal Supreme Court

07-24-2012
Plaintiff
Motion ...
Motion ...
- Exhibit 1
07-09-2012
Court

07-09-2012
Defendant

06-26-2012
Court

06-25-2012
Defendant

06-25-2012
Court

06-25-2012
Defendant

- Continuation
000646
Case Summary
06-25-2012
Court

06-25-2012
Court
Order ...
Order ...
06-15-2012
Court

06-14-2012
Defendant

06-14-2012
Defendant

- Exhibit 1
- Exhibit 2
06-11-2012
Court

06-11-2012
Court

06-09-2012
Plaintiff
Supplemental ...
Supplemental ...
06-08-2012
Plaintiff
Mtn Alter or Amend Judgment

05-22-2012
Court

05-22-2012
Defendant

- Continuation
05-22-2012
Court

05-22-2012
Court
Order ...
Order ...
000647
Case Summary
05-09-2012
Court

05-09-2012
Defendant

04-19-2012
Court

04-19-2012
Defendant
Mtn for Attorney's Fee

Mtn for Attorney's Fee
- Exhibit 1
- Exhibit 2
- Exhibit 3
- Exhibit 4
04-19-2012
Court

04-18-2012
Defendant

04-13-2012
Court

04-13-2012
Court

04-13-2012
Court
04-13-2012
Defendant

04-13-2012
Court

04-13-2012
Court

04-13-2012

000648
Case Summary
Court

04-13-2012
Plaintiff

04-12-2012
Defendant

04-12-2012
Defendant

- Exhibit 1
04-09-2012
Court

04-09-2012
Court

04-07-2012
Plaintiff

04-07-2012
Plaintiff
Opposition to ...
Opposition to ...
04-05-2012
Court

04-05-2012
Plaintiff

04-04-2012
Court

04-03-2012
Defendant
Memorandum of Costs
Memorandum of Costs
- Exhibit 1
03-30-2012
Court

000649
Case Summary
03-30-2012
Defendant

- Continuation
03-30-2012
Court

03-30-2012
Court
Order ...
Order ...
03-27-2012
Court

03-27-2012
Court
Order ...
Order ...
03-26-2012
Court

03-26-2012
Court
***Minutes
***Minutes
03-23-2012
Court

03-23-2012
Court
***Minutes
***Minutes
03-14-2012
Court

03-14-2012
Court

03-13-2012
Plaintiff
Supplemental ...
Supplemental ...
03-13-2012
Defendant
Subpoena Duces Tecum

Subpoena Duces Tecum
- Exhibit 1
- Exhibit 2
000650
Case Summary
03-09-2012
Court

03-09-2012
Court
03-09-2012
Court

03-09-2012
Defendant

- Continuation
03-08-2012
Court

03-08-2012
Court
Ord Denying Motion

Ord Denying Motion
03-08-2012
Court

03-08-2012
Plaintiff

03-07-2012
Court

03-07-2012
Plaintiff

03-07-2012
Court
Affidavit of Service
Affidavit of Service
03-05-2012
Court

03-05-2012
Court

000651
Case Summary
02-27-2012
Court

02-27-2012
Defendant
Errata...
Errata...
02-27-2012
Defendant

02-27-2012
Defendant

02-27-2012
Court

02-27-2012
Court
Amended ...
Amended ...
02-27-2012
Court
Amended ...
Amended ...
02-24-2012
Court

02-24-2012
Court

02-24-2012
Defendant
Answering Brief
Answering Brief
- Exhibit 1
- Exhibit 2
- Exhibit 3
- Exhibit 4
- Exhibit 5
- Exhibit 6
02-24-2012
Defendant
Motion ...
Motion ...
- Exhibit 1
02-22-2012
Court

000652
Case Summary
02-22-2012
Court
02-22-2012
Court

02-16-2012
Court

02-16-2012
Plaintiff
Mtn Proceed Forma Pauperis

Mtn Proceed Forma Pauperis
02-15-2012
Court

02-15-2012
Plaintiff

02-14-2012
Court

02-14-2012
Defendant

02-14-2012
Court

02-14-2012
Court

02-14-2012
Court

02-14-2012
Plaintiff

02-14-2012
Plaintiff

02-14-2012

000653
Case Summary
Plaintiff

02-14-2012
Plaintiff

02-10-2012
Court

02-10-2012
Defendant

- Continuation
02-09-2012
Court

02-09-2012
Defendant

02-08-2012
Court

02-08-2012
Court
Ord to Show Cause

Ord to Show Cause
02-08-2012
Court

02-08-2012
Defendant

02-07-2012
Plaintiff
Supplemental ...
Supplemental ...
- Exhibit 1
02-07-2012
Court

02-07-2012
Court

000654
Case Summary
02-07-2012
Court

02-06-2012
Plaintiff
Mtn for Extension of Time

02-06-2012
Plaintiff

02-06-2012
Plaintiff
Opening Brief
Opening Brief
02-06-2012
Court

02-04-2012
Plaintiff
Opening Brief
Opening Brief
02-03-2012
Court

02-03-2012
Defendant

02-03-2012
Defendant
Opposition to ...
Opposition to ...
02-02-2012
Court

02-02-2012
Plaintiff
Notice to Set
Notice to Set
01-31-2012
Court

01-30-2012
Plaintiff

01-20-2012
Court

000655
Case Summary
01-20-2012
Defendant
Mtn Ord to Show Cause

Mtn Ord to Show Cause
- Exhibit 1
- Exhibit 2
- Exhibit 3
- Exhibit 4
- Exhibit 5
- Exhibit 6
- Exhibit 7
01-17-2012
Court

01-17-2012
Court

01-14-2012
Plaintiff

01-14-2012
Plaintiff

01-12-2012
Court
Supplemental ...
Supplemental ...
01-11-2012
Court

01-11-2012
Defendant

- Continuation
01-11-2012
Court

01-11-2012
Court
Order ...
Order ...
01-10-2012
Court

000656
Case Summary
01-10-2012
Plaintiff
Notice of Appearance
01-06-2012
Court

01-06-2012
Court
Ord for Briefing Schedule

01-06-2012
Court

01-06-2012
Court

01-06-2012
Defendant

01-06-2012
Court

01-05-2012
Court
01-05-2012
Court
Reply...
Reply...
- Exhibit 1
- Exhibit 2
01-04-2012
Court
Supplemental ...
Supplemental ...
01-03-2012
Court

01-03-2012

- Exhibit 1
- Exhibit 2
- Exhibit 3
- Exhibit 4
000657
Case Summary
Court
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
5
6
7
8
9
10
11
12-30-2011
Court

12-30-2011
Court

12-30-2011
Court
Amended ...
Amended ...
- Exhibit 1
12-30-2011
Court
Mtn for TRO

Mtn for TRO
- Exhibit 1
12-21-2011
Plaintiff
Appeal from Justice's Court

12-21-2011
Plaintiff

12-21-2011
Plaintiff

12-21-2011
Plaintiff

12-21-2011
Plaintiff
$Appeal From Justice's Court

$Appeal From Justice's Court
000658
000659
000660
000661
000662
000663
000664
000665
000666
000667
000668
000669
000670
State Bar Of Nevada
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FIND A LAWYER
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Dorothy N. Holmes
Company:
Reno Municipal Court
Address:
P.O. Box 1900
~
Reno
,
NV
89505
Phone Number:
7753343822
Fax number:
~
Email:
No information provided
Website:
http://www.reno.gov
Admit Date:
09/17/77
Law School:
McGeorge
Specialization:
000671
file:///R|/1%20a%20NEW%20temp/190%20judge%20nash%20holmes%20mcgeorge%201977%2026800%2000696%2012420%20063341%20065630.htm[11/23/2012 2:04:11 AM]
000672
000673
000674
000675
000676
000677
000678
000679
000680
000681
000682
000683
000684
000685
000686
000687
Print
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RE: damaged personal property

From: Kandaras, Mary (mkandaras@da.washoecounty.us) This sender is in your safe list.
Sent: Mon 4/16/12 3:19 PM
To: Zach Coughlin, Esq. (zachcoughlin@hotmail.com); Beckman, Trish
(TBeckman@washoecounty.us)
This claim must be presented to Washoe County Risk Management. You will have to contact that office
and follow their procedures.
Mary Kandaras
Deputy District Attorney
Phone: (775) 337 - 5723
Fax: (775) 337 - 5732
From: Zach Coughlin, Esq. [mailto:zachcoughlin@hotmail.com]

Sent: Monday, April 16, 2012 3:14 PM
To: Beckman, Trish; Kandaras, Mary; zachcoughlin@hotmail.com
Subject: damaged personal property
Ms. Beckman and Ms. Kandaras,
Please accept this correspondence as a request for a new G2 HTC smartphone, a new Samsung cell phone, and a new
32GB micro sd card. The card has been rendered unusable and all the data then existing on it at the time of its seizure
has been removed. Please provide an indication of whether that was done on purpose or not, in writing. Further, I
believe I should be provided with compensation for the cost of new phones as these are obviously rather suspect at this
point.
Further, with local attorney Pam Willmore present a WCSO Deputy and Ms. Campbell indicated to me that per Courts
Orders I was to contact RMC Marshal Deighton. I did and he never responded in any way. Please indicate why exactly I
000688
file:///F|/...%204/4%2016%2012%20email%20to%20kandaras%2026800%200434%20063341%20065630%20067980.htm[11/23/2012 2:12:35 AM]
was told to so contact Marshal Deighton, and why that Deputy told me, at that time, that the property had already been
returned to the RMC Marshals because it would just be easier to get it back to you that way (ie, having me retrieve the
property from the RMC Marshals versus retrieving it directly from the WCSO). Further, that Deputy admitted, with Ms.
Willmore present, that Ms. Cumming and Ms. Campbell were, in fact, incorrect, in their assertions that the micro sd card
had been returned the acquaintance of mine whom retrieved my keys while I was incarcerated. Rather, that Deputy then
admitted the micro sd card, in fact, was not returned at that time. Of course, a 32 GB micro sd card was returned to me
with Deputy Ivers present, however, he and Ms. Beckman, Ms. Berryman, Deputy Cheung, and one other Deputy all
scattered quickly after I began opening the secured envelope, refusing to allow me to test the micro sd card in their
presence.
Sincerely,
Zach Coughlin
From: Beckman, Trish [mailto:TBeckman@washoecounty.us]

Subject: RE: request for written response regarding property being held in evidence

To: Beckman, Trish
Dear Ms. Beckman,

There was nothing attached to your email. Would you please resend and attach the file you
referenced below?
Thanks,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
No: 9473
000689
Date: Tue, 20 Mar 2012 08:49:52 -0700
From: TBeckman@washoecounty.us
Mr. Coughlin, Attached is the written response to your email. Per our phone conversation a copy of this response has
been sent to the fax number you gave me (949-667-7402).
Trish

Sent: Monday, March 19, 2012 4:58 PM
To: Beckman, Trish
Subject: request for written response regarding property being held in evidence
Dear Ms. Beckman,

A WCSO Deputy informed me that my property was being held in evidence, including a flip
phone style cell phone, and an HTC g2 smartphone in addition to a micro sd memory card,
and an electric shaved. He indicated the items were booked into evidence on 2/27/12, then
taken by the City of Reno Marshal Division on 2/28/12. A WCSO Deputy also indicated these
items in evidence were release again to the City of Reno Marshal Division on 3/14/12
because "its just easier to get it back to you that way"....However, now it appears once
again your office has the property.
I would like a written response detailing the chain of custody of all the property for all
times since the arrest, and itemized listing of the property, and an indication of when, if
ever, I will be informed of why it is being held and when, if ever, it will be returned to me,
and and indication of what exactly has been done with this property, including whether an
viewing or copying of the contents has been undertaken or will remain in anyone's
possession other than mine.
Sincerely,
Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
000690
Print
Close

Sent: Fri 12/16/11 10:44 PM
Dear Ms. Longoni,

Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

Sent: Wed 12/21/11 12:02 AM
000691
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
Dear RMC,
which I am sending this correspondence: renomunirecords@reno.gov which is the email address filing
office supervisor Donna Ballard indicated to me was acceptable for sending correspondence and
regarding my recent messages to her. I was told by a RMC filing office counter employee that I must
get the transcript through Ms. Longoni, as she is the "official transcriptionist" for the RMC. Please
confirm that I am no able to have another certified court reporter or transcriptionist create the official
transcript and indicate by what date this must be done, how it must be done, etc.
writing.
Sincerely,
/s/Zach Coughlin
000692

Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,

Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
000693
000694
000695
000696
000697
000698
000699
000700
000701
000702
: Coughlin's
erty
s his
er's
nse
ite RSIC
cer
ford's
imony
1/30/11
1CR22176
000703
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Tribal Police not allowed to arrest for misdemeanors FW:

Case No. RCR2011-063341
Sent: Sun 11/11/12 8:40 AM
To: homerj@reno.gov (homerj@reno.gov); complaints@nvbar.org (complaints@nvbar.org);
hazlett-stevensc@reno.gov (hazlett-stevensc@reno.gov); robertsp@reno.gov
(robertsp@reno.gov); kadlicj@reno.gov (kadlicj@reno.gov); fflaherty@dlpfd.com
(fflaherty@dlpfd.com); patrickk@nvbar.org (patrickk@nvbar.org); tsusich@nvdetr.org
(tsusich@nvdetr.org); wongd@reno.gov (wongd@reno.gov); ormaasa@reno.gov
(ormaasa@reno.gov); bonyr@reno.gov (bonyr@reno.gov); skauc@reno.gov (skauc@reno.gov);
davidc@nvbar.org (davidc@nvbar.org); drakej@reno.gov (drakej@reno.gov); je@eloreno.com
(je@eloreno.com); cvellis@bhfs.com (cvellis@bhfs.com); mike@tahoelawyer.com
(mike@tahoelawyer.com); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
skent@skentlaw.com (skent@skentlaw.com)
How exactly is it that both City Attorney Pamela Roberts, Esq. and Chris HazlettStevens, Esq. did not violate RPC 3.8 or otherwise prosecute for arrests that were not
lawful
in RMC 11 CR 22176 (Indian Tribe police custodial arrest for misdemeanor? Not
lawful under NRS 171.1255, and even if they were RPD, which they are not, its not like
they charge Coughlin with something other than petty larceny a la NRS 171.136(2)...
Further, can you provide me an indication of how it was lawful for RSIC Officer's
Kameron Crawford or Donnie Braunworth to arrest me on 9/9/11 (and Wal-Mart's
Thomas Frontino made explicitly clear in his testimony at trial on 11/30/11 that neither
he nor any of Wal-Mart's staff in any way effected a custodial arrest of Coughlin on that
date) for a misdemeanor given the following:
NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by Indian
tribe.
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian Affairs or a
person employed as a police officer by an Indian tribe may make an arrest in obedience to a warrant
delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officer
or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has
reasonable cause for believing the person arrested to have committed it.
000704
for a public offense, and the officer or agent has reasonable cause to believe that the person arrested
is the person so named or described.
(f) When the peace officer has probable cause to believe that the person to be arrested has committed
a battery upon that persons spouse and the peace officer finds evidence of bodily harm to the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on that
reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in fresh
pursuit of a person who is reasonably believed by the officer or agent to have committed a felony
within the boundaries of the reservation or colony or has committed, or attempted to commit, any
criminal offense within those boundaries in the presence of the officer or agent.
For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
(Added to NRS by 1985, 452)
While Ormaas made sure to get judicial notice taken of jurisdiction in 11 TR 26800, it doesn't seem
Pamela Roberts, Esq. did in the Indian Colony Wal-Mart matter...Why is that, Pam? Tribal land? Never
determined if Coughlin had even an ounce of tribal blood? RSIC Officers not entitled to make custodial
arrests for misdemeanors, even, apparently, one's committed right in their presence? So, even if
Coughlin did refuse to provide his driver's license (which has been proven to be a lie, and perjury
suborned by Pam Roberts as to the testimony of Wal-Mart's Frontino and the RSIC Officer's Crawford
and Braunworth via police reports, dispatch recordings (AND PLEASE BE ADIVSED, AS ITS WITHIN THE
2 YEARS, THAT THE CITY OF RENO, THE SOUTH DISPATCH CENTER FOR ECOMM OR WASHOE
COUNTY, OR WHOEVER IT IS THAT HANDLES THE RSIC DISPATCH CALLS, IT ON A LITIGATION HOLD
NOTICE. COUGHLIN DEMANDS (AND THE DISPATCH/ECOMM SOUTH DISPATCH CENTER WILL GET
ITS NRS 174.345 SUBPOENA IN THE MAIL FOR A MISDEMEANOR SOON ENOUGH) THAT THE
CUSTODIAN OF RECORDS MAINTAIN ANY AND ALL RECORDINGS, LOGS, OR OTHER DOCUMENTATION
OR MEDIA IN ANY WAY CONNECTED TO ZACHARY B. COUGHLIN IN ANY WAY WHATSOEVER,
ESPECIALLY WITH REGARD TO THE ARREST OF 9/9/11 AT THE RSIC WAL-MART IN RENO NEVADA
NEAR GLENDALE AND W. 2ND ST.
So, all these arrests by the RSIC police of alleged shoplifters at Wal-Mart...Sling Bla...er, Officer
Braunworth testified that there was lots of them (sounds like Wal-Mart and the RSIC have the whole
"find a way to get a search incident to arrest" thing down part, while avoiding any wrongful arrest
liability against the deep pocket tenant Wal-Mart by avoiding any "shopkeeper's privilege" type citizen's
arrests (or trying to use just as much intimidation and coercion as Frontino and the gang can muster,
while seeking to claim not to have effected a citizen's arrest later in court, given setting the RSIC up to
handle those types of lawsuits is arguably a better long term loss mitigation approach for these long
term business partners, Wal-Mart and their partner/landlord the RSIC.
So, please enlighten me. How is it these RSIC Officers are making all these custodial arrests for simple
misdemeanors? And just where in the audio transcript of the Trial (you might want to have RMC house
000705
transcriptionist Pam Longoni finally get around to making a transcript and providing it to Coughlin, as
the handouts the RMC itself provides defendants baring Longoni's and the RMC's "down
payment"/transcript hostage rules are tantamount to extortion in violation of NRS 189.030. Then there
is the bit about the RMC and or other discovering over $700K was "missing", and the attempts to chalk
it up to "data entry" errors. Please get that transcript to me right away, and transcripts of every other
hearing I have ever had in the RMC, including the one on or around February 2nd, 2012 or so where
RMC court appointed defender Roberto Puentes successfully argued for an Order Granting His
Withdrawal (five Withdrawals by court appointed counsel of Coughlin, four via an Order Granting a duly
filed Motion (though these guy's Motions wouldn't pass my 7th grade English Class's bi-weekly writing
assignment in my days at Swope Middle School) and Hon. W. Gardner starts to divulge, only after
Coughlin's prompting, bit by bit some of the patent conflicts that should have prevented him from ever
ruling on a single motion in that case 11 CR 26405. With such lack of vigor from the RMC's court
appointed defense counsel, could a class action lawsuit agains them, the RMC, and or the City of Reno
be a possibility someday? Certainly is a nice lil side gig $7K a month those guys get...and all these
prosecutions and trips to jail this year certainly have afforded an opportunity to see the "operation" up
close.
Also, you know, as to lots of these arrests, like say the July 3rd, 2012 arrest by RPD Officer Alan
Weaver and now Sargent Brian Dye in 12 CR 12420 (wherein two RMC court appointed counsel have
already sought and obtained Orders Granting Their Withdrawal, one, by Keith Loomis, one by Henry
Sotelo, the latter in violation of the stay in NRS 178.405) the legitimacy of effecting a custodial arrest is
completely suspect considering:
ARREST: BY WHOM AND HOW MADE

NRS 171.124 Arrest by peace officer or officer of Drug Enforcement Administration.
1. Except as otherwise provided in subsection 3 and NRS 33.070 and 33.320, a peace officer or an
officer of the Drug Enforcement Administration designated by the Attorney General of the United States
for that purpose may make an arrest in obedience to a warrant delivered to him or her, or may,
without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officers presence.
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the officers
presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer has reasonable
cause for believing the person arrested to have committed it.
for a public offense, and the officer has reasonable cause to believe that the person arrested is the
person so named or described.
2. A peace officer or an officer of the Drug Enforcement Administration designated by the Attorney
General of the United States for that purpose may also, at night, without a warrant, arrest any person
whom the officer has reasonable cause for believing to have committed a felony or gross misdemeanor,
and is justified in making the arrest, though it afterward appears that a felony or gross misdemeanor
has not been committed.
000706
So back to the Wal-Mart RSIC arrest...the charge sheet doesn't say Coughlin was arrested for anything
other than petty larceny....but:
NRS 171.136 When arrest may be made.

1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day, and at
any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m., except:
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
(c) When the person is found and the arrest is made in a public place or a place that is open to the
public and:
(1) There is a warrant of arrest against the person; and
(2) The misdemeanor is discovered because there was probable cause for the arresting
officer to stop, detain or arrest the person for another alleged violation or offense;
(d) When the offense is committed in the presence of a private person and the person
makes an arrest immediately after the offense is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018 and
the arrest is made in the manner provided in NRS 171.137;
(f) When the offense charged is a violation of a temporary or extended order for protection against
domestic violence issued pursuant to NRS 33.017 to 33.100, inclusive;
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding warrant of
arrest.
So, on exactly what basis was the July 3rd, 2012 arrest made by the RPD? The police report says the
arrest was made for "disturbing the peace", yet the only allegation of anything remotely in the "officer's
presence" relates to the minor traffic citation the City of Reno is clinging to in attempts to mitigate the
Sec. 1983 damages here. However, the RPD admits at least one vehicle was between their's and
Coughlin's and Sooudi et al (besides making an incomprehensibly stupid decision to briefly file an
amended complaint for trespassing where even the RPD was smart enough to realize that was a poor
choice given Coughlin still had lease at Northwind, and thus a pat claim of right defense to any trespass
allegation absent something like the manufactured protection order that RPD Officer Weaver coerced
Milan Krebs into obtaining, just like Weaver attempted to get Superior Storage's Matt Grant to do,
shortly after Weaver, in full view of Welch, Sargent Miller, and other RPD Officer's, on September 21st,
000707
2012, threatened to come up with yet another fraudulent "failure to secure a load on one's vehicle"
arrest of Coughlin). So, even though Weaver and Dye are stuck with their statements in the written
reports, wherein they allege to have arrest Coughlin for "disturbing the peace" only to then tack on
"citations" for the two traffic offenses (and the "proof of insurance" citation, even after Officer Weaver
admits to being provided a high definition pdf picture on a 5 inch smart phone screen with a policy
number, etc., only to be amplified by the July 5th, 2012 bail hearing racket tearing (a tennis reference
for Jill Drake, Esq.,... for shame, really Jill, really, really unimpressed).
Please remit a certified check for $450,000 in satisfaction of these torts committed upon Coughlin,
under color of law.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
To: homerj@reno.gov; complaints@nvbar.org; hazlett-stevensc@reno.gov; robertsp@reno.gov;
kadlicj@reno.gov; fflaherty@dlpfd.com; patrickk@nvbar.org; tsusich@nvdetr.org
Date: Thu, 8 Nov 2012 20:36:27 -0800
couldn't open them, and I don't accept service of anything form you... See Allison
Ormaas comments on 3/12/12 in 11 tr 26800 with respect to your offices violation of
the RMC Rules to the extent there is not difference technologically anymore between
an email and a fax:
A. All rules and procedures that apply to motions/pleadings filed in person at the court shall also apply to motions/pleadings filed by
facsimile, except as otherwise specified in this rule.
C. Except by prior court approval, a motion/pleading by facsimile shall not exceed fifteen (15) pages in length, including the cover sheet
and exhibits. A document shall not be split into multiple transmissions to avoid the page limitation.
F. All motions/pleadings filed by facsimile must be accompanied by a cover sheet which must include the persons name, address, fax
number and telephone number.
G. All facsimile motions/pleadings filed by an attorney must include the attorney's name, the firms name, address, fax number and
telephone number. In addition, the attorneys state bar number must be conspicuously displayed on the cover sheet.
H. All motions /pleadings filed by facsimile must be accompanied by proof of service. Service may be accomplished by facsimile when
the receiving party is a governmental agency, an attorney, or with the consent of the receiving party. If service of the
motion/pleading is accomplished by facsimile the 3-day allowance for mailing shall not be computed into the time for response.
J. Any motion /pleading received by the court after 4:30 p.m. or on a non-court day shall be filed on the following court day.
000708

No continuance shall be granted, including a stipulated continuance, except for good cause. A motion or stipulation for continuance must
state the reason therefore and whether or not any continuance has previously been sought or granted.
Further, Please consider Pamela Roberts attempts to mislead the Court and opposing counsel where (despite Rich HIll getting a
continuance agree to by then court appointed defense counsel Lew Taitel, whose business partners Coughlin was suing in CV11-03015
and or CV11-03126, Taitel agreed to a continuance, in violation of Coughlin's speedy trial right, where Hill needed to go on a six week
vacation in 11 cr 26405) Roberts at first agreed, in writing, to a continuance in response to Coughlin's request for one in 11 CR 22176, but
then retaliated against Coughlin's pointing out her RPC 3.8 violations on the day of Trial, 11/30/12 by refusing the stipulate to a continuance
an blaming it on the Court.
Pursuant to RMCR Rule 5(H), the City Attorney's Office does not have my consent to service via any means
other than the traditional snail mail, usps, or personal service. And I am not currently included amongst those
who are "attorneys", so you are stuck with that. Your office on the other hand, fits within both the
'governmental agency" and "attorney exceptions"...someone needs to tell Christopher Hazlett-Stevens, Esq. that
becuase he has lied numerous times, on the record about not being served where he has been. Take, for
instance
Further, does your office represent any of the RMC's court appointed defenders? Taitel, in 11 CR 26405, failed
to follow RMC Rules in withdrawing from representation:
A. Attorneys representing defendants shall promptly serve written notice of their appearance with the City Attorney and file the same
with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the court and serve the City Attorney with the same. The court
may rule on the motion or set a hearing.
Hazlett-Steven's lies, in part, helped secure a dismissal of my appeal in cr12-1262 (the appeal of the Richard G. Hill eviction trespass
case). Also, you will want to query the RMC's D2 and Lisa Gardner as to why Coughlin has a confirmation of delivery of his timely under
NRS 189.010 Notice of Appeal in 11 cr 26405, yet D2 failed to file it, and the appeal in cr12-1262 was dismissed in light of the combination
of both asserting, in one way or another, that the Notice of Appeal was not received in a timely manner. The delivery confirmations say
otherwise.
Please remit $250,000 in the form of a certified check to the address below within 10 days in settlement of these torts. SBN, please
provide to me the grievance number associate with this new grievance that is created upon the successful transmission of this email.
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
000709
utbound fax report
Inbox
Jun 27
to me
Hi zachcoughlin,
xoxo,
The Voxox Team
This message was intended for renoattorney@gmail.com. Want to control which emails you receive from Voxox?
Get Voxox: http://download.voxox.com and adjust your Notifications in the Settings/Preferences window. Voxox by
TelCentris, Inc. is located at 10180 Telesis Ct., San Diego, CA 92109.
Jun 27
to me
Hi zachcoughlin,
Jun 28
to me
Hi zachcoughlin,
Jun 28
to me
Hi zachcoughlin,
Jun 28
to me
Hi zachcoughlin,
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Sent: Fri 12/16/11 10:44 PM
Dear Ms. Longoni,

Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

000773
Sent: Wed 12/21/11 12:02 AM

Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
Dear RMC,
which I am sending this correspondence: renomunirecords@reno.gov which is the email address
filing office supervisor Donna Ballard indicated to me was acceptable for sending correspondence and
regarding my recent messages to her. I was told by a RMC filing office counter employee that I
must get the transcript through Ms. Longoni, as she is the "official transcriptionist" for the RMC.
Please confirm that I am no able to have another certified court reporter or transcriptionist create the
official transcript and indicate by what date this must be done, how it must be done, etc.
writing.
Sincerely,
/s/Zach Coughlin
000774
Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,

Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
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RE: arraignment
Sent: Fri 2/24/12 4:29 PM
To: Dogan, Biray
'Sup Biray,
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CV11-03628
Judge:
PATRICK FLANAGAN
02-08-2012:16:34:48
Clerk Accepted:
02-08-2012:16:35:22
Court:
Case Title:

MERLISS (D7)
Ord to Show Cause
Filed By:
Kathryn Sims
COUGHLIN
000796
FILED
Electronically
02-10-2012:01:49:40 PM
Clerk of the Court
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FILED
Electronically
02-10-2012:01:49:40 PM
Clerk of the Court
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CV11-03628
Judge:
PATRICK FLANAGAN
02-10-2012:13:49:40
Clerk Accepted:
02-10-2012:13:50:37
Court:
Case Title:

MERLISS (D7)

- **Continuation
Filed By:
RICHARD HILL, ESQ.

COUGHLIN
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Clerk of the Court
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Due Process concerns related to the "grievances"

Sent: Sat 3/24/12 1:28 AM
To: patrickk@nvbar.org
4 attachments
3 23 12 FAX TO BAR COUNSEL PATRICK KING NEVADA BAR.pdf (55.3 KB) , 3 19 12 fas to
rmc marshals regarding property wcso.pdf (40.0 KB) , Pages from mary barker rmc 11 tr
26800 order denying motion for return of bond.pdf (508.2 KB) , notice of appeal 11 tr
26800 rmc and Motion for reconsideration set aside etc.pdf (2.6 MB)
Zach Coughlin, Esq.

Nevada Bar No: 9473
PO Box 60952
RENO, NV 89506
tel: 775 338 8118
fax: 949 667 7402
TO: Patrick King, Esq.

State Bar of Nevada Assistant Bar Counsel
sent via email to: PatrickK@nvbar.org
March 23, 2012

Dear Assistant Bar Counsel King,
I have a few question I would like to respectfully submit to you. What have you done to ascertain whether the
Marshal's have a vested interest in discrediting me? I would like you to forward me all communications from
anyone in Department Three. I would like for you to obtain a copy of the hearing today, wherein Judge Flanagan
concluded the hearing by quoting to something I wrote (it was the only thing he mentioned after indicating that he
wished to speak to the attorney's in this matter after dismissing the witness, the lying contractor for Richard G.
Hill, Phil Stewart, who has offered perjured testimony numerous times on Mr. Hill's and his client's behalf. Judge
000845
Flanagan quote something I wrote in a filing in 11 TR 26800, where the Judge, Dorothy Nash Holmes, a lifetime
prosecutor and or warden of a prison (or something along those lines) had me arrested and confiscated my
property, including a smart phone (and a smart phone these days could store the entire contents of a law firm's
files and a law library in one), my less advanced cell phone, my premium electric shaver and other items. My car
was towed during the summary 5 day jail stay Judge Nash Holmes found appropriate, costing me $300 to get it out
of the lot (also lost a client that would have brought in a substantial amoutn of money, by my standards anyway).
A $100 bail was paid to get me out of jail on the fourth day (thus avoiding a fifth day) and accepted by the RMC,
yet, I was not released and the RMC has decided to keep the money anyways.
Yesterday I went to the RMC to pick up a copy of the audio transcript of the 2/27/12 Trial in that matter 11 TR
26800. After asking some questions of filing office supervisor Donna Ballard and a front counter clerk named
Daniel, wherein both agree with me that some of the ways things were done done at the Reno Municipal Court
lacked transparency, a system of checks and balances, and other fundamental notions of due process and fair play,
all of the sudden, two beefy City of Reno Marshals in their mid 20's decided, unilaterally, it seems, to ask me to
leave, as Ms. Ballard certainly had expressed nothing in the way of discontent with our conversation, nor had
Daniel. While I was leaving I could clearly hear Marshal Thompson lying extensively into his radio, trying to
manufacture some sort of report of a scene were there had been none, other than that put on by the City of Reno
Marshals, whom have lied extensively about whether or not they ever took possession of a micro sd card incident
to the full body all pockets, belligerent, accusatory search they performed incident to the summary contempt
finding and arrest of 2/27/12. I request that you ask for a copy of Marshal Harley's employment file from BOTH
the RMC and the City of Reno Marshals Division and see if they put in my letter and complaint in that regard.
Or, do you "find that the burden of proof in the various grievances I have filed with you has not been met, that all
the evidence needed for a conviction has not been presented to your lap with a bow? Did Mr. Hill present such
proof, meeting such a burden. Clearly, the only thing you provided to me from Mr. Hill was an EXCERPT of his
1/14/12 letter to you, which reference numerous shadowy previous phone calls between the two of you (are you
Mr. Hill's hand picked Bar Counsel, or was this case assigned randomly? Does Mr. Hill get to pick which RPD
Sargents and Officers show up for his calls for help? Have you made any inquiry to ascertain this. Why does
Richard Hill constantly file a peremptory challenge anytime he is assigned to Judge Adam's Department 6,
apparently? Did the innuendo and hearsay Richard G. Hill, Esq. Mentioned in his unsigned, unsworn letter to you
of 1/14/12 provide you sufficient proof to meet the clear and convincing evidence stand you indicate that the
grievances I filed did not? How do the copies of electronic correspondences between myself, State Bar of Nevada
Director of Admissions Patrice Eichman, Peter Christiansen, Esq., and Michael Sanft, Esq.,'s legal assistant Kelly
Huff, wherein she explicitly admits to her firm committing malpractice in my case, fail to provoke even a scintilla
of investigation into a grievance from or the State Bar of Nevada?
And the impropriety implicated by Kevin Kelley's conduct, and Mr. Christiansen's later lying under oath at the
June 2002 Character and Fitness Committee hearing for which he feels he satisfied the $5,000 he received in
payment (well, okay, he did file an 8 page pre-hearing brief that rehashed factual recitations from various previous
filings of the Committee, then did manage to cite to the Claiborne case, which concerned a former judge, not an
applicant for admission to the bar, and he did fail to subpoena percipient witness Mark Tratos, or any of the
relevant faculty from Boyd School of Law, and he did screw up the affidavits of the students witnessing me
turning in the hard copy of the paper, and his office did forward a correspondence about alcoholism to the State
Bar despite an express indication by the client atop of it that said not to do so, and his office did mistate whether
they ever turned in the second Consent Agreement send with confirmation to them on September 27th , 2004 in a
November 2004 email, so....wait, are you really saying there isn't enough there for a grievance FROM A CLIENT
FILING ONE AGAINST HE WHO WAS COMPENSATED $5,000 TO REPRESENT HIM (THOUGH
CHRISTIANSEN LIED UNDER OATH AND SAID IT WAS ON A PRO BONO BASIS, IN ACCORD WITH
THE REPRESENTATIONS MADE BY STRIP CLUB SPEARMINT RHINO OWNING CHARACTER AND
FITNESS COMMITTEE MEMBER KEVIN KELLEY, ESQ., WHOSE BEST FRIEND WAS THE
PSYCHOLOGIST THE APPLICANT WAS STEERED TO IN THE ADMISSIONS PROCESS)? BUT, YOU
ARE SAYING PURSUING A GRIEVANCE PROCEDURE AND, APPARENTLY, FORMAL HEARING
INCIDENT TO THE ATTEMPT TO FILE A GRIEVANCE BY A KNOWN SCANDALOUS OPPOSING
ATTORNEY RICHARD G. HILL, ESQ., AGAINST MYSELF, IN A MATTER FOR WHICH I AM NOT AN
ATTORNEY OF RECORD (PRO SE ATTORNEY LITIGATNS, APPARENTLY, CANNOT RECEIVE
ATTORNEY'S FEE AWARDS UNDER THE SELLERS CASE, SO HOW CAN THE RULES OF
PROFESSIONAL CONDUCT BE APPLIED TO ANY OF MY CONDUCT IN A CASE WHERE I AM A PRO
SE LITIGANT?)? It sure is curious how you find sufficient proof to pursue Richard G. Hill, Esq.'s grievance
against me, yet, you claim that all the grievances I filed do not warrant any sort of investigation on your part. Very
000846
curious, indeed...
You wrote: "As Assistant Bar Counsel I would like to help you. However, my primary responsibility is to protect
the public and the administration of justice by insuring that Nevada Lawyers are complying with standards
required of the profession. It appears that you are not."
I would like you to specify in detail exactly what forms the basis of your assertions in those a statements, as
heretofore you seem to rely upon only the unsigned, unsworn, hearsay cited to by Richard G. Hill and some
apparent grievances filed by judges, to which you have not previously informed me of or offered any proof
thereof, despite your incorrect assertion that you have done so. If you, as you wrote that you did, previously
provide any indication or documentation in support of these "grievances" filed by Judges, please provide support
therefor in explicit written detail with supporting documentation and proof service.
You further wrote, and I seek explication and specificity with regard to details and attribution incident to the
allegations therein contained that:
" I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal
research." Would you say, Mr. King, that you would very much prefer it if I had done NO legal research prior to
meeting with you?
You go on to write "You asked if Mr. Hill has standing to file a grievance against you. Not only does he have
standing to file a grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As
I have explained to you, the grievances against you came not only from Mr. Hill but also from Judges from
different Courts."
That statement casts extreme doubt upon everything you have said to me, Mr. King, and everything you will say to
me. Please provide the requested proof of any grievances against me that came from "Judges from different
Courts". You do realize, Sir, that some "Judges in Different Courts" have pulled drivers over recently and
impersonated a highway patrol officer, and that some Clerks of Court have embezzled $250,000 from the public
fisc? And, just to be clear, you truly do not find anything worthy of a grievance per Mr. Taitel's curious
appearance/disappearance as attorney of record, failure to do a conflicts check, failure to subsequently disclose
such a failure and the tangible harm it has done to me vis a vis my suing Nevada Court Services and his sharing
an office, receptionist, and being listed on the Nevada Court Services web site as "associated with" their business
entity? Didn't Mr. Taitel have a recent ethics investigation pursuant to some run for judicial office?
Also, Judge Nash Holmes indicated at trial, and this is a direct quote, that she "doesn't care about corruption, or
bribery, retaliation, or police misconduct"...well, that is as close to a direct quote as I can make given the fact that
the RMC, just yesterday refused to provide me a copy of the audio transcript from the 2/27/12 Trial in 11 TR
26800, presided over by Judge Nash Holmes, after a length disappearance by her immediately before calling my
case, and after hearing all the other matters on that stacked docket, and after denying my request for a continuance
but granting Deputy City Attorney Allison Ormaas's request for one to "speak" with Reno Police Department
Sargent Tarter, whose cross examination formed the basis for my arrest and incarceration incident to the summary
contempt finding. The cross examination focused on whether Sargent Tarter had retaliated against me for reporting
the bribery admission by RPD Officer Chris Carter (he admitted Richard G. Hill, Esq. bribes him) to Sargent
Tarter while at the scene of my attempts to get Richard G. Hill to turn over my client's files and my wallet and
state issued identification. If you want to put your name on the line over this, Mr. King, and you think we still live
in a world with very little transparency, who am I to tell you any different.
You further wrote: "These grievances, and the evidence attached with them, rather clearly puts into question your
competence to practice law." Please narrow down which parts of which grievances you feel so implicate my
competence, in explicit written detail.
You further wrote: "As I have explained to you, I will make the evidence and exhibits available to you when you
come to inspect them at my office." Mr. King, please indicate when it was and in what form or method you
communicated this offer to "make the evidence and exhibits available to you when you come to inspect them at
my office"? Please further explain why on earth I would only be allowed to inspect them at your office and how
that does not create and overly bullying and intimidating scenario departing entirely from fundamental notions of
due process. Please just fax and email (both please) the entire contents of all these materials to me. I am likely
suing the USPS and some of its local postal inspectors and or station supervisors under the Federal Tort Claim Act
000847
and while I have taken every prudent step to ensure the timely delivery of my mail (I have a ton of evidence and
documentation in support of this), I am EXPLICITLY indicating to you that I wish for you to fax and email me all
of these materials rather than send them through the mails (USPS, UPS, Fed-Ex, etc, etc.).
You then wrote: "I will not send you reports or document, especially since you claim your mail is being
compromised. " I am appalled that you would write this, and offended really. Please email and or fax them to me.
I have communicated with the USPS and my change of address has been processed (there was a delay through no
fault of my own) and if you refuse to send these to me via email or fax, the go ahead and mail them to my new PO
BOX, though taking that tact will likely only make your conduct throughout this proceeding further suspect. Such
as when you wrote:
" As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters.
As such, at this time we have not opened any files based on the information you have submitted. " Please indicate
how, exactly, Richard G. Hill's grievance met such a standard of proof where the one's I submitted did not.
Further, while you have indicated that I have not responded to your request to meet with you (which is not the
case), you only just, for the first time, today, even mentioned anything about any judges filing or corresponding
anywith with or to you, and you have failed to provide any documentation of such or copies thereof sufficient to
satisfy my Sixth Amendment Right to Confrontation, etc. Please do so.
Sincerely,
/S/
Zach Coughlin, Esq.
CC: DavidC@nvbar.org
Date: Fri, 23 Mar 2012 19:10:10 +0000
March 23, 2012
Dear Mr. Coughlin,
required of the profession. It appears that you are not. I believe that there are ways 000848 you
to get
difficult time.

To: Patrick King
Mr. King,
Sincerely,
No: 9473
000849
FILED
Electronically
08-28-2012:04:32:12 PM
Clerk of the Court
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000868
000869
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D
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FILED
Electronically
03-27-2012:08:56:46 AM
Clerk of the Court
000881
000882
000883
000884
000885
000886
000887
000888
000889
FILED
Electronically
08-16-2011:01:34:07 PM
Howard W. Conyers
Clerk of the Court
000890
000891
FILED
Electronically
02-08-2012:04:34:48 PM
Clerk of the Court
000892
000893
000894
000895
000896
000897

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000901
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000903
000904
000905
000906
000907
000908
000909
000910
000911
000912
Print
Close
RE: WCSO Deputy Machem's "personally served" Affidavit of

11/1/2011
Sent: Tue 2/07/12 11:40 AM
Cc: Kandaras, Mary (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.

WCSO Civil Section

To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna; kadlicj@reno.gov; fourthestate@gmail.com;
jamesandreboles@msn.com
lstuchell@washoecounty.us mkandara@da.washoecounty.us

000913
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
Summary Eviction against 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), especially where a stay of eviction was
not granted even while the RJC held on to most all my money...).
"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 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 "served" in
compliance with all time related rules because it was done in the "usual custom and
practice of the WCSO. What, exactly, is the "usual custom and practice of the
phraseology: "
Eviction was signed by October 27th , 2011. That language is only found in situations
000914
and,
000915
MACHEM THAT ADMITS THAT I WAS NOT PERSONALLY PRESENT WHEN
HE SERVED THE ORDER FOR SUMMARY EVICTION IN RJC REV2011-001708
ON 11/1/12 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
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 000916
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
for removal of the tenant or an order providing for the nonadmittance of the
tenant....
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 10 days after
the filing of the motion. The court shall affix the date of the hearing to the motion
and order a copy served upon the landlord by the sheriff, constable or other
process server. At the hearing, the court may:
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
000917
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 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 118A.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 County Sheriff (despite what their Affidavit of
Service 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 40.253(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, 12 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 following 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 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 911incident 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
000918
ordered a custodial arrest of me for "jaywalking".
following one:
From: NvRenoPd@coplogic.com
Sent: Wed 9/07/11 10:51 PM
THIS 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.
Thank you,
Officer WOZNIAK,
ADDRESSED."
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 118A.460
may deem "reasonable storage" expenses for which a lien is available to a landlord,
though NRS 118A.520 has outlawed rent distraints upon tenant's personal
000919
Actually, upon being release from jail on November 15th, 2011, incident to the
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 earlier. 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 11/12/11 trespassing arrest, that Sargent immediately
informed me that, despite this being the first he heard of that, he was sure that was not
happening....I 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 attorney being
required to report said conviction to the State Bar of Nevada under SCR 111, 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 11/15/11 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 12th, 2011 (custodial arrest, bail of $160 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"
000920
found in NRS 118A.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 12th, 2011 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.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 signed 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...).
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,
"Court Services, come out now!", wearing their pretend Sheriff outfits, big equipment
saddled belts (including firearms, I believe, and radios), etc. ,etc.
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
filed a notice of appearance, and received my confidential file, pc sheet, arrest reports,
000921
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):
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 2011. 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, 2011)
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 1/12/12.
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 911" just two days later, on
January 14th, 2011 when I called 911 to report that my roommates were laughing
000922
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 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 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 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)...I
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 of this...But that would
require and awful lot of coincidences.
Sincerely,
Zach Coughlin, Esq.

1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
000923
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
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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
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please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone
other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
RE: IFP Coughlin Service of Complaints WLS employment law;

landlord tenant case
Sent: Mon 12/05/11 12:32 PM
Mr. Coughlin,
Per your demand stated in the e-mail received from you on November 7th, all document packets that were provided by
you were assembled and served by November 16 th . Affidavits of Service were sent to your new address that you
provided on November 30 th . Affidavits with case numbers were sent directly to the court. Last week copies of those
were sent to you free of charge. You also will receive original Affidavits of Service of documents that did not have case
numbers.
Any further inquiries should be made to our Civil Attorney, Mary Kandaras at the District Attorneys Office.
Liz Stuchell
WCSO Civil Section

Sent: Sunday, December 04, 2011 2:53 AM
Dear Ms. Stuchell and Ms. Silva,

I don't mean to be a jerk, I am under inordinate stress right now (not that that is anybody's problem but mine).
The citation below would tend to indicate that your office might, MIGHT, have a duty to photocopy000924
the
electronic versions I sent and serve them in a manner that the opposing attorneys will not respond to by filing
"Motions to Dismiss" based upon illegibility or bad copying/printing. They object to the 9 pages per page
stuff...In an ideal world your office would serve one page per page of these things, after you print them out,
etc...If you can do that, I would of course be extremely grateful, if you can't, I am of course let to scratch and
claw my way through this lawsuit like every other thing in my life as an IFP who can seemingly be curbstomped
by the older richer attorneys whenever they feel like it (and who have some dubious help in doing so). One
interesting thing is that one of the employment cases, etierh cv11-01955 or cv11-01986 (whichever was filed on
June 27th with an IFP) has to be served within 120 days of WHEN? The docket seems to suggest the Complaint
in that IFP case was only entered on or around August 11th, 2011, which would obvioulsy changed the 120 days
calculation, however, whether the filing date relates back to the IFP is something I have never been able to get a
clear answer on anywhere....
Thank You,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 25102521, 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
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.
Date: Thu, 1 Dec 2011 08:52:29 -0800
From: RSilva@washoecounty.us
You and I are the only ones who got this. Is he asking us to serve more docs?

Sent: Wednesday, November 30, 2011 6:37 AM
Subject: IFP Coughlin Service of Complaints WLS employment law; landlord tenant case
"The defect in service (that the photocopy of the complaint provided was too
faint) was not attributable to the plaintiff, but to court personnel, who are
responsible for making copies of the initial pleadings for IFP litigants".
McKENZIE v. AMTRAK M OF E, 777 F.Supp. 1119.
000925
Please serve a full, one page per page copy of each complaint to each defendant in all of
the matters for which I have provided you IFP proof, summons, and complaints.
PLEASE NOTE I HAVE A NEW ADDRESS.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and
may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you
are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted
to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in
error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client,
work product, or other applicable privilege.
000926
000927
000928
000929
000930
000931
000932
000933
000934
000935
000936
Print
Close
WLS
location.
Sent: Wed 5/06/09 9:38 AM
Dear Zach,
You are correct about the letter being delivered on April 20 th , I misread my timeline. My decision is limited to the
hearing conduct. You have proffered nothing that indicates that the way you acted in court is in any way related to any outside
event. Your 50 page motion for reconsideration before Judge Gardner has not linked your conduct in any way to an outside
event. You have refused to give me a time and date to meet once again, and I will issue my determination tomorrow morning
at 9:00 am.
Access to your computer materials, will be made at a convenient time and place with our office manager, executive
director or designee and our computer specialist present. This is a business computer, and without further research I will not
give you access to it privately. You have been given a tape of the two Joshi hearings. To date, you have not agreed to meet
at any time and place to discuss these hearings; and you have not specifically requested any identified items, documents etc.
that were related to your conduct in this hearing. Your series of questions about the Board is irrelevant. The Board delegated
this matter to me to handle as a personnel matter.
-Paul
000937
FILED
Electronically
01-20-2012:02:35:37 PM
Clerk of the Court
000938
000939
000940
000941
000942
000943
000944
000945
FILED
Electronically
01-20-2012:02:35:37 PM
Clerk of the Court
000946
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000949
FILED
Electronically
01-20-2012:02:35:37 PM
Clerk of the Court
000950
000951
000952
000953
000954
FILED
Electronically
03-30-2012:04:14:37 PM
Clerk of the Court
000955
000956
000957
000958
000959
000960
000961
000962
60302: Case View
Disclaimer: The information and documents available here should not be relied upon as an
official record of action.
Only filed documents can be viewed. Some documents received in a case may not be
available for viewing.
Some documents originating from a lower court, including records and appendices, may not
be available for viewing.
For official records, please contact the Clerk of the Supreme Court of Nevada at (775) 6841600.
Case Information: 60302
COUGHLIN VS. WASHOE
Civil Appeal - General Short Caption:
Classification:
LEGAL SERVICES
Other
Related
60317, 60838, 60975
Case(s):
Lower Court
Washoe Co. - Second
Case Status: Briefing Reinstated
Case(s):
Judicial District CV1101896
Panel
Disqualifications: Hardesty
Panel
Assigned:
Replacement:
To SP/Judge:
SP Status:
Exempt
Oral
Oral Argument:
Argument
Location:
How
Submission Date:
Submitted:
+ Party Information
+ Due Items
Docket Entries
Date
Type/Subtype
Filing Fee - Filing Fee
02/27/2012
Waived
Description
Pending Document
Appeal Filing fee waived. In
Forma Pauperis.
Filed Notice of Appeal. Appeal
Notice of Appeal
docketed in the Supreme Court
02/27/2012 Documents - Notice of
12-06119
this day. (Docketing statement
Appeal
mailed to counsel for appellant.)
Justice James W. Hardesty
Other - Disqualification of disqualified from participation
02/27/2012
Justice
in this matter. Disqualification
Reason: Voluntary Recusal.
Issued Notice of Referral to
000963
Settlement Program. This
Print
Close
WLS
location.
Sent: Fri 5/01/09 8:52 AM
Cc: Kathy Breckenridge (kathy@kbreckenridgelaw.com)
1 attachment
ltrCoughlin2ndDraft.doc (30.5 KB)
Letter attached.
000964
file:///R|/...0a%20NEW%20temp/5%201%2009%20elcano's%20pelcano@washoelegalservices.org%200435%2060302.htm[11/23/2012 1:16:39 AM]
Dear Zach,
I have been authorized by the Board to handle this matter.
1.
Your current suspension was a result of the order entered by Judge Gardner in
the Joshi matter;
2.
Suspension means that you are no longer to participate as a lawyer in any case
assigned to you by WLS until further notice. You may appear on your own
behalf to litigate the order of sanctions entered by Judge Gardner. If any
lawyer contacts you about a WLS case you must refer them to Caryn
Sternlicht or Marc Ashley;
3.
According to the Courts order, you were sanctioned for arguing incessantly,
being unprepared, making sarcastic and derogatory remarks to the Court, and
for rude and disrespectful conduct. You were personally fined $934 as a result
of this conduct;
4.
I could not evaluate your conduct at trial until I received the tape of the
hearing; this tape was promptly ordered, and was finally received on
Thursday, April 23rd. I have not yet reviewed this tape in its entirety.
5.
You have requested a copy of your personnel file. This has been made
available to you;
6.
We have delivered a copy of the tape of the Joshi matter to you;
7.
You requested a formal response to your complaint concerning Rhonda. This

was investigated by me within 48 hours of your complaint. There is no
question that your office behavior (which included yelling, and calling her a
hall monitor, etc.) upset her, and as a direct result she made a comment to you.
She was counseled as to the type of language she used, and specifically told
that even though she was upset this language (bite me) was not appropriate
for the workplace. I did not realize you wanted a formal response to this
incident. Please consider this your formal response. I am unaware of any
specific written complaints other than the one you made to me about Rhonda.
Please provide me with copies of all other written complaints sent by you to
me prior to the entry of Judge Gardners order. Please make sure they are
dated. I will review them and indicate to you what the disposition of those
matters may be.
000965
8.
Counseling for difficulties in office interaction had already been scheduled

when I received Judge Gardners order. You did not appear for the mandatory
meeting at which I announced this counseling;
9.
We have received a copy of a 50 page motion for reconsideration you filed in

the Joshi matter. I will review this in its entirety. If there is any other written
material you want me to review in determining whether or not your
employment should continue with WLS you must provide it to me by 5:00 pm
Monday, May 4th. I will be happy to pick up any such material at a reasonable
time and place if you are not comfortable emailing it to me.
Based on the forgoing I will be taking the following action:
1. I will review the tape in the Joshi matter, your fifty page motion for
reconsideration and any other written material you provide to me. If your conduct
was as represented by Judge Gardner you will be terminated. This termination
will be based exclusively on the manner in which you conducted this hearing, and
will not be related to any ultimate outcome regarding the sanctions order. WLS
can not maintain an employment relationship with a lawyer who argues
incessantly, appears unprepared and makes sarcastic and derogatory remarks to
the court, and otherwise conducts his or her case in a rude and disrespectful
manner. This determination will be made by me by 10:00 am Wednesday
morning, May 6, 2009.
2. If the hearing tape does not justify Judge Gardners order WLS will require you to
participate in the previously referred to employee counseling pursuant to the
directives of our industrial psychologist. This counseling is currently going on
with other employees at WLS. The counselor will determine the extent to which
you will participate and maintain a case load. You will maintain your employment
status, and will receive pay and benefits throughout this course of counseling.
3. If you wish to discuss any resolution of this matter between now and Wednesday
morning at 10 am I will be available to meet with you at any convenient time and
place, including this weekend. You may bring any person you would like to a
resolution discussion. I will come alone unless you request otherwise.
This has been sent to you by email. Please advise me as to the address to which a hard
copy of this transmittal should be delivered.
Sincerely,
Paul Elcano
000966
60302: Case View
Notice/Outgoing - Notice
appeal may be assigned to the
02/27/2012 of Referral to Settlement
settlement program. Timelines
Program
for requesting transcripts and
filing briefs are stayed.
Notice/Outgoing - Notice Issued Notice to File Case
02/27/2012 to File Case Appeal
Appeal Statement/Civil. Due
Statement/Civil
date: 10 days.
Issued Notice: Exemption from
Settlement Program. It has been
determined that this appeal will
Settlement Notice not be assigned to the
02/27/2012 Notice: Exemption from
settlement program.
Settlement Program
Appellant(s) 15 days transcript
request form; 120 days opening
brief:
Case Search
Filed District court order. Copy
Participant Search
of Order Denying Motion to
Proceed In Forma Pauperis filed
Order/Incoming - District in district court on 3/8/2012 and
03/09/2012
Court Order
Case Appeal Statement or, Pled
in the alternative, Motion for
Extension of Time to Correct
Deficiencies in Appeal Papers.
Motion - Motion to
Filed Motion to Dismiss
03/26/2012
Dismiss Appeal
Appeal.
Notice/Incoming - Notice (Brian A. Gonsalves appearing
03/26/2012
of Appearance
on behalf of respondent Crisis
Intervention Services).
04/09/2012
Motion
Dismiss.
Notice of Appeal
04/13/2012 Documents - Case Appeal Filed Case Appeal Statement.
Statement
Motion - Reply to
04/16/2012
Response
Motion to Dismiss Appeal.
Filed Order Dismissing Appeal
in Part. We dismiss this appeal
as to CIS, only. Appellant shall
have 11 days from the date of
05/31/2012 Order/Procedural - Order this order to file and serve his
(1) transcript request form or
certificate that no transcript will
be requested, and (2) docketing
statement.
Transcript Request Filed Certificate of No
06/14/2012 Certificate of No
Transcript Request.
Transcript Request
Docketing Statement 06/14/2012
Filed Docketing Statement.
Docketing Statement
12-06121
12-06126
12-06222
12-07769
12-09480
12-09496
12-11097
12-11962
12-12020
12-17190
12-18622
12-18740
000967
60302: Case View
Notice/Outgoing - Notice Issued Notice to File Opening

06/27/2012 to File Opening Brief and Brief and Appendix. Due Date:
Appendix
15 days.
(Joseph Garin and Shannon
Notice/Incoming - Notice
07/13/2012
Nordstrom of Lipson Neilson
of Appearance
Cole Seltzer & Garin appearing
on behalf of respondents).
Motion - Motion to
Filed Respondents' Motion to
07/13/2012
Dismiss Appeal
Dismiss Appeal.
Filed Motion for Permission to
File Opening Brief After
07/25/2012 Motion - Motion
Deadline has run and
Opposition to Motion to
Dismiss.
Dismiss (and request for 15
07/26/2012
Motion
days extension to file opening
brief and appendix).
Filed Response to Plaintiff's
Motion for Permission to File
07/31/2012
Opening Brief After Deadline
Motion
Has Run and Opposition to
Motion to Dismiss.
Motion - Reply to
08/03/2012
Respondents' Motion to Dismiss
Response
Appeal.
12-20249
12-22194
12-22195
12-23543
12-23572
12-24165
12-24569
000968
000969
000970
000971
000972
000973
000974
000975
000976
000977
000978
000979
000980
000981
000982
000983
000984
000985
000986
000987
000988
000989
000990
000991
000992
000993
000994
000995
000996
Print
Close
RE: arraignment
Sent: Fri 2/24/12 4:29 PM
To: Dogan, Biray
'Sup Biray,
000997
file:///R|/...20continuance%20of%202%2027%2012%20status%20conference%20held%20clandestine%20anyways%2026800%200204.htm[11/22/2012 6:06:00 PM]
000998
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001002
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001004
001005
001006
001007
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001011
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Docket Report Results - Not an Official Document
Report Selection Criteria

Case ID:
DV08-01168
Docket Start Date:
Docket Ending Date:
Case Description
Case ID:
Filing Date:
Type:
Status:
DV08-01168 - ASHWIN JOSHI VS. BHARTI JOSHI (D14)

Tuesday , July 01st, 2008
DO - DIVORCE - NO CHILDREN
CLOSED - Case Closed
Related Cases
FV08-01910
Case Event Schedule
No case events were found.
Case Parties
Seq #
6
Assoc Expn Date

3,10
Type
ID
Plaintiff/Counter-Deft
@1144868 JOSHI, ASHWIN
Address: unavailable
11,12
Aliases: none
Defendant
Counterclaimant
Judge
Address: WASHOE LEGAL

SERVICES
@1144866 JOSHI, BHARTI
Aliases: none
D14
GARDNER, HONORABLE
LINDA
Aliases: none
Address: P. O. BOX 30083

RENO NV 89520
10
Name
Attorney
4391
Sternlicht, Esq., Caryn

R.
Aliases: Sternlicht, Esq., Caryn R

001017
299 South Arlington

Avenue
Reno NV 89501
11
Sternlicht, Esq., Caryn

R.
Aliases: Sternlicht, Esq., Caryn R
Address: WASHOE LEGAL

SERVICES
299 South Arlington
Avenue
Reno NV 89501
14
4391
Attorney
Real Party in Interest
Address: P. O. Box 3961

Reno NV 89505
9473
Coughlin, Esq., Zachary
Aliases: none
Docket Entries
Filing Date
Description
Name
01-JUL-2008
08:50 AM
**Civil Cover Sheet
Entry:
none.
01-JUL-2008
08:51 AM
$Complaint-Divorce No Children
Entry:
none.
01-JUL-2008
08:51 AM
** Summons Issued
Entry:
none.
01-JUL-2008
08:53 AM
Financial Declaration ...
Entry:
SHORT FORM FINANCIAL DECLARATION ASHWIN JOSHI
01-JUL-2008
08:55 AM
**Payment Receipted
Monetary
001018
03-OCT-2008 Heard-Not Settled

03:53 PM
Entry:
JTAYLOR, CLERK; CD
10-OCT-2008 ***Minutes
09:32 AM
Entry:
10/3/08: Case Management Conference - Transaction 405010 - Approved By: NOREVIEW

: 10-10-2008:09:33:20
10-OCT-2008 ** Notes ...

09:38 AM
Entry:
FILE RETURNED TO FILING OFFICE; JT
15-OCT-2008 ** Notes ...

10:10 AM
Entry:
CMC NOT ON RECORD CALLED ADVICE ZACHARY B. COUGHLIN JA
17-DEC-2008 Notice to Set

04:18 PM
Entry:
NOTICE TO SET TRIAL: JANUARY 7, 2009 @ 10:30
07-JAN-2009
09:36 AM
Application for Setting
Entry:
1/2 DAY TRIAL
25-FEB-2009 Pre-Trial Order

02:50 PM
Entry:
none.
05-MAR-2009 Trial Statement - Defendant

09:26 AM
Entry:
none.
11-MAR-2009 Trial Statement - Plaintiff

04:56 PM
Springgate, Esq., John P.

001019
Entry:
TRIAL STATEMENT OF PLAINTIFF - Transaction 644213 - Approved By: TPRINCE : 0312-2009:07:20:23
12-MAR-2009 Heard ...

05:00 PM
Entry:
SETTLEMENT CONFERENCE NOT ON RECORD; TRIAL COMMENCED ON THE

RECORD-JAVS, NOT CONCLUDED, CONTINUED TO 3/17/09. PLAINTIFF PRESENT
WITH COUNSEL. DEFENDANT PRESENT WITH COUNSEL. RM 4; MCA
17-MAR-2009 Under Advisement

11:11 AM
Entry:
PLAINTIFF WAS PRESENT WITH COUNSEL; DEFENDANT WAS PRESENT WITH

COUNSEL; JAVS RM 4; MCA
09-APR-2009 ** Notes ...

10:41 AM
Entry:
CD BURNED HEARING DATE 03-12-2009 & 03-17-2009 REQUESTED BY ZACHARY B.

COUGHLIN CALLED FOR PICK UP 03-17-2009/JA
13-APR-2009 Order ...

09:23 AM
Entry:
AFTER TRIAL - Transaction 706269 - Approved By: NOREVIEW : 04-13-2009:09:24:06
13-APR-2009 Notice of Entry of Ord

03:21 PM
Entry:
NOTICE OF ENTRY OF ORDER AFTER TRIAL - Transaction 708197 - Approved By:

ASMITH : 04-13-2009:15:37:59
INTERESTING TO NOTE WLS DOESN'T REQUEST CD UNTIL AFTER 4/19/09

23-APR-2009 ** Notes ... WRITTEN COMPLAINT BY COUGHLIN-NOTE BY ZC
04:13 PM
Entry:
CD BURNED HEARING DATE 03-12-2009 & 03-17-2009 REQUESTED BY MARC

ASHELEY AND TODD TORVINEN CALLED FOR PICK UP 04-23-2009/JA
29-APR-2009 Request for Submission

09:53 AM
Entry:
Sternlicht, Esq., Caryn R.
DOCUMENT TITLE: STIPULATION AND ORDER TO ENLARGE TIME PERIOD FOR

MOTION FOR RECONSIDERATION PARTY SUBMITTING: CARYN STERNLICHT, ESQ
DATE SUBMITTED: 04/29/09 SUBMITTED BY: JN DATE RECEIVED JUDGE OFFICE:
001020
29-APR-2009 Request for Hearing

04:48 PM
Entry:
REQUEST FOR ADJUSTMENT OF FILING DATE OR EXTENSION OF TIME Transaction 741585 - Approved By: MPURDY : 04-29-2009:17:02:19
30-APR-2009 Mtn for Reconsideration

03:35 PM
Entry:
REQUEST FOR RECONSIDERATION ; REQUEST FOR EXTENSION OF TIME TO

RESPOND - Transaction 744344 - Approved By: ASMITH : 04-30-2009:16:09:49
30-APR-2009 Request for Submission Complet

04:31 PM
Entry:
none.
30-APR-2009 Stip and Order...

04:39 PM
Entry:
TO ENLARGE TIME PERIOD FOR MOTION FOR RECONSIDERATION
12-MAY-2009 Notice of Appeal Supreme Court

12:03 AM
Entry:
ORDER AFTER TRIAL - Transaction 765327 - Approved By: MPURDY : 05-122009:09:36:43
12-MAY-2009 Notice of Appeal Supreme Court

12:15 AM
Entry:
OPPOSITION TO REQUEST FOR RECONSIDERATION - Transaction 769905 - Approved

By: MPURDY : 05-13-2009:13:33:42
13-MAY-2009 Mtn to Strike...

01:13 PM
Entry:
ORDER AFTER TRIAL - Transaction 765328 - Approved By: MPURDY : 05-122009:09:38:37
13-MAY-2009 Opposition to ...

01:13 PM
Entry:
Transaction 769905 - Approved By: MPURDY : 05-13-2009:13:33:42
001021
13-MAY-2009 ** Case Reopened

04:10 PM
Entry:
none.
13-MAY-2009 Ex-Parte Mtn...

04:11 PM
Entry:
DEFENDANT'S EMERGENCY MOITON FOR ORDER SHORTENING TIME AND ORDER

GRANTING EMERGENCY REQUEST TO PROCEED ON APPEAL IN FORMA
PAUPERIS
13-MAY-2009 Request for Submission

04:11 PM
Entry:
DOCUMENT TITLE: MOTION AND AFFIDAVIT TO PROCEED IN FORMA PAUPERIS

PARTY SUBMITTING: ZACHARY COUGHLIN, ESQ DATE SUBMITTED: 05/13/09
SUBMITTED BY: JN DATE RECEIVED JUDGE OFFICE:
13-MAY-2009 Amended Notice of Appeal

04:28 PM
Entry:
MOTION AND AFFIDAVIT IN SUPPORT OF MOTION TO PROCEED ON APPEAL IN

FORMA PAUPERIS

04:27 PM
Entry:
DOCUMENT TITLE: MOTION FOR RECONSIDERATION PARTY SUBMITTING:

ZACHARY COUGHLIN, ESQ DATE SUBMITTED: 05/13/09 SUBMITTED BY: JN DATE
RECEIVED JUDGE OFFICE:
13-MAY-2009 Motion ...

04:27 PM
Entry:
DOCUMENT TITLE: DEFENDANTS EMERGENCY MOTION ORDER SHORTENING

TIME PARTY SUBMITTING: ZACHARY COUGHLIN, ESQ DATE SUBMITTED: 05/13/09
SUBMITTED BY: JN DATE RECEIVED JUDGE OFFICE:

04:23 PM
Entry:
none.
001022
13-MAY-2009 Case Appeal Statement

04:28 PM
Entry:
FOR AMENDED NOTICE OF APPEAL ONLY
14-MAY-2009 Notice ...

03:33 PM
Entry:
Ashley, Esq., Marc
OF SUBSTITUTION OF STAFF COUNSEL
14-MAY-2009 Supreme Ct Deficiency Notice

04:48 PM
Entry:
FOR NOTICE OF APPEAL FILED 5/12/09 TRANSACTION #765328

04:49 PM
Entry:
FOR NOTICE OF APPEAL FILED 5/12/09 TRANSACTION #765327

04:49 PM
Entry:
FOR AMENDED NOTICE OF APPEAL FILED 5/13/09. NO FEES PAID, ZACHARY

COUGHLIN, ESQ., FILED FOR IN FORMA PAUPERIS STATUS FOR HIMSELF IN THIS
CASE.
15-MAY-2009 Amended ...

12:10 AM
Entry:
AMENDED CASE APPEAL STATEMENT OR PETITION FOR WRIT OF MANDAMUS OR

OTHER EXTRAORDINARY WRIT - Transaction 774264 - Approved By: MPURDY : 05-152009:07:52:03
15-MAY-2009 Amended ...

12:11 AM
Entry:
SECOND AMENDED NOTICE OF APPEAL; OR ALTERNATIVELY PETITION FOR WRIT

OF MANDAMUS OR OTHER EXTRAORDINARY WRIT - Transaction 774265 - Approved
By: MPURDY : 05-15-2009:07:53:39

09:19 AM
Entry:
none.
001023
15-MAY-2009 Certificate of Clerk

09:37 AM
Entry:
FOR 1ST 5/12/09 APPEAL, NO CASE APPEAL STATEMENT OR FEES
15-MAY-2009 Certificate of Transmittal

09:38 AM
Entry:
FOR 1ST 5/12/09 APPEAL, NO CASE APPEAL STATEMENT OR FEES

09:39 AM
Entry:
FOR 2ND 5/12/09 APPEAL, NO CASE APPEAL STATEMENT OR FEES

09:39 AM
Entry:
FOR 2ND 5/12/09 APPEAL, NO CASE APPEAL STATEMENT OR FEES

09:40 AM
Entry:
FOR 5/13/09 JOINT AMENDED APPEAL, NO FEES

09:41 AM
Entry:
FOR 5/13/09 JOINT AMENDED APPEAL

09:41 AM
Entry:
FOR 5/15/09 SECOND AMENDED APPEAL & AMENDED CASE APPEAL STATEMENT

09:51 AM
Entry:
FOR 5/15/09 SECOND AMENDED APPEAL & AMENDED CASE APPEAL STATEMENT
19-MAY-2009 Ord Deny in Forma Pauperis

12:00 PM
Entry:
001024
ON BEHALF OF ZACHARY COUGHLIN, ESQ.
20-MAY-2009 Reply...
11:40 PM
Entry:
REPLY TO OPPOSITION
21-MAY-2009 Ord Denying ...

11:27 AM
Entry:
REQUEST FOR RECONSIDERATION - Transaction 785777 - Approved By: NOREVIEW :

05-21-2009:11:35:08
21-MAY-2009 Request for Submission Complet

11:27 AM
Entry:
none.

11:27 AM
Entry:
none.

11:27 AM
Entry:
none.
21-MAY-2009 Supreme Court Receipt for Doc

03:03 PM
Entry:
SUPREME COURT CASE NO. 53833 RECEIPT FOR DOCUMENTS (INCLUDES ALL 4
NOTICE OF APPEALS)
21-MAY-2009 **Supreme Court Case No. ...

03:04 PM
Entry:
SUPREME COURT CASE NO. 53833

04:06 PM
Entry:
DOCUMENT TITLE: FINDINGS OF FACT, CONCLUSIONS OF LAW, & DECREE OF

DIVORCE PARTY SUBMITTING: JOHN P. SPRINGGATE, ESQ. DATE SUBMITTED:
5/22/09 SUBMITTED BY: CPARSLEY DATE RECEIVED JUDGE OFFICE:
001025

02:03 PM
Entry:
DOCUMENT TITLE: REPLY TO OPPOSITION PARTY SUBMITTING: ZACHARY

COUGHLIN, ESQ DATE SUBMITTED: 05/26/09 SUBMITTED BY: JN DATE RECEIVED
JUDGE OFFICE:
26-MAY-2009 Supreme Court Notice

03:09 PM
Entry:
SUPREME COURT CASE NO. 53833 NOTICE TO PAY SUPREME COURT FILING FEE
27-MAY-2009 Motion ...

09:58 AM
Entry:
Ashley, Esq., Marc
TO CORRECT PROPOSED DECREE

01:28 PM
Entry:
none.

01:45 PM
Entry:
MOTION TO STRIKE THE NOTICE(S) OF APPEAL - Transaction 795498 - Approved By:

MPURDY : 05-27-2009:15:13:37 DOCUMENT TITLE: MOTION TO STRIKE THE
NOTICE(S) OF APPEAL PARTY SUBMITTING: JOHN SPRINGGATE, ESQ DATE
SUBMITTED: 05/27/09 SUBMITTED BY: JN DATE RECEIVED JUDGE OFFICE:
01-JUN-2009 Supreme Court Receipt for Doc

04:41 PM
Entry:
03-JUN-2009 $Notice/Appeal Supreme Court

04:35 PM
Entry:
ZACHARY COUGHLIN ESQ. ( FOR AMENDED NOTICE OF APPEAL FILED MAY 13,
2009 )
04-JUN-2009 **Payment Receipted

09:29 AM
001026
Entry:
A Payment of -$34.00 was made on receipt DCDC237460.
08-JUN-2009 Opposition to Mtn ...

08:55 AM
Entry:
OPPOSITION TO MOTION TO CORRECT PROPOSED DECREE - Transaction 818528 Approved By: MPURDY : 06-08-2009:09:24:39
08-JUN-2009 **Supreme Court Appeal Bond

10:29 AM
Entry:
none.
08-JUN-2009 $Def 1st Appearance - DV

10:52 AM
Entry:
MOTION TO TREAT SECOND AMENDED NOTICE OF APPEAL OR PLED IN THE

ALTERNATIVE PETITION FOR WRIT OF MANDAMUS AS A PETITION FOR WRIT OF
MANDAMUS ONLY AND NOT A NOTICE OF APPEAL
08-JUN-2009 Mtn to Strike...

10:57 AM
Entry:
none.

11:01 AM
Entry:
OPPOSITION TO MOTION TO STRIKE

11:06 AM
Entry:
08-JUN-2009 Request for Submission

11:53 AM
Entry:
DOCUMENT TITLE: REQUEST FOR SUBMISSION OF OPPOSITION TO MOTION TO

STRIKE PARTY SUBMITTING: ZACH COUGHLIN, ESQ. DATE SUBMITTED: 06/08/09
SUBMITTED BY: MRYBKA DATE RECEIVED JUDGE OFFICE:

12:18 PM
001027
Entry:
DOCUMENT TITLE: MOTION TO STRIKE PARTY SUBMITTING: ZACH COUGHLIN,

ESQ. DATE SUBMITTED: 06/08/09 SUBMITTED BY: MRYBKA DATE RECEIVED JUDGE
OFFICE:
08-JUN-2009 ***Minutes
03:45 PM
Entry:
RE: 3 12 09 - Transaction 820893 - Approved By: NOREVIEW : 06-08-2009:15:47:27

04:16 PM
Entry:
DOCUMENT TITLE: MOTION TO CORRECT PROPOSED DECREE PARTY

SUBMITTING: MARC ASHLEY, ESQ. DATE SUBMITTED: 6/9/09 SUBMITTED BY:
ASIMPSON DATE RECEIVED JUDGE OFFICE:
09-JUN-2009 Reply...
02:59 PM
Entry:
DOCUMENT TITLE: MOTION TO STRIKE - Transaction 824177 - Approved By: MPURDY

: 06-09-2009:15:33:59 PARTY SUBMITTING: JOHN SPRINGGATE, ESQ. DATE
SUBMITTED: 6/9/09 SUBMITTED BY: ASIMPSON DATE RECEIVED JUDGE OFFICE:

02:59 PM
Entry:
REPLY ON MOTION TO STRIKE - Transaction 824177 - Approved By: MPURDY : 06-092009:15:33:59

02:59 PM
Entry:
Ashley, Esq., Marc
OPPOSITION TO MOTION TO STRIKE - Transaction 824177 - Approved By: MPURDY :

06-09-2009:15:33:59
10-JUN-2009 ***Minutes
03:04 PM
Entry:
re: 3 17 09 - Transaction 827393 - Approved By: NOREVIEW : 06-10-2009:15:14:02
17-JUN-2009 Affidavit of Resident Witness

04:23 PM
Entry:
Transaction 842514 - Approved By: MPURDY : 06-17-2009:16:31:09

001028
19-JUN-2009 Decree of Divorce

09:57 AM
Entry:
Transaction 846216 - Approved By: NOREVIEW : 06-19-2009:10:01:39
19-JUN-2009 Request for Submission Complet

10:02 AM
Entry:
none.

10:04 AM
Entry:
none.
19-JUN-2009 ** Notes ...

10:23 AM
Entry:
E-FILED DECREE OF DIVORCE; NOTIFIED JOHN SPRINGGATE'S OFFICE OF SAME

BY TELEPHONE
19-JUN-2009 Decision With Hearing

11:51 AM
Entry:
none.
19-JUN-2009 ** Case Reopened

11:52 AM
Entry:
none.

08:48 AM
Entry:
none.
22-JUN-2009 Notice of Entry of Decree

02:12 PM
Entry:
15-JUL-2009
02:34 PM
NOTICE OF ENTRY OF FINDINGS OF FACT, CONCLUSIONS OF LAW AND DECREE

OF DIVORCE - Transaction 851165 - Approved By: ASMITH : 06-22-2009:14:47:32
Ord Denying Motion

001029
Entry:
TO STRIKE IN PART; ORDER GRANTING MOTION TO STRIKE IN PART - Transaction

899705 - Approved By: NOREVIEW : 07-15-2009:14:37:24
15-JUL-2009
02:35 PM
Request for Submission Complet
Entry:
none.
15-JUL-2009
02:36 PM
Entry:
none.
15-JUL-2009
02:37 PM
** Case Closed
Entry:
none.
20-JUL-2009
02:51 PM
Entry:
NOTICE OF ENTRY OF ORDER DENYING MOTION TO STRIKE IN PART; ORDER

GRANTING MOTION TO STRIKE IN PART - Transaction 909119 - Approved By: ASMITH
: 07-20-2009:15:10:12
22-JUL-2009
09:32 AM
Stipulation ...
Entry:
STIPULATION TO AMEND DECREE OF DIVORCE
23-JUL-2009
04:17 PM
Order ...
Entry:
23-JUL-2009
04:23 PM
Entry:
24-JUL-2009
02:13 PM
TO AMEND DECREE OF DIVORCE - Transaction 920637 - Approved By: NOREVIEW :

07-23-2009:16:19:47
** Notes ...
ORDER TO AMEND DECREE OF DIVORCE EFILED; COUNSEL TO RECEIVE
ELECTRONIC NOTIFICATION

001030
Entry:
Transaction 922926 - Approved By: AZION : 07-24-2009:14:19:03
04-AUG-2009 Mtn Ord to Show Cause

03:02 PM
Entry:
MOTION FOR ORDER TO SHOW CAUSE RE: CONTEMPT - Transaction 945045 Approved By: ASMITH : 08-04-2009:15:22:54
28-SEP-2009 Supreme Ct Ord Dismis Appeal

02:39 PM
Entry:
SUPREME COURT CASE NO. 53833 - Transaction 689 - Approved By: NOREVIEW : 0928-2009:14:40:14
28-SEP-2009 Proof of Electronic Service

02:41 PM
Entry:
01-OCT-2009 Withdrawal of Counsel

04:23 PM
Entry:
none.
14-OCT-2009 Withdrawal of Counsel

11:54 AM
Entry:
Ashley, Esq., Marc
JOHN P SPRINGGATE, ESQ/ASHWIN JOSHI - Transaction 1099490 - Approved By:

ASMITH : 10-14-2009:12:06:21
14-OCT-2009 Proof of Electronic Service

12:15 PM
Entry:
07-DEC-2009 **Supreme Court Case No. ...

02:27 PM
Entry:
07-DEC-2009 Supreme Court Order Denying

02:58 PM
Entry:
ORDER DENYING PETITION FOR WRIT OF MANDAMUS; SUPREME COURT CASE

001031
NO. 54844 - Transaction 1192001 - Approved By: NOREVIEW : 12-07-2009:14:58:18
07-DEC-2009 Proof of Electronic Service

02:58 PM
Entry:
08-DEC-2009 Supreme Ct Accept - eFile Doc

11:53 AM
Entry:

12:07 PM
Entry:
28-DEC-2009 Motion ...

12:30 PM
Entry:
MOTION FOR RETURN OF SUPERSEDEAS BOND - Transaction 1230075 - Approved

By: AZION : 12-28-2009:12:33:01

12:33 PM
Entry:
30-DEC-2009 Supreme Ct Not/Lieu/Remittitur

04:45 PM
Entry:
SUPREME COURT CASE NO. 54844 - Transaction 1235784 - Approved By: NOREVIEW
: 12-30-2009:16:46:19

04:47 PM
Entry:
12-JAN-2011
11:01 AM
Family Court Info Sheet
Entry:
12-JAN-2011
001032
11:05 AM
Entry:
05-JUL-2011
12:15 PM
** Case Reopened
Entry:
none.
05-JUL-2011
12:17 PM
Entry:
MOTION FOR RETURN OF SUPERSEDEAS BOND (NO PAPER ORDER PROVIDED) Transaction 2325502 - Approved By: MCHOLICO : 07-05-2011:12:28:59 PARTY
SUBMITTING: ZACH COUGHLIN DATE SUBMITTED: 7/5/11 SUBMITTED BY:
MCHOLICO DATE RECEIVED JUDGE OFFICE:
05-JUL-2011
12:29 PM
Entry:
23-AUG-2011 Order ...

11:59 AM
Entry:
TO RETURN BOND - Transaction 2424815 - Approved By: NOREVIEW : 08-232011:12:00:24
23-AUG-2011 Request for Submission Complet

11:59 AM
Entry:
none.
23-AUG-2011 ** Case Closed

12:00 PM
Entry:
none.
23-AUG-2011 Proof of Electronic Service

12:01 PM
Entry:
30-AUG-2011 **Trust Disbursement

12:30 PM
SITE DEFINED TRUST DEPOSIT,
001033
Entry:
A Disbursement of $250.00 on Check Number 19067
31-AUG-2011 ** Notes ...

12:51 PM
Entry:
4 CD'S BURNED FOR HEARINGS 03/12/09 & 03/17/09 REQUESTED BY DEBORAH

PRINGLE / PAUL ELCANO CALLED FOR PU - ME
001034
001035
001036
001037
001038
001039
001040
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001042
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Page 1 of 6

Case ID:
CR12-0376
Docket Start Date:
Docket Ending Date:
Case Description
Case ID:
Filing Date:
Type:
Status:
CR12-0376 - STATE VS ZACHARY BARKER COUGHLIN (D10)

Tuesday , February 28th, 2012
CR - CRIMINAL
DISPOSED - Case Disposed
Related Cases
CR11-2064
FV12-00122
FV12-00187
FV12-00188
FV12-01011
FV12-01012
Case Event Schedule

Case Parties
Seq #
Assoc Expn Date
2
3,4,9

Reno NV 89503
Address: 75 Court Street

Reno NV 89501
ID
Name
Judge
Type
D10
ELLIOTT, HONORABLE
STEVEN P.
Aliases: none
Plaintiff
STATE
STATE OF NEVADA
Aliases: STATE OF NEVADA
District
Attorney
4059
Stralla, Esq., Roy L.
Aliases: none
District
Attorney
6668
Halstead, Esq., Patricia

C.
001047
http://www.ccwashoe.com/public/ck_public_qry_doct.cp_dktrpt_docket_report?backto=P&case_id=C...
Address: HALE LANE PEEK

DENNISON
AND HOWARD
5441 KIETZKE LANE,
2ND FLR.
RENO NV 89511
6,7
Address: Washoe Co. PD's Office

350 S. Center St., 5th Fl
P.O. Box 30083
Reno NV 89501
7
Address: Office of the Attorney

General
100 N. Carson St.
Carson City NV 89701
Aliases: none
Defendant
Address: WASHOE COUNTY

DISTRICT ATTY
P.O. BOX 30083-3083
RENO NV 89520
@1206272 COUGHLIN, ZACHARY
Aliases: COUGHLIN, ZACHARY BARKER

CAUGHLIN, ZACHARY
COUGHLIN, ZACHARY BARKER
COUGHLIN, ZACHARY
COUGHLIN, ZACH
COUGHLIN, ZACKARY
Public
Defender
6976
Fortier, Esq., Chris
Aliases: none
Public
Defender
10566
Dogan, Esq., Biray
Aliases: none
Parole &
Probation
Address: 10 State Street

Reno NV 89501
Page 2 of 6
DPNP
Parole & Probation, Div.

of
Aliases: none
District
Attorney
9227
Young, Esq., Zach
Aliases: YOUNG, ZACH

Young, Esq., Zach
001048
Page 3 of 6
Docket Entries
Filing Date
Description
Name
Monetary
28-FEB-2012 Ord Psychiatric Evaluation

02:43 PM
Entry:
none.
29-FEB-2012 Court Services Report

09:17 AM
Entry:
29-FEB-2012 Proof of Electronic Service

09:23 AM
Entry:
29-FEB-2012 Vacated
10:16 AM
Entry:
MOVED BY THE COURT TO 4/3 - COUNSEL NOTIFIED
30-MAR-2012 Application for Setting

04:14 PM
Entry:
Dogan, Esq., Biray
COMP EVAL HEARING: 4-19-12 AT 8:30 - Transaction 2859998 - Approved

By: SHAMBRIG : 04-02-2012:08:05:13
02-APR-2012 Proof of Electronic Service

08:07 AM
Entry:
02-APR-2012 Vacated
10:55 AM
Entry:
RESET FOR 4/19/12
001049
Page 4 of 6
18-APR-2012 Crt Ord Psych Eval - Conf.

02:34 PM
Entry:
LETTER FROM LAKE'S CROSSING RE TERMINATION OF COURT

ORDERED PSYCH EVAL - Transaction 2897316 - Approved By: ASMITH :
04-18-2012:14:40:49

02:42 PM
Entry:
19-APR-2012 Heard-Continued Court

11:23 AM
Entry:
none.
24-APR-2012 Vacated
09:00 AM
Entry:
RESET FOR 4/26/12
24-APR-2012 Application for Setting

10:43 AM
Entry:
Dogan, Esq., Biray
SB89 COMP EVAL 04-26-12 @ 08:30AM - Transaction 2908436 - Approved

By: ASMITH : 04-24-2012:11:01:16

11:04 AM
Entry:

03:07 PM
Entry:
4/23/12 COMPETENCY EVALUATION BY DR. MARY VIETH, PH.D. Transaction 2909741 - Approved By: LMATHEUS : 04-24-2012:15:52:32

03:07 PM
Entry:
4/23/12 COMPETENCY EVALUATION BY DR. RICHARD BISSETT, PH.D. Transaction 2909741 - Approved By: LMATHEUS : 04-24-2012:15:52:32
001050
Page 5 of 6

03:54 PM
Entry:
25-APR-2012 ***Minutes
09:43 AM
Entry:
4/19/12 - REPORT PSYCHIATRIC EVALUATION - Transaction 2911060 Approved By: NOREVIEW : 04-25-2012:09:44:46

09:46 AM
Entry:
25-APR-2012 Motion ...

12:07 PM
Entry:
Dogan, Esq., Biray
MOTION TO RELEASE ZACHARY COUGHLIN FROM CUSTODY Transaction 2911936 - Approved By: SHAMBRIG : 04-25-2012:12:25:23

12:26 PM
Entry:
26-APR-2012 Found Competent Returned to JC

08:30 AM
Entry:
none.
02-MAY-2012 ***Minutes
03:02 PM
Entry:
02-MAY-2012 Proof of Electronic Service

03:03 PM
Entry:
001051
Page 6 of 6
09-MAY-2012 Transcript
09:42 AM
Entry:
4/19/12 - Report Psychiatric Evaluation - Transaction 2941159 - Approved

By: NOREVIEW : 05-09-2012:09:46:24

09:48 AM
Entry:
09-MAY-2012 Order of Competency/Return JC

05:17 PM
Entry:

05:19 PM
Entry:
09:10 PM
Entry:

By: NOREVIEW : 05-17-2012:21:11:14

09:12 PM
Entry:
18-MAY-2012 General Receipt

09:19 AM
Entry:
none.
001052
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CR12-1201 - Second Judicial District Court

www.washoecourts.com/index.cfm?page=casedesc&case_id...
Jul 13, 2012 STEVEN ELLIOTT, H808 - SENTENCING, D655 - Pled Guilty filed on:
20-Sep-2012 .... COMPETENCY EVALUATION BY BILL DAVIS, PH.D. - Transaction
... District Court, State of Nevada, Washoe County All Rights Reserved.

May 30, 2012 STEVEN ELLIOTT, H780 - REPORT PSYCHIATRIC EVALUATION,
Outcome is ... COMPETENCY EVALUATION BY BILL DAVIS, PH.D. - Transaction ....
District Court, State of Nevada, Washoe County All Rights Reserved.

Mar 2, 2012 STEVEN ELLIOTT, H808 - SENTENCING, Outcome is Pending ....
COMPETENCY EVALUATION BY BILL DAVIS, PH.D. - Transaction 2814838 ...
Judicial District Court, State of Nevada, Washoe County All Rights Reserved.

washoecourts.com/index.cfm?page=casedesc&case_id=CR12...
Sep 20, 2012 STEVEN ELLIOTT, H780 - REPORT PSYCHIATRIC EVALUATION,
D412 ... 9/28/12 COMPETENCY EVALUATION BY BILL DAVIS, PH.D. - Transaction

Oct 10, 2012 Honorable Steve Elliott Department 15 ... COMPETENCY
EVALUATION BY BILL DAVIS, PH.D. - Transaction 3325661 ... Copyright 2012
Second Judicial District Court, State of Nevada, Washoe County All Rights Reserved.

Sep 26, 2012 Honorable Steve Elliott Department 15 ... COMPETENCY
EVALUATION BY BILL DAVIS, PH.D. - Transaction 3309662 ... Copyright 2012
Second Judicial District Court, State of Nevada, Washoe County All Rights Reserved.

Jan 6, 2012 STEVEN ELLIOTT, H808 - SENTENCING, D150 - Bench Warrant
Issued-Forfeit filed .... BY DR BILL DAVIS, PH.D.- Transaction 2806567 - Approved
By: ... District Court, State of Nevada, Washoe County All Rights Reserved.
Case Description - Docket Report Results - Not an Official Document

www.ccwashoe.com/.../ck_public_qry_doct.cp_dktrpt_docket_report...
2, Judge, D10, ELLIOTT, HONORABLE STEVEN P. Address ... Address: Washoe Co.
... Entry: 1/20/09 COMPETENCY EVALUATION BY BILL DAVIS, Ph.D.

1, Judge, D10, ELLIOTT, HONORABLE STEVEN P. ... Address: WASHOE COUNTY
COURTS COMPLEX ... Entry: 4/5/04 REPORT BY BILL DAVIS, PH.D.

2, Judge, D10, ELLIOTT, HONORABLE STEVEN P. Address: unavailable ...
Prengaman, Esq., Luke J. Address: WASHOE COUNTY COURTS COMPLEX ... Entry:
8/12/08 COMPETENCY EVALUATION BY BILL DAVIS, Ph.D. 15-AUG-2008 ...
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Address: Washoe County DA's Office P.O. Box 30083 ... Address: WASHOE COUNTY
COURTS COMPLEX CRIMINAL .... Entry: BILL DAVIS, Ph.D. 23-FEB-2011 ...

Oct 12, 2011 STEVEN ELLIOTT, H852 - TRIAL - JURY, Outcome is Pending. 2. ....
COMPETENCY EVALUATION BY BILL DAVIS, PH.D. - Transaction 2594723 ...
Judicial District Court, State of Nevada, Washoe County All Rights Reserved.

Oct 14, 2011 STEVEN ELLIOTT, H184 - CHANGE OF PLEA, Outcome is Pending
.... Text: 10/21/11 COMPETENCY EVALUATION BY BILL DAVIS, PH.D. - Transaction
[PDF]
Case Information Case Description: CR11-1150 - STATE VS. MAR
www.washoecourts.com/print_casedesc.cfm?case_id=CR11-1150
File Format: PDF/Adobe Acrobat - Quick View
Jul 27, 2011 ELLIOTT, STEVEN P. 3. PLTF - Plaintiff. STATE OF NEVADA,. 4 .... BY
BILL DAVIS, PH.D. - Transaction 2472690 -. Approved By: NOREVIEW ...
[PDF]
Case Information Case Description: CR11-0427 - STATE VS MAR
Mar 21, 2011 ELLIOTT, STEVEN P. 3. PLTF - Plaintiff. STATE OF NEVADA,. 4 ....
BY DR BILL DAVIS, PH.D. (hh) - Transaction. 2215096 - Approved By: ...

Jul 8, 2008 STEVEN ELLIOTT, H808 - SENTENCING, D765 - Sentenced filed on:
06-Jan-2009 .... Text: 8/8/08 COMPETENCY EVALUATION BY BILL DAVIS, Ph.D. ...
[PDF]
Case Information Case Description: CR12-0841 - STATE VS. ERI
May 15, 2012 1652 - Evaluations 17-Jul-2012 Extra Text: BILL DAVIS, PH.D. 7. 1652
- Evaluations 16-Jul-2012 Extra Text: SALLY FARMER, PH.D. 8. 2960 - ...

Sep 21, 2011 Honorable Steve Elliott Department 15 ..... 1652 - Evaluations,
19-Oct-2011, Extra Text: BILL DAVIS, PH.D. 65. ... Copyright 2012 Second Judicial

Mar 31, 2011 Honorable Steve Elliott Department 15 ..... BY BILL DAVIS, PH.D Transaction 2176647 - Approved By: JYOST ... Copyright 2012 Second Judicial District
Court, State of Nevada, Washoe County All Rights Reserved.
[PDF]
Case Information Case Description: CR08-0895 - STATE VS ...
Apr 29, 2008 21-May-2008Extra Text: FOR TRANSFER AND SETTING. 34. 1652 Evaluations 16-May-2008Extra Text: BILL DAVIS, Ph.D. *** FILED ...
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Second Judicial District Court
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Judge Elliott graduated from Stanford University in 1971 and earned a Juris Doctor degree from the University of Denver in
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1975. He worked for the law firm of Echeverria and Osborne in Reno and served as an Assistant City Attorney for the City of
Sparks.
In June 1979, he was elected Sparks City Attorney and held that position until his election to the District Court. He completed
the Course for Prosecutors sponsored by the National Association of District Attorneys at Northwestern University. He was a
founder of the Washoe County Domestic Violence Task Force and supported the founding of the Washoe County DUI Task
Force. He served as Chairman of the Nevada Delegation to the National Institute of Municipal Law Officers and served on
several national committees including Civil Rights, Municipally Owned Utilities, Land Use and Eminent Domain. He crafted
legislation requiring land developers to dedicate water rights to local governments. This saved taxpayers millions of dollars
when Reno, Sparks and Washoe County purchased the water utility from Sierra Pacific Power Company. He was co-counsel
on the Sparks Tank Farm fuel spill lawsuit which resulted in a multi-million dollar award used to create Sparks Marina Park.
In January 1997, Judge Elliott assumed his position as District Judge. Following a four month assignment to the Family
Division, he has served in General Jurisdiction where his docket consists of civil and criminal cases. Judge Elliott has worked
diligently to improve the efficiency of the District Court. He has served on committees regarding Budget, Employee Relations,
Court Facilities and Court Reporters. As Chairman of the Employee Relations Committee he lead a year-long task force to
revise the Employee Manual. He served on the Nevada Statewide Court Security Task Force to improve security for judges
and the public at courthouses throughout Nevada.
Judge Elliott has been active in community organizations. He has served as a director of the Truckee Meadows Boys and Girls
Club, Truckee Meadows Community College Legal Assistant Advisory Board, Committee to Aid Abused Women Advisory
Board, Sparks Chamber of Commerce, Western Nevada Clean Communities and Friends for Afghan Reconstruction. He is a
past president of the Pyramid Sertoma Club, Sparks Traffic Survival School and Reno Area Stanford Club.
He is married to Mendy Elliott. They have 3 sons.
Copyright 2012 Second Judicial District Court, State of Nevada, Washoe County All Rights Reserved.
Court Employee Emergency Hotline
775-328-3535
001055
http://www.washoecourts.com/... http://www.washoecourts.com/index.cfm?page=elliott&judge_id=d10
001056

CR12-0376
Judge:
STEVEN ELLIOTT
05-17-2012:21:10:43
Clerk Accepted:
05-17-2012:21:11:14
Court:
Case Title:
STATE VS ZACHARY BARKER COUGHLIN

(D10)
Transcript
Filed By:
Lori Urmston
PATRICIA HALSTEAD, ESQ. for STATE OF
NEVADA
ROY STRALLA, ESQ. for STATE OF NEVADA
BIRAY DOGAN, ESQ. for ZACHARY COUGHLIN
CHRIS FORTIER, ESQ. for ZACHARY
COUGHLIN
DIV. OF PAROLE &PROBATION
ZACH YOUNG, ESQ. for STATE OF NEVADA
001057
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001059
001060
001061
001062
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Print
Close
RE: does Richard Hill have standing to file a grievance

From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Fri 3/23/12 10:17 AM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Dear Mr. Coughlin,
I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal research.
You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a
grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As I have explained to
you, the grievances against you came not only from Mr. Hill but also from Judges from different Courts. These grievances,
and the evidence attached with them, rather clearly puts into question your competence to practice law. As I have
explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I
will not send you reports or document, especially since you claim your mail is being compromised.
As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters. As
such, at this time we have not opened any files based on the information you have submitted.
Sincerely,
Patrick King

To: Patrick King; cdbaker@richardhillaw.com
Subject: does Richard Hill have standing to file a grievance
American Jurisprudence Trials

001068
file:///R|/...20clear%20and%20convincing%20evidence%20standard%20echo%20from%20nash%20holmes%2026800.htm[12/10/2012 2:37:38 PM]
Database updated April 2011

Defending Lawyers in Disciplinary Proceedings
31 Am. Jur. Trials 633 (Originally published in 1984)
III Attorney-Client Grievances
10 In general
11 Sources of complaints and grievances; checklist
12 Former criminal clients
13 Particular problem clients
14 Fee disputes; checklist of factors of reasonableness
15 Arbitration; forms
16 Fee dispute committee hearings; illustrative testimony
Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
and engaging in conduct prejudicial to administration of justice, where attorney, acting in bad faith,
filed documents which he or someone in his office generated to falsely certify debtors' completion of
required credit counseling course and which he knew, or should have known, that debtors did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11 U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev. 2010).
Mr. King, could you please update me on that status and progress of the various grievances I filed
recently in addition to providing a detailed summary of the content of all of your correspondences,
written or otherwise, and telephone communciatiosn with Richard Hill or anyone with his office.
Further, please state whether Casey Baker is part of the grievance, as Hill asserts he is filing it on
Mr. Baker's behalf.
Sincerely,
Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy work" for
opposing counsel?
001069
No: 9473
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RE: does Richard Hill have standing to file a grievance

From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Fri 3/23/12 12:08 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Cc: David Clark (DavidC@nvbar.org)
March 23, 2012
Dear Mr. Coughlin,
required of the profession. It appears that you are not. I believe that there are ways to get you
difficult time.

To: Patrick King
Mr. King,
001074
file:///R|/...ot%20note%20from%20clerk%20of%20court%20department%203%2003628%201708%2026800%201708.htm[12/10/2012 2:37:13 PM]
Sincerely,
No: 9473
Date: Fri, 23 Mar 2012 17:18:34 +0000
Dear Mr. Coughlin,
I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal research.
You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a
grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As I have explained to
you, the grievances against you came not only from Mr. Hill but also from Judges from different Courts. These grievances,
and the evidence attached with them, rather clearly puts into question your competence to practice law. As I have
explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I
will not send you reports or document, especially since you claim your mail is being compromised.
As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters. As
such, at this time we have not opened any files based on the information you have submitted.
Sincerely,
Patrick King

To: Patrick King; cdbaker@richardhillaw.com
Subject: does Richard Hill have standing to file a grievance
001075
American Jurisprudence Trials

Database updated April 2011
Defending Lawyers in Disciplinary Proceedings
31 Am. Jur. Trials 633 (Originally published in 1984)
III Attorney-Client Grievances
10 In general
11 Sources of complaints and grievances; checklist
12 Former criminal clients
13 Particular problem clients
14 Fee disputes; checklist of factors of reasonableness
15 Arbitration; forms
16 Fee dispute committee hearings; illustrative testimony
Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining
professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or
misrepresentation
and engaging in conduct prejudicial to administration of justice, where attorney, acting in
bad faith,
filed documents which he or someone in his office generated to falsely certify debtors'
completion of
required credit counseling course and which he knew, or should have known, that debtors
did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11
U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev.
2010).
Mr. King, could you please update me on that status and progress of the various grievances
001076
I filed recently in addition to providing a detailed summary of the content of all of your
correspondences, written or otherwise, and telephone communciatiosn with Richard Hill or
anyone with his office. Further, please state whether Casey Baker is part of the grievance,
as Hill asserts he is filing it on Mr. Baker's behalf.
Sincerely,
Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy
work" for opposing counsel?
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
001077
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legal research stuff

Sent: Fri 2/10/12 8:12 AM
To: bdogan@washoecounty.us
5 attachments
001_MOTIONS AND RESPONSES A-D big Brief Bank WCDA DA.pdf (1177.2 KB) , 001_MOTIONS%20AND%20RESPONSES%20A-D.pdf (2.0 MB) , suing pd Public defender's immunity from liability for malpractice
collection.pdf (4.0 MB) , conflicts with PUBLIC DEFENDER EMPLOYEES.pdf (2.0 MB) , public defenders client controls objectives of litigation.pdf (10.7 MB)
i haven't grabbed any specific to the misues of 911 thing. but i will. can one call 911 about the police? probably, right? rodney king thing...can sargent sigfree tell a dv victim he is arresting him because the victim
"keeps putting themselves in this situation, where you are a victim" and therefore, sigfree is "trying to help the victim" smirk, high five, chortle, gum chewing, DJ Pauly D Jersey Shore, cue the excessive force,
injuries to arrestees writst, etc. etc....Do you have a police report for this yet? I think I ordered one the yesterday and will probably pick it up from the RPD on 2nd tomorrow....or today is what i mean, I had to stay up
to get some deadliens met... god...prviate practice is funl
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby
notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work
product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this
message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
FW: Motion to Suppress

Sent: Fri 2/10/12 5:51 AM
6 attachments
jgoodnight@washoecounty.us negotiations plea agreement correspondence.pdf (93.2 KB) , 001_Prosecutors.pdf (246.3 KB) , Crossing the Line, Responding to Prosecutorial Misconduct.pdf (185.8 KB) ,
gov.uscourts.nvd.65837.46.0 NVD on prosecutorial immunity.PDF (467.7 KB) , prosecutorial misconduct.pdf (106.0 KB) , Prosecutors.pdf (246.3 KB)
Hi Biray,
nice to catch up with you the other day...here is a criminal appeal i have been doing lately for a really difficult client.
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!2003&parid=root
i actually got sentenced to 3 days in jail for summary contempt in the court's presence. the stuff on "10 days to file notice of appeal" from "rendition of judgment" and its 10 CALENDAR days (though I don't think
NRS 189.010 actually makes it easy to know that....do any civil rules of procedure apply to criminal cases? thes crim rules are light totally short...what about NRCP 60(b) newly discovered evidence....how does
exculpatory dna evidence get a crim case overturned if not via nrcp 60(b). I am curious if motions in limine to preserve issues for appeal is a good tactic in criminal cases:
http://www.clarkcountybar.org/index.php?option=com_content&task=view&id=486&Itemid=43
have you ever hear of James Andre Boles? he sues the reno pd a lot....a lot.....
http://www.youtube.com/watch?v=5PR7q4OI5b0
001081
i might have been a little off on whether a disturbing the peace was ever offered in the one Joe "Show 'n Go" Goodnight is on...seems it was offered, but as a conviction that would not be withdraw and dismissed with
prejudice upon 8 months of good behavior....
Zach Coughlin, Esq.
1422 E. 9th St. #2

RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby
notified that you have received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work
product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this
message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
To: jgoodnight@washoecounty.us
Subject: RE: Motion to Suppress
Date: Thu, 9 Feb 2012 13:07:35 -0800
Joe, I will give you a call in a minute. Sorry for the mix up on times to meet. My power was shut off unnotice last friday and NV energy is refusing to let me put it in my name (see email below) but also see emaisl
below that on Plea Agreements deal
I guess you and I can spend another 2 hours minimum trying to figure out if "distrubing the peace" fits into SCR 111 vis a vis the "serious offense" standard requiring reporting. I have other things that might required
reporting, so, even though "disturbing the peace" doesn't sound too bad...its the multiplicity of things that are starting to add up that makes me desire a straight dismissal. But I remain open to discussion, of course.
> Subject: RE: Motion to Suppress

> Date: Wed, 8 Feb 2012 22:12:29 -0800
> From: JGoodnight@washoecounty.us
>
> Mr. Coughlin,
> The times you mention in your email below are for last week (it appears as if you composed a message and then never sent it until now). I am available tomorrow (2/9) at 1:30 p.m. and Friday at 1:00 or 2:00 p.m. Let
me know what works for you and we can discuss presenting a resolution to the state. I believe I can get "disturbing the peace" back on the table, but it may require you to submit to a mental health evaluation and
following any recommendations made by the evaluator. We can discuss further when you come in. Let me know if there is anyone you'd like to bring with you or anyone else from my office that you'd like to be present
and I'll try to arrange it.
> Sincerely,
> Joe Goodnight
>
>
> -----Original Message----> From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
> Sent: Wed 2/8/2012 8:09 PM
> To: Goodnight, Joseph W
> Subject: RE: Motion to Suppress
>
>
> Dear Mr. Goodnight,
>
>
>
>
>
> Hi Joe, good to hear from you. I lost most of the stuff I gather for
> you, but the long story short is that if one review Bar Counsel reports
> that invoke SCR 111 you can find stuff that says the deal DDA young
> proposes (pled to petit larceny, get 8 months good beahvior shrink,
> abstain, etc., etc....then if all good da withdraws the guilty plea and
001082
> dismisses with prejudice) has come up before and BAr Counsel has rule
> that that is still a "conviction" within the meanign of Nevada Supreme
> Court Rule 111 requiring the attorney to report it to Bar Counsel, and
> where the conviction is a "serious offense" as defined in SCR 111, which
> also defines what a "conviction is" (and its pretty clear, when
> reviewing Bar Counsel reports that the plea agreement young offers is
> basically a loser for me on the SCR 111 thing. now a "distrubing the
> peace" plea probably would be a good offer, but a "plead to petit
> larceny" is, in my opinion, doo doo. its like saying, why even go up
> to the plate, just gonna strike out.... some examples here: http://www.google.com/#sclient=psyab&hl=en&source=hp&q=%22scr+111%22+++%22with+prejudice%22+nevada&psj=1&oq=%22scr+111%22+++%22with+prejudice%22+nevada&aq=f&aqi=&aql=&gs_sm=3&gs_upl=5882l5882l0l6222l1l1l0l0l0l0l257l257l21l1l0&bav=on.2,or.r_gc.r_pw.,cf.osb&fp=6134ab16fe89b6fc&biw=1044&bih=499
>
>
>
>
>
> Rule 111. Attorneys convicted of crimes.
>
> 1. "Conviction" defined. For
> purposes of this rule, in addition to a final judgment of conviction, a
> "conviction" shall include a plea of guilty or nolo contendere, a plea under North
> Carolina v. Alford, 400 U.S. 25 (1970), or a guilty verdict following
> either a bench or a jury trial, regardless of whether a sentence is suspended
> or deferred or whether a final judgment of conviction has been entered, and
> regardless of any pending appeals.
>
>
> 2. Duty to inform bar counsel. Upon
> being convicted of a crime by a court of competent jurisdiction, other than a
> misdemeanor traffic violation not involving the use of alcohol or a controlled
> substance, an attorney subject to these rules shall inform bar counsel within
> 30 days.
>
>
> 3. Court clerks to transmit proof of
> conviction. The clerk of any court in this state in which an
> attorney is convicted of a crime, other than a misdemeanor traffic violation
> not involving the use of alcohol or a controlled substance, shall transmit a
> certified copy of proof of the conviction to the supreme court and bar counsel
> within 10 days after its entry.
>
>
> 4. Bar counsel's responsibility. Upon
> being advised that an attorney subject to the disciplinary jurisdiction of the
> supreme court has been convicted of a crime, other than a misdemeanor traffic
> violation not involving the use of alcohol or a controlled substance, bar
> counsel shall obtain a certified copy of proof of the conviction and shall file
> a petition with the supreme court, attaching the certified copy. Upon being
> advised that an attorney subject to the disciplinary jurisdiction of the supreme
> court has been convicted of a misdemeanor involving the use of alcohol or a
> controlled substance and the offense is not the attorney's first such offense,
> bar counsel shall investigate and present the matter to the appropriate panel
> of the disciplinary board prior to the filing of the petition. The petition
> shall be accompanied by the panel's recommendation regarding the appropriate
> disciplinary action, if any, to be imposed under these or any other rules of
> the supreme court that pertain to the conduct of attorneys.
>
>
> 5. Certified document conclusive. A
> certified copy of proof of a conviction is conclusive evidence of the
> commission of the crime stated in it in any disciplinary proceeding instituted
> against an attorney based on the conviction.
>
>
> 6. Definition of "serious crime." The
> term "serious crime" means (1) a felony and (2) any crime less than a felony a
> necessary element of which is, as 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 "serious crime."
>
>
001083
> 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 a
> serious crime, the court shall enter an order suspending the attorney,
>
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regardless of the pendency of an appeal, pending final disposition of a

disciplinary proceeding, which shall be commenced by the appropriate
disciplinary board upon referral by the supreme court. For good cause, the
court may set aside its order suspending the attorney from the practice of law.
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. The panel may, for good cause, postpone the proceeding until all
appeals from the conviction have been concluded.
9. Conviction for other than a serious
crime. Upon receipt of a petition demonstrating that an
attorney has been convicted of a crime which is not a serious crime, the
supreme court may refer the matter to the appropriate disciplinary board for
any action it may deem warranted under these or any other rules of the supreme
court that pertain to the conduct of attorneys, provided, however, that the
supreme court may decline to refer a conviction for a minor offense to the
board. If the conviction adversely reflects on the attorney's fitness to
practice law, the supreme court may issue an order to show cause, requiring the
attorney to demonstrate why an immediate temporary suspension should not be
imposed.
I would like to meet as soon as possible to
discuss your Trial preparation in RCR11-063341, including why you have
not responded to my written requests for you to file a Motion for
Continuance of the February 29th Trial date at 8:00 am before Judge
Sferrazza based upon the rationale I previoulsy indicated and your
recent failure to communicate with me or respond to my stated, written
requests, objectives, demands, etc. Please see the attached pdf
regarding client's rights. Further, I have not received anything from
you in the mail since at least January 1, 2012. I AM HEREBY REITERATING
MY PREVIOUS WRITTEN REQUESTS THAT YOU COPY MY ON ALL FILINGS,
CORRESPONDENCE, MAILINGS, DISCOVERY, PAPERS,PLEADINGS IN ANY WAY
CONNECTED WITH THIS CASE AND OR YOUR REPRESENTATION IN IT BY SENDING ME
AN ELECTRONIC COPY OF SUCH ITEMS, EITHER TO THIS EMAIL ADDRESS OR TO MY
FAX NUMBER (949 667 7402). FURTHER, I AM REQUESTED A COMPLETE COPY OF
THE ENTIRE CONTENTS OF MY FILE BE PROVIDED TO ME BY FAX OR EMAIL AS SOON
AS POSSIBLE. PLEASE ALSO INDICATE WHETHER YOU HAVE FILED EITHER OF THE
DRAFT FILINGS YOU PRESENTED TO ME AT OUR LAST IN PERSON MEETING.
FURTHER, PLEASE INDICATE YOUR NEXT AVAILABLE TIME TO MEET AND DISCUSS
THIS MATTER. I AM AVAILABLE TO MEET WITH YOU AND OR MR. NOVAK OR BOTH
ANYTIME THIS WEEK BESIDE PRIOR TO NOON TOMORROW, TUESDAY, AND PRIOR TO
NOON ON THURSDAY, FEBRUARY 2ND, 2012. NEXT WEEK I AM AVAILABLE anytime
besides prior to noon on February 5th, 2012.
Please indicate
whether you will pursue settlement negotiations with DDA Young
consistent with my stated objectives of not being convicted, or having
exposure to any risk of being convicted of any charges that would
required mandatory reporting to the State Bar of Nevada under SCR 111
(please find attached a collection of State Bar of Nevada Bar Counsel
reports interpreting SCR 111, and would you please provide you legal
opinion as to whether the Plea Agreement offered by DDA Young would or
would not require such a mandatory report of a "conviction" to Bar
Counsel?).
Please correct me if I am wrong, but my understanding

of the Plea Agreement offered was that the best offer, and only offer, I
believe, is memorialized below:
From: Young, Zach
001084
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Sent: Tuesday, October 25, 2011 8:35 AM
To: Goodnight, Joseph W
Cc: Spencer, Darcy
Subject: RE: Coughlin - DA#432068

Sorry, got caught up with a pretrial.
Mr. Coughlin can get

mental health eval and if counseling is recommended and medications
prescribed, he can plead guilty to Petit Larceny as charged, set
sentencing out 6-8 months (or thereabouts) and if he obeys all laws,
abstains alcohol/non-Rx drugs, takes Rx meds as prescribed, and abides
by counseling/medication recommendations (with updates provided and
final letter from counselor saying he is doing well, etc.), State will
allow him to withdraw his plea and dismiss the case with prejudice. An informal diversion if you will.
If no counseling is
recommended or if Mr. Coughlin chooses otherwise, he can plead guilty to
Disturbing the Peace, stip 180 days WCJ s/s, mental health eval follow
recs, abstain alcohol/non-Rx drugs, obey all laws, take Rx meds as
prescribed.
I am CC'ing Darcy, who is covering file for me tomorrow afternoon.
Zach"
My
independent legal research on this matter (including items such as the
attache reports of State Bar of Nevada Bar Counsel) strongly suggest
that the above Plea Agreement would require mandatory reporting to Bar
Counsel of a "conviction" of a "serious crime". I do not really see how
this is all that useful to me or in the spirit of settlement. You, the
DA, the RPD, Goble, Zarate, the WCPD, etc all have exposure in
connection with this matter. By that I mean, everyone has risk here
which prudence dictates attempting to minimize. I am in no way
threatening any violence or unlawful conduct. I abhor violence and do
at all times attempt to maintain the highest fidelity possible to lawful
practices.
My
then girlfriend of almost 5 years, Melissa Ulloa, 29 of Reno, Nevada,
(whom I co-habitated with for 4 years) graduate from UNR in mid-May of
2011. I supported her and sacrificed a great deal for her in helping
001085
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her finish three years worth of credits at UNR in 4 years and graduate
with a degree in Journalism. She broke up with me and moved out
suddenly two days after graduating. It was devastating. She left with a
dog we got together and shared for 3 years as well that I was quite
fond of. Further, my family was extremely fond of Ms. Ulloa an
generally seemed to side with or empathize with her pretty much
exclusively. Ms. Ulloa is an insulin dependent diabetic and a fine
person, however, that condition can take a toll on one and their partner
given the severe mood swings attendant to it. On top of that, I
received an email from our landlord on August 11th, 2011 indicating that
Ms. Ulloa had failed to pay half of the rent for May and all for June
2011 despite my providing her with my share of the rent for those
months, unbeknowst to me. Ms. Ulloa and I had an arrangement for about
four years where I would provide her a check or cash for my share of our
rent and she would add hers and forward the sum to our landlord. I can
provide an email from Ms. Ulloa that confirms or admits to this.
So,
I soon found myself served with an Eviction Notice (actually, I spent 6
days in jail in connection with the arrest in this case, from August
20th to August 26th due to the difficulties in remembering friends and
families cell phone numbers, delay in getting access to those numbers
while in jail, and what has always been a sink or swim approach to
parenting towards me in my family as the only son in a family full of
sisters). The eviction notice in REV2011-001708 was served, or posted
to my home law office's door while I was in jail on August 22nd, 2011.
I litigated that summary eviction from what I believe is a commercial
lease (the Lease Agreement explicitly allowed for use of the location as
a business, as do the applicable zoning laws) where only a No Cause
Eviction Notice was served (ie, the landlord did not allege failure to
pay rent; however, and impermissilby under NRS 40.253(6), Judge
Sferrazza ordered me to deposit a rent escrow amount of $2,275 on
October 13th, 2011, which I did, in order to go forward and contest the
eviction. The JCRRT do not have an analogue to JCRLV 44, which allows
such an Order to deposit a rent escrow amount within a summary eviction
proceeding. Further, NRS 40.253 forbids using a summary eviction
proceeding against a commercial lessee unless a Non Payment of Rent For
Cause Eviction Notice is served (which was not the case in that matter)
as the burdens of facing a summary eviction proceeding (which lack
practically all of the protections and due process safeguards of a
plenary unlawful detainer action) are extremely unfair to foist on a
business owner, particularly where that owner is not charged with
failure to pay rent. Nonetheless, Judge Sferrazza required the $2,275
deposit into the RJC's rent escrow account from October 13th until he
Ordered that amount released to me in his November 7th, 2011 Order. I
was not afforded a legitimate opportunity to take possession of that
check until after I was released from jail on October 14th, 2011 (I was
subject to a custodial arrest for "trespass" at the former home law
office location despite a citation being the more established practice
and where opposing counsel in the eviction matter had arguably rescinded
the eviction by providing me a bill, in writing, for the full rental
value of the property for the month of November 2011 (some $900) rather
than asserting a lien on my property consistent with NRS 118.490, which
allows for a landlord to charge "reasonable storage, moving, and
inventorying" expenses (ie, not full rental value of a 1,200 sq ft home
law office location with all the attendants rights to use such).
What
I really hope for here is a result that will not adversely impact my
ability or right to practice law. I do not harbor any grand illusions
about the chances of success of any police misconduct or prosecutorial
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misconduct or malpractice actions against the WCPD or the WCDA. I just

want to practice law and earn a living, that's it.
Fact that
defendant who pled guilty to felony of driving after forfeiture of
license was given an alternative sentence as a misdemeanor did not alter
his felony status nor preclude court from suspending his license.
Gentry v. State, 526 N.E.2d 1187 (Ind. Ct. App. 1st Dist. 1988).
Rule 111. Attorneys convicted of crimes.
1. "Conviction" defined. For
purposes of this rule, in addition to a final judgment of conviction, a
"conviction" shall include a plea of guilty or nolo contendere, a plea under North
Carolina v. Alford, 400 U.S. 25 (1970), or a guilty verdict following
either a bench or a jury trial, regardless of whether a sentence is suspended
or deferred or whether a final judgment of conviction has been entered, and
regardless of any pending appeals.
2. Duty to inform bar counsel. Upon
being convicted of a crime by a court of competent jurisdiction, other than a
misdemeanor traffic violation not involving the use of alcohol or a controlled
substance, an attorney subject to these rules shall inform bar counsel within
30 days.
3. Court clerks to transmit proof of
conviction. The clerk of any court in this state in which an
attorney is convicted of a crime, other than a misdemeanor traffic violation
not involving the use of alcohol or a controlled substance, shall transmit a
certified copy of proof of the conviction to the supreme court and bar counsel
within 10 days after its entry.
4. Bar counsel's responsibility. Upon
being advised that an attorney subject to the disciplinary jurisdiction of the
supreme court has been convicted of a crime, other than a misdemeanor traffic
violation not involving the use of alcohol or a controlled substance, bar
counsel shall obtain a certified copy of proof of the conviction and shall file
a petition with the supreme court, attaching the certified copy. Upon being
advised that an attorney subject to the disciplinary jurisdiction of the supreme
court has been convicted of a misdemeanor involving the use of alcohol or a
controlled substance and the offense is not the attorney's first such offense,
bar counsel shall investigate and present the matter to the appropriate panel
of the disciplinary board prior to the filing of the petition. The petition
shall be accompanied by the panel's recommendation regarding the appropriate
disciplinary action, if any, to be imposed under these or any other rules of
the supreme court that pertain to the conduct of attorneys.
5. Certified document conclusive. A
certified copy of proof of a conviction is conclusive evidence of the
commission of the crime stated in it in any disciplinary proceeding instituted
against an attorney based on the conviction.
6. Definition of "serious crime." The
term "serious crime" means (1) a felony and (2) any crime less than a felony a
necessary element of which is, as 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 "serious crime."
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 a
serious crime, the court shall enter an order suspending the attorney,
regardless of the pendency of an appeal, pending final disposition of a
001087
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disciplinary proceeding, which shall be commenced by the appropriate

disciplinary board upon referral by the supreme court. For good cause, the
court may set aside its order suspending the attorney from the practice of law.
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. The panel may, for good cause, postpone the proceeding until all
appeals from the conviction have been concluded.
9. Conviction for other than a serious
crime. Upon receipt of a petition demonstrating that an
attorney has been convicted of a crime which is not a serious crime, the
supreme court may refer the matter to the appropriate disciplinary board for
any action it may deem warranted under these or any other rules of the supreme
court that pertain to the conduct of attorneys, provided, however, that the
supreme court may decline to refer a conviction for a minor offense to the
board. If the conviction adversely reflects on the attorney's fitness to
practice law, the supreme court may issue an order to show cause, requiring the
attorney to demonstrate why an immediate temporary suspension should not be
imposed.
10. Reinstatement. An
attorney suspended under the provisions of subsection 7 or 9 of this rule may
be reinstated by filing a certificate with the supreme court demonstrating that
the underlying conviction has been reversed, but reinstatement will not
terminate any formal proceeding pending against the attorney, the disposition
of which shall be determined by the hearing panel on the basis of the available
evidence.
11. Conviction of attorney who is
prohibited from practicing. If an attorney convicted of a
crime is at that time prohibited from practicing due to a disciplinary
suspension or transfer to disability inactive status under Rule 117, then the
petition filed under subsection 7 or 9 of this rule shall state that the
attorney is prohibited from practicing and under what provision. If the
attorney has been suspended as discipline, then the petition shall indicate the
suspension's length and whether the attorney must file a reinstatement petition
under Rule 116 to regain active status. The supreme court shall then enter an
appropriate order directing how the conviction shall be addressed.
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512tel: 775 338 8118

fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This
message and accompanying documents are covered by the electronic
Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain
confidential information intended for the specified individual (s)
only. If you are not the intended recipient or an agent responsible for
delivering it to the intended recipient, you are hereby notified that
you have received this document in error and that any review,
dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This
message is confidential, intended only for the named recipient(s) and
may contain information that is privileged, attorney work product or
001088
> 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.
>
>
>
> Subject: Motion to Suppress
> Date: Wed, 8 Feb 2012 18:15:32 -0800
>
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> Mr. Coughlin,
>
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> I'll be filing the attached motion by
> the end of this week. I took many of your comments into consideration
> and used the ones I felt were appropriate.
>
> Sincerely,
>
>
> Joe Goodnight
>
>
>
>
> <<Coughlin_suppression_motion.pdf>>
>
>
> *********************************
>
> Zach Coughlin, Esq.
>
> 1422 E. 9th St. #2
>
>
>
> RENO, NV 89512tel: 775 338 8118
>
>
> fax: 949 667 7402
> ZachCoughlin@hotmail.com
> Nevada Bar No: 9473
>
>
> ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual
(s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination,
copying, or the taking of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named recipient(s) and may contain information that is privileged,
attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in
reliance on the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and
destroy any copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable privilege.
>
>
001089
>
> Subject: Motion to Suppress
> Date: Wed, 8 Feb 2012 18:15:32 -0800

>
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> Message body
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> Mr. Coughlin,
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> I'll be filing the attached motion by the end of this week. I took many of your comments into consideration and used the ones I felt were appropriate.
>
> Sincerely,
>
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> Joe Goodnight
>
>
>
>
> <<Coughlin_suppression_motion.pdf>>
>
>
> **********************************************************
>
> Joseph W. Goodnight
>
> Deputy Public Defender
>
> (775) 337-4839
>
> jgoodnight@washoecounty.us
>
>
> ** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information intended for the specified individual
(s) only. If you are not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination,
copying, or the taking of any action based on the contents of this information is strictly prohibited.
>
>
>
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001090
001091
001092
001093
001094
Message-ID: <BAY148-W345B0D64B95EB16EEB60DCC2350@phx.gbl>
Content-Type: multipart/alternative;
boundary="_819a7e35-4326-4756-90c6-9dadd3d51388_"
X-Originating-IP: [64.134.234.49]
Reply-To: <zachcoughlin@hotmail.com>
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: <jbosler@washoecounty.us>, <bdogan@washoecounty.us>,
<jgoodnight@washoecounty.us>, <jleslie@washoecounty.us>,
<william.rempel@latimes.com>, <stermitz@sbcglobal.net>,
<sfarmer@lakes.nv.gov>, <billdavis@lakes.nv.gov>, <stuttle@washoecounty.us>,
<zyoung@da.washoecounty.us>, <mkandaras@da.washoecounty.us>,
<kstancil@washoecounty.us>, <rbaker@washoecounty.us>
Subject: Biray Dogan's Malpractice
Date: Wed, 11 Apr 2012 09:51:28 -0700
Importance: Normal
MIME-Version: 1.0
--_819a7e35-4326-4756-90c6-9dadd3d51388_
Content-Type: text/plain; charset="iso-8859-1"
Content-Transfer-Encoding: quoted-printable
Dear Mr. Bosler=2C

Mr. Dogan's malpractice and violations of the RPD are bad enough. Your com=
pounding them with your mincing=2C nonsensical interpretation of Dogan's ta=
cky commentary on my suit and tie ("so=2C are you workin' construction thes=
e days?") is something much worse.
As was supervisor Jim Leslie's painful=
attempts at humor prior to a hearing wherein he attempted to mitigate risk=
from behind the bar=2C from gallery=2C after admittedly muzzling Joe Goodn=
ight=2C who I respected at one time. Mr. Goodnight=2C please do not speak =
with Biray Dogan about my case ever=2C at all. I am formally requesting un=
der FOIA and the Nevada Open Records law copies of all emails and other cor=
respondence between anyone with the WCPD and anyone with the WCDA. Mr. Dog=
an=2C your commentary regarding Ms. Halstead was especially troubling.
I =
am formally forbidding anyone with the WCPD from speaking with anyone with =
the Reno Municipal Court or otherwise sharing any documentation=2C any copi=
es of micro sd card data that was seized from an attorney in open court und=
er a search incident to arrest following a pretexutal summary contempt arre=
st (which came just moments after the Judge began a sua sponte interrogatio=
n of the attorney in an apparent attempt to protect Reno City Attorney Orma=
as and RMC Marshal Harley from their own misconduct and intentional failure=
to document admissions of bribery by the RPD's Officer Chris Carter involv=
ing Richard G. Hill=2C Esq. incident to a pathetic criminal trespass arrest=
in the context of a civil eviction proceeding=2C especially where Hill adm=
its on film and in writing that he was seeking to charge the same $900 "fai=
r rental value" of the tenant=2C that was attendant to full use and occupan=
cy=2C in violation of the prohibition of such unlawful rent distraints unde=
r NRS 118A.520 and in a perverted interpretation of NRS 118A.460. =20
RJC Court Administrator Steve Tuttle assures me that he will get to the bot=
tom of these retaliatory competency evaluation requests and the complete an=
d utter lack of documentation in these files setting forth any reasonable b=
asis for so seeking such and evaluation=2C and the apparent dishonesty atte=
ndant to filings which indicate that a hearing and motion exist in that reg=
ard where no such hearing or motion was ever conducted. Further=2C Mr. Goo=
dnight=2C the file int he RJC for the matter you are attached to indicates =
that I need to be arraigned on the second charged. That has not been done.=
Please have the Trial date vacated=2C and file a Motion to Dismiss based =
upon the right to a speedy trial found in the Sixth Amendment. Further=2C =
Mr. Dogan and Mr. Goodnight constantly quote me the "basis in fact and law"=
language in NRCP Rule 11 when explaining their complete failure and refusa=
l to do anything I ask be done in my case (subpoena officer's personnel fil=
e=2C file a motion in limine=2C etc.=2C etc.) then turn right around and in=
dicate that NRCP Rule 11 is inapplicable in a criminal setting when explain=
ing their refusal to move for sanctions or file any sort of motion or griev=
ance against DDA Zach Young=2C Esq.=2C and the WCDA's office for continuing=
to prosecute this pathetic gross misdemeanor "misuse of 911" charge agains=
t a victim of domestic violence (according to Master Edmondson in FV12-0018=
8 and FV12-00187 and NRS 33.018) even where the DA has been provided a vide=
o of the arresting RPD Sargent Sifre admitting he was engaging in classic "=
blame the victim" police work wherein Sifre admits=2C on film=2C that he is=
making the arrest because the victim keeps putting their self into situati=
ons where they are victimized.
Further troubling is that RPD Sargent Zach=
Thew had directed the victim to make such a call=2C though Sifre curtly an=
d dismissively rebuked such involvement by Sargent Thew.
About six weeks =
later=2C Sargent Sifre then subsequently went on to detain Coughlin for ove=
r an hour (after Sifre had=2C in his own word=2C screwed up and let out Cou=
ghlin's dog during a subsequent and legitimate "misuse of 911" violation by=
001095
file:///R|/...NEW%20temp/4%2011%2012%20email%20to%20kandaras%20and%20young%20on%20biray%20dogans%20malpractice.htm[12/10/2012 3:09:26 PM]
someone other than Coughlin=2C who could articulate no basis whatsoever fo=
r their apparent "fear" sufficient to support at least two 911 calls within=
a couple hours. =20
The wrongful arrest for which a gross misdemeanor charge is still being Nif=
onged by DDA Zach Young and for which DPD Biray Dogan has sought a retaliat=
ory competency evaluation after Coughlin reported and criticized Dogan's fa=
ilure to appear for a court date:
http://www.youtube.com/watch?v=3DoU3t_kRR0RA
The jaywalking arrest of Coughlin for which Hill was awarded a Protection O=
rder by the RJC:
http://www.youtube.com/watch?v=3DgBu9zflGALE
Further=2C DPD Goodnight. You have failed to provide me with the recent mo=
tion work in RJC RCR 2012-063341=2C including the disclosure of witnesses. =
Amazingly=2C you have disclosed a "Colton Templeton" while refusing to dis=
close Nicole Watson or Lucy Byington=2C two individuals who were there when=
the unidentified man threatened to "throw this phone in the river if someb=
ody doesn't claim it right now".
This "Lawyer Kevorkian" approach needs t=
o cease=2C Mr. Goodnight. =20
The Arrest:
http://www.youtube.com/watch?v=3D5PR7q4OI5b0
Nicole Watson admitting that she heard the man saying he would throw this p=
hone in the river if somebody doesn't claim it right now:
http://www.youtube.com/watch?v=3Dto_UOFIccLw
Biray Dogan is not very fond of individuals recording events and conversati=
ons=2C however=2C without the above recordings=2C it is a very different la=
ndscape here.
Further=2C your WCPD office has repeatedly refused to indicate=2C in writi=
ng=2C why an SB89 form and or "motion" for Order for Competency Evaluation =
was sought=2C after a "hearing" for BOTH of the competency evaluations I ha=
ve been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was=
held=2C however=2C the record at the RJC filing office indicates "upon mot=
ion of Defendants counsel and after a hearing on the matter an Order for Co=
mpetency Evaluation....".
There was no hearing.
There was no motion.
=
There was a retaliatory motive. There is an impermissible quid pro quo bet=
ween Lake's Crossing and the WCPD=2C and an illegal tying arrangement with =
Lake's Crossing=2C which subjects those forced to have evaluations done the=
re to impermissible searches in violation of the Fourth Amendment and which=
filed with the RJC lie riddled note attempting to describe my first trip d=
own to Lake's Crossing.
I wish to have other evaluators perform these eva=
luations and want to be reimbursed for the cost of doing so. Please let me=
know=2C in writing=2C how much your office pays Lake's Crossing (Judge Sfe=
rrazza sent the bill back to you after the last evaluation=2C or at least m=
ade statements in court that he would do so=2C given how weak Goodnight and=
Hylin's rationale was for seeking such an evaluation in the first place=2C=
in pathetic combination with Goodnight immediate request to be allowed out=
of the case at the status conference hearing following the evaluation. Ju=
dge Sferrazza pointed out to Goodnight how very intellectually dishonest it=
was for he and the WCPD to alternately force me to have such and evaluatio=
n conducted=2C only to immediately seek to withdraw=2C then to divulge clie=
nt confidences in open court over the remonstrances of the client. =20
Lorrain Pelosi=2C from Lake's Crossing indicates that "we have a contract w=
ith the Public Defender" and=2C therefore=2C I am only able to utilize a no=
n-Lake's Crossing evaluator if I have a "private attorney". Further=2C she=
indicates that I will not be provided reimbursement for using a non-Lake's=
Crossing evaluator if I utilize the services of the WCPD. =20
Further=2C there are reports that Mr. Dogan and someone else from the WCPD =
called Department 3 of the RMC and made impermissible communications in vio=
lation of the duty of confidentiality attendant to the attorney-client rela=
tionship.
This is not the first report of such a violation=2C Mr. Bosler=
=2C and the practice of having WCPD's drag their clients to Bailiff's to ha=
ve blood alcohol level breath tests forced upon them based upon "hunches" a=
nd the DPD's "duty to the court" is rather suspect. =20
Lastly=2C RJC Bailiff John Reyes=2C whom has previously menacingly indicate=
d to Coughlin that he would "put my foot up your ass" (at a time during wh=
ich Bailiff Reyes was attempting to prevent Coughlin from standing near the=
second floor filing counter in the RJC to hear what Coughlin's Deputy Publ=
ic Defender Goodnight and Goodnight's supervisor were purporting to the RJC=
counter staff). Bailiff Reyes now obsessively positions himself all over =
the RMC And RJC Courthouse to insure he will encounter Coughlin as each and=
every court appearance Coughlin has=2C whereupon Reyes will offer a menanc=
ing glare that he alternates with a shingle eating smile and cutesy comment=
ary. Bailiff Reyes will then follow Coughlin around from the RJC's civil f=
001096
iling office to its criminal filing office=2C hounding Coughlin and insisti=
ng that Coughlin leave. While Richard G. Hill=2C Esq. was extremely succes=
sful in getting a protection order from Judge Schroeder of the RJC=2C in a =
scant 40 minutes from the time he filed it no less (and that application co=
ntained perjury by Hill that was subsequently unveiled at the hearing on Hi=
ll's Motion for Order to Show Cause before Judge Flanagan on 3/23/12)=2C Co=
ughlin was not so successful in getting a Protection Order against Bailiff =
Reyes. While Hill's protection order application contained only unsupporte=
d hearsay=2C and some nonsense about climbing on a truck (which was thoroug=
hly discredited at the 3/23/12 Hearing in D7)=2C Coughlin's TPO application=
against Bailiff Reyes actually set forth a threat of sexual assault=2C yet=
Coughlin did not even get a hearing on the matter and now Bailiff Reyes ha=
s amped up his misbehavior. This=2C in combination with RJC civil office c=
ounter clerk Christine Erickson brazen refusal to file various exigent Moti=
on's and Notices of Appeal and other landlord tenant based filings submitte=
d by Coughlin=2C despite Coughlin providing the RJC with support for his co=
ntention that such refusals are clearly in violation of established Nevada =
law and contribute to substantial losses to Coughlin personally and profess=
ionaly. Most ironic of all=2C Bailiff Reyes=2C recently=2C explained to RJ=
C Court Administrator Tuttle in Coughlin's presence at the RJC civil divisi=
on filing office that Reyes "does not think it is appropriate" for Coughlin=
to have any communications with RJC civil division filing office staff of =
anything other than the most brief and sterile nature.
Apparently Bailiff=
Reyes finds telling Coughlin=2C under color of law=2C and for no legitimat=
e reason=2C that he will "put my foot up your ass"=2C while=2C curiously Ba=
iliff Reyes somehow finds Coughlin's sayign "hello" and "how was your weeke=
nd" to filing office staff to be "inappropriate". =20
Further=2C Richard G. HIll=2C Esq. threatened Coughlin at the 12/20/11 Hear=
ing on Coughlin's Motion to Release Personal Property (where Coughlin as ch=
arged the outrageous sum of $30 per day "storage" and forced to pay a lien =
for the contents of his former law office after Richard G. Hill=2C Esq.'s n=
egligence cause it to be burglarized on December 12=2C 2011=2C something fo=
r which Hill now seeks to have Coughlin pay for in his ridiculous Memorandu=
m of Costs on appeal in D7 in CV11-03628) when Hill exclaimed to Coughlin=
=2C in front of Bailiff Reyes and Chief Bailiff Sexton (whom has also made =
threatening commentary to Coughlin on multiple occasions seeking to prevent=
Coughlin from filing documents with the RJC incident to exigent eviction m=
atters) that Hill=2C too=2C "would like to stick something up Coughlin's a=
ss".
Hill said this in a loud voice approximately 20 feet from Coughlin=
=2C with Bailiff Reyes and Chief Bailiff Sexton standing near Hill=2C all t=
hree gentlemen sharing a good laugh=2C during a recess=2C but while in the =
courtroom=2C in RJC Rev201-001708's 12/20/11 Hearing. Judge Sferrazza was =
informed of this on the record.
Please place a copy of this formal compla=
int in both Deputy Reyes and Chief Deputy Sexton's employment and personnel=
files.
Sincerely=2C
Zach Coughlin=2C Esq.=2C PO BOX 60952=2C RENO=2C NV=2C 89506=2C tel: 775 33=
8 8118=2C fax: 949 667 7402=3B ZachCoughlin@hotmail.com
Nevada Bar No: 94=
73
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id=3D"ecxFontBreak">Dear Mr. Bosler=2C Mr. Dogan's malpractic=
e and violations of the RPD are bad enough.&nbsp=3B Your compounding them w=
ith your mincing=2C nonsensical interpretation of Dogan's tacky commentary =
on my suit and tie ("so=2C are you workin' construction these days?") is so=
mething much worse.&nbsp=3B&nbsp=3B As was supervisor Jim Leslie's painful =
attempts at humor prior to a hearing wherein he attempted to mitigate risk =
001097
from behind the bar=2C from gallery=2C after admittedly muzzling Joe Goodni=
ght=2C who I respected at one time.&nbsp=3B Mr. Goodnight=2C please do not =
speak with Biray Dogan about my case ever=2C at all.&nbsp=3B I am formally =
requesting under FOIA and the Nevada Open Records law copies of all emails =
and other correspondence between anyone with the WCPD and anyone with the W=
CDA.&nbsp=3B Mr. Dogan=2C your commentary regarding Ms. Halstead was especi=
ally troubling.&nbsp=3B&nbsp=3B I am formally forbidding anyone with the WC=
PD from speaking with anyone with the Reno Municipal Court or otherwise sha=
ring any documentation=2C any copies of micro sd card data that was seized =
from an attorney in open court under a search incident to arrest following =
a pretexutal summary contempt arrest (which came just moments after the Jud=
ge began a sua sponte interrogation of the attorney in an apparent attempt =
to protect Reno City Attorney Ormaas and RMC Marshal Harley from their own =
misconduct and intentional failure to document admissions of bribery by the=
RPD's Officer Chris Carter involving Richard G. Hill=2C Esq. incident to a=
pathetic criminal trespass arrest in the context of a civil eviction proce=
eding=2C especially where Hill admits on film and in writing that he was se=
eking to charge the same $900 "fair rental value" of the tenant=2C that was=
attendant to full use and occupancy=2C in violation of the prohibition of =
such unlawful rent distraints under NRS 118A.520 and in a perverted interpr=
etation of NRS 118A.460.&nbsp=3B&nbsp=3B RJC Court Administrator St=
eve Tuttle assures me that he will get to the bottom of these retaliatory c=
ompetency evaluation requests and the complete and utter lack of documentat=
ion in these files setting forth any reasonable basis for so seeking such a=
nd evaluation=2C and the apparent dishonesty attendant to filings which ind=
icate that a hearing and motion exist in that regard where no such hearing =
or motion was ever conducted.&nbsp=3B Further=2C Mr. Goodnight=2C the file =
int he RJC for the matter you are attached to indicates that I need to be a=
rraigned on the second charged.&nbsp=3B That has not been done.&nbsp=3B Ple=
ase have the Trial date vacated=2C and file a Motion to Dismiss based upon =
the right to a speedy trial found in the Sixth Amendment.&nbsp=3B Further=
=2C Mr. Dogan and Mr. Goodnight constantly quote me the "basis in fact and =
law" language in NRCP Rule 11 when explaining their complete failure and re=
fusal to do anything I ask be done in my case (subpoena officer's personnel=
file=2C file a motion in limine=2C etc.=2C etc.) then turn right around an=
d indicate that NRCP Rule 11 is inapplicable in a criminal setting when exp=
laining their refusal to move for sanctions or file any sort of motion or g=
rievance against DDA Zach Young=2C Esq.=2C and the WCDA's office for contin=
uing to prosecute this pathetic gross misdemeanor "misuse of 911" charge ag=
ainst a victim of domestic violence (according to Master Edmondson in FV12-=
00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a =
video of the arresting RPD Sargent Sifre admitting he was engaging in class=
ic "blame the victim" police work wherein Sifre admits=2C on film=2C that h=
e is making the arrest because the victim keeps putting their self into sit=
uations where they are victimized. &nbsp=3B Further troubling is that RPD S=
argent Zach Thew had directed the victim to make such a call=2C though Sifr=
e curtly and dismissively rebuked such involvement by Sargent Thew.&nbsp=3B=
&nbsp=3B About six weeks later=2C Sargent Sifre then subsequently went on t=
o detain Coughlin for over an hour (after Sifre had=2C in his own word=2C s=
crewed up and let out Coughlin's dog during a subsequent and legitimate "mi=
suse of 911" violation by someone other than Coughlin=2C who could articula=
te no basis whatsoever for their apparent "fear" sufficient to support at l=
east two 911 calls within a couple hours.&nbsp=3B&nbsp=3B The wrong=
ful arrest for which a gross misdemeanor charge is still being Nifonged by =
DDA Zach Young and for which DPD Biray Dogan has sought a retaliatory compe=
tency evaluation after Coughlin reported and criticized Dogan's failure to =
appear for a court date: <a href=3D"http://www.youtube.com/watch?v=3DoU3t_k=
RR0RA" class=3D"ecx" target=3D"_blank">http://www.youtube.com/watch?v=3DoU3=
t_kRR0RA</a> The jaywalking arrest of Coughlin for which Hill=
was awarded a Protection Order by the RJC: <a href=3D"http://www.youtube=
.com/watch?v=3DgBu9zflGALE" class=3D"ecx" target=3D"_blank">http://www.yout=
ube.com/watch?v=3DgBu9zflGALE</a> Further=2C DPD Goodnigh=
t.&nbsp=3B You have failed to provide me with the recent motion work in RJC=
RCR 2012-063341=2C including the disclosure of witnesses.&nbsp=3B Amazingl=
y=2C you have disclosed a "Colton Templeton" while refusing to disclose Nic=
ole Watson or Lucy Byington=2C two individuals who were there when the unid=
entified man threatened to "throw this phone in the river if somebody doesn=
't claim it right now".&nbsp=3B&nbsp=3B This "Lawyer Kevorkian" approach ne=
eds to cease=2C Mr. Goodnight.&nbsp=3B The Arrest: <a href=3D"http://ww=
w.youtube.com/watch?v=3D5PR7q4OI5b0" class=3D"ecx" target=3D"_blank">http:/=
/www.youtube.com/watch?v=3D5PR7q4OI5b0</a> Nicole Watson admittin=
g that she heard the man saying he would throw this phone in the river if s=
omebody doesn't claim it right now: <a href=3D"http://www.youtube.com/watch=
?v=3Dto_UOFIccLw" class=3D"ecx" target=3D"_blank">http://www.youtube.com/wa=
tch?v=3Dto_UOFIccLw</a> Biray Dogan is not very fond of indiv=
iduals recording events and conversations=2C however=2C without the above r=
ecordings=2C it is a very different landscape here. Further=2C your =
001098
WCPD&nbsp=3B office has repeatedly refused to indicate=2C in writing=2C why=

an SB89 form and or "motion" for Order for Competency Evaluation was sough=
t=2C after a "hearing" for BOTH of the competency evaluations I have been o=
rdered to undergo.&nbsp=3B Mr. Hylin admitted to me that no "hearing" was h=
eld=2C however=2C the record at the RJC filing office indicates "upon motio=
n of Defendants counsel and after a hearing on the matter an Order for Comp=
etency Evaluation....". &nbsp=3B There was no hearing. &nbsp=3B There was n=
o motion. &nbsp=3B There was a retaliatory motive.&nbsp=3B There is an impe=
rmissible quid pro quo between Lake's Crossing and the WCPD=2C and an illeg=
al tying arrangement with Lake's Crossing=2C which subjects those forced to=
have evaluations done there to impermissible searches in violation of the =
Fourth Amendment and which filed with the RJC lie riddled note attempting t=
o describe my first trip down to Lake's Crossing. &nbsp=3B I wish to have o=
ther evaluators perform these evaluations and want to be reimbursed for the=
cost of doing so.&nbsp=3B Please let me know=2C in writing=2C how much you=
r office pays Lake's Crossing (Judge Sferrazza sent the bill back to you af=
ter the last evaluation=2C or at least made statements in court that he wou=
ld do so=2C given how weak Goodnight and Hylin's rationale was for seeking =
such an evaluation in the first place=2C in pathetic combination with Goodn=
ight immediate request to be allowed out of the case at the status conferen=
ce hearing following the evaluation.&nbsp=3B Judge Sferrazza pointed out to=
Goodnight how very intellectually dishonest it was for he and the WCPD to =
alternately force me to have such and evaluation conducted=2C only to immed=
iately seek to withdraw=2C then to divulge client confidences in open court=
over the remonstrances of the client.&nbsp=3B&nbsp=3B Lorrain Pelo=
si=2C from Lake's Crossing indicates that "we have a contract with the Publ=
ic Defender" and=2C therefore=2C I am only able to utilize a non-Lake's Cro=
ssing evaluator if I have a "private attorney".&nbsp=3B Further=2C she indi=
cates that I will not be provided reimbursement for using a non-Lake's Cros=
sing evaluator if I utilize the services of the WCPD.&nbsp=3B&nbsp=3B <=
br>Further=2C there are reports that Mr. Dogan and someone else from the WC=
PD called Department 3 of the RMC and made impermissible communications in =
violation of the duty of confidentiality attendant to the attorney-client r=
elationship.&nbsp=3B&nbsp=3B This is not the first report of such a violati=
on=2C Mr. Bosler=2C and the practice of having WCPD's drag their clients to=
Bailiff's to have blood alcohol level breath tests forced upon them based =
upon "hunches" and the DPD's "duty to the court" is rather suspect.&nbsp=3B=
&nbsp=3B Lastly=2C RJC Bailiff John Reyes=2C whom has previously me=
nacingly indicated to Coughlin that he would "put my foot up your ass"&nbsp=
=3B (at a time during which Bailiff Reyes was attempting to prevent Coughli=
n from standing near the second floor filing counter in the RJC to hear wha=
t Coughlin's Deputy Public Defender Goodnight and Goodnight's supervisor we=
re purporting to the RJC counter staff).&nbsp=3B Bailiff Reyes now obsessiv=
ely positions himself all over the RMC And RJC Courthouse to insure he will=
encounter Coughlin as each and every court appearance Coughlin has=2C wher=
eupon Reyes will offer a menancing glare that he alternates with a shingle =
eating smile and cutesy commentary.&nbsp=3B Bailiff Reyes will then follow =
Coughlin around from the RJC's civil filing office to its criminal filing o=
ffice=2C hounding Coughlin and insisting that Coughlin leave.&nbsp=3B While=
Richard G. Hill=2C Esq. was extremely successful in getting a protection o=
rder from Judge Schroeder of the RJC=2C in a scant 40 minutes from the time=
he filed it no less (and that application contained perjury by Hill that w=
as subsequently unveiled at the hearing on Hill's Motion for Order to Show =
Cause before Judge Flanagan on 3/23/12)=2C Coughlin was not so successful i=
n getting a Protection Order against Bailiff Reyes.&nbsp=3B While Hill's pr=
otection order application contained only unsupported hearsay=2C and some n=
onsense about climbing on a truck (which was thoroughly discredited at the =
3/23/12 Hearing in D7)=2C Coughlin's TPO application against Bailiff Reyes =
actually set forth a threat of sexual assault=2C yet Coughlin did not even =
get a hearing on the matter and now Bailiff Reyes has amped up his misbehav=
ior.&nbsp=3B This=2C in combination with RJC civil office counter clerk Chr=
istine Erickson brazen refusal to file various exigent Motion's and Notices=
of Appeal and other landlord tenant based filings submitted by Coughlin=2C=
despite Coughlin providing the RJC with support for his contention that su=
ch refusals are clearly in violation of established Nevada law and contribu=
te to substantial losses to Coughlin personally and professionaly.&nbsp=3B =
Most ironic of all=2C Bailiff Reyes=2C recently=2C explained to RJC Court A=
dministrator Tuttle in Coughlin's presence at the RJC civil division filing=
office that Reyes "does not think it is appropriate" for Coughlin to have =
any communications with RJC civil division filing office staff of anything =
other than the most brief and sterile nature.&nbsp=3B&nbsp=3B Apparently Ba=
iliff Reyes finds telling Coughlin=2C under color of law=2C and for no legi=
timate reason=2C that he will "put my foot up your ass"=2C while=2C curious=
ly Bailiff Reyes somehow finds Coughlin's sayign "hello" and "how was your =
weekend" to filing office staff to be "inappropriate".&nbsp=3B&nbsp=3B =
 Further=2C Richard G. HIll=2C Esq. threatened Coughlin at the 12/20/11 =
Hearing on Coughlin's Motion to Release Personal Property (where Coughlin a=
s charged the outrageous sum of $30 per day "storage" and forced to pay a l=
ien for the contents of his former law office after Richard G. Hill=2C Esq.=
's negligence cause it to be burglarized on December 12=2C 2011=2C somethin=
g for which Hill now seeks to have Coughlin pay for in his ridiculous Memor=
001099
andum of Costs on appeal in D7 in CV11-03628) when Hill exclaimed to Coughl=

in=2C in front of Bailiff Reyes and Chief Bailiff Sexton (whom has also mad=
e threatening commentary to Coughlin on multiple occasions seeking to preve=
nt Coughlin from filing documents with the RJC incident to exigent eviction=
matters) that Hill=2C too=2C "would like to stick something&nbsp=3B up Cou=
ghlin's ass".&nbsp=3B&nbsp=3B Hill said this in a loud voice approximately =
20 feet from Coughlin=2C with Bailiff Reyes and Chief Bailiff Sexton standi=
ng near Hill=2C all three gentlemen sharing a good laugh=2C during a recess=
=2C but while in the courtroom=2C in RJC Rev201-001708's 12/20/11 Hearing.&=
nbsp=3B Judge Sferrazza was informed of this on the record.&nbsp=3B&nbsp=3B=
Please place a copy of this formal complaint in both Deputy Reyes and Chie=
f Deputy Sexton's employment and personnel files. Sincerely=2C <b=
r>Zach Coughlin=2C Esq.=2C </font=
>PO BOX 60952=2C RENO=2C NV=2C 89506=2C tel: 775 338 8118=
=2C fax: 949 667 7402=3B ZachCoughlin@hotmail.com&nbsp=3B&nbsp=3B Nevada Ba=
r No: 9473<=
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001100
Message-ID: <BAY148-W539B0D6B664D82CDA3BD99C23F0@phx.gbl>
Content-Type: multipart/alternative;
boundary="_07cfdc78-89af-41fb-b385-c0bb8e0dd8d9_"
X-Originating-IP: [64.134.228.63]
Reply-To: <zachcoughlin@hotmail.com>
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: <stuttle@washoecounty.us>, <zyoung@da.washoecounty.us>,
<phalstead@da.washoecounty.us>, <mkandaras@da.washoecounty.us>,
<william.rempel@latimes.com>, <ed@npri.org>, <jgoodnight@washoecounty.us>,
<bdogan@washoecounty.us>, <jbosler@washoecounty.us>,
<jleslie@washoecounty.us>, <billdavis@lakes.nv.gov>, <sfarmer@lakes.nv.gov>,
<oliverocskay@yahoo.com>
Subject: FW: CHANGE OF ADDRESS Goodnight speedy trial motion? and RE:
Dogan's "workin' construction" commentary
Date: Mon, 16 Apr 2012 22:58:07 -0700
Importance: Normal
In-Reply-To: <BAY148-W1025F01CB6CBDFD8E52418C23F0@phx.gbl>
References:
<A96F8C2360D670469701E599CE502492100D7C66@wcmailcj.cj.washoecounty.us>,<BAY148W32DFE82807704E111B66F1C2340@phx.gbl>,<A96F8C2360D670469701E599CE502492100D7C79@wcmailcj.cj.washoecou
W1025F01CB6CBDFD8E52418C23F0@phx.gbl>
MIME-Version: 1.0
--_07cfdc78-89af-41fb-b385-c0bb8e0dd8d9_
Content-Type: text/plain; charset="iso-8859-1"
Dear Mr. Tuttle et al=2C

Please accept this writing as the correspondence you requested from me. I =
have not received any of the filings from either the DA or the PD since las=
t I visited the RJC Criminal Division filing office and requested copies of=
everything in the file. My records indicate that that last visit (and I a=
m referring to visits where I was allowed to receive such copies only) was =
approximately approximately February 20th=2C 2012 (though I am sure Nefi wi=
ll have notated when last I was in there and provided copies=2C as he is ve=
ry conscientious and thorough=2C a real credit to the Criminal Division Fil=
ing Office). =20
I have had some difficulties lately with the USPS delivering my mail. Some=
=2C like the 3/13/12 letter from the RJC Civil Division=2C did in fact=2C u=
ltimately make it to me=2C in accordance with the Change of Address I filed=
with the USPS.
Other pieces of mail=2C such as a 3/14/12 mailing from th=
e Reno Municipal Court=2C were ultimately returned to the RMC. With respec=
t to any court documents=2C correspondence=2C or court filings in matters f=
or which Biray Dogan is attached=2C I have received nothing in the mail=2C =
and I am pretty sure I have not received a copy of any such matters via fax=
or email (despite my numerous written please to Mr. Dogan et al at the WCP=
D=2C wherein I set forth the interference with my mail and concomitant stru=
ggles with the USPS that ensued incident to my being adjudge a vicdtim of d=
omestic violence in FV12-00188 and FV12-00187=2C in addition to the malfeas=
ance of the landlord and its agents in RJC Rev2012-000374.
So=2C my please to the WCPD (Dogan and Goodnight) that I be copied via fax =
and email on all documentation=2C filings=2C etc. having gone unresponded t=
o (though I believe Mr. Goodnight=2C to his credit=2C has actually done so =
one or twice=2C in addition to phoning me while I was in jail incident to a=
summary contempt finding by Judge Nash Holmes=2C which resulted in my smar=
t phone being seized incident to the summary contempt arrest=2C and it and =
a 32gb micro sd card being returned to me only 38 days later=2C with the co=
ntents of the micro sd card having been erased....and only after the WCSO r=
efused to comply with the RMC Order of 3/30/12=2C but rather pass me off to=
Mary Kandaras=2C of the District Attorney's Office=2C which brings up the =
point=2C I feel yet another conflict now exists requiring the Districtd Att=
orney's office to withdraw from this prosecution=2C given the ultra suspici=
ous circumstances of the seizing of this micro sd card and smartphone=2C th=
e prolonged detention thereof=2C and the suspicious erasure of its contents=
=2C particularly in the context of the WCSO stalling the returning thereof =
with directions to contact Mary Kandaras=2C especially where "Matty" of the=
WCSO front desk refused to tell me whom gave here those instructions to pa=
ss along=2C but rather=2C where "Matty" responded by having Deputy Beatson =
track me down outside and threaten me with malicious prosecution and retali=
atory arrest and where he threatened to completely fabricate a "distrubing =
the peace" charge merely in an attempt to confiscate the netbook I had in m=
y hands=2C presumbaly so the WCSO could seize that item too for some 38 day=
s only to return it with the hard drive wiped.
So=2C anyways=2C yes=2C please Mr. Tuttle=2C please accept this writing as =
001101
file:///R|/...20CHANGE%20OF%20ADDRESS%20Goodnight%20speedy%20trial%20motion%20Dogan's%20workin%20construction.htm[12/10/2012 3:09:27 PM]
the request for copies of court filings that you asked me to provide you gi=
ven the failure of Mr. Goodnight (to some extent) and Mr. Dogan (to every e=
xtent) to either mail me copies=2C and or to alert me to the fact that they=
received any such mailing back from the USPS as "undeliverable" or otherwi=
se.
Lastly=2C Mr. Tuttle=2C I will point out (given the interest you expressed =
in my disatisfacdtion with how these competency evaluation Orders were bein=
g procured) that not only does the file in many matters indicate such an Or=
der was rendered after a "hearing" and upon a "motion by the defendant's co=
unsel" (where no "hearing" took place=2C and where no "motion" was ever fil=
ed"....can't have an oral motion if there was not actual hearing...can't ma=
ke oral motions to the filing office counter=2C corner cut=2C corner cut=2C=
tsk...tsk...)_but now=2C at least according to Mr. Bosler=2C whom was hand=
picked=2C at least in part=2C by District Attorney Gammick (whom did invit=
e me back for a follow up to my interview=2C to offer some advice=2C a clas=
sy and thoughtful gesture to be sure) http://www.newsreview.com/reno/new-de=
fender/content?oid=3D24938 =2C "the Court" itself is insisting I utilize on=
ly that entity that the Washoe County Public Defender has a requirements co=
ntract with=2C Lake's Crossing=2C to perform a competency evaluation for wh=
ich the statutory requirements only consist of certain certifications and l=
icensures being required of those performing the evaluations=2C and which s=
ay nothing of the requirements contract with Lake's Crossing that Mr. Bosle=
r speaks of. Mr. Bosler has refused to compensate my choices of evaluators=
or otherwise reimburse me for this second round of competency evaluations =
(a round which was highly surprising considering that Judge Sferrazza refus=
ed to accept the bill from Lake's Crossing after the first competency evalu=
ation=2C particularly where Judge Sferrazza chided DPD Joe Goodnight for se=
eking to withdrawal so soon after insisting upon a competency evaluation. =
Judge Sferrazza sagely pointed out to Goodnight=2C further=2C that convicti=
on would have dire consequences upon Mr. Goodnight's client's law license (=
the crime charge is likely a "serious offense" within the purview of SCR 11=
1)=2C something which Mr. Goodnight was sure to point out he didn't much ca=
re about and didn't consider "part of his job". Mr. Goodnight=2C did=2C ho=
wever=2C take care to point out to his client=2C Coughlin=2C the 'holistic'=
approach that the WCPD likes to take=2C early on in the representation. A=
pparently such a holistic approach does not much take into account the effe=
ct on one's livelihood such a prosecution as this would have should a convi=
ction be had.
What=2C perhaps=2C is most disturbing about this case=2C ho=
wever=2C is the fact that video and audio evidence exists proving that this=
was a wrongful arrest and that the material witness is a liar=2C and that =
a retaliatory motive was displayed throughout the arrest=2C and that perhap=
s=2C an extortionate attempt to secure consent to an impermissible search w=
as made by "Officer Dosa" (note to Goodnight=2C please seek to have this c=
ase dismissed based upon the State continually referring to Officer Rosa as=
Officer Dosa in the Complaint=2C perhaps=2C an error that would cause many=
to miss the fact that Officer Rosa was named in a suit=2C in his official =
capacity in 1994=2C something for which Coughlin has requested Goodnight an=
d the WCPD look into=2C but for which no research on the part of the WCPD h=
as been undertaken....) http://www.youtube.com/watch?v=3D5PR7q4OI5b0
Well=2C then there is the fact that the investigator for DDA Young suggeste=
d pursuing a "intimidating a witness" charge against the investigator for t=
he defendant merely because the defendant's investigator caught the State's=
star material witness=2C Nate Zarate=2C who is a liar=2C attempting to int=
imidate one Nicole Watson=2C who admitted to the investigator=2C on tape=2C=
that Zarate's version of the events of the arrest of 8/20/11 were inaccura=
te when she revealed that she herself witnessed the unidentified man hold t=
he iphone aloft=2C and exclaim to the denizens of the Cal-Nevada ice-rink s=
kate plaza=2C that he would "throw this iphone in the river if someone does=
n't claim it right away...."=2C which of course completely contradicts Zara=
te's telling Officer Duralde that he witnessed Coughlin grab the phone off =
the concret ledge and walk away with it.....lies=2C lies=2C lies=2C Zarate.=
Further lying is Mr. Goble=2C allegedly the phone's owner=2C who claims =
he was a mere 15 feet away from his phone=2C yet=2C someone=2C he didn't he=
ar this unidentified man hold the phone aloft and announce to everyone in t=
he skate plaze=2C in a loud=2C booming voice=2C that he would "throw this p=
hone in the river if someone doesn't claim it right away".... http://www.y=
outube.com/watch?v=3Dto_UOFIccLw
What is interesting=2C is that=2C if the Reno City Attorney's office recent=
ly refused to provide RMC defender Keith Loomis a copy of the cd propounded=
to Coughlin's previous defender Roberto Puentes=2C because=2C according to=
the Reno City Attorney's Office=2C it "cost them $200 to have a copy of a =
cd made=2C they have to send it out=2C blah=2C blah=2C blah..."..then just =
how much money is Lake's Crossing getting paid to do these competency evalu=
ations?
Could this be the same reason that the City of Reno does not list the cost =
it pays for employees health care benefits when reporting its budget? Lets=
001102
take RPD Sargent Tarter=2C for instance=2C whom Coughlin was cross examing=
about an admission of bribery of the Reno PD involving local attorney Rich=
ard G. Hill=2C Esq. (in the context of examining whether Sargent Tarter's t=
raffic citations were based in a retaliatory motive)=2C shortly before RMC =
Judge Nash Holmes seized Coughlin's smartphone and 32gb micro sd card=2C in=
a traffic citation trial=2C 11 TR 26800=2C and ordered local attorney Coug=
hlin to spend 5 days in jail (prejudice to his client's cases be damned) in=
cident to a summary contempt finding...
http://www.transpa.com/sarentnevada.com/salaries/2011/reno/john-tarter/
"The City of Reno failed to report the cost of employee health care=20
benefits. Only the cost of retirement benefits is included within the=20
"Benefits" category for this jurisdiction."
http://www.transparentnevada.com/salaries/2009/reno/john-tarter/
DDA Young and Halstead were copied on this to avoid an appearance of ex par=
te communciations=2C though RJC Court Administrator requested this writing=
=2C and though no RJC Judge is copied hereon...
Sincerely=2C
Sincerely=2C
8118=2C fax: 949 667 7402=3B ZachCoughlin@hotmail.com
Nevada Bar No: 947=
3
To: jbosler@washoecounty.us=3B loodew@hotmail.com=3B billdavis@lakes.nv.gov=
=3B sfarmer@lakes.nv.gov=3B stermitz@sbcglobal.net=3B jgoodnight@washoecoun=
ty.us=3B oliverocskay@yahoo.com
Subject: CHANGE OF ADDRESS Goodnight speedy trial motion? and RE: Dogan's=
"workin' construction" commentary
Date: Mon=2C 16 Apr 2012 21:42:12 -0700
Mr. Bosler=2C=20
Thank you for your response. Actually=2C in at least one of the Orders for=
Competency Evaluation=2C I saw that the only mention of Lake's Crossing wa=
s something scrawled out in handwriting atop the Order.
Are you sure it w=
as the "Court" that ordered I utilize only Lake's Crossing? Wouldn't that =
be a bit untoward for a court to insist I utilize only one entity when a st=
atute specifies merely that I must utilize an individual with a certain cer=
tification. I realize that is pretty much the business model of the public=
defenders office=2C it=2C a court agreeing to provide a counsel=2C but the=
n insisting that the defendant may only receive paid representation if the =
defendant utilizes the attorney provided by the public defender's office (t=
hough=2C see Widdis v. Second Judicial District Court for a counterpoint to=
that)=2C but I am not sure that approach extends all the way to competency=
evaluations.
Can you clarify that=2C indeed=2C it is "the Court" insisti=
ng I utilize Lake's Crossing for the evaluation=2C and not just that that i=
s your wish given your requirements contract with Lakes? Further=2C I real=
ly would appreciate a written response from you as to how Dogan's asking me=
if I was currently "workin' construction" while sneeringly looking me up a=
nd down was at all appropriate.
I have never received this supposed Order for Competency Evaluation in the =
matter Dogan is attorney of record on. I have requested Dogan send me a co=
py of my file=2C yet I have not received one. Please email or fax me a cop=
y of my file in the matter Dogan is appearing on as well as in the matter G=
oodnight is appearing in. Mr. Tuttle has refused to provide me those mater=
ials=2C especially the newer filings. Mr. Tuttle=2C please let this writin=
g serve as my request that you provide me a copy of all materials new to ei=
ther file since last I ventured into the RJC Criminal Division filing offic=
e=2C (an dealt with all the harrasment by RJC Bailiff John Reyes=2C he of t=
he "I am going to put my foot up your ass" sexual assault committed upon me=
in full view of Washoe County Public Defender's Jim Leslie and Joe Goodnig=
ht=2C whom each did nothing whatsoever).
Mr. Goodnight=2C the "Go Trial" date in the matter you are attorney of reco=
rd on fast approaches. I have asked for you to make several filings on my =
behalf=2C and yet=2C I have not heard from you. Please update me in writin=
001103
g with respect to all those requests=2C including=2C but not limited to=2C =
the Sixth Amendment Right to A Speedy Trial Motion to Dismiss that I have r=
equested you file based upon the State's failure to appropriately arraign m=
e on the amended charge=2C as well as subpoening Nicole Watson=2C Rob Dawso=
n=2C Lucy Byington=2C et al=2C and explaining your dumbfounding decision to=
subpoena Colton Templeton before any of those individuals.
Please identi=
fy and or disclose the video and audio materials to be put forth at trial=
=2C especially the one where Nicole Watson admits to hearing the man say he=
would "throw the phone in the river"=2C you know=2C the one where the Stat=
e's star witness=2C Nate Zarate=2C quickly seeks to dissuade Nicole Watson =
from making any further statements that show Zarate to be the liar and untr=
ustworthy witness that he is? That one.
Further=2C Ms. Pelosi from Lake's Crossing has made statements similar to t=
hose made by Mr. Bosler=2C with respect to the public being forced to send =
business Lake's Crossing's way anytime a competency evaluation is ordered. =
I would appreciate a response from a supervisor at Lake's Crossign with r=
espect to why the evaluation was not conducted when I presented on time las=
t Thursday=2C and as to the anti-trust matters referenced herein.
I realize Mr. Bosler was chosen to be the Public Defender in large part bec=
ause District Attorney Gammick approved of Mr. Bosler=2C but I would still =
like some zealous representation here:
http://www.newsreview.com/reno/new-defender/content?oid=3D24938
Further=2C I realize my being a National Merit Finalist=2C passing the bar =
examination after my second year of law school=2C being ranked in the top 1=
0 in my law school class=2C being a licensed patent attorney=2C have extrem=
ely deep ties to the community I spent the last 32 years in and where my en=
tire family resides=2C having litigation experience=2C and repeatedly apply=
ing for a position with the Washoe County Public Defender's Office was not =
enough to get me much considered for an interview=2C but hopefully those at=
tributes will not prevent me from getting some zealous advocacy too=2C here=
.
Sincerely=2C
8118=2C fax: 949 667 7402=3B ZachCoughlin@hotmail.com
Nevada Bar No: 947=
3
Subject: RE: Dogan's "workin' construction" commentary
Date: Wed=2C 11 Apr 2012 13:45:37 -0700
From: JBosler@washoecounty.us
CC: BDogan@washoecounty.us
Zach=2C
=20
The procedures regarding competency evaluations are=20
found in NRS 178.3981=2C et seq. Under NRS 178.415=2C the Court appoints th=
e=20
persons who are to conduct the evaluation. Those persons must be=20
certified by the Department of Health and Human Services. NRS=20
178.417.
=20
The court has ordered you to complete the evaluation=20
through Lake's Crossing. They are required to provide certified evaluator=20
and provide a copy of the report to the court. The Public Defender's Office=
will=20
not be providing monies for an evaluation by an outside psychologist or=20
psychiatrist.=20
=20
Again=2C I encourage you to cooperate with=20
Lake's. Failure to do so may result in sanctions by the=20
court.
=20
Thank you in advance for your=20
cooperation.
=20
001104
Jeremy Bosler=20
Washoe County Public=20
Defender=20
350 South=20
Center Street=2C 5th Floor=20
PO Box 30083=20
Reno=2C NV 89520-3083=20
775-337-4823=20
jbosler@washoecounty.us=20
**=20
Notice** This=20
message and accompanying documents are covered by the electronic Communicat=
ions=20
Privacy Act=2C 18 U.S.C. =A7=A7 2510-2521=2C and may contain confidential i=
nformation=20
intended for the specified individual (s) only. If you are not the intended=
=20
recipient or an agent responsible for delivering it to the intended recipie=
nt=2C=20
you are hereby notified that you have received this document in error and t=
hat=20
any review=2C dissemination=2C copying=2C or the taking of any action based=
on the=20
contents of this information is strictly prohibited.=20
=20
=20
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]=20

Sent: Tuesday=2C April 10=2C 2012 4:49 PM
To: Bosler=2C=20
Jeremy
Subject: RE: Dogan's "workin' construction"=20
commentary
Mr.=20
Bosler=2C
Must I utilize Lake's Crossing for the evaluation or can I have=20
an outside psychologist and psychiatrist perform the evaluations and will t=
he=20
WCPD reimburse them if that is allowable. Please respond in writing with=20
citations to authority.
Sincerely
Zach Coughlin=2C Esq.=2C=20
PO BOX 60952=2C RENO=2C NV=2C 89506=2C tel: 775 338=20
8118=2C fax: 949 667 7402=3B=20
Nevada Bar No: 9473
> Subject: Dogan's "workin' construction"=20

commentary=20
> Date: Tue=2C 10 Apr 2012 10:02:41 -0700
> From:=20
JBosler@washoecounty.us
>=20
>=20
> Zach=2C
>=20
> I spoke with Biray and he told me that he was=20
surprised by your appearance. He said your clothes were dirty and you appea=
red=20
as if you hadn't showered. He was concerned that other people=2C including =
the=20
courts and Lake's Crossing personnel=2C might find that unusual (for a lice=
nsed=20
001105
attorney to present in such a way). Nothing more.

>=20
> I would also=20
encourage you to contact Lake's and get the evaluation completed.=20
>=20
>=20
>=20
> Jeremy Bosler
> Washoe County Public=20
Defender
> 350 South Center Street=2C 5th Floor
> PO Box 30083
>=20
Reno=2C NV 89520-3083
> 775-337-4823
> jbosler@washoecounty.us
>=20
> ** Notice** This message and accompanying documents are covered by the=20
electronic Communications Privacy Act=2C 18 U.S.C. =A7=A7 2510-2521=2C and =
may contain=20
confidential information intended for the specified individual (s) only. If=
you=20
are not the intended recipient or an agent responsible for delivering it to=
the=20
intended recipient=2C you are hereby notified that you have received this d=
ocument=20
in error and that any review=2C dissemination=2C copying=2C or the taking o=
f any=20
action based on the contents of this information is strictly prohibited.=20
>=20
>=20
>=20
>=20
>=20
>=20
> -----Original=20
Message----> From: Zach Coughlin=2CEsq.=20
[mailto:zachcoughlin@hotmail.com]
> Sent: Monday=2C April 09=2C 2012 9:33=20
PM
> To: Dogan=2C Biray=3B Bosler=2C Jeremy
> Subject: Dogan's "workin'=20
construction" commentary
>=20
> Please explain
>=20
>=20
"Dogan=2C Biray" <BDogan@washoecounty.us> wrote:
>=20
> >Mr.=20
Coughlin=2C here is the email that Lake's Crossing sent to me. Please sched=
ule=20
your evaluations soon. Your Court date is set on April=2C 19th at 8:30 a.m.=
=20
> >
> >________________________________
> >
>=20
>From: Lorraine M. Pelosi [mailto:lmpelosi@lakes.nv.gov]
> >Sent:=20
Friday=2C April 06=2C 2012 4:27 PM
> >To: Dogan=2C Biray
> >Subject:=20
Client Contact
> >
> >
> >=20
> >
>=20
>Mr. Dogan=2C
> >
> >=20
> >
> >Lake's=20
Crossing Center has been having some issues with your client=2C Zachary Cou=
ghlin=20
001106
with regard to him emailing the psychologists to make an appointment. If yo=

u=20
would please instruct your client to contact me=2C Lorraine Pelosi to sched=
ule his=20
appointment it would be appreciated. I have called Mr. Coughlin and left a=
=20
message with two available dates for an appointment and rather than return =
my=20
call he emailed Dr. Farmer stating phone problems. Thank you for your assis=
tance=20
in this matter.
> >
> >=20
> >
> >Lorraine=20
Pelosi=2C AA IV
> >
> >Lake's Crossing Center
>=20
>
> >500 Galletti Way
> >
> >Sparks=2C NV=20
89431
> >
> >775 688-1900 ext. 228
> >
>=20
>775 688-1909 Fax
> >
> >lmpelosi@lakes.nv.gov
>=20
>
> >=20
> >
> >=20
> >
> >This=20
ions=20
nformation=20
intended for the specified individual(s) only. If you are not the intended=
=20
nt=2C=20
hat=20
on the=20
contents of this information is strictly prohibited. If you have received t=
his=20
communication in error=2C please notify us immediately by E-mail=2C and del=
ete the=20
original message.
> >
> >=20
> >
>=20
=
--_07cfdc78-89af-41fb-b385-c0bb8e0dd8d9_
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001107

id=3D"ecxFontBreak">
Dear=
Mr. Tuttle et al=2C Please accept this writing as the correspondenc=
e you requested from me.&nbsp=3B I have not received any of the filings fro=
m either the DA or the PD since last I visited the RJC Criminal Division fi=
ling office and requested copies of everything in the file.&nbsp=3B My reco=
rds indicate that that last visit (and I am referring to visits where I was=
allowed to receive such copies only) was approximately approximately Febru=
ary 20th=2C 2012 (though I am sure Nefi will have notated when last I was i=
n there and provided copies=2C as he is very conscientious and thorough=2C =
a real credit to the Criminal Division Filing Office).&nbsp=3B I ha=
ve had some difficulties lately with the USPS delivering my mail.&nbsp=3B S=
ome=2C like the 3/13/12 letter from the RJC Civil Division=2C did in fact=
=2C ultimately make it to me=2C in accordance with the Change of Address I =
filed with the USPS.&nbsp=3B&nbsp=3B Other pieces of mail=2C such as a 3/14=
/12 mailing from the Reno Municipal Court=2C were ultimately returned to th=
e RMC.&nbsp=3B With respect to any court documents=2C correspondence=2C or =
court filings in matters for which Biray Dogan is attached=2C I have receiv=
ed nothing in the mail=2C and I am pretty sure I have not received a copy o=
f any such matters via fax or email (despite my numerous written please to =
Mr. Dogan et al at the WCPD=2C wherein I set forth the interference with my=
mail and concomitant struggles with the USPS that ensued incident to my be=
ing adjudge a vicdtim of domestic violence in FV12-00188 and FV12-00187=2C =
in addition to the malfeasance of the landlord and its agents in RJC Rev201=
2-000374. So=2C my please to the WCPD (Dogan and Goodnight) that I b=
e copied via fax and email on all documentation=2C filings=2C etc. having g=
one unresponded to (though I believe Mr. Goodnight=2C to his credit=2C has =
actually done so one or twice=2C in addition to phoning me while I was in j=
ail incident to a summary contempt finding by Judge Nash Holmes=2C which re=
sulted in my smart phone being seized incident to the summary contempt arre=
st=2C and it and a 32gb micro sd card being returned to me only 38 days lat=
er=2C with the contents of the micro sd card having been erased....and only=
after the WCSO refused to comply with the RMC Order of 3/30/12=2C but rath=
er pass me off to Mary Kandaras=2C of the District Attorney's Office=2C whi=
ch brings up the point=2C I feel yet another conflict now exists requiring =
the Districtd Attorney's office to withdraw from this prosecution=2C given =
the ultra suspicious circumstances of the seizing of this micro sd card and=
smartphone=2C the prolonged detention thereof=2C and the suspicious erasur=
e of its contents=2C particularly in the context of the WCSO stalling the r=
eturning thereof with directions to contact Mary Kandaras=2C especially whe=
re "Matty" of the WCSO front desk refused to tell me whom gave here those i=
nstructions to pass along=2C but rather=2C where "Matty" responded by havin=
g Deputy Beatson track me down outside and threaten me with malicious prose=
cution and retaliatory arrest and where he threatened to completely fabrica=
te a "distrubing the peace" charge merely in an attempt to confiscate the n=
etbook I had in my hands=2C presumbaly so the WCSO could seize that item to=
o for some 38 days only to return it with the hard drive wiped. So=
=2C anyways=2C yes=2C please Mr. Tuttle=2C please accept this writing as th=
e request for copies of court filings that you asked me to provide you give=
n the failure of Mr. Goodnight (to some extent) and Mr. Dogan (to every ext=
ent) to either mail me copies=2C and or to alert me to the fact that they r=
eceived any such mailing back from the USPS as "undeliverable" or otherwise=
. Lastly=2C Mr. Tuttle=2C I will point out (given the interest you e=
xpressed in my disatisfacdtion with how these competency evaluation Orders =
were being procured) that not only does the file in many matters indicate s=
uch an Order was rendered after a "hearing" and upon a "motion by the defen=
dant's counsel" (where no "hearing" took place=2C and where no "motion" was=
ever filed"....can't have an oral motion if there was not actual hearing..=
.can't make oral motions to the filing office counter=2C corner cut=2C corn=
er cut=2C tsk...tsk...)_but now=2C at least according to Mr. Bosler=2C whom=
was hand picked=2C at least in part=2C by District Attorney Gammick (whom =
did invite me back for a follow up to my interview=2C to offer some advice=
=2C a classy and thoughtful gesture to be sure) <a href=3D"http://www.n=
ewsreview.com/reno/new-defender/content?oid=3D24938" class=3D"ecx" target=
=3D"_blank">http://www.newsreview.com/reno/new-defender/content?oid=3D24938=
</a> =2C "the Court" i=
tself is insisting I utilize only that entity that the Washoe County Public=
Defender has a requirements contract with=2C Lake's Crossing=2C to perform=
a competency evaluation for which the statutory requirements only consist =
of certain certifications and licensures being required of those performing=
the evaluations=2C and which say nothing of the requirements contract with=
Lake's Crossing that Mr. Bosler speaks of.&nbsp=3B Mr. Bosler has refused to compensate my choic=
es of evaluators or otherwise reimburse me for this second round of compete=
ncy evaluations (a round which was highly surprising considering that Judge=
Sferrazza refused to accept the bill from Lake's Crossing after the first =
competency evaluation=2C particularly where Judge Sferrazza chided DPD Joe =
Goodnight for seeking to withdrawal so soon after insisting upon a competen=
cy evaluation.&nbsp=3B Judge Sferrazza sagely pointed out to Goodnight=2C f=
001108
urther=2C that conviction would have dire consequences upon Mr. Goodnight's=
client's law license (the crime charge is likely a "serious offense" withi=
n the purview of SCR 111)=2C something which Mr. Goodnight was sure to poin=
t out he didn't much care about and didn't consider "part of his job".&nbsp=
=3B Mr. Goodnight=2C did=2C however=2C take care to point out to his client=
=2C Coughlin=2C the 'holistic' approach that the WCPD likes to take=2C earl=
y on in the representation.&nbsp=3B Apparently such a holistic approach doe=
s not much take into account the effect on one's livelihood such a prosecut=
ion as this would have should a conviction be had.&nbsp=3B&nbsp=3B What=2C =
perhaps=2C is most disturbing about this case=2C however=2C is the fact tha=
t video and audio evidence exists proving that this was a wrongful arrest a=
nd that the material witness is a liar=2C and that a retaliatory motive was=
displayed throughout the arrest=2C and that perhaps=2C an extortionate att=
empt to secure consent to an impermissible search was made by "Officer Dosa=
"&nbsp=3B (note to Goodnight=2C please seek to have this case dismissed bas=
ed upon the State continually referring to Officer Rosa as Officer Dosa in =
the Complaint=2C perhaps=2C an error that would cause many to miss the fact=
that Officer Rosa was named in a suit=2C in his official capacity in 1994=
=2C something for which Coughlin has requested Goodnight and the WCPD look =
into=2C but for which no research on the part of the WCPD has been undertak=
en....)&nbsp=3B <a href=3D"http://www.youtube.com/watch?v=3D5PR7q4OI=
5b0" class=3D"ecx" target=3D"_blank">http://www.youtube.com/watch?v=3D5PR7q=
4OI5b0</a> Well=2C then there is the fact that the investigator for =
DDA Young suggested pursuing a "intimidating a witness" charge against the =
investigator for the defendant merely because the defendant's investigator =
caught the State's star material witness=2C Nate Zarate=2C who is a liar=2C=
attempting to intimidate one Nicole Watson=2C who admitted to the investig=
ator=2C on tape=2C that Zarate's version of the events of the arrest of 8/2=
0/11 were inaccurate when she revealed that she herself witnessed the unide=
ntified man hold the iphone aloft=2C and exclaim to the denizens of the Cal=
-Nevada ice-rink skate plaza=2C that he would "throw this iphone in the riv=
er if someone doesn't claim it right away...."=2C which of course completel=
y contradicts Zarate's telling Officer Duralde that he witnessed Coughlin g=
rab the phone off the concret ledge and walk away with it.....lies=2C lies=
=2C lies=2C Zarate.&nbsp=3B&nbsp=3B Further lying is Mr. Goble=2C allegedly=
the phone's owner=2C who claims he was a mere 15 feet away from his phone=
=2C yet=2C someone=2C he didn't hear this unidentified man hold the phone a=
loft and announce to everyone in the skate plaze=2C in a loud=2C booming vo=
ice=2C that he would "throw this phone in the river if someone doesn't clai=
m it right away"....&nbsp=3B <a href=3D"http://www.youtube.com/watch?v=3Dto=
_UOFIccLw" class=3D"ecx" target=3D"_blank">http://www.youtube.com/watch?v=
=3Dto_UOFIccLw</a> What is interesting=2C is that=2C if the Reno Cit=
y Attorney's office recently refused to provide RMC defender Keith Loomis a=
copy of the cd propounded to Coughlin's previous defender Roberto Puentes=
=2C because=2C according to the Reno City Attorney's Office=2C it "cost the=
m $200 to have a copy of a cd made=2C they have to send it out=2C blah=2C b=
lah=2C blah..."..then just how much money is Lake's Crossing getting paid t=
o do these competency evaluations? Could this be the same reason=
that the City of Reno does not list the cost it pays for employees health =
care benefits when reporting its budget?&nbsp=3B Lets take RPD Sargent Tart=
er=2C for instance=2C whom Coughlin was cross examing about an admission of=
bribery of the Reno PD involving local attorney Richard G. Hill=2C Esq. (i=
n the context of examining whether Sargent Tarter's traffic citations were =
based in a retaliatory motive)=2C shortly before RMC Judge Nash Holmes seiz=
ed Coughlin's smartphone and 32gb micro sd card=2C in a traffic citation tr=
ial=2C 11 TR 26800=2C and ordered local attorney Coughlin to spend 5 days i=
n jail (prejudice to his client's cases be damned) incident to a summary co=
ntempt finding... <a href=3D"http://www.transparentnevada.com/salaries/2011=
/reno/john-tarter/" class=3D"ecx" target=3D"_blank">http://www.transpa.com/=
sarentnevada.com/salaries/2011/reno/john-tarter/</a> "The City of Reno failed to repor=
t the cost of employee health care=20
benefits. Only the cost of retirement benefits is included within the=20
"Benefits" category for this jurisdiction." <a href=3D"http://www.transpare=
ntnevada.com/salaries/2009/reno/john-tarter/" class=3D"ecx" target=3D"_blan=
k">http://www.transparentnevada.com/salaries/2009/reno/john-tarter/</a> =
 DDA Young and Halstead were copied on this to avoid an appea=
rance of ex parte communciations=2C though RJC Court Administrator requeste=
d this writing=2C and though no RJC Judge is copied hereon... Sincer=
ely=2C Sincerely=2C Zach Coughlin=2C Esq.=2C PO BOX 3961=2C RENO=2C NV=
=2C 89505=2C tel: 775 338 8118</f=
ont>=2C fax: 949 667 7402=3B Zach=
Coughlin@hotmail.com&nbsp=3B&nbsp=3B Nevada Bar No: 9473<s=
pan lang=3D"en-us"><strong=
></s=
001109
trong> <div><div id=3D=
"ecxSkyDrivePlaceholder"></div><hr id=3D"ecxstopSpelling">From: zachcoughli=
n@hotmail.com To: jbosler@washoecounty.us=3B loodew@hotmail.com=3B billd=
avis@lakes.nv.gov=3B sfarmer@lakes.nv.gov=3B stermitz@sbcglobal.net=3B jgoo=
dnight@washoecounty.us=3B oliverocskay@yahoo.com Subject: CHANGE OF ADDR=
ESS Goodnight speedy trial motion? and RE: Dogan's "workin' construction"=
commentary Date: Mon=2C 16 Apr 2012 21:42:12 -0700 
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<div dir=3D"ltr">
Mr. =
Bosler=2C Thank you for your response.&nbsp=3B Actually=2C in at le=
ast one of the Orders for Competency Evaluation=2C I saw that the only ment=
ion of Lake's Crossing was something scrawled out in handwriting atop the O=
rder.&nbsp=3B&nbsp=3B Are you sure it was the "Court" that ordered I utiliz=
e only Lake's Crossing?&nbsp=3B Wouldn't that be a bit untoward for a court=
to insist I utilize only one entity when a statute specifies merely that I=
must utilize an individual with a certain certification.&nbsp=3B I realize=
that is pretty much the business model of the public defenders office=2C i=
t=2C a court agreeing to provide a counsel=2C but then insisting that the d=
efendant may only receive paid representation if the defendant utilizes the=
attorney provided by the public defender's office (though=2C see Widdis v.=
Second Judicial District Court for a counterpoint to that)=2C but I am not=
sure that approach extends all the way to competency evaluations.&nbsp=3B&=
nbsp=3B Can you clarify that=2C indeed=2C it is "the Court" insisting I =
utilize Lake's Crossing for the evaluation=2C and not just that that is=
your wish given your requirements contract with Lakes?&nbsp=3B Further=2C =
I really would appreciate a written response from you as to how Dogan's ask=
ing me if I was currently "workin' construction" while sneeringly looking m=
e up and down was at all appropriate. I have never received this sup=
posed Order for Competency Evaluation in the matter Dogan is attorney of re=
cord on.&nbsp=3B I have requested Dogan send me a copy of my file=2C yet I =
have not received one.&nbsp=3B Please email or fax me a copy of my file in =
the matter Dogan is appearing on as well as in the matter Goodnight is appe=
aring in.&nbsp=3B Mr. Tuttle has refused to provide me those materials=2C e=
specially the newer filings.&nbsp=3B Mr. Tuttle=2C please let this writing =
serve as my request that you provide me a copy of all materials new to eith=
er file since last I ventured into the RJC Criminal Division filing office=
=2C (an dealt with all the harrasment by RJC Bailiff John Reyes=2C he of th=
e "I am going to put my foot up your ass" sexual assault committed upon me =
in full view of Washoe County Public Defender's Jim Leslie and Joe Goodnigh=
t=2C whom each did nothing whatsoever). Mr. Goodnight=2C the "Go Tri=
al" date in the matter you are attorney of record on fast approaches.&nbsp=
=3B I have asked for you to make several filings on my behalf=2C and yet=2C=
I have not heard from you.&nbsp=3B Please update me in writing with respec=
t to all those requests=2C including=2C but not limited to=2C the Sixth Ame=
ndment Right to A Speedy Trial Motion to Dismiss that I have requested you =
file based upon the State's failure to appropriately arraign me on the amen=
ded charge=2C as well as subpoening Nicole Watson=2C Rob Dawson=2C Lucy Byi=
ngton=2C et al=2C and explaining your dumbfounding decision to subpoena Col=
ton Templeton before any of those individuals.&nbsp=3B&nbsp=3B Please ident=
ify and or disclose the video and audio materials to be put forth at trial=
=2C especially the one where Nicole Watson admits to hearing the man say he=
would "throw the phone in the river"=2C you know=2C the one where the Stat=
e's star witness=2C Nate Zarate=2C quickly seeks to dissuade Nicole Watson =
from making any further statements that show Zarate to be the liar and untr=
ustworthy witness that he is?&nbsp=3B That one. Further=2C Ms. Pelos=
i from Lake's Crossing has made statements similar to those made by Mr. Bos=
ler=2C with respect to the public being forced to send business Lake's Cros=
sing's way anytime a competency evaluation is ordered.&nbsp=3B&nbsp=3B I wo=
uld appreciate a response from a supervisor at Lake's Crossign with respect=
to why the evaluation was not conducted when I presented on time last Thur=
sday=2C and as to the anti-trust matters referenced herein. I realiz=
e Mr. Bosler was chosen to be the Public Defender in large part because Dis=
trict Attorney Gammick approved of Mr. Bosler=2C but I would still like som=
e zealous representation here: <a href=3D"http://www.newsreview.com/reno/new-defender/content?=
oid=3D24938" class=3D"ecxnewlyinsertedlink" target=3D"_blank">http://www.ne=
wsreview.com/reno/new-defender/content?oid=3D24938</a> Fu=
rther=2C I realize my being a National Merit Finalist=2C passing the bar ex=
amination after my second year of law school=2C being ranked in the top 10 =
in my law school class=2C being a licensed patent attorney=2C have extremel=
001110
y deep ties to the community I spent the last 32 years in and where my enti=
re family resides=2C having litigation experience=2C and repeatedly applyin=
g for a position with the Washoe County Public Defender's Office was not en=
ough to get me much considered for an interview=2C but hopefully those attr=
ibutes will not prevent me from getting some zealous advocacy too=2C here.<=
/font> Sincerely=2C <font=
style=3D"" face=3D"Times New Roman">Zach Coughlin=2C Esq.=2C PO BOX=
3961=2C RENO=2C NV=2C 89505=2C t=
el: 775 338 8118=2C fax: 9=
49 667 7402=3B ZachCoughlin@hotmail.com&nbsp=3B&nbsp=3B Nevada Bar No: 9473=
<=
i> <=
br><div><div id=3D"ecxSkyDrivePlaceholder"></div><hr id=3D"ecxstopSpelling"=
>Subject: RE: Dogan's "workin' construction" commentary Date: Wed=2C 11 =
Apr 2012 13:45:37 -0700 From: JBosler@washoecounty.us To: zachcoughli=
n@hotmail.com CC: BDogan@washoecounty.us 
<style>
.ExternalClass .ecxhmmessage P
{padding-right:0px=3Bpadding-left:0px=3Bpadding-bottom:0px=3Bpadding-top:0p=
x=3B}
.ExternalClass BODY.ecxhmmessage
{font-size:10pt=3Bfont-family:Tahoma=3B}
</style>
<div dir=3D"ltr" align=3D"left"><spa=

n class=3D"ecx507452920-11042012">Zach=2C</div>
n class=3D"ecx507452920-11042012">&nbsp=3B</div>
n class=3D"ecx507452920-11042012">The procedures regarding competency evalu=
ations are=20
found in&nbsp=3BNRS 178.3981=2C et seq. Under NRS 178.415=2C the Court appo=
ints the=20
persons who are to conduct the evaluation. Those persons must be=20
certified&nbsp=3Bby the Department of Health and Human Services.&nbsp=3B NR=
S=20
178.417.</div>
n class=3D"ecx507452920-11042012">&nbsp=3B</d=
iv>
n class=3D"ecx507452920-11042012">The court has ordered you to complete the=
evaluation=20
through Lake's Crossing. They are required to provide certified&nbsp=3Beval=
uator=20
and provide a copy of the report to the court. The Public Defender's Offi=
ce will=20
not be providing monies for an evaluation by an outside psychologist or=20
psychiatrist. </div>
n class=3D"ecx507452920-11042012">Again=2C I&nbsp=3Bencourage you to cooper=
ate with=20
Lake's.&nbsp=3BFailure to do so may result in sanctions by the=20
court.</div>
n class=3D"ecx507452920-11042012">Thank you in advance for your=20
cooperation.</div>
n class=3D"ecx507452920-11042012">
Jeremy Bosler</=
span>=20
 Washoe County Publ=
ic=20
001111
Defender 350 South=20
Center Street=2C 5th Floor PO Box 30083 =
Reno=2C NV 89520-3083 <sp=
an lang=3D"en-us">775-337-4823</span=
> <a href=3D"mailto:jbosler@washoecounty.us=
">jbosler@washoecounty.us</a> =
 
**=20
Notice** This=20
ions=20
nformation=20
intended for the specified individual (s) only. If you are not the intended=
=20
nt=2C=20
hat=20
on the=20
contents of this information is strictly prohibited.=20
 &nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B&nbsp=3B</=
div>
n class=3D"ecx507452920-11042012">&nbsp=3B</div><=
/font> 
<div class=3D"ecxOutlookMessageHeader" dir=3D"ltr" align=3D"left" lang=3D"e=
n-us">
<hr tabindex=3D"-1">
From: Zach Coughlin [mailto:zachcoughlin@hotma=
il.com]=20
 Sent: Tuesday=2C April 10=2C 2012 4:49 PM To: Bosler=
=2C=20
Jeremy Subject: RE: Dogan's "workin' construction"=20
commentary </div>
<div></div>
<div dir=3D"ltr">Mr.=20
Bosler=2C Must I utilize Lake's Crossing for the evaluation or can I=
have=20
an outside psychologist and psychiatrist perform the evaluations and will t=
he=20
WCPD reimburse them if that is allowable.&nbsp=3B Please respond in writing=
with=20
citations to authority. Sincerely </f=
ont> Zach Coughlin=2C Esq.=2C=20
PO BOX 60952=2C RENO=2C NV=2C 89506=
=2C tel: 775 338=20
8118=2C fax: 949 667 7402=3B=20
ZachCoughlin@hotmail.com&nbsp=3B&nbsp=3B Nevada Bar No: 9473<str=
ong><stron=
g> 
<div>
<div id=3D"ecxSkyDrivePlaceholder"></div>&gt=3B Subject: Dogan's "workin' c=
onstruction"=20
commentary &gt=3B Date: Tue=2C 10 Apr 2012 10:02:41 -0700 &gt=3B Fro=
m:=20
JBosler@washoecounty.us &gt=3B To: zachcoughlin@hotmail.com &gt=3B <b=
r>&gt=3B=20
 &gt=3B Zach=2C &gt=3B &gt=3B I spoke with Biray and he told me t=
hat he was=20
surprised by your appearance. He said your clothes were dirty and you appea=
red=20
as if you hadn't showered. He was concerned that other people=2C including =
the=20
courts and Lake's Crossing personnel=2C might find that unusual (for a lice=
nsed=20
attorney to present in such a way). Nothing more. &gt=3B &gt=3B I wo=
uld also=20
encourage you to contact Lake's and get the evaluation completed. &gt=
=3B=20
001112
 &gt=3B &gt=3B &gt=3B Jeremy Bosler &gt=3B Washoe County Publ=

ic=20
Defender &gt=3B 350 South Center Street=2C 5th Floor &gt=3B PO Box 30=
083 &gt=3B=20
Reno=2C NV 89520-3083 &gt=3B 775-337-4823 &gt=3B jbosler@washoecounty=
.us &gt=3B=20
 &gt=3B ** Notice** This message and accompanying documents are covered =
by the=20
electronic Communications Privacy Act=2C 18 U.S.C. =A7=A7 2510-2521=2C and =
may contain=20
confidential information intended for the specified individual (s) only. If=
you=20
are not the intended recipient or an agent responsible for delivering it to=
the=20
intended recipient=2C you are hereby notified that you have received this d=
ocument=20
in error and that any review=2C dissemination=2C copying=2C or the taking o=
f any=20
action based on the contents of this information is strictly prohibited.=20
 &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=
=3B -----Original=20
Message----- &gt=3B From: Zach Coughlin=2CEsq.=20
[mailto:zachcoughlin@hotmail.com] &gt=3B Sent: Monday=2C April 09=2C 201=
2 9:33=20
PM &gt=3B To: Dogan=2C Biray=3B Bosler=2C Jeremy &gt=3B Subject: Doga=
n's "workin'=20
construction" commentary &gt=3B &gt=3B Please explain &gt=3B =
&gt=3B=20
"Dogan=2C Biray" &lt=3BBDogan@washoecounty.us&gt=3B wrote: &gt=3B &g=
t=3B &gt=3BMr.=20
Coughlin=2C here is the email that Lake's Crossing sent to me. Please sched=
ule=20
your evaluations soon. Your Court date is set on April=2C 19th at 8:30 a.m.=
=20
 &gt=3B &gt=3B &gt=3B &gt=3B________________________________ &gt=
=3B &gt=3B &gt=3B=20
&gt=3BFrom: Lorraine M. Pelosi [mailto:lmpelosi@lakes.nv.gov] &gt=3B &gt=
=3BSent:=20
Friday=2C April 06=2C 2012 4:27 PM &gt=3B &gt=3BTo: Dogan=2C Biray &g=
t=3B &gt=3BSubject:=20
Client Contact &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=
=3B &gt=3B &gt=3B=20
&gt=3BMr. Dogan=2C &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &=
gt=3B &gt=3BLake's=20
Crossing Center has been having some issues with your client=2C Zachary Cou=
ghlin=20
with regard to him emailing the psychologists to make an appointment. If yo=
u=20
would please instruct your client to contact me=2C Lorraine Pelosi to sched=
ule his=20
appointment it would be appreciated. I have called Mr. Coughlin and left a=
=20
message with two available dates for an appointment and rather than return =
my=20
call he emailed Dr. Farmer stating phone problems. Thank you for your assis=
tance=20
in this matter. &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=
=3B &gt=3BLorraine=20
Pelosi=2C AA IV &gt=3B &gt=3B &gt=3B &gt=3BLake's Crossing Center =
&gt=3B=20
&gt=3B &gt=3B &gt=3B500 Galletti Way &gt=3B &gt=3B &gt=3B &gt=3BSp=
arks=2C NV=20
89431 &gt=3B &gt=3B &gt=3B &gt=3B775 688-1900 ext. 228 &gt=3B &gt=
=3B &gt=3B=20
&gt=3B775 688-1909 Fax &gt=3B &gt=3B &gt=3B &gt=3Blmpelosi@lakes.nv.g=
ov &gt=3B=20
&gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=
=3B &gt=3B &gt=3BThis=20
ions=20
nformation=20
intended for the specified individual(s) only. If you are not the intended=
=20
nt=2C=20
hat=20
on the=20
contents of this information is strictly prohibited. If you have received t=
001113
his=20
communication in error=2C please notify us immediately by E-mail=2C and del=
ete the=20
original message. &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &gt=3B &g=
t=3B=20
 </div></div></div>
</div></div>
</div></body>
</html>=
--_07cfdc78-89af-41fb-b385-c0bb8e0dd8d9_--
001114
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ZACHARY COUGHLIN CONFLICT CHECK

From: Fortier, Chris (CFortier@washoecounty.us) You moved this message to its current location.
Sent: Mon 2/06/12 3:57 PM
Mr. Coughlin,
My name is Chris C. Fortier. I am an attorney with the Washoe County Public Defenders Office in Reno,
Nevada. It appears that you have a current case with my colleague, Joesph Goodnight. You have a new case that
has been assigned to the felony team/gross misdemeanor team, more specifically, to Mr. Biray Dogan, Esq. There
is some question as to whether a conflict of interest exist with Mr. Dogan. Mr. Dogan claims that he attended
High School with you and as a result a conflict may exist. Do you know Mr. Dogan? How?
If there is a conflict of interest, the case will be assigned to me.
If you have any questions you may contact me at 337-4817.
Thank you,
CHRIS C. FORTIER
WASHOE COUNTY DEPUTY PUBLIC DEFENDER
001115
001116
001117
001118
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subpoena duces tecum for any written notice or any other sort of notice
Sent: Mon 10/29/12 2:56 AM
To: ltibbals@washoecounty.us; lgray@washoecounty.us; bdogan@washoecounty.us
that your office purports to have provided me for the August 6th, 2012 "combo hearing" in rcr2012065630 and rcr2012-067980....you had no problem faxing me somethign similar on or around August
23rd, so, it should be no problem producing any purported written notice (along with an attestation
that such was actually sent to me via any medium at all, which would be contrary to Ms. Gray's
previous indications).
Sincerely,
this is a supboena for my Nov 14th, 2012 hearing in SBN v Coughlin ng12-0205, ng12-0435 and
0434...please comply or be prepared to explain yourself at the hearing.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax 949 667 7402
001120
file:///R|/...EMAIL%20TO%20DOGAN%20AND%20LESLIE%20REGARDING%20GRAY%208%206%2012%20065630%20067980.htm[12/10/2012 3:09:36 PM]
001121
001122
001123
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LITIGATION HOLD NOTICE

Sent: Wed 11/21/12 4:38 PM
To: bdogan@washoecounty.us (bdogan@washoecounty.us); zyoung@da.washoecounty.us
(zyoung@da.washoecounty.us); jgoodnight@washoecounty.us (jgoodnight@washoecounty.us);
stuttle@washoecounty.us (stuttle@washoecounty.us)
candor to the tribunals, boys...check that cert of service on ol' Leslie Tibals 11/7/12
faxing to Coughlin at 949 667 7402...one, fax to coughlin not sufficient service...two,
she didn't fax anything to coughlin, three, certificate of service does not mention it
being served on DDA Young...yet DDA Young had it at the 11/19/12 Trial date in
RR2011-063341 (the one where his only "proof" as to the identity or nature of the
thing allegedly stolen was some "veripic" thing that he DDA Young took directly out
of the police report...where DDA Young then demonstrated a lack of candor to the
tribunal in alleging it was not part of the police report, especially where DDA sought to
exclude the Witness Statements, Supplemental Declaration, and subsequently produced
"Narrative" (which DDA further demonstrated a lack of candor to the tribunal and in
dealings with opposing counsel by purporting the narrative to have been included in the
initial discovery propounded....which it was not. then there is the fact that the RJC
purports to have fax Coughlin two different Orders on 11/16/12 speaking to the various
motions to quash subpoenas, but that, however, the RJC seems to have, uh, accidentally
faxed the same order twice, therefore prejudicing coughlins case with respect to his not
having been served the second order a single time, but rather his having been served
the 12/16/11 filed rcr2011-06334 "Order Denying Motions for Mistrial and
Continuance" (with a file stamp of 11:41 AM) TWICE, while the "Order" baring a file
stamp of 11:42 am on 12/16/11 in rcr2011-063341 was never faxed to Coughlin,
despite the Certificate of Service of RJC Lori Townsend indicating it was...the digitally
verifiable receipts on Coughlin's end prove otherwise, and YOU ARE HEREBY
PLACED ON A LITIGATION HOLD NOTICE WITH RESPECT TO ANY AND
ALL FAX LOGS BY EITHER THE WASHOE COUNTY PUBLIC DEFENDER
AND RENO JUSTICE COURT, OR THE RENO CITY ATTORNEY, OR WASHOE
COUNTY DISTRICT ATTORNEY'S OFFICE AS TO ANY FAXES, EMAILS, OR
OTHER TRANSMISSIONS PURPORTING TO BE DELIVERED OR SENT TO
ZACH COUGHLIN AT ZACHCOUGHLIN@HOTMAIL.COM AND OR ZACH
COUGHLIN'S FAX NUMBER AS LISTED UNDER SCR 70 AT WW.NVBAR.ORG
001125
file:///R|/1%20a%20NEW%20temp/Outlook%20Print%20Messagenot%20sure.htm[11/21/2012 10:51:24 PM]
OF 949 667 7402.

ADD TO THIS ANY AND ALL FAX LOGS (INTERESTING WHAT CURTIS
HARVEY HAS TO SAY ABOUT THINGS) THE RENO JUSTICE COURT AND
WASHOE COUNTY SHERIFFS OFFICE (AND THE SAME WATTS-VIAL NAME
COMES UP ON MOTIONS TO QUASH AS IN JUDICIAL ASSISTANTS IN THE
RJC...HMMMMN....LIKE THE TOWNSEND NAME COMES UP IN RJC JUDGE'S
SECRETARIES AND RENO MARSHALS IN THE RMC, LIKE THE MARRIAGE
BETWEEN MATERIAL WITNESS ARRESTING OFFICER RPD NICK DURALDE
AND ECOMM/911 DISPATCHER WORKING THAT NIGHT WHOSE VOICE IS
APPARENTLY ON EXHIBIT 2 FROM THE 063341 TRIAL DISPATCH TAPES,
HIS WIFE, JESSICA DURALDE..
ADD TO THAT THE FACT THAT THE RENO JUSTICE COURT FAILED TO
COMPLY WITH COUGHLIN'S SUBPOENAS FOR THE 11/14/12 DISCIPLINARY
HEARING AT THE STATE BAR OF NEVADA (THE ONE WHERE THE SBN
AND PANEL TRIED TO PULL A IN RE MIRCH ON COUGHLIN BY USING SCR
111(5)'S "IF A JUDGE SIGNED AN ORDER ITS CONCLUSIVE PROOF OF A
CONVICTION, SO WE'LL HAVE HER COME IN AND TESTIFY TOO AND
ALLUDE TO UNSWORN HEARSAY (LIKE BY RMC MARSHAL HARLEY
ABOUT SOME "DISASSEMBLING A RECORDING DEVICE AND HIDING IT IN
THE BATHROOM" NONSENSE THAT IS PATENTLY FALSE) AND THEN
CLOAK THE JUDGES LIES IN A WARM CURTAIN OF JUDICIAL
IMMUNITY....
Judge Sferrazza, in his order as rendered alluded to matters (eviction cases
RJCrev2011-001708, where the RJC failed to or refused to filed Coughlin's 12/26/11
Notice of Appeal of the Order following the 12/21/11 Hearing on Coughlin's 11/16/11
Motion to Contest Personal Property Lien (the one Coughlin was denied for over 6
weeks despite NRS 40.253 (7)-(8) requiring one within 10 days be heard by the
RJC...and Coughlin was the only one who showed up (he checked in with RJC Chief
Bailiff Sexton, on time, on 11/22/11 for the hearing Coughlin was noticed on ("notice"
just as good under
The problem for the RJC under Glazier v. Justice Court and Lippis v. Justice Court is
that, while the Judges may enjoy immunity, the Court does not, nor does its staff or
administrators. So, where the RJC notices landlord and tenant in writing of a "Trial"
001126
on 10/25/11 in the Richard G. Hill summary eviction "Trial" debacle, and that setting is
violative of NJCRCP 109 respecting the 20 days required between service of the
summons and complaint and setting of a "trial on the merits"...the Court has exposure.
Same goes for failing to file the Notice of Appeal Coughlin submitted, appropriately,
in accordance with the rules in RJC Rev2011-000374, on March 16th, 2012, in
response to the March 15th, 2012 Order by Judge Schroeder (and the clerk's voice on
the audio tape of that summary eviction proceeding in rev2012-000374 ("excuse me
Judge Schroeder, I know you wanted to do that other case first, but Coughlin is not
here yet, so do you wanna rush a default through on his case" or something awfully
similar to that....) reveals an express intention to try to hurriedly secure a default
against Coughlin, even though the fax headers say the summary eviction order was
faxed at 8:24 am am for a hearing noticed for 8:30 am...which makes such an
So, while the WCDA Office and Mary Kandaras might want a conviction of Coughlin
in rjc rev2011-063341 (and the SBN's King always enjoys a good SCR 111(5) short
workday, to be sure)....it is not so clear its worth it to the Reno Justice Court, its
Judges, Administration or Staff, nor worth the appearance of the Judiciary "being
pushed around" as Judge Clifton apparently indicated to Judge Sferrazza during the
conference they had (at Clerk Tami announced in Court to Young and Coughlin)
wherein impermissible extra judicial discussions resulted in an impermissible effect
being had on the ruling in rev2011-063341 (not to mention City Attorney Skau's
fraudulent assertion of an Order by Judge Sferrazza authorizing Skau to secure
Coughlin's attendance at the 11/13/12 Hearing, via service "by email"....to say nothing
of the impermissible ex parte communications occuring between the RJC, WCDA,
WCPD, and Reno City Attorney on 11/8/12 (especially considering the impermissible
release of Coughlin's smart phone and micro sd card to the RMC Marshals, as admitted
to by WCSO employees in easily provable was, to the Reno Marshals, a full day after
Coughlin's smartphone and micro sd card were booked into Coughlin's secured
property at the WCDC...(therefore, not at all a "search incident to arrest"...which is too
bad, considering all that Diaz would allow....)
RULE 109. SETTING OF TRIAL IN ACTIONS
PURSUANT TO NRS 40.290
(a) In no case shall a trial on the merits be set less than 20 calendar days after service of summons and complaint.
(b) If the court issues an order to show cause why a temporary writ of restitution shall not be issued, it may notice on such order the date
and time set for trial in addition to the date and time set for the temporary writ show cause hearing. However, if service of the summons and
complaint occurs less than 11 days prior to the date for a hearing for a temporary writ or less than 20 calendar days prior to a trial date, the
court shall continue the relevant hearing date upon request by the tenant.
001127
(c) The trial on the merits shall not be set and noticed using an order to show cause.
So, add up Dogan's secretary not faxing something to Coughlin that she attested to faxing, while delivering it to
Young even where the attestation lacks any indication it was so given to Young...Add to that the RJC's failure to
Comply with Coughlin's lawfully issued subpoenas in the State Bar of Nevada Disciplinary matter (hint...NRCP 45
only applies to State Bar Hearings to the extent the SBN/NNDB/Panel say it does, especially in consideration of
SCR 105(4)...so all those Motions to Quash, especially where ex parte, and based upon fraudulent sewer
service, really don't excuse the fact that the RJC, WCDA, WCPD, et al failed to show up at the Disciplinary
Hearing)...
And then there is Coughlin's father's patient, Judge Salcedo, showing up out of the blue at the RJC and lobbying
for more of his "first century Chrisitanity" by force approach...
Oh, and then there is the sudden expression by Judge Sferrazza that Coughlin's previously filed Motions
contained "empty cd/dvd cases"....Well, they sure didn't when Coughlin delivered them, and one has to
wonder whether Coughlin has some easily verifiable evidence of that...no sure exactly what that could be that
could so easily prove a cd/dvd was in a case/paper sheath attached to the motions....what could prove that?
hmmmmn its almost not even necessary to put the RENO JUSTICE COURT AND WASHOE COUNTY DISTRICT
ATTORNEY'S OFFICE AND WASHOE COUNTY SHERIFF'S OFFICE ON A LITIGATION HOLD NOTICE AS TO THE VIDEO
FOOTAGE OF COUGHLIN FILING THOSE RESPECTIVE MOTIONS, INCLUDING THE ONE'S FILED ON 11/15/12
(COUGHLIN KNOWS WHAT WAS ATTACHED TO WHAT BUT IT MIGHT BE HARD FOR THE COURT TO KEEP THAT
CLEAR AS TO RCR2011-063341 AND RCR2012-065630...BUT THAT WILL BECOME AWFULLY IMPORTANT,
ESPECIALLY CONSIDERING THE CELL PHONE RECORDS OF COREY GOBLE, FOR THE AUGUST 20TH, 2011 ARREST
IN QUESTION, THE TESTIMONY OF ZARATE, GOBLE, TEMPLETON, AND LICHTY ET AL CONSIDERING THE SCANT
AMOUNT OF CALLS AND BY WHOM REVEALED IN THOSE RECORDS AND SET FORTH IN COUGHLIN'S MOTION
FOR MISTRIAL ETC. AND THE VARIOUS TESTIMONY SPEAKING TO THOSE CALLS (COACH DDY YOUNG SURE HAD
THOSE WITNESSES UNABLE TO REMEMBER MUCH OF ANYTHING ABOUT WHO MADE THE CALLS, HUH? JUST
TESTIMONY THAT A CALL WAS MADE....BUT ABOUT 5 OUT OF 5 WITNESS COULDN'T REMEMBER WHO MADE IT
ABOUT ALL OF THE CALLS THAT NIGHT, AND GIVEN THERE WAS ONLY 4 TO OR FROM GOBLE'S PHONES
DURING THE RELEVANT PERIOD...THE MATH IS FUZZY...TAPE DON'T LIE...WHY ELSE WOULD DDA YOUNG AND
JIM LESLIE BE SO KEEN TO KEEP OUT OF EVIDENCE ALL OF THE VIDEO AND AUDIO EVIDENCE INSPECTOR
COUGHLIN COLLECTED? The got a real routine goin'....but real problematic is that fact that all the files on
those dvd's were part of the exhibits marked as exhibits and offered into evidence...and the appellate court will
have an awful lot of stuff to pick and choose from with respect to what is considered reversible error or not on
account of being excluded....sure, it would have been kind of involved for the Court or Young to have looked at
the stuff attached to the Motions...and it was just about "about a cell phone" as court staff could not believe
the case got so involved (kind of makes it look like more was at stake than a cell phone, as though leverage,
and mitigation of liability as to a County and Municipality become the job of the RJC...some might say)
Zach Coughlin
1471 E. 9th St.
001128
Reno, NV 89512
Tel and Fax: 949 667 7402
for DDA Young, City Attorney's Bony and Christensen city hall cameras and RPD recording admission 063341.pdf
final Motion for Mistrial and Memorandum of Law State v Coughlin rcr2011-063341.pdf
11 12 12 revised 063341 final Motion for Mistrial and Memorandum of Law State v Coughlin rcr2011-063341.pdf
11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf
11 13 12 065630 Motion for Recond on Amend Issue and for Mistrial and Self Representation.pdf
11 13 12 063341 submission of materials and motion for order dmv and cell records or subpoena.pdf
11 9 12 stamped 60302 wls garin notice of lack of access roa 12-35541.pdf
rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS (2).pdf
11 9 12 stamped 60302 Notice of Lack of Access with both parts of exhibit 1.pdf
10 31 12 Coughlin's DoWSoE needs cert of service file stampe though 0204.pdf
all emails sent to jleslie@washoecounty.us between 12 25 11 and 9 27 12with bates stampes .pdf
11 2 12 file stamped complete w 195 ex and dvd notice of errata and revised supplemental 26405 1708 0204.pdf
11 8 12 and 119 12 emails 063341 handed by skau at 11 13 12 hearing.pdf
11 8 12 emails to dogan, kandaras and skau 0204.htm
11 8 12 homer and 11 9 12 skau reno city attorney's office emails 063341.htm
11 9 12 email from skau 063341 purporting that Judge authorized service of notice of hearing by email.htm
11 14 12 email dda young and 0204 panel regarding skau and update dispatch discovery.htm
11 16 12 skau grievance materials combined 0204 063341.pdf
Download all
LITIGATION HOLD NOTICE i was not faxed the 11 7 12

motion to quash subpoena that
Sent: Wed 11/21/12 4:53 PM
To: ltibbals@washoecounty.us (ltibbals@washoecounty.us); lgray@washoecounty.us
(lgray@washoecounty.us)
please NOTE YOU ARE ON A LITIGATION HOLD NOTE TO RETAIN AND FAX
LOGS OR PROOF OF RECEIPT, TRANSMISSION, CONFIRMATION OF
ATTEMPTED TRANSMISSION ETC OF THE PURPORTED SERVICE OF THE
001129
NOVEMBER 7TH, 2012 MOTION TO QUASH SUBPOENA DUCES TECUM

FILED STAMPED 11/7/12 BY BIRAY DOGAN IN RCR2011-063341. LESLIE
TIBBALS SIGNED A CERTIFICATE OF SERVICE DATED 11/7/12. THIS
DOCUMENT WAS NEVER FAXED TO THE FAX NUMBER IT LISTS FOR ZACH
COUGHLIN OF 949 667 7402. DDA YOUNG HAD THE DOCUMENT IN COURT
AND SHOWED IT TO THE DEFENDANT AT THAT TIME. PLEASE ALERT THE
COURT TO YOUR FRAUD.
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
001130
Print
Close
please email me the materials produced by ecomm/K.

Odom/ dispatch tapes
Sent: Fri 11/02/12 12:12 AM
To: jleslie@washoecounty.us (jleslie@washoecounty.us); lgray@washoecounty.us
(lgray@washoecounty.us); ltibbals@washoecounty.us (ltibbals@washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us)
Dear Mr. Leslie,

Please email me the materials produced by ecomm/K. Odom (in response to your subpoena of 10 3
12, surely you have review these materials given your stated intention on 9 5 12 to jam me into a
conclusion of trial on 10 15 12, at which time you anticipated "calling no witnesses" and "being able
to wrap this thing up in less than an hour, Your Honor..."
So, please send me the materials propounded by ECOMM/the RPD/ K. Odom/ Emergency
Communications, etc., along with an inventory of what fails are included therein (to the extent the
attachment file name don't make that obvious. The nice thing about the audio files that ECOMM
produced to you is they are such small files. For instance, the 911 recordings propounded earlier (2
calls be Goble, one by Coughlin) are each only about 200 kb in size...My hotmail accepts up to 25
mb files at a time, and to the extent you have anything larger than that (pretty doubtful, beyond the
large video files I have given to you) it really should be no trouble for you to digitially transmit (and
it is so cute how you have developed this "hand-off transmittal" jibberish/garbage to make an attempt
to excuse your transparent refusal to be held accountable to the 1's and 0's of a digital transmission
(but you do leave yourself exposed to a claim that you have failed to maintain a client's file...by your
indication that you wish to ("because there is just no time to put a cd in the computer and click
"attach" and add an .avi file to an email") do a "hand-off transmittal", at which point you purport to
be handing over the only copies your office has of things like the materials propounded by
ECOMM/K. Odom.
Please get this done today, or a continuance will be in order.
Oh, if you are so busy, Jim, perhaps some of your staff could do the emailing and the clicking of the
"attachment" button, etc., etc.
Jim, I haven't heard anything substantive from Biray Dogan in months depsite my numerous written
inquiries. You claim to be responsible for his work as his supervisor....yet, I also remember you
putting a "gag order" on Joe Goodnight, preventing him from even speaking when appearing on my
behalf in court (truly an odd sight/lack of sound). Have you placed a similar "no speach or
communication" embargo on Mr. Dogan? How does that relate to Dogan and your professional
responsibilities?
I am still waiting to get a copy of anything, anything at all that your office has to support your
001131
file:///R|/...202%2012%20EMAIL%20TO%20DOGAN%20AND%20LESLIE%20ECOMM%20065630%20066341%200204.htm[12/10/2012 3:09:38 PM]
contention, made under oath, that it noticed me in any way on the August 6th, 2012 "combo
hearing", which the record reflects I failed to appear at, which has not subjected me to certain bail
revocation consequences. Ms. Gray, you will recall our conversations in that regard, and the
statements you made, which conflict sharply with those made under oath by Mr. Leslie. Please go
ahead and send me any such documentation or explanation, and be prepared to speak to these
discrepancies at my bar hearing on November 14th, 2012, 9 am, at the State Bar of Nevada's Offices
at 9200 Double R. Blvd., Reno, NV, all of you.
Sincerely,
Zach Coughlin
001132
file:///R|/...202%2012%20EMAIL%20TO%20DOGAN%20AND%20LESLIE%20ECOMM%20065630%20066341%200204.htm[12/10/2012 3:09:38 PM]

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001139
Page 1 of 5
your failure to appear at the arraignment

Sent: Fri 2/17/12 10:49 AM
To:
bdogan@washoecounty.us
2 attachments
notice of appearance.pdf (386.5 KB) , rcr11-063341 affidavit in support of motion to file pre-trail
motions late bw.pdf (224.4 KB)
Dear Mr. Dogan,
This writing serves to memorialize, in part, the discussion we had yesterday when Mr. Goodnight
abruptly interjected you into a private, privileged, confidential, attorney-client conversation between he
and I. Upon placing me on speakerphone (which PD"s should suspect their clients would hate), I asked
you for your report on the arraingment that we agreed you would appear at for me an enter a not guilty
plea (the arraingment was set for February 14th, 2012 at 9:30 am before Judge Lynch) and asked you if
you had received my email from two days prior asking the same. You indicated that you did not go to
the arraingment, and disagreed with me about whether we had agreed that you would when we met
and discussed this case for approximately 1.5 hours. I asked you what typically results in such situations,
wherea a dispute about whether the PD had a duty to show up to the arraingment or whether the PD
had agreed to enter a plea on a defendant's behalf arises. You indicated a defendant's bail is often
revoked. I responded by elucidating to you how much that happening right now would prejudice my
clients cases (and I left you a voice mail stating as much shortly after 5 pm on 2/16/12) and that I wished
for you to immediately (or as soon thereafter as practicable) file some type of Motion and Entry of
Plea/Waiver of Right To Arraignment seeking to avoid such a result. You flatly refused and reverted to
the time honored PD practice of covering one's exposure, whilst coming up with ever more creative
rationale for why you would continue to "give those typewriters a rest". The "give those typewriters a
rest" reference, of course refers to that story I relayed to you that my friend Dennis Widdis told me of his
days at the WCPD from 1979-1990 (See, Widdis v. Second Judicial District Court, Ford, Coleman, Thomas,
etc., etc), which is what a supervisor said the Widdis and other PD's at one point, much to Widdis's
disgust. Anyways, the WCPD has made several statements to me about the "holistic" approach taken
with regard to client's matters, but yet, you refuse to file anything to address an exigent situation here. I
have a trail onFebruary 29th, 2012 that I must prepare for, especially considering the apathetic
representation Mr. Goodnight, also fo the WCPD, is offering. Being forced to pay the WCSO some more
ransom or bail would be inordinately burdensome to me right now, and further, would only underscore
the improprieties highlighted by my letter of 2/12/12, for which you were included as a recipient.
Sincerely,
Zach Coughlin, Esq.
Date: Tue, 14 Feb 2012 11:17:36 -0800
001140
http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=749de173-d268-4037... 2/17/2012
Page 2 of 5
Dear Mr. Dogan,

Just checking in with you to see if DDA Young was amenable to the
resolution we discussed, or if not, whether a court date was issued at the
arraignment today. Please confirm that you entered a not guilty plea for
me as we discussed.
Sincerely,
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
To: jgoodnight@washoecounty.us
Subject: your reprehensible violations of the Rules of Professional Conduct
Date: Thu, 16 Feb 2012 17:54:30 -0800
Mr. Goodnight,
Writing will memorialize, in part, but I don't have time to do so fully, the
conversation we just had on the telephone. I called you seeking to encourage you to
fulfill your duty to maintain communication with me, the client, particularly where
Trial is set for a scant 13 days from now, on February 16th, 2012, and where you
made statements and writings that I reasonably relied upon to the effet that you
would be filing a Motion for Continuance of the upcoming Trial. However, a review
001141
Page 3 of 5
of the docket indicates that you have failed to do so timely. I then corresponded with
to indicate that you should immediately seek leave of court to so file such an
untimely pre-trial motion under NRS 174.125(3)-(4):
"NRS 174.125 Certain motions required to be made before trial. 1. All motions in a
criminal
prosecution to suppress evidence, for a transcript of former proceedings, for a
preliminary hearing,
for severance of joint defendants, for withdrawal of counsel, and all other motions
which by their
nature, if granted, delay or postpone the time of trial must be made before trial,
unless an opportunity
to make such a motion before trial did not exist or the moving party was not aware of
the grounds for
the motion before trial. 2. In any judicial district in which a single judge is provided:
(a) All motions
subject to the provisions of subsection 1 must be made in writing, with not less than
10 days notice
to the opposite party unless good cause is shown to the court at the time of trial why
the motion could
not have been made in writing upon the required notice. (b) The court may, by
written order, shorten
the notice required to be given to the opposite party. 3. In any judicial district in
which two or more
judges are provided: (a) All motions subject to the provisions of subsection 1 must
be made in writing
not less than 15 days before the date set for trial, except that if less than 15 days
intervene between
entry of a plea and the date set for trial, such a motion may be made within 5 days
after entry of the
plea. (b) The court may, if a defendant waives hearing on the motion or for other
good cause shown,
001142
Page 4 of 5
permit the motion to be made at a later date. 4. Grounds for making such a motion
after the time
provided or at the trial must be shown by affidavit."
So, of course, you will need to file such a Motion immediately. However, upon calling you shortly before
5 pm today, instead of addressing that exigent concern, you ran an got your guy DPDBiray Dogan, Esq.
to eavesdrop in on our confidential attorney client, privileged communications. Of course its not
probably technically "eavedropping" when you mincingly say, beforehand, "hang on, I'm going to go
grab, Biray...", but given the time contraints we are operating under and the imbalance of power, it really
feels like it. Why did you need to get Biray? Is the fact that you make so much more money than me,
operate under color of law (which will arise in any subsequent 42 USC Sec 1983 analysis), and have a staff
of sullen retaliatory government workers at your diposal (the receptionist who lied about whether I
"kicked" furniture in the WCPD lobby when I was tapping my toes, Cary Hylin, Esq., the DPD who
retailiates against anyone who may even begin to point out that his approach to defense work is kind of
like Bernie's approach to weekending, and Evo Novak, whom demands that absolutely no one tell him
how to do his job, even where he clearly is not doing it at all, much less doing it well...). With all that, you
still need to go and grab Biray? This makes twice today, a most exigent of days in the course of this
litigation that you have slammed down the phone in terrible anger towards me, abruptly ending the call,
causing me great anguish and worry given the path you have led me down, and the proximity to so
precarious a situation I now find myself in. I am, of course referring to the specter of a looming Trial on
February 29th, 2012, where you have already blown extremely important deadlines, on top of where you
have flat out refused totake basic, essential that any zealous advocate would intuitively know to do, and
where such an advocate would not even imagine refusing to do them where a client has laid them out
and substantially contributed towards completing the work involved in such tasks. You really come
across as a sot of Dr. Kevorkian for the PD set. Joey Kevorkian, kind of catchy.
Please mitigate the damages you have caused me at once, and cease your attempts to obstruct me from
appearing as co-counsel in this matter, in direct contravention of Judge Sferrazza's explicit indication, on
the record, in open court, that I am allowed to so appear in this matter as co-counsel. Please copy me
immediately on your written indications to that effect to the RJC. Please refrain from taking the, for what
seems quite typical for me, futile stance of suggesting that you will "get this on calendar for next week"
the matter of whether Joe Goodnight, Esq., DPD will grant me the right to appear as co-counsel. For all
the money you make Joe, and for the scant contribution you have made to my defense, it is highly ironic
to me that I am the one facing a theft based charge. I would imagine you are wracked with guilt on a
daily basis in consideration of those circumstances and attributes. You are well aware that given the
paucity of days before the Trial is set to occur, for which DDA Zach Young, Esq. refused toeven consider
a continuance. Speaking of DDA Young,I have seen you having coffee with at the organic, free trade,
overpriced, bourgie coffee place between the PD's and the RJC ($3.35 for one small coffee, no refills,
must be nice, guys).
Sincerely,
Zach Coughlin, Esq.

1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
001143
Page 5 of 5
fax: 949 667 7402

Nevada Bar No: 9473
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Print
Close
sexual assault/ meeting with the perpetrator/ intertwined

with Summary Eviction Hearing for return of property
Sent: Wed 11/30/11 5:20 AM
To: stuttle@washoecounty.us; kstancil@washoecounty.us
I could swear Ms. Stancil said something about conditioning one on the other, but there
is just no way you are asking the victim to meetin a small confined room with the
person who committed the sexual assault, is there? Nor could you possibly be
conditioning the right to a hearing within 10 days of filing the Motion for Return of
PErsonal PRoperty/Contest Landlord's lien upon agreeing to such a meeting, right?
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
another Bailiff making comments involving my "ass"

Sent: Mon 11/28/11 11:52 AM
To: stuttle@washoecounty.us
Dear Court Adminstrator Tuttle,

Today, Bailiff Reyes made several threatening comments related to my "ass". I am
001151
file:///R|/...1%20and%2011%2030%2011%20rjc%201708%20Bailiffs%20wcso%20tuttle%20to%20@washoecounty.us.htm[12/10/2012 3:09:39 PM]
writing this to formally complain. Please place a copy of this writing in Bailiff Reyes'
employment or personnel file, or both. Included in Bailiff Reyes commentary was a
threat wherein he stated to me, shortly after invading my personal space, that he would
"place my boot up your ass". There were additional inappropriate threats and comments
made by Bailiff Reyes. Please note I have a new address.
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
001152
file:///R|/...1%20and%2011%2030%2011%20rjc%201708%20Bailiffs%20wcso%20tuttle%20to%20@washoecounty.us.htm[12/10/2012 3:09:39 PM]
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Eviction Procedure - Washoe County Sheriff's Office - 911 Parr Blvd, Ren...
1 of 2
http://www.washoesheriff.com/eviction-process.htm
Eviction Procedure
SECTIONAL LINKS
Liz Stuchell, I.A. Supervisor

Main Phone: (775) 328-3310
Civil Fee Schedule
EVICTION PROCEDURE
Eviction Procedure
The Sheriff's Office will endeavor to complete an eviction as soon as possible. In order to perform
this service in a timely manner as required by the court, the Sheriff's Office and the landlord must
work together closely. The landlord or their representative must be available to speak with the
deputy who is scheduling the eviction and must provide a telephone number where they can be
reached between 8:00 a.m. and 5:00 p.m. - no voice mail or answering machine. The landlord or
their representative must be able to perform the eviction within 30 minutes of being contacted by
the deputy.
At the time set for the eviction, two deputies will meet the landlord or a designated representative
at the address of the eviction. The deputies drive unmarked cars but are in uniform.
Home
Administrative Services
Division
Front Desk
Records Section
It is important that the landlord, or the designated representative of the landlord, and the
locksmith (if needed) be on time. If for some reason one or all of the above are not at the address
on time, the eviction will be cancelled. The entire procedure will have to be repeated, and another
service fee will be charged.
Be prepared to wait up to 30 minutes. The deputies are sometimes delayed by additional law
enforcement duties. The deputies will remove each and every person on the premises. Any
personal property in the dwelling will have to be removed by the tenant at a time that has been
arranged with the landlord. If there are any animals left on the property, it is the landlord's
responsibility to care for the animals.
If the evicted tenant breaks into the dwelling after the eviction, the landlord is to call the law
enforcement agency that has jurisdiction for the area.
If the landlord wants to cancel the eviction or has any questions, call the Civil Section at
328-3310.
There is no refund of service fees for a cancelled eviction.
Home Page | Executive Staff | Administration | Detention | Operations | Forensic Science

Patrol | Detectives | Records | Employment | Contact | Site Index | Front Page
001188
3/16/2012 12:57 PM
Eviction Procedure - Washoe County Sheriff's Office - 911 Parr Blvd, Ren...
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http://www.washoesheriff.com/eviction-process.htm
Copyright 2009 Washoe County Sheriff's Office - All Rights Reserved.

Location: 911 Parr Blvd., Reno, NV 89512 - Main Phone: 775-328-3001 - Email: sheriffweb@washoecounty.us
001189
3/16/2012 12:57 PM
001190
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Page 1 of 22
Evictions RE: WCSO Deputy Machem's "personally

served" Affidavit of 11/1/2011
Sent: Mon 2/13/12 3:01 AM
To:
Zach Coughlin (zachcoughlin@hotmail.com)
To: lstuchell@washoecounty.us; mkandaras@da.washoecounty.us; drakej@reno.gov; kadlicj@reno.gov;
cdbaker@richardhillaw.com; jboles@callatg.com; bbuckley@lacsn.org; daolshan@yahoo.com;
jsoderlund@nlslaw.net; jdelikanakis@swlaw.com; jgoodnight@washoecounty.us;
jbosler@washoecounty.us; bdogan@washoecounty.us; mechols@maclaw.com; mclarkson@puc.nv.gov
Subject: Evictions RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
Date: Fri, 10 Feb 2012 12:14:01 -0800
Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011

Date: Tue, 7 Feb 2012 11:40:39 -0800
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.
WCSO Civil Section

001192
http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=084f5caf-5632-11e1-... 2/13/2012
Page 2 of 22
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna;

kadlicj@reno.gov; fourthestate@gmail.com; jamesandreboles@msn.com
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 Summary Eviction against 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), especially where a stay of
eviction was not granted even while the RJC held on to most all my money...).
"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 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 "served"
in compliance with all time related rules because it was done in the "usual custom
and practice of the WCSO. What, exactly, is the "usual custom and practice of the
phraseology: "
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
001193
Page 3 of 22
Eviction was signed by October 27th, 2011. That language is only found in situations
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 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
and,
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
statutory citations, and in employment law litigations where one must file a
Complaint within 90 days of receipt of a Right To Sue Letter, a situation which
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 114 (1st 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 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 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).... ...
001194
Page 4 of 22
Dear Washoe County Sheriff's 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 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]"
I 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://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!
1897&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,
001195
Page 5 of 22
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 partys 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 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 118A)
the tenant cannot be deemed to have received or constructively received the Order
until the 3 days for mailing has passed.
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
001196
Page 6 of 22
may be "drop" served, and it is considered a valid service. Personal service of

process has been the hallmark for initialing litigation for nearly 100 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 Sheriff's 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
118A.460 "reasonable storage, 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 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 118A.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 121
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 118A 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 I thought.
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 the only thing I have of monetary value (my professional
001197
Page 7 of 22
reputation and name). It ain't no stand up 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 right
to litigate habitability issues. Now, nevermind the fact that Judge Sferrazza actually
did not 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 Nevada Supreme Court first....period.). Okay,
so, to take it a step even further, Baker's order goes 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 10 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, darn 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...).
001198
Page 8 of 22
NRS 40.380 Provisions governing appeals. Either party may, within 10 days, appeal
from the judgment rendered. But an appeal by the defendant shall not stay the
execution of the judgment, unless, within the 10 days, the defendant shall execute
and file with the court or justice the defendants 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 CV11-03628? 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.com/watch?v=5PR7q4OI5b0
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 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
001199
Page 9 of 22
not, because, despite, ol' Contractor Phil's fraudulent $1,060 bill for "securing" the
back porch (with screws facing the outside, inexplicably, and a window unit a/c 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 12, 2011 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
118A.460....). Jeez, your probably going to tell me Sargent Sigfree ordered another
custodial arrest on Coughlin just 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 911" 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 33.010,
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 911" 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, 2011, 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....
NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of
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Page 10 of 22
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 of the
appellate court and irrevocably appoints the clerk of that court as the suretys agent
upon whom papers affecting the suretys 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 100 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 of NRS 40.220 to
40.420, inclusive; 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 of NRS, Nevada Rules of Civil
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 terms, but was
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rather renewed. This is particularly true where NRS 118A prevents so terminating 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 corners 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 Amendment Right To Counsel,
the finds him guilty of NRS 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 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
defendants 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 place and stating
the latest date known to affiant when such party so resided there); that such place is
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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
Sheriff's Office. Your money is always good with me.
Zach Coughlin, Esq.

Subject: RE: WCSO Deputy Machem's "personally served" Affidavit of 11/1/2011
Date: Tue, 7 Feb 2012 11:40:39 -0800
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.
WCSO Civil Section

001203
Page 13 of 22
To: Stuchell, Liz; Kandaras, Mary; nvrenopd@coplogic.com; Silva, Roxanna;

kadlicj@reno.gov; fourthestate@gmail.com; jamesandreboles@msn.com
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 Summary Eviction against 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), especially where a stay of
eviction was not granted even while the RJC held on to most all my money...).
"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 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 "served"
in compliance with all time related rules because it was done in the "usual custom
and practice of the WCSO. What, exactly, is the "usual custom and practice of the
phraseology: "
of the order... is inapplicable to this situation, where an Order Granting Summary
001204
Page 14 of 22
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 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
and,
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
statutory citations, and in employment law litigations where one must file a
Complaint within 90 days of receipt of a Right To Sue Letter, a situation which
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 114 (1st 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 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 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).
001205
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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
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. 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, 2011. That is a lie by Mr. Machem, unless "personally served" is
defined in a rather impersonal way and or Machem and I have totally different
understanding of the definition 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 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 118A.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
Sheriff's 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.
MACHEM THAT ADMITS THAT I WAS NOT PERSONALLY PRESENT
WHEN HE SERVED THE ORDER FOR SUMMARY EVICTION IN RJC
REV2011-001708 ON 11/1/12 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
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
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for removal of the tenant or an order providing for the nonadmittance of the tenant....
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 10 days after the filing of the
motion. The court shall affix the date of the hearing to the motion and order a copy
served upon the landlord by the sheriff, constable or other process server. At the
hearing, the court may:
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
001207
Page 17 of 22
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 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 118A.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 County Sheriff (despite what their
Affidavit of Service 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 40.253
(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, 12 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 following 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 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 911incident 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".
following one:
From:
NvRenoPd@coplogic.com
Sent:
001208
Page 18 of 22
Wed 9/07/11 10:51 PM

THIS 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.
Thank you,
Officer WOZNIAK,
ADDRESSED."
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
118A.460 may deem "reasonable storage" expenses for which a lien is available to a
landlord, though NRS 118A.520 has outlawed rent distraints upon tenant's personal
001209
Page 19 of 22
Actually, upon being released from jail on November 15th, 2011, incident to the
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 earlier. 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 11/12/11 trespassing arrest, that Sargent
immediately informed me that, despite this being the first he heard of that, he was
sure that was not happening....I 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 attorney being required to report said conviction to the State Bar of Nevada
under SCR 111, 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 11/15/11 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 12th, 2011 (custodial arrest, bail
of $160 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 118A.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 12th, 2011 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.030 that that was not the case (attaching a two
001210
Page 20 of 22
page report to the RPD as an Exhibit). Then Hill and his contractor Phil Howard both
committed perjury when the signed 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...).
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,
"Court Services, come out now!", wearing their pretend Sheriff outfits, big
equipment saddled belts (including firearms, I believe, and radios), etc. ,etc.
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
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):
001211
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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 2011. 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, 2011)
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
1/12/12. 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 911" just two days
later, on January 14th, 2011 when I called 911 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 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 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 preTrial 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)...I 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
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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 of this...But that would require and awful lot of
coincidences.
Sincerely,
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This message and accompanying documents are covered by the
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001213
Print
Close
DAMAGED PERSONAL PROPERTY

Sent: Mon 4/16/12 3:15 PM
To: tbeckman@washoecounty.us; mkandaras@da.washoecounty.us
Ms. Beckman and Ms. Kandaras,
Please accept this correspondence as a request for a new G2 HTC smartphone, a new Samsung cell phone, and a new
32GB micro sd card. The card has been rendered unusable and all the data then existing on it at the time of its seizure
has been removed. Please provide an indication of whether that was done on purpose or not, in writing. Further, I
believe I should be provided with compensation for the cost of new phones as these are obviously rather suspect at this
point.
Further, with local attorney Pam Willmore present a WCSO Deputy and Ms. Campbell indicated to me that per Courts
Orders I was to contact RMC Marshal Deighton. I did and he never responded in any way. Please indicate why exactly I
was told to so contact Marshal Deighton, and why that Deputy told me, at that time, that the property had already been
returned to the RMC Marshals because it would just be easier to get it back to you that way (ie, having me retrieve the
property from the RMC Marshals versus retrieving it directly from the WCSO). Further, that Deputy admitted, with Ms.
Willmore present, that Ms. Cumming and Ms. Campbell were, in fact, incorrect, in their assertions that the micro sd card
had been returned the acquaintance of mine whom retrieved my keys while I was incarcerated. Rather, that Deputy then
admitted the micro sd card, in fact, was not returned at that time. Of course, a 32 GB micro sd card was returned to me
with Deputy Ivers present, however, he and Ms. Beckman, Ms. Berryman, Deputy Cheung, and one other Deputy all
scattered quickly after I began opening the secured envelope, refusing to allow me to test the micro sd card in their
presence.
Please forward this communication on to whomever processes requests for reimbursement of damaged personal
property.
Sincerely,
Zach Coughlin
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(Reprinted with amendments adopted on April 22, 2011)

FIRST REPRINT
A.B. 226
ASSEMBLY BILL NO. 226ASSEMBLYMEN FRIERSON,

BROOKS, CARRILLO, SEGERBLOM; AND PIERCE
MARCH 2, 2011
____________
Referred to Committee on Judiciary
SUMMARYRevises various provisions governing landlords and
tenants. (BDR 3-669)
FISCAL NOTE: Effect on Local Government: No.
Effect on the State: No.
~
EXPLANATION Matter in bolded italics is new; matter between brackets [omitted material] is material to be omitted.
AN ACT relating to property; revising various provisions governing

landlords and tenants; and providing other matters
properly relating thereto.
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Legislative Counsels Digest:

Existing law generally authorizes a landlord to have a tenant removed from
rental property if the tenant defaults on rental payments and continues to occupy the
property. (NRS 40.253) Section 1 of this bill requires a landlord to advise a tenant
of certain information in a notice before applying for a court order to evict the
tenant.
Additionally, existing law provides tenants with certain remedies if a landlord
is required to provide certain essential services and fails to do so, or if the landlord
commits certain other acts that interfere with the tenants use of the rental property.
(NRS 118A.380, 118A.390) Section 6 of this bill includes a functioning door lock
among essential items or services that a landlord must provide a tenant. Section 7
of this bill authorizes a tenant to recover immediate possession of rental property if
a landlord takes possession of the property in violation of NRS 118A.480, which
prohibits a landlord from taking possession of the property unless the landlord
pursues an available legal remedy or the tenant surrenders possession of or
abandons the property.
THE PEOPLE OF THE STATE OF NEVADA, REPRESENTED IN

SENATE AND ASSEMBLY, DO ENACT AS FOLLOWS:
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Section 1. NRS 40.253 is hereby amended to read as follows:

40.253 1. Except as otherwise provided in subsection 10, in
addition to the remedy provided in NRS 40.2512 and 40.290 to
40.420, inclusive, when the tenant of any dwelling, apartment,
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mobile home, recreational vehicle or commercial premises with

periodic rent reserved by the month or any shorter period is in
default in payment of the rent, the landlord or the landlords agent,
unless otherwise agreed in writing, may serve or have served a
notice in writing, requiring in the alternative the payment of the rent
or the surrender of the premises:
(a) At or before noon of the fifth full day following the day of
service; or
(b) If the landlord chooses not to proceed in the manner set forth
in paragraph (a) and the rent is reserved by a period of 1 week or
less and the tenancy has not continued for more than 45 days, at or
before noon of the fourth full day following the day of service.
As used in this subsection, day of service means the day the
landlord or the landlords agent personally delivers the notice to the
tenant. If personal service was not so delivered, the day of service
means the day the notice is delivered, after posting and mailing
pursuant to subsection 2, to the sheriff or constable for service if the
request for service is made before noon. If the request for service by
the sheriff or constable is made after noon, the day of service shall
be deemed to be the day next following the day that the request is
made for service by the sheriff or constable.
2. A landlord or the landlords agent who serves a notice to a
tenant pursuant to paragraph (b) of subsection 1 shall attempt to
deliver the notice in person in the manner set forth in paragraph (a)
of subsection 1 of NRS 40.280. If the notice cannot be delivered in
person, the landlord or the landlords agent:
(a) Shall post a copy of the notice in a conspicuous place on the
premises and mail the notice by overnight mail; and
(b) After the notice has been posted and mailed, may deliver the
notice to the sheriff or constable for service in the manner set forth
in subsection 1 of NRS 40.280. The sheriff or constable shall not
accept the notice for service unless it is accompanied by written
evidence, signed by the tenant when the tenant took possession of
the premises, that the landlord or the landlords agent informed the
tenant of the provisions of this section which set forth the lawful
procedures for eviction from a short-term tenancy. Upon
acceptance, the sheriff or constable shall serve the notice within 48
hours after the request for service was made by the landlord or the
landlords agent.
3. A notice served pursuant to subsection 1 or 2 must:
(a) Identify the court that has jurisdiction over the matter; and
(b) Advise the tenant [of] :
(1) Of the tenants right to contest the matter by filing, within
the time specified in subsection 1 for the payment of the rent or
surrender of the premises, an affidavit with the court that has
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jurisdiction over the matter stating that the tenant has tendered
payment or is not in default in the payment of the rent [.] ;
(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; and
(3) That, pursuant to NRS 118A.390, a tenant may seek
relief if a landlord unlawfully removes the tenant from the
premises or excludes the tenant by blocking or attempting to block
the tenants entry upon the premises or willfully interrupts or
causes or permits the interruption of an essential service required
by the rental agreement or chapter 118A of NRS.
4. If the tenant files such an affidavit at or before the time
stated in the notice, the landlord or the landlords agent, after receipt
of a file-stamped copy of the affidavit which was filed, shall not
provide for the nonadmittance of the tenant to the premises by
locking or otherwise.
(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 remove the tenant within 24 hours after receipt of the
order. The affidavit must state or contain:
(3) The amounts of any cleaning, security or rent deposits
paid in advance, in excess of the first months rent, by the tenant.
(5) The length of time the tenant has remained in possession
without paying rent.
(7) A statement that the written notice was served on the
tenant in accordance with NRS 40.280.
(b) Except when the tenant has timely filed the affidavit
described in subsection 3 and a file-stamped 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
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or the landlords agent may, in a peaceable manner, provide for the

nonadmittance of the tenant to the premises by locking or otherwise.
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. If the court determines that there is a
legal defense as to the alleged unlawful detainer, the court shall
refuse to grant either party any relief, and, except as otherwise
provided in this subsection, shall require that any further
proceedings be conducted pursuant to NRS 40.290 to 40.420,
inclusive. The issuance of a summary order for removal of the
tenant does not preclude an action by the tenant for any damages or
other relief to which the tenant may be entitled. If the alleged
unlawful detainer was based upon subsection 5 of NRS 40.2514, the
refusal by the court to grant relief does not preclude the landlord
thereafter from pursuing an action for unlawful detainer in
accordance with NRS 40.251.
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
118.207 or 118A.460 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,
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 10 days after the filing of the motion. The court shall
affix the date of the hearing to the motion and order a copy served
upon the landlord by the sheriff, constable or other process server.
At the hearing, the court may:
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(a) Determine the costs, if any, claimed by the landlord pursuant

to NRS 118.207 or 118A.460 and any accumulating daily costs; and
(b) Order the release of the tenants property upon the payment
of the charges determined to be due or if no charges are determined
to be due.
9. A landlord shall not refuse to accept rent from a tenant that
is submitted after the landlord or the landlords agent has served or
had served a notice pursuant to subsection 1 if the refusal is based
on the fact that the tenant has not paid collection fees, attorneys
fees or other costs other than rent, a reasonable charge for late
payments of rent or dishonored checks, or a security. As used in this
subsection, security has the meaning ascribed to it in
NRS 118A.240.
10. This section does not apply to the tenant of a mobile home
lot in a mobile home park or to the tenant of a recreational vehicle
lot in an area of a mobile home park in this State other than an area
designated as a recreational vehicle lot pursuant to the provisions of
subsection 6 of NRS 40.215.
Sec. 2. (Deleted by amendment.)
Sec. 6. NRS 118A.380 is hereby amended to read as follows:
118A.380 1. If the landlord is required by the rental
agreement or this chapter to supply heat, air-conditioning, running
water, hot water, electricity, gas, a functioning door lock or another
essential item or service and the landlord willfully or negligently
fails to do so, causing the premises to become unfit for habitation,
the tenant shall give written notice to the landlord specifying the
breach. If the landlord does not adequately remedy the breach, or
use his or her best efforts to remedy the breach within 48 hours,
except a Saturday, Sunday or legal holiday, after it is received by
the landlord, the tenant may, in addition to any other remedy:
(a) Procure reasonable amounts of such essential items or
services during the landlords noncompliance and deduct their
actual and reasonable cost from the rent;
(b) Recover actual damages, including damages based upon the
lack of use of the premises or the diminution of the fair rental value
of the dwelling unit;
(c) Withhold any rent that becomes due during the landlords
noncompliance without incurring late fees, charges for notice or any
other charge or fee authorized by this chapter or the rental
agreement, until the landlord has attempted in good faith to restore
the essential items or services; or
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(d) Procure other housing which is comparable during the

landlords noncompliance, and the rent for the original premises
fully abates during this period. The tenant may recover the actual
and reasonable cost of that other housing which is in excess of the
amount of rent which is abated.
2. If the tenant proceeds under this section, the tenant may not
proceed under NRS 118A.350 and 118A.360 as to that breach.
3. The rights of the tenant under this section do not arise until
the tenant has given written notice as required by subsection 1,
except that the tenant may, without having given that notice:
(a) Recover damages as authorized under paragraph (b) of
subsection 1 if the landlord:
(1) Admits to the court that the landlord had knowledge of
the lack of such essential items or services; or
(2) Has received written notice of the uninhabitable
condition caused by such a lack from a governmental agency
authorized to inspect for violations of building, housing or health
codes.
(b) Withhold rent under paragraph (c) of subsection 1 if the
landlord:
(1) Has received written notice of the condition constituting
the breach from a governmental agency authorized to inspect for
violations of building, housing or health codes; and
(2) Fails to remedy or attempt in good faith to remedy the
breach within the time prescribed in the written notice of that
condition from the governmental agency.
4. The rights of the tenant under paragraph (c) of subsection 1
do not arise unless the tenant is current in the payment of rent at the
time of giving written notice pursuant to subsection 1.
5. If such a condition was caused by the deliberate or negligent
act or omission of the tenant, a member of his or her household or
other person on the premises with his or her consent, the tenant has
no rights under this section.
118A.390 1. If the landlord unlawfully removes the tenant
from the premises or excludes the tenant by blocking or attempting
to block the tenants entry upon the premises , [or] willfully
interrupts or causes or permits the interruption of any essential item
or service required by the rental agreement or this chapter [,] or
otherwise recovers possession of the dwelling unit in violation of
NRS 118A.480, the tenant may recover immediate possession
pursuant to subsection 4, proceed under NRS 118A.380 or terminate
the rental agreement and, in addition to any other remedy, recover
the tenants actual damages, receive an amount not greater than
[$1,000] $2,500 to be fixed by the court, or both.
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2. In determining the amount, if any, to be awarded under

subsection 1, the court shall consider:
(b) The course of conduct between the landlord and the tenant;
and
(c) The degree of harm to the tenant caused by the landlords
conduct.
3. If the rental agreement is terminated pursuant to subsection
1, the landlord shall return all prepaid rent and security recoverable
under this chapter.
4. Except as otherwise provided in subsection 5, the tenant may
recover immediate possession of the premises from the landlord by
filing a verified complaint for expedited relief for the unlawful
removal or exclusion of the tenant from the premises , [or] the
willful interruption of any essential [services.] item or service or the
recovery of possession of the dwelling unit in violation of
NRS 118A.480.
5. A verified complaint for expedited relief:
(a) Must be filed with the court within 5 judicial days after the
date of the unlawful act by the landlord, and the verified complaint
must be dismissed if it is not timely filed. If the verified complaint
for expedited relief is dismissed pursuant to this paragraph, the
tenant retains the right to pursue all other available remedies against
the landlord.
(b) May not be filed with the court if an action for summary
eviction or unlawful detainer is already pending between the
landlord and tenant, but the tenant may seek similar relief before the
judge presiding over the pending action.
6. The court shall conduct a hearing on the verified complaint
for expedited relief [within] not later than 3 judicial days after the
filing of the verified complaint for expedited relief. Before or at the
scheduled hearing, the tenant must provide proof that the landlord
has been properly served with a copy of the verified complaint for
expedited relief. Upon the hearing, if it is determined that the
landlord has violated any of the provisions of subsection 1, the court
may:
(a) Order the landlord to restore to the tenant the premises or
essential items or services, or both;
(b) Award damages pursuant to subsection 1; and
(c) Enjoin the landlord from violating the provisions of
subsection 1 and, if the circumstances so warrant, hold the landlord
in contempt of court.
7. The payment of all costs and official fees must be deferred
for any tenant who files a verified complaint for expedited relief.
After any hearing and not later than final disposition of the filing or
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order, the court shall assess the costs and fees against the party that
does not prevail, except that the court may reduce them or waive
them, as justice may require.
118A.480 The landlord shall not recover or take possession of
the dwelling unit by action or otherwise, including willful
diminution or interruption or causing or permitting the diminution
or interruption of any essential item or service required by the rental
agreement or this chapter, except:
1. By an action for possession or other civil action or summary
proceeding in which the issue of right of possession is determined;
2. When the tenant has surrendered possession of the dwelling
unit to the landlord; or
3. When the tenant has abandoned the dwelling unit as
provided in NRS 118A.450.
118A.510 1. Except as otherwise provided in subsection 3,
the landlord may not, in retaliation, terminate a tenancy, refuse to
renew a tenancy, increase rent or decrease essential items or
services required by the rental agreement or this chapter, or bring or
threaten to bring an action for possession if:
(a) The tenant has complained in good faith of a violation of a
building, housing or health code applicable to the premises and
affecting health or safety to a governmental agency charged with the
responsibility for the enforcement of that code;
(b) The tenant has complained in good faith to the landlord or a
law enforcement agency of a violation of this chapter or of a
specific statute that imposes a criminal penalty;
(c) The tenant has organized or become a member of a tenants
union or similar organization;
(d) A citation has been issued resulting from a complaint
described in paragraph (a);
(e) The tenant has instituted or defended against a judicial or
administrative proceeding or arbitration in which the tenant raised
an issue of compliance with the requirements of this chapter
respecting the habitability of dwelling units;
(f) The tenant has failed or refused to give written consent to a
regulation adopted by the landlord, after the tenant enters into
the rental agreement, which requires the landlord to wait until the
appropriate time has elapsed before it is enforceable against the
tenant; or
(g) The tenant has complained in good faith to the landlord, a
government agency, an attorney, a fair housing agency or any other
appropriate body of a violation of NRS 118.010 to 118.120,
inclusive, or the Fair Housing Act of 1968, 42 U.S.C. 3601
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et seq., or has otherwise exercised rights which are guaranteed or

protected under those laws.
2. If the landlord violates any provision of subsection 1, the
tenant is entitled to the remedies provided in NRS 118A.390 and has
a defense in any retaliatory action by the landlord for possession.
3. A landlord who acts under the circumstances described in
subsection 1 does not violate that subsection if:
(a) The violation of the applicable building, housing or health
code of which the tenant complained was caused primarily by the
lack of reasonable care by the tenant, a member of his or her
household or other person on the premises with his or her consent;
(b) The tenancy is terminated with cause;
(c) A citation has been issued and compliance with the
applicable building, housing or health code requires alteration,
remodeling or demolition and cannot be accomplished unless the
tenants dwelling unit is vacant; or
(d) The increase in rent applies in a uniform manner to all
tenants.
The maintenance of an action under this subsection does not
prevent the tenant from seeking damages or injunctive relief for the
landlords failure to comply with the rental agreement or maintain
the dwelling unit in a habitable condition as required by this chapter.
H
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Print
Close
LITIGATION HOLD NOTICE rev2011-001708 cv11-03628,

60331 61383
Sent: Mon 10/15/12 5:03 PM
To: patrickk@nvbar.org; davidc@nvbar.org; nvscclerk@nvcourts.nv.gov
4 attachments
sbn v coughlin CASE NUMBER NG12-0204, NG-0435, NG 0434 combined filing 10 15 12.pdf
(378.5 KB) , DistCtOrder_REDACTED cr12-1018 longoni transcript defective.pdf (141.4 KB) ,
rev2011-001708 opposition to coughlin's second motion to contest personal property lien
merliss hill sbn.pdf (3.2 MB) , CR12-1262-3059269 transcript from criminal trespass trial
testimony of richard hill and his associate before RMC Judge William Gardner.pdf (3.5 MB)
Mr. King,
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).
You might want to look at AB226 and the Committee on the Judiciary notes from March 31, 2011.
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
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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:
(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 remove the
tenant within 24 hours after receipt of the order. The affidavit must state or contain:
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(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess of the
first months rent, by the tenant.
40.280.
(7) A statement that the written notice was served on the tenant in accordance with NRS
(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.
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
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 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
001233
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:
NRS 118A.242 Security: Limitation on amount or value; surety bond in lieu of security; duties and liability of landlord; damages;
disputing itemized accounting of security; prohibited provisions.
1. The landlord may not demand or receive security or a surety bond, or a combination thereof, including the last months rent, whose
total amount or value exceeds 3 months periodic rent.
2. In lieu of paying all or part of the security required by the landlord, a tenant may, if the landlord consents, purchase a surety bond to
secure the tenants obligation to the landlord under the rental agreement to:
001234
(a) Remedy any default of the tenant in the payment of rent.

(b) Repair damages to the premises other than normal wear and tear.
(c) Clean the dwelling unit.
3. The landlord:
(a) Is not required to accept a surety bond purchased by the tenant in lieu of paying all or part of the security; and
(b) May not require a tenant to purchase a security bond in lieu of paying all or part of the security.
4. Upon termination of the tenancy by either party for any reason, the landlord may claim of the security or surety bond, or a
combination thereof, only such amounts as are reasonably necessary to remedy any default of the tenant in the payment of rent, to repair
damages to the premises caused by the tenant other than normal wear and to pay the reasonable costs of cleaning the premises. The landlord
shall provide the tenant with an itemized written accounting of the disposition of the security or surety bond, or a combination thereof, and
return any remaining portion of the security to the tenant no later than 30 days after the termination of the tenancy by handing it to the
tenant personally at the place where the rent is paid, or by mailing it to the tenant at the tenants present address or, if that address is
unknown, at the tenants last known address.
5. If a tenant disputes an item contained in an itemized written accounting received from a landlord pursuant to subsection 4, the tenant
may send a written response disputing the item to the surety. If the tenant sends the written response within 30 days after receiving the
itemized written accounting, the surety shall not report the claim of the landlord to a credit reporting agency unless the surety obtains a
judgment against the tenant.
6. If the landlord fails or refuses to return the remainder of a security deposit within 30 days after the end of a tenancy, the landlord is
liable to the tenant for damages:
(a) In an amount equal to the entire deposit; and
(b) For a sum to be fixed by the court of not more than the amount of the entire deposit.
7. In determining the sum, if any, to be awarded under paragraph (b) of subsection 6, the court shall consider:
(b) The course of conduct between the landlord and the tenant; and
(c) The degree of harm to the tenant caused by the landlords conduct.
NRS 118A.360 Failure of landlord to comply with rental agreement or maintain dwelling unit in habitable condition where cost of
compliance less than specified amount.
1. If the landlord fails to comply with the rental agreement or his or her obligation to maintain the dwelling unit in a habitable condition
as required by this chapter, and the reasonable cost of compliance or repair is less than $100 or an amount equal to one months periodic
rent, whichever amount is greater, the tenant may recover damages for the breach or notify the landlord of the tenants intention to correct
the condition at the landlords expense. If the landlord fails to use his or her best efforts to comply within 14 days after being notified by the
tenant in writing or more promptly if conditions require in case of emergency, the tenant may cause the work to be done in a workmanlike
manner and after submitting to the landlord an itemized statement, the tenant may deduct from his or her rent the actual and reasonable cost
or the fair or reasonable value of the work, not exceeding the amount specified in this subsection.
2. The landlord may specify in the rental agreement or otherwise that work done under this section and NRS 118A.380must be
performed by a named person or firm or class of persons or firms qualified to do the work and the tenant must comply with the
specifications. If the person qualified to do the work is unavailable or unable to perform the repairs the tenant shall use another qualified
person who performs repairs.
3. A tenant may not repair at the landlords expense if the condition was caused by the deliberate or negligent act or omission of the
tenant, a member of the tenants household or other person on the premises with his or her consent.
4. The landlords liability under this section is limited to $100 or an amount equal to one months periodic rent, whichever amount is
greater, within any 12-month period.
5. A tenant may not proceed under this section unless the tenant has given notice to the landlord that the dwelling is not in a habitable
condition as required by this chapter.
001235
NRS 118A.355 Failure of landlord to maintain dwelling unit in habitable condition.

1. Except as otherwise provided in this chapter, if a landlord fails to maintain a dwelling unit in a habitable condition as
required by this chapter, the tenant shall deliver a written notice to the landlord specifying each failure by the landlord to
maintain the dwelling unit in a habitable condition and requesting that the landlord remedy the failures. If a failure is
remediable and the landlord adequately remedies the failure or uses his or her best efforts to remedy the failure within 14
days after receipt of the notice, the tenant may not proceed under this section. If the landlord fails to remedy a material
failure to maintain the dwelling unit in a habitable condition or to make a reasonable effort to do so within the prescribed
time, the tenant may:
(a) Terminate the rental agreement immediately.
(b) Recover actual damages.
(c) Apply to the court for such relief as the court deems proper under the circumstances.
(d) Withhold any rent that becomes due without incurring late fees, charges for notice or any other charge or fee
authorized by this chapter or the rental agreement until the landlord has remedied, or has attempted in good faith to remedy,
the failure.
2. The tenant may not proceed under this section:
(a) For a condition caused by the tenants own deliberate or negligent act or omission or that of a member of his or her
household or other person on the premises with his or her consent; or
(b) If the landlords inability to adequately remedy the failure or use his or her best efforts to remedy the failure within 14
days is due to the tenants refusal to allow lawful access to the dwelling unit as required by the rental agreement or this
chapter.
3. If the rental agreement is terminated, the landlord shall return all prepaid rent and security recoverable by the tenant
under this chapter.
4. A tenant may not proceed under this section unless the tenant has given notice as required by subsection 1, except
that the tenant may, without giving that notice:
(a) Recover damages under paragraph (b) of subsection 1 if the landlord:
(1) Admits to the court that the landlord had knowledge of the condition constituting the failure to maintain the
dwelling in a habitable condition; or
(2) Has received written notice of that condition from a governmental agency authorized to inspect for violations of
building, housing or health codes.
(b) Withhold rent under paragraph (d) of subsection 1 if the landlord:
(1) Has received written notice of the condition constituting the failure to maintain the dwelling in a habitable
condition from a governmental agency authorized to inspect for violations of building, housing or health codes; and
(2) Fails to remedy or attempt in good faith to remedy the failure within the time prescribed in the written notice of
that condition from the governmental agency.
5. Justice courts shall establish by local rule a mechanism by which tenants may deposit rent withheld
under paragraph (d) of subsection 1 into an escrow account maintained or approved by the court. A tenant
does not have a defense to an eviction under paragraph (d) of subsection 1 unless the tenant has deposited
the withheld rent into an escrow account pursuant to this subsection.
Mr's. Baker and HIll, would you not say it more accurate to characterize the situation in rev2011-001708 as one fitting under the NRS
118A.355 heading, particulary where the RJC, at the time of that summary eviction "Trial" had, according to Judge Sferrazza, no "local
rule" or "mechanism by which tenants may deposit rent withheld under paragraph..." and therfore acknowledging the brilliance in
Coughlin's JCRLV Rule 44 corollary in the RJC argument? Certainly, under the NRS 118A.355 analysis, after one strips away the agreed
to $350 for weeds maintenance (which kind of amounts to a waiver of term in the Standard Rental Agreement that Judge Sferrazza
interprets to require such "care" of the "lawn and surrounding grounds" (which, to the Court, apparently, included "weeds"), doesn't it?),
and the agreed upon credit for fixing the stairs, well, then, and other amounts fit quite nicely into the "fix and deduct" approach set forth in
NRS 118A.360. But, regardless, you proceeded under a No Cause Eviction basis, but against a commercial tenant, a fact you are stuck
with, as the Tenant's Answer, numerous phone calls to Baker, and many, many instances throughout the filings in that matter make clear
thta this was Coughlin's home law office, a commercial lease which the Standard Rental Agreement specifically allows for. And take a look
at that 2008 Winchell v Schiff seafood business goes under because of wrongful eviction case wherein damages accounting for the loss of
one's entire business (and what is a patent attorney's business worth, do you think, Dr. Merliss?) are allowable under Nevada law. Please
remit $450,000 to me within 7 days of this email being sent to you in satisfaction of this dispute against you, Dr. Merliss. Richard and
Casey, I will deal with you later, but your liability is on par with Dr. Merliss's, no doubt, and that is before the FDCPA stuff and the fact
001236
that your office is not licensed as a bill collector.
Further,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel and Fax 949 667 7402
001237
001238
001239
001240
001241
FILED
Electronically
04-20-2012:03:49:12 PM
Clerk of the Court
001242
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001247
A.B. 226 STATE COMPARISON CHART
STATE
Alaska
STATUTE
Alaska Stat. 09.45.090 (c)

Alaska Stat. 09.45.110
AK Civil Rule 85
NOTICE TO
QUIT-TIME TO
CURE OR
VACATE
7 Calendar days. If
sent by registered or
certified mail, then
an additional 3 days
provided
WHEN LAWSUIT CAN BE

FILED
On the 8th day. Tenant need not file a
written answer to summary eviction.
Alaska Stat. 09.45.120
Arizona
Ariz. Rev. Stat. 33-1368

Ariz. Rev. Stat. 33-1377
RULES FOR SETTING COURT HEARINGS RULES FOR SERVICE OF

WRIT BY SHERIFF
Summary trial must be held at least two days after service
of summons and complaint for eviction, and not more
than 15 days after case is filed. AK Civil Rule 85.
TIME UNTIL
EVICTION
Sheriff authorized to serve, but

timelines unspecified.
10 days to 24 days.
Landlord may apply within 5 days of

judgment. Landlord may discontinue
utilities on the day following
execution of writ.
15 days to 18 days.
Writ of possession gives tenant 5

days upon service to leave
voluntarily.
14 days if
uncontested. 34
days if contested.
No continuance longer than 2 days without assurances

given to landlord.
5-day notice
On the 6th day. No written response

required. Once the lawsuit is filed, tenant
can still cure by paying all past due rent
and legal fees.
Summary trial must be held not more than 6 days from

the date of the summons.
No continuance for longer than 3 days in justice court for
5 days in superior court.
California
Cal. Code Civ. Pro 1161

Cal. Code Civ. Pro 1170.5
3-day notice.
On the 4th day. Tenant is allowed 5 days

to file a written response.
Trial required only if contested. Must be held within 20

days.
Colorado
Colo. Rev. Stat. 13-40-104
3-day notice.
On the 4th day. No written answer

required.
Summons must be served no less than 5 business days nor Writ of restitution issued after 48
more than 10 calendar days from the date it was issued.
hours of judgment.
Summons must also be served at least 5 business days prior
to the scheduled trial.
11 days to 16 days.
Idaho
Idaho Code Ann. 6-303
3 business days
notice.
On next business day.
Summary trial is available within 5 to 12 days after

tenant is served with summons.
9 days to 16 days.
Unspecified.
1
0012
001248

STATE
Nevada
STATUTE
NRS 40.253
NOTICE TO
QUIT-TIME TO
CURE OR
VACATE
5-day notice.
Supreme Court of
Nevada instructions
interpret this as
judicial days.
WHEN LAWSUIT CAN BE

FILED
Noon of the 5th judicial day after service
of the notice. Tenant must file an
affidavit indicating that he is not in
default to avoid a lock-out.
Nevada JCRCP 104

Las Vegas JCR 34

WRIT BY SHERIFF
Court will set a hearing if tenant files an affidavit. If
tenant does not file an affidavit, the court may or may not
hold a hearing. The court may enter an order based solely
on landlords declaration for summary eviction. Once
the order is singed, landlord may lock out.
TIME UNTIL
EVICTION
6 judicial days to 8
judicial days if
uncontested. If
contested, it
depends on justice
court schedule. In
Las Vegas, 13 to 15
days.
Justice court rules allow individual courts to set

schedules for hearings.
Issued within 24 hours of judgment
New
Mexico
N.M. Stat. 47-8-33

N.M. Stat. 47-8-43
N.M. Stat. 47-8-46
3-day notice.
On the 4th day.
Matter brought by owner for possession must be held not

less than 7 nor more than 10 days after service of
summons.
Matter brought by tenant for possession must be held not
less than 3 nor more than 5 days after service of
summons.
Continuance of trial allowed up to 7 days.
If owner prevails, writ must be

served not less than 3 nor more than
7 days post judgment.
If tenant prevails, writ must be
served within 24 hours post
judgment.
14 days to 21 days.
Oregon
Or. Rev. Stat. 90.394,

90.392
72 hours if rent is 7
days late, or 144
hours if rent is 5
days late.
On the 4th day.
A first appearance hearing is scheduled 7 days after

service of summons.
Tenant must move within 4 days of

notice of writ.
15 days if
uncontested, 30
days if contested.
Tenant must move within 3 calendar

days of order of restitution.
20 days.
Tenant must appear and file an answer at first appearance

if he wants to contest the eviction.
Trail will be held within 15 days of the first appearance.
Utah
Utah code Ann. 78B-6-802

Utah Code Ann. 78B-6-812
3-day notice
th
On the 4 day. Tenant is allowed days to

respond upon service of summons.
Tenant must file a written response or
default.
Either party may request a hearing after the complaint is

filed. Hearing will be set within 10 days of tenant filing
an answer.
2
001249
K-2

STATE
STATUTE
Washington
Wash. Rev. Code 59.12.030
NOTICE TO
QUIT-TIME TO
CURE OR
VACATE
3-day notice.
WHEN LAWSUIT CAN BE

FILED
On the 4th day.

WRIT BY SHERIFF
Trial date must not be less than 7 days norm ore than 30
from the date of service.
A writ of restitution may be applied

for while the case is pending, with
posting of a bond.
TIME UNTIL
EVICTION
11 days to 34 days.
If upon entry judgment for nonpayment of rent, the terms

of the lease have not expired., tenant has 5 days to pay
the judgment and costs to be restored to the estate.
In all other cases, judgment may be enforced
immediately.
3
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K-3
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EagleWeb for Washoe County
Washoe County Search Results

Document Search
My Documents
Help
About
Logout Public
Fictitious Firm Name - Counter - 74040

Filing Information
Filing Number
74040
Filing Date
04/01/1997 12:00:00 AM
Expiration Date
04/01/2002
Images
Business Information
Business Name
NORTHWIND APARTMENTS
No Image
Owner Information
Owner/Corporate Name
NORTHWIND APARTMENT ASSOCIATES, LLC
Book Page
001254
file:///R|/...%20temp/EagleWeb%20for%20Washoe%20County%20northwind%20apartments%20dba%20rjc%20rpd%20wcso%20ncs.htm[12/10/2012 3:09:46 PM]
001255
001256
001257
001258
001259
001260
001261
001262
001263
001264
001265
001266
001267
001268
001269
001270
001271
001272
001273
001274
001275
001276
001277
001278
001279
001280
001281
001282
001283
Washoe Legal Services, Paul Elcano, et all

zach coughlin
x
Please see the attached letter providing all the

required information, resident agents, addresses,
etc.
available
Case: CV11-01896 ZACH COUGHLIN VS. WASHOE LEGAL SERVICES ET AL.(D6)
Plaintiff 27-JUN-2011
@1206272 COUGHLIN, ZACH unavailable
Case: CV11-01955 ZACHARY COUGHLIN VS. WASHOE LEGAL SRVC, ET AL(D10)
Pla
available
Case: CV11-01896 ZACH COUGHLIN VS. WASHOE LEGAL
SERVICES ET AL.(D6) Plaintiff 27-JUN-2011
Case: CV11-01955 ZACHARY COUGHLIN VS. WASHOE LEGAL
SRVC, ET AL(D10)
Pla
please see signature on attached letter.
775 338 8118
001284
Matt Merliss , et al
Zach Coughlin
rev2011-001492 and
rev2011-001708
x
this is a counterclaim in a summary
eviction action, as such the summons is
essentially the unlawful detainer notice
filed by the Plaintiff
Please see signature on attached letter
001285
Zach Coughlin, Esq.

121 River Rock St.
Reno, NV 89501
Tele: 775 338 8118;
Fax: 949 667 7402
Licensed in Nevada
Dear Washoe County Sheriff's Office Civil Process Division

Please find below the names, firm names search results, resident agents, etc for the parties that need to
be served in the different actions for which I have been granted a fee waiver or In Forma Pauperis
status.
First is for the fee waiver granted in cases in District Court for the 2nd Judicial District, Washoe County:
Case: CV11-01896 ZACH COUGHLIN VS. WASHOE LEGAL SERVICES ET AL.(D6)
Plaintiff
27-JUN-2011
Case: CV11-01955 ZACHARY COUGHLIN VS. WASHOE LEGAL SRVC, ET AL(D10)
Plaintiff
30-JUN-2011
These cases are pretty much the same cases, except the second was filed due to the danger of the IFP
being denied and having the 90 day deadline to file after receipt of a Right to Sue letter from the EEOC
pass in the interim while waiting for a decision on the fee waiver. There is a pending motion to
combine these cases. As such, all defendants should be served the Complaint and Summons in both
cases. Attached is a copy of the Order granting the fee waiver, and a list of the persons or resident
agents that need to be served is included below:
PAUL DAVID ELCANO Address 1:
156 GREENRIDGE DRIVE
Address 2:
RENOState: NV Zip Code:
89509 # Email: pelcano@washoelegalservices.org
City:
Caryn Sternlicht, Esq.:1731 Glen Oaks Dr Reno, NV 89523

Tahoe Women's Services: www.tahoewomenservices.org - 948 Incline Way, Incline Village, NV (775) 298-0010 INCLINE VILLAGE, NEVADA (Washoe County)
948 Incline Way
Incline Village, NV 89451
(775) 298-0010
CAAW, Committee to Aid Abused Women: Office: 1735 Vassar Street Reno, NV 89502 Phone: (775)
329-4150 Fax: (775) 785-7550 Email: caaw_reno@charter.net Board of Directors Kathy Boyce
Rayleen Cudworth Jim Durand, LCSW Secretary Kari Earle Sharon Gibbons Chairperson
Diana Lee Vice Chairperson Cory Hernandez Treasurer
1
001286
Melissa Mangiaracina, Karen Sabo, Jon Sasser, Marc Ashley, Zandra Lopez, Caryn Sternlicht all
work at Washoe Legal Services at 299 South Arlington Ave. Reno NV 89501 tel 775 329 2727
Kathleen T. Breckenridge * Company: Kathleen T. Breckenridge Ltd. * Address: 462 Court Street
Reno , NV 89501 * Phone Number: 775-786-5055 * Fax number: 775-786-8449 * Email:
kathy@kbreckenridgelaw.com * Website: No information provided * Primary Practice Location:
Reno , NV * Admit Date: 10/13/97 * Law School: University of the Pacific, McGeorge School of Law
* Interest Areas: No information provided * Specialization: Family Law * Professional Liability
Insurance: No * Disciplinary Actions: Current Member Status Attorney Active * Bar Number: 6459
WASHOE LEGAL SERVICES Business Entity Information Status:
ActiveFile Date:
8/26/1965 Type:
Domestic Non-Profit Corporation Entity Number:
C1420-1965
Qualifying State:
NV List of Officers Due: 8/31/2012 Managed By:
Expiration
Date: NV Business ID:
NV19651001269
Business License Exp:
Additional
Information Central Index Key:
Registered Agent Information Name:
PAUL ELCANO JR
Address 1:
299 S ARLINGTON AVENUE Address 2:
City: RENO State: NV
Zip Code:
89501 Phone:
Fax: Mailing Address 1:
Mailing
Address 2:
Mailing City:
Mailing State:
NV Mailing Zip Code:
Agent Type: Noncommercial Registered Agent View all business entities under this registered
agent Financial Information No Par Share Count: 0
Capital Amount:
$ 0 No stock records
found for this company Officers
Include Inactive Officers President - JOHN DESMOND Address
1:
100 WEST LIBERTY STREET, 12TH FLOOR Address 2:
City: RENO
State:
NV Zip Code:
89504 Country:
USA Status: Historical
Email: President - JOHN
DESMOND Address 1:
300 EAST SECOND STREET, SUITE 1510
Address 2:
City:
RENO State: NV Zip Code:
89504 Country:
USA Status: ActiveEmail: Director PAUL ELCANO Address 1: 650 TAHOE STREET
Address 2:
City: RENO
State:
NV Zip Code:
89509 Country:
Status:
Historical
Email: Director - PAUL
ELCANO Address 1: 299 SOUTH ARLINGTON AVENUE
Address 2:
City: RENO
State: NV Zip Code:
89501 Country:
Status:
ActiveEmail: Treasurer JIM PROCTOR Address 1: 5420 KIETZKE LANE
Address 2:
SUITE 108 City:
RENO
State: NV Zip Code:
89511 Country:
Status:
Historical
Email:
Secretary - JIM PROCTOR Address 1:
5420 KIETZKE LANE
Address 2:
SUITE 108
City: RENO
State: NV Zip Code:
89511 Country:
Email: Treasurer - JIM PROCTOR Address 1:
200 RIDGE STREET
Address 2:
SUITE 240 City:
RENO
State: NV Zip Code:
89501 Country:
Status:
Active Email: Secretary - JIM PROCTOR Address 1:
200 RIDGE STREEET
Address 2:
SUITE 240 City:
RENO
State: NV Zip Code:
89501 Country:
USA Status:
Active Email:
Todd L. Torvinen * Company: No information provided * Address: 232 Court Street Reno , NV 89501
* Phone Number: 775-825-6066 * Fax number: 775-322-5484 * Email: toddtorvinen@sbcglobal.net *
Website: No information provided * Primary Practice Location: Reno , NV * Admit Date: 12/16/87 *
Law School: U. of Arizona * Interest Areas: No information provided * Specialization: None *
Professional Liability Insurance: Yes * Disciplinary Actions: Current Member Status Attorney Active *
Bar Number: 3175
2
001287
Next is the Summary Eviction/Complaint small claims action in Reno Justice Court for
rev2011-001708. Attached is a copy of the Order granting the fee waiver, and a list of the persons or
resident agents that need to be served is included below:
Fictitious Firm Name - 95195 Filing Information Filing Number 95195 Filing Date 05/09/2003
12:00:00 AM Expiration Date 05/08/2008 Business Information Business Name GREEN ACTION
LAWN SERVICE Owner Information Owner/Corporate Name NERY R MACAL-CRUZ
Darlene Sharpe
Dickson Realty - Damonte Ranch
500 Damonte Ranch Pkwy 625
Reno, NV 89521
(775) 850-7000
Richard G. Hill, Esq.
Casey D. Baker, Esq.
652 Forest Street
Reno, NV 89509
Attorneys for Matthew Merliss
NV ENERGY, INC. Business Entity Information Status: ActiveFile Date:
12/12/1983 Type:
Domestic Corporation
Entity Number:
C8123-1983 Qualifying State:
NV List of
Officers Due: 12/31/2011 Managed By:
Expiration Date:
NV Business ID:
NV19831015840
12/31/2011 Registered Agent Information Name:
GREGG P. BARNARD
Address 1:
6100 NEIL ROAD Address 2:
STE. 500
City:
RENO State: NV Zip Code:
895111149 Phone:
Mailing Address 2: Mailing City:
Mailing State:
Mailing Zip Code:
Agent Type: Noncommercial Registered Agent
DICKSON REALTY, INC. Business Entity Information (note: I think just the resident agent or a
director is all that is required) Status:
ActiveFile Date:
6/18/1996 Type:
Domestic
Corporation Entity Number:
C13338-1996 Qualifying State:
NV List of Officers Due:
6/30/2012 Managed By:
Expiration Date:
NV Business ID:
NV19961141961
6/30/2012 Additional Information Central Index Key:
Registered Agent Information Name:
AVANSINO MELARKEY KNOBEL & MULLIGAN
Address 1:
4795 CAUGHLIN PARKWAY SUITE 100 Address 2:
City: RENO
State: NV Zip Code:
89519 Phone:
Mailing Address 2: Mailing City:
Mailing State:
Mailing Zip Code:
Agent Type: Noncommercial Registered Agent Financial Information No Par Share
Count:
25,000.00
Capital Amount:
$ 0 No stock records found for this company
Officers
Include Inactive Officers Director - REBECCA A DICKSON Address 1: 500
DAMONTE RANCH PARKWAY #675
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Email: Director - REBECCA A DICKSON
Address 1:
500 DAMONTE RANCH PARKWAY #675
Address 2:
City: RENO
3
001288
State: NV Zip Code:

89521 Country:
USA Status: ActiveEmail: Treasurer HARVEY C FENNELL Address 1: 500 DAMONTE RANCH PARKWAY #675
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
Historical
Email: Director - HARVEY FENNELL Address 1:
500 DAMONTE RANCH
PARKWAY, #625
Address 2:
City: RENO
State: NV Zip Code:
89521
Country:
Status:
Historical
Email: Treasurer - HARVEY C FENNELL
Address 1:
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
ActiveEmail: Director HARVEY FENNELL Address 1:
500 DAMONTE RANCH PARKWAY, #625
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
ActiveEmail:
President - NANCY P FENNELL Address 1:
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
Historical
Email: Director - NANCY FENNELL Address 1: 1030 CAUGHLIN
CROSSING Address 2:
City: RENO
State: NV Zip Code:
89519 Country:
Status:
Historical
Email: President - NANCY P FENNELL Address 1:
500
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
ActiveEmail: Director - NANCY FENNELL Address 1:
1030 CAUGHLIN CROSSING
Address 2:
City: RENO
State: NV Zip Code:
89519 Country:
Status:
ActiveEmail: Director - JEFF GIESLER Address 1:
500
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Email: Director - JEFF GIESLER Address
1:
Address 2:
City: RENO
State:
NV Zip Code:
89521 Country:
USA Status: ActiveEmail: Secretary - DAN RIDER
Address 1:
500 DAMONTE RANCH PKWY Address 2:
SUITE 675 City:
RENO
State: NV Zip Code:
89521 Country:
Status:
Historical
Email:
Director - DAN RIDER Address 1: 500 DAMONTE RANCH PARKWAY, #625
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
Historical
Email: Secretary - DAN RIDER Address 1:
500 DAMONTE RANCH PKWY
Address 2:
SUITE 675 City:
RENO
State: NV Zip Code:
89521
Country:
Status:
ActiveEmail: Director - DAN RIDER Address 1: 500
DAMONTE RANCH PARKWAY, #625
Address 2:
City: RENO
State: NV Zip Code:
89521 Country:
Status:
ActiveEmail:
Sincerely,
Zach Coughlin, Esq.
4
001289
** Notice** This message and accompanying documents are covered by the electronic
Communications Privacy Act, 18 U.S.C. 2510-2521, and may contain confidential information
intended for the specified individual (s) only. If you are not the intended recipient or an agent
responsible for delivering it to the intended recipient, you are hereby notified that you have received
this document in error and that any review, dissemination, copying, or the taking of any action based on
the contents of this information is strictly prohibited.
5
001290
Electronically Filed
Apr 13 2012 04:21 p.m.
Tracie K. Lindeman
Clerk of Supreme Court
001291
Docket 60331 Document 2012-11964
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001386
001387
Paul D. Elcano, Jr. - Lawyer in Reno, Nevada (NV) - Lawyers.com
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001388
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001389
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Page 1 of 5

Case ID:
CR12-1262
Docket Start Date:
Docket Ending Date:
Case Description
Case ID:
Filing Date:
Type:
Status:
CR12-1262 - ZACHARY COUGHLIN VS. CITY OF RENO (D10)

Wednesday, July 25th, 2012
MO - OTHER MUNICIPAL COURT CRIMINAL
Related Cases
No related cases were found.
Case Event Schedule
Case Parties
Seq #
Assoc
Expn
Date
ID
Name
Judge
Type
D10
ELLIOTT,
HONORABLE
STEVEN P.
4,5
Address: P.O. Box 1900
Aliases: none
Appellant
@1206272 COUGHLIN,
ZACHARY
CAUGHLIN, ZACHARY
COUGHLIN, ZACHARY
COUGHLIN, ZACH
COUGHLIN, ZACKARY
Respondent
RENO
CITY OF RENO
Aliases: none
001390
Page 2 of 5
Office of the City

Attorney
Reno NV 89505
City Attorney
Address: JILL E. DRAKE

DEPTY ATTORNEY
GENERAL
100 N. CARSON
STREET
CARSON CITY NV
89701-4717
Drake, Jill E.
Aliases: none
City Attorney
Address: 300 E Second St,

Ste 1200
Reno NV 89501
8045
10075
Hazlett-Stevens, Esq.,
Chris
Aliases: none
Pro PerPltf/Pet/Appellant

Reno NV 89505
9473
Coughlin, Esq.,
Zachary
Aliases: none
Docket Entries
Filing Date
Description
Name
25-JUL-2012
11:36 AM
Appeal from Municipal's Court
Entry:
none.
25-JUL-2012
03:36 PM
** Exhibit(s) ...
Entry:
CITY'S EXHIBITS 1, 2, and 3 LOCATED IN EXHIBIT ROOM
30-JUL-2012
03:57 PM
Addendum
Monetary
CITY OF RENO,
001391
Entry:
Page 3 of 5
ADDENDUM TO CERTIFIED COPY OF DOCKET FROM RENO

MUNICIPAL COURT
31-JUL-2012
07:03 AM
Entry:
Transaction 3116927 - Approved By: JYOST : 07-31-2012:08:04:28
31-JUL-2012
07:05 AM
Mtn to Dismiss ...
Entry:
Chris
Chris
MOTION TO DISMISS APPEAL - Transaction 3116928 - Approved By:

JYOST : 07-31-2012:08:03:27
31-JUL-2012
08:06 AM
Entry:
31-JUL-2012
08:07 AM
Entry:
31-JUL-2012
05:17 PM
Entry:
31-JUL-2012
05:18 PM
Entry:
14-AUG-2012 Request for Submission

07:51 AM
Entry:
Chris
CITY OF RENO'S MOTION TO DISMISS - Transaction 3145816 - Approved

By: AZION : 08-14-2012:09:20:23 DOCUMENT TITLE: CITY OF RENO'S
MOTION TO DISMISS PARTY SUBMITTING: CHRIS HAZLETT-STEVENS
ESQ DATE SUBMITTED: 08-14-12 SUBMITTED BY: AZION DATE
001392
Page 4 of 5

09:25 AM
Entry:
15-AUG-2012 Notice of Appearance

11:47 PM
Entry:
ZACH COUGHLIN, PRO SE - Transaction 3151467 - Approved By: JYOST :

08-16-2012:08:13:24
15-AUG-2012 Opposition to Mtn ...

11:50 PM
Entry:
OPPOSITION TO MOTION TO DISMISS - Transaction 3151468 - Approved

By: JYOST : 08-16-2012:08:11:56

08:13 AM
Entry:

08:15 AM
Entry:
27-AUG-2012 Request for Submission

10:09 AM
Complet
Entry:
none.
27-AUG-2012 Ord Dismiss Appeal/Remand

10:10 AM
Entry:

REMANDED 09/12/12 - CERTIFIED COPY OF ORDER GRANTING
RESPONDENT'S MOTION TO DISMISS APPEAL and CITY'S EXHIBITS 1,
2 AND 3 - JYOST

10:12 AM
Entry:
001393
27-AUG-2012 Mtn Alter or Amend Judgment

04:38 PM
Entry:
Page 5 of 5
APPELLANT'S MOTION FOR RECONSIDERATION OF THE ORDER

DISMISSING THE APPEAL, OR FILED IN THE ALTERNATIVE MOTION TO
ALTER AMEND OR SET ASIDE ORDER DISMISSING APPELLANT'S
APPEAL - Transaction 3178319 - Approved By: AZION : 08-272012:16:41:45

04:43 PM
Entry:
12-SEP-2012 General Receipt

02:32 PM
Entry:
none.
29-NOV-2012 Appeal from Municipal's Court

11:50 AM
Entry:
COUGHLIN, ZACHARY
none.
001394
Page 1 of 52

Case ID:
CV11-01955
Docket Start Date:
Docket Ending Date:
Case Description
Case ID:
Filing
Date:
Type:
Status:
CV11-01955 - ZACHARY COUGHLIN VS. WASHOE LEGAL SRVC, ET AL

(D10)
Thursday , June 30th, 2011
WT - TORTS-WRONGFUL TERMINATION
ORD/JUDFLD - Order or Judgement Filed
Related Cases
No related cases were found.
Case Event Schedule
Case Parties
Seq #
Assoc
Expn
Type
Date
Judge
2
ID
D10
Aliases: none
28
Plaintiff
@120627
Aliases: COUGHL
BARKER
CAUGHLI
COUGHL
BARKER
COUGHL
COUGHL
COUGHL
001395
Page 2 of 52
Pro PerPROPER
Pltf/Pet/Appellant
Aliases: none
21
Defendant
Aliases: none
24 4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
Attorney
Address: 9580 West Sahara Ave., Ste 120

Las Vegas NV 89117
Attorney
Address: 9580 WEST SAHARA AVE, STE 120

LAS VEGAS NV 89117
22
Attorney
Address: 121 River Rock St.

Reno NV 89501
125
Aliases: none
23,31
Attorney
Address: 5450 LONGLEY LN

RENO NV 89511
28
8211
Aliases: none

Reno NV 89505
27
6653
Aliases: none
25 4,5,6,7,8,9,10,11,12,13,14,15,16,17,18,19,20
26
@120664
9815
Aliases: none
Attorney
9473
Aliases: none
001396
Page 3 of 52
29
Defendant
Aliases: none
30
Defendant
32
@121897
@121471
Aliases: none
22
Attorney
Address: 9950 W. Cheyenne Ave.

Las Vegas NV 89129
10801
Aliases: none
33
Attorney
Address: 301 E. Clark Ste. 1000

Las Vegas NV 89155
116
Aliases: none
Docket Entries
Filing Date
Description
Name
Monetary
30-JUN-2011 **Civil Cover Sheet

05:04 PM
Entry:
none.
30-JUN-2011 $Complaint - Civil

05:04 PM
Entry:
COUGHLIN, ZACHARY
none.

05:10 PM
001397
Entry:
19-SEP-2011 Mtn to Dismiss ...

02:34 PM
Entry:
Garin, Esq., Joseph P.
PAUL ELCANO - Transaction 2478024 - Approved By: AZION : 09-192011:14:47:25
19-SEP-2011 $Addl Def/Answer - Prty/Appear

02:34 PM
Entry:
WASHOE LEGAL SERVICES - Transaction 2478024 - Approved By:

AZION : 09-19-2011:14:47:25
19-SEP-2011 $Addl Def/Answer - Prty/Appear

02:34 PM
Entry:
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANO'S MOTION TO

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS AND OTHER
RELIEF - Transaction 2478024 - Approved By: AZION : 09-19-2011:14:47:25
19-SEP-2011 $Def 1st Appearance - CV

02:34 PM
Entry:
Page 4 of 52
PAUL ELCANO, EXECUTIVE DIRECTOR OF WASHOE LEGAL SERVICES

- Transaction 2478024 - Approved By: AZION : 09-19-2011:14:47:25
19-SEP-2011 **Payment Receipted

02:50 PM
Entry:
A Payment of $273.00 was made on receipt DCDC329631.
19-SEP-2011 Proof of Electronic Service

02:51 PM
Entry:
05-OCT-2011 Opposition to Mtn ...

03:03 PM
Entry:
COUGHLIN, ZACHARY
OPPOSITION TO DEFENDANT'S WLS AND PAUL ELCANO'S MOTION TO

RELIEFE; MOTION FOR SANCTIONS; MOTION TO CONSOLIDATE
CASES
001398
05-OCT-2011 Proof of Service

03:03 PM
Entry:
COUGHLIN, ZACHARY
BERTA MANN AND JESSICA GARZAC - WASHOE LEGAL SERVICES 08/29/11
07-OCT-2011 Reply to/in Opposition

02:01 PM
Entry:
Page 5 of 52
DEFT'S REPLY IN SUPPORT OF MOTION TO DISMISS FOR

INSUFFICIENT SERVICE OF PROCESS AND OTHER RELIEF Transaction 2518387 - Approved By: AZION : 10-07-2011:14:16:11

02:18 PM
Entry:
10-OCT-2011 Request for Submission

02:53 PM
Entry:
DEFENDANTS' MOTION TO DISMISS FOR INSUFFICIENT SERVICE OF

PROCESS AND OTHER RELIEF, OPPOSITION HAVING BEEN FILED
OCT. 5, 2011, AND REPLY BRIEF FILED OCT. 7, 2011 (NO PAPER
ORDER PROVIDED) - Transaction 2522005 - Approved By: MCHOLICO :
10-10-2011:14:58:49 PARTY SUBMITTING: JOSEPH P. GARIN, ESQ.
DATE SUBMITTED: 10/10/11 SUBMITTED BY: MCHOLICO DATE

03:02 PM
Entry:
02-NOV-2011 Proof of Service

11:03 AM
Entry:
COUGHLIN, ZACHARY
TODD TORVINEN & PAUL ELCANO - OCTOBER 27, 2011
02-NOV-2011 Mtn to Dismiss ...

03:27 PM
Fuller, Esq., Gary

Michael
COMMITTEE TO AID ABUSED WOMAN'S MOTION TO DISMISS

001399
Entry:
COMPLAINT - Transaction 2566972 - Approved By: AZION : 11-022011:15:36:17
02-NOV-2011 $Def 1st Appearance - CV

03:27 PM
Entry:
Page 6 of 52
Fuller, Esq., Gary

Michael
COMMITTEE TO AID ABUSED WOMAN - Transaction 2566972 - Approved

By: AZION : 11-02-2011:15:36:17
02-NOV-2011 **Payment Receipted

03:36 PM
Entry:
02-NOV-2011 Proof of Electronic Service

03:37 PM
Entry:
15-NOV-2011 Motion ...

08:47 AM
Entry:
DEFT PAUL ELCANO'S MOTION TO DISMISS FOR INSUFFICIENT

SERVICE OF PROCESS - Transaction 2588886 - Approved By: AZION : 1115-2011:09:02:34

09:04 AM
Entry:

09:38 AM
Entry:
DEFT TODD TORVINEN'S MOTION TO DISMISS FOR INSUFFICIENT

PROCESS - Transaction 2589204 - Approved By: AZION : 11-152011:09:56:56

09:38 AM
Entry:
TODD TORVINEN - Transaction 2589204 - Approved By: AZION : 11-152011:09:56:56
001400
15-NOV-2011 $Addl Def/Answer - Prty/Appear

09:38 AM
Entry:
Page 7 of 52
TODD TORVINEN AS WASHOE LEGAL SERVICES BOARD MEMBER Transaction 2589204 - Approved By: AZION : 11-15-2011:09:56:56

09:59 AM
Entry:

10:01 AM
Entry:
22-NOV-2011 Summons Filed

01:11 PM
Entry:
MARK ASHLEY SERVED 11/14/11 JON SASSER SERVED 11/14/11

CARYN STERNLICHT SERVED 11/15/11 CAAW BY SERVING DENISE
YOXSIMER SERVED 11/14/11 MELISSA MANGIARACINA SERVED
11/16/11 KAREN SABO SERVED 11/16/11 TAHOE WOMEN SERVICES
AKA TAHOE SAVE ALLIANCE BY SERVING JACKIE DONTCHO 11/09/11
PAUL ELCANO SERVED 11/15/11

12:34 PM
Entry:
DEFENDANT KAREN SABO'S MOTION TO DISMISS FOR NON-SERVICE

OF PROCESS - Transaction 2610560 - Approved By: MCHOLICO : 11-282011:12:55:41

12:34 PM
Entry:
COUGHLIN, ZACHARY
KAREN SABO - Transaction 2610560 - Approved By: MCHOLICO : 11-282011:12:55:41

12:56 PM
Entry:
001401
Page 8 of 52

12:56 PM
Entry:

01:02 PM
Entry:
DEFT KATHY BRECKENRIDGE'S MOTION TO DISMISS FOR

NONSERVICE OF PROCESS AND IN THE ALTERNATIVE INSUFFICIENT
PROCESS - Transaction 2610611 - Approved By: ASMITH : 11-282011:13:44:00

01:02 PM
Entry:
KATHY BRECKENRIDGE - Transaction 2610611 - Approved By: ASMITH :

11-28-2011:13:44:00
28-NOV-2011 $Addl Def/Answer - Prty/Appear

01:02 PM
Entry:
KATHY BRECKENRIDGE, BOARD PRESIDENT OF WLS - Transaction

2610611 - Approved By: ASMITH : 11-28-2011:13:44:00

01:45 PM
Entry:

01:46 PM
Entry:

02:41 PM
Entry:
DEFT MELISSA MANGIARACINA'S MOTION TO DISMISS FOR NONSERVICE OF PROCESS AND IN THE ALTERNATIVE INUFFICIENT
PROCESS - Transaction 2611023 - Approved By: AZION : 11-282011:15:17:36
001402

02:41 PM
Entry:
DEFENDANT JON SASSER'S MOTION TO DISMISS FOR INSUFFICIENT

PROCESS - Transaction 2611097 - Approved By: MCHOLICO : 11-282011:15:00:50

02:56 PM
Entry:
MELISSA MANGIARACINA - Transaction 2611023 - Approved By: AZION :

11-28-2011:15:17:36

02:56 PM
Entry:
Page 9 of 52
JON SASSER - Transaction 2611097 - Approved By: MCHOLICO : 11-282011:15:00:50

03:01 PM
Entry:

03:02 PM
Entry:

03:18 PM
Entry:

03:18 PM
Entry:

03:32 PM
Entry:
DEFT MARC ASHLEY'S MOTION TO DISMISS FOR NON-SERVICE OF

PROCESS AND IN THE ALTERNATIVE INSUFFICIENT PROCESS 001403
Page 10 of 52

03:32 PM
Entry:
MARC ASHLEY - Transaction 2611262 - Approved By: AZION : 11-282011:15:49:58
28-NOV-2011 Initial Appear. Fee Disclosure

03:46 PM
Entry:
Gonsalves, Esq, Brian A.
CRISIS INTERVENTION SERVICES' MOTION TO QUASH SEVICE AND

TO DISMISS (SCANNED IMAGE REFLECTS MANNER IN WHICH
DOCUMENT WAS RECEIVED - 11-30-2011-SC)

03:49 PM
Entry:
none.

03:47 PM
Entry:
CRISIS INTERVENTION SERVICES

03:50 PM
Entry:

03:51 PM
Entry:

03:52 PM
Entry:
29-NOV-2011 Notice of Appearance

01:07 AM
001404
Entry:
Page 11 of 52
ZACH COUGHLIN ESQ FOR ZACH COUGHLIN - Transaction 2611948 Approved By: AZION : 11-29-2011:09:22:27

09:26 AM
Entry:
30-NOV-2011 Opposition to Mtn ...

12:00 AM
Entry:
OPPOSITION TO DEFT'S TORVINEN AND ELCANO'S MOTION TO

DISMISS - Transaction 2614885 - Approved By: AZION : 11-302011:08:20:33

08:22 AM
Entry:
30-NOV-2011 Supplemental ...

04:09 PM
Entry:
Fuller, Esq., Gary

Michael
SUPPLEMENT TO COMMITTEE TO AID ABUSED WOMENS MOTION TO

DISMISS COMPLAINT TO ASSERT INSUFFICIENT SERVICE OF
PROCESS - Transaction 2618007 - Approved By: MLAWRENC : 11-302011:16:16:59

04:34 PM
Entry:
08-DEC-2011 Ord Granting Mtn ...

11:22 AM
Entry:
TO DISMISS FOR INSUFFICIENT SERVICE OF PROCESS AND OTHER

RELIEF - Transaction 2634050 - Approved By: NOREVIEW : 12-082011:11:28:49

11:33 AM
Entry:

001405
Page 12 of 52
08-DEC-2011 Adj Motion to Dismiss by DEFT

04:14 PM
Entry:
none.
08-DEC-2011 Request for Submission Complet

04:14 PM
Entry:
none.
10-DEC-2011 Summons Filed

04:46 AM
Entry:
PAUL ELEANE AND WASHOE LEGAL SERVICES - 12-9-11 - Transaction

2638027 - Approved By: MLAWRENC : 12-12-2011:09:44:20

09:49 AM
Entry:
12-DEC-2011 Reply...
03:51 PM
Entry:
DEFTS PAUL ELCANOS REPLY IN SUPPORT OF MOTION TO DISMISS

FOR INSUFFUCIENT SERVICE OF PROCESS - Transaction 2640464 Approved By: MLAWRENC : 12-12-2011:16:25:04
03:52 PM
Entry:
DEFT TODD TORVINENS REPLY IN SUPPORT OF MOTION TO DISMISS

FOR INSUFFICIENT PROCESS - Transaction 2640469 - Approved By:
MLAWRENC : 12-12-2011:16:24:03

04:26 PM
Entry:

04:28 PM
001406
Entry:
13-DEC-2011 Memorandum of Costs

03:32 PM
Entry:
Page 13 of 52
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANOS VERIFIED

MEMORANDUN OF COSTS - Transaction 2643519 - Approved By:
MLAWRENC : 12-13-2011:15:36:34

03:39 PM
Entry:
15-DEC-2011 Certificate of Service

08:51 AM
Entry:
ZACH COUGHLIN - 12-14-11 - Transaction 2647104 - Approved By:

MLAWRENC : 12-15-2011:08:56:31

08:57 AM
Entry:
15-DEC-2011 ** Case Reopened

11:30 AM
Entry:
none.
15-DEC-2011 Request for Submission

11:38 AM
Entry:
DEFENDANT TODD TORVINEN'S MOTION TO DISMISS FOR

INSUFFICIENT PROCESS (NO PAPER ORDER PROVIDED) - Transaction
2647983 - Approved By: MCHOLICO : 12-15-2011:12:29:23 PARTY
SUBMITTING: JOSEPH P. GARIN, ESQ. DATE SUBMITTED: 12/15/11
SUBMITTED BY: MCHOLICO DATE RECEIVED JUDGE OFFICE:

12:33 PM
Entry:
001407
15-DEC-2011 Opposition to Mtn ...

01:20 PM
Entry:
OPPOSITION TO ALL DEFENDANT'S MOTIONS TO DISMISS and all

Defendant's Motions to Quash Service, MOTION FOR EXTENSION OF
TIME TO RESPOND/CONTINUANCE; OPPOSITION TO MOTION TO TAX
COSTS SIMLUTANEOUSLY SEEKING EXTENSIONS OF TIME OR
CONTINUANCE TO RESPOND - Transaction 2648437 - Approved By:
MCHOLICO : 12-15-2011:15:43:18

01:59 PM
Entry:
Page 14 of 52
DEFT PAUL ELCANOS MOTION TO DISMISS FOR INSUFFICIENT

SERVICE OF PROCESS - Transaction 2648676 - Approved By:
MLAWRENC : 12-15-2011:14:08:46 DOCUMENT TITLE: DEFT PAUL
ELCANOS MOTION TO DISMISS FOR INSUFFICIENT SERVICE OF
PROCESS PARTY SUBMITTING: JOSEPH GARIN ESQ DATE
SUBMITTED: 12-15-11 SUBMITTED BY: MLAWRENCE DATE RECEIVED
JUDGE OFFICE:

02:09 PM
Entry:

03:44 PM
Entry:

12:51 AM
Entry:
OPPSITION TO ALL DEFENDANT'S MOTIONS TO DISMISS; MOTION TO

SET ASIDE OR VACATE ORDER GRANTING DISMISSAL NRCP 59, NRCP
60; MOTION FOR RECONSIDERATION - Transaction 2650015 - Approved
By: MCHOLICO : 12-16-2011:09:29:43

09:30 AM
Entry:
001408
04:44 PM
Entry:
Fuller, Esq., Gary

Michael
REQUEST FOR SUBMISSION OF COMMITTEE TO AID ABUSED

WOMENS MOTION TO DISMISS COMPLAINT - Transaction 2652157 Approved By: MLAWRENC : 12-19-2011:09:23:59 DOCUMENT TITLE:
REQUEST FOR SUBMISSION OF COMMITTEE TO AID ABUSED
WOMENS MOTION TO DISMISS COMPLAINT PARTY SUBMITTING:
GARY FULLER ESQ DATE SUBMITTED: 12-16-11 SUBMITTED BY:
MLAWRENCE DATE RECEIVED JUDGE OFFICE:
16-DEC-2011 Mtn to Set Aside Decree

05:04 PM
Entry:
Fuller, Esq., Gary

Michael
REPLY IN SUPPORT OF COMMITTEE TO AID ABUSED WOMENS

MOTION TO DISMISS COMPLAINT - Transaction 2652157 - Approved By:
MLAWRENC : 12-19-2011:09:23:59

04:44 PM
Entry:
Page 15 of 52
SUPPLEMENT TO MOTION FOR RECONSIDERATION AND MOTION TO

SET ASIDE NRCP 59.60 DISMISSAL AND SUPPLEMENT TO
OPPOSITION TO ALL DEFENDANT'S MOTIONS TO DISMISS AND ALL
DEFENDANT'S MOTION TO QUASH SERVICE, MOTION FOR
EXTENSION FO TIME TO RESPOND/CONTINUANCE: - Transaction
2652308 - Approved By: LMATHEUS : 12-16-2011:17:11:04 2 IS A CD
LOCATED IN THE EXHIBIT ROOM - LM

05:12 PM
Entry:

09:24 AM
Entry:
20-DEC-2011 Notice of Entry of Ord

04:27 PM
Entry:
NOTICE OF ENTRY OF ORDER - ORDER GRANTING MOTION TO

RELIEF Transaction 2658170 - Approved By: NOREVIEW : 12-202011:16:28:21
001409
Page 16 of 52

04:29 PM
Entry:
20-DEC-2011 Reply to/in Opposition

09:31 PM
Entry:
REPLY IN SUPPORT OF CRISIS INTERVENTION SERVICES' MOTION TO

QUASH SERVICE AND TO DISMISS - Transaction 2658428 - Approved By:
MCHOLICO : 12-21-2011:11:20:22

09:33 PM
Entry:
CRISIS INTERVENTION SERVICES' MOTION TO QUASH SERVICE AND

TO DISMISS (NO PAPER ORDER PROVIDED) - Transaction 2658429 Approved By: MCHOLICO : 12-21-2011:11:42:08 PARTY SUBMITTING:
BRIAN A. GONZALEVES, ESQ. DATE SUBMITTED: 12/20/11 SUBMITTED
BY: MCHOLICO DATE RECEIVED JUDGE OFFICE:

11:21 AM
Entry:

11:43 AM
Entry:
11:32 AM
Entry:
DEFENDANT KAREN SABO'S REPLY IN SUPPORT OF MOTION TO

DISMISS FOR NON-SERVICE OF PROCESS - Transaction 2667949 Approved By: MCHOLICO : 12-27-2011:11:53:41
11:47 AM
Entry:
DEFT KAREN SABOS REPLY IN SUPPORT OF MOTION TO DISMISS

FOR NON-SERVICE OF PROCESS - Transaction 2667993 - Approved By:
001410
Page 17 of 52
MLAWRENC : 12-27-2011:11:50:05

11:51 AM
Entry:

11:55 AM
Entry:
01:42 PM
Entry:
DEFT KATHY BRECKENRIDGES REPLY IN SUPPORT OF MOTION TO

DISMISS FOR NON-SERVICE OF PROCESS AND IN THE ALTERNATIVE
INSUFFICIENT PROCESS - Transaction 2668308 - Approved By:
MLAWRENC : 12-27-2011:13:53:08
01:50 PM
Entry:
DEFENDANT JON SASSER'S REPLY IN SUPPORT OF MOTION TO

DISMISS FOR NON-SERVICE OF PROCESS AND, IN THE ALTERNATIVE,
MCHOLICO : 12-27-2011:14:06:48
01:54 PM
Entry:
DEFENDANT MARC ASHLEY'S REPLY IN SUPPORT OF MOTION TO

DISMISS FOR NON-SERVICE OF PROCESS AND, IN THE ALTERNATIVE,
MCHOLICO : 12-27-2011:14:16:02

01:55 PM
Entry:

02:09 PM
001411
Entry:
27-DEC-2011 Mtn for Attorney's Fee

02:15 PM
Entry:
Page 18 of 52
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANOS MOTION FOR

ATTORNEYS FEES - Transaction 2668540 - Approved By: MLAWRENC :
12-27-2011:14:33:38

02:18 PM
Entry:

02:35 PM
Entry:

03:18 PM
Entry:
DEFENDANTS WASHOE LEGAL SERVICES AND PAUL ELCANO'S

OPPOSITION TO PLAINTIFF'S MOTION FOR RECONSIDERATION AND
MOTION TO SET ASIDE OR VACATE ORDER GRANTING DISMISSAL Transaction 2668923 - Approved By: MCHOLICO : 12-27-2011:15:46:53

03:49 PM
Entry:

04:17 PM
Entry:
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANOS OPPOSITION

TO MOTION TO TAX COSTS - Transaction 2669334 - Approved By:
MLAWRENC : 12-27-2011:16:49:40
04:30 PM
DEFENDANT MELISSA MANGIARACINA'S REPLY IN SUPPORT OF

MOTION TO DISMISS FOR NON-SERVICE OF PROCESS AND, IN THE
001412
Entry:
ALTERNATIVE, INSUFFICIENT PROCESS - Transaction 2669371 Approved By: JYOST : 12-27-2011:16:47:18

04:45 PM
Entry:
DEFENDANT KATHY BRECKENRIDGE'S MOTION TO DISMISS FOR NON

SERVICE OF PROCESS, OPPOSITION(S) FILED DEC. 15 AND 16, 2011,
AND REPLY BRIEF FILED DEC. 27, 2011 (NO PAPER ORDER
PROVIDED) - Transaction 2669453 - Approved By: MCHOLICO : 12-282011:10:04:29 PARTY SUBMITTING: JOSEPH P. GARIN, ESQ. DATE
SUBMITTED: 12/27/11 SUBMITTED BY: MCHOLICO DATE RECEIVED
JUDGE OFFICE:

04:49 PM
Entry:
DEFENDANT JOHN SASSSER'S MOTION TO DISMISS FOR NON

SERVICE OF PROCESS AND , IN THE ALTERNATIVE, INSUFFICIENT
PROCESS, OPPOSITION(S) FILED DEC. 15 AND 16, 2011, AND REPLY
BRIEF FILED DEC. 27, 2011 (NO PAPER ORDER PROVIDED) Transaction 2669451 - Approved By: MCHOLICO : 12-28-2011:10:02:58
PARTY SUBMITTING: JOSEPH, P. GARIN, ESQ. DATE SUBMITTED:
12/27/11 SUBMITTED BY: MCHOLICO DATE RECEIVED JUDGE OFFICE:

04:47 PM
Entry:
DEFENDANT MELISSA MANGIARACINA'S MOTION TO DISMISS FOR

NON-SERVICE OF PROCESS AND , IN THE ALTERNATIVE,
INSUFFICIENT PROCESS, OPPOSITION(S) FILED DEC. 15 AND 16,2011,
AND REPLY BRIEF FILED DEC. 27, 2011 (NO PAPER ORDER
PROVIDED) - Transaction 2669442 - Approved By: MCHOLICO : 12-282011:09:57:14 PARTY SUBMITTING: JOSEPH P. GARIN, ESQ. DATE
SUBMITTED: 12/27/11 SUBMITTED BY: MCHOLICO DATE RECEIVED
JUDGE OFFICE:

04:46 PM
Entry:
Page 19 of 52
DEFENDANT MARC ASHLEY'S MOTION TO DISMISS FOR NON

SERVICE OF PROCESS AND , IN THE ALTERNATIVE, INSUFFICIENT
PROCESS, OPPOSITION(S) FILED DEC. 15 AND 16, 2011, AND REPLY
BRIEF FILED DEC. 27, 2011 (NO PAPER ORDER PROVIDED) Transaction 2669461 - Approved By: MCHOLICO : 12-28-2011:10:05:59
PARTY SUBMITTING: JOSEPH P. GARIN, ESQ. DATE SUBMITTED:
001413
Page 20 of 52

04:49 PM
Entry:

04:50 PM
Entry:
DEFENDANT KAREN SABO'S MOTION TO DISMISS FOR NON SERVICE

OF PROCESS, OPPOSITION(S) FILED DEC. 15, AND 16, 2011, AND
REPLY BRIEF FILED DEC. 27, 2011 (NO PAPER ORDER PROVIDED) Transaction 2669464 - Approved By: MCHOLICO : 12-28-2011:10:07:48

04:52 PM
Entry:

09:58 AM
Entry:

10:04 AM
Entry:

10:05 AM
Entry:

10:07 AM
Entry:

001414
Page 21 of 52
10:09 AM
Entry:
10-JAN-2012
02:52 PM
Entry:
10-JAN-2012
02:56 PM
Entry:
PLTF'S MOTION FOR RECONSDIERATION AND MOTION TO SET ASIDE

OR VACATE ORDER GRANTING DISMISSAL - Transaction 2691915 Approved By: AZION : 01-10-2012:15:17:10 DOCUMENT TITLE: PLTF'S
MOTION FOR RECONSDIERATION AND MOTION TO SET ASIDE OR
VACATE ORDER GRANTING DISMISSAL PARTY SUBMITTING: JOSEPH
GARIN ESQ DATE SUBMITTED: 01-10-12 SUBMITTED BY: AZION DATE
PLTF'S MOTION TO TAX COSTS - Transaction 2691927 - Approved By:

AZION : 01-10-2012:15:22:25 DOCUMENT TITLE: PLTF'S MOTION TO
TAX COSTS - PARTY SUBMITTING: JOSEPH GARIN ESQ DATE
SUBMITTED: 01-10-12 SUBMITTED BY: AZION DATE RECEIVED JUDGE
OFFICE:
10-JAN-2012
03:18 PM
Entry:
10-JAN-2012
03:23 PM
Entry:
13-JAN-2012
10:14 AM
Ord Granting Mtn ...
Entry:
13-JAN-2012
10:14 AM
TO DISMISS FOR INSUFFICIENT PROCESS (AS TO DEFENDANT TODD

TORVINEN) - Transaction 2699027 - Approved By: NOREVIEW : 01-132012:10:14:22
Ord Denying ...

MOTION TO DISMISS FOR INSUFFICIENT SERVICE OF PROCESS (AS
001415
Entry:
13-JAN-2012
10:14 AM
Entry:
13-JAN-2012
10:14 AM
Entry:
13-JAN-2012
10:14 AM
Entry:
13-JAN-2012
10:14 AM
Entry:
13-JAN-2012
10:14 AM
Entry:
13-JAN-2012
10:14 AM
Entry:
Page 22 of 52
TO DEFENANT PAUL ELCANO) - Transaction 2699027 - Approved By:

NOREVIEW : 01-13-2012:10:14:22

TO DISMISS COMPLAINT (AS TO DEFENDANT COMMITTEE TO AID
ABUSED WOMEN) - Transaction 2699027 - Approved By: NOREVIEW : 0113-2012:10:14:22
TO QUASH SERVICE AND TO DISMISS (AS TO DEFENDANT CRISIS
INTERVENTION SERVICES) - Transaction 2699027 - Approved By:
NOREVIEW : 01-13-2012:10:14:22
TO DISMISS FOR INSUFFICIENT PROCESS (AS TO DEFENDANT MARC
ASHLEY) - Transaction 2699027 - Approved By: NOREVIEW : 01-132012:10:14:22

TO DISMISS FOR INSUFFICIENT PROCESS (AS TO DEFENDANT JON
SASSER) - Transaction 2699027 - Approved By: NOREVIEW : 01-132012:10:14:22

TO DISMISS FOR INSUFFICIENT SERVICE OF PROCESS (AS TO
DEFENDANT MELISSA MANGIARACINA) - Transaction 2699027 Approved By: NOREVIEW : 01-13-2012:10:14:22

TO DISMISS FOR INSUFFICIENT SERVICE OF PROCESS (AS TO
DEFENDANT KATHY BRECKENRIDGE) - Transaction 2699027 - Approved
By: NOREVIEW : 01-13-2012:10:14:22
001416
13-JAN-2012
10:14 AM
Entry:
13-JAN-2012
10:14 AM
Entry:
Page 23 of 52

TO DISMISS FOR NON-SERVICE OF PROCESS (AS TO DEFENDANT
KAREN SABO) - Transaction 2699027 - Approved By: NOREVIEW : 01-132012:10:14:22
Ord Denying Motion
PLAINTIFF'S MOTION FOR RECONSIDERATION AND MOTION TO SET
ASIDE OR VACATE ORDER - Transaction 2699027 - Approved By:
NOREVIEW : 01-13-2012:10:14:22
13-JAN-2012
10:15 AM
Entry:
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
001417
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
10:17 AM
Entry:
none.
13-JAN-2012
03:33 PM
Page 24 of 52
Entry:
Fuller, Esq., Gary

Michael

DISMISS COMPLAINT - COMMITTEE TO AID ABUSED WOMEN Transaction 2700189 - Approved By: NOREVIEW : 01-13-2012:15:34:04
13-JAN-2012
03:34 PM
Entry:
13-JAN-2012
04:16 PM
Entry:
none.
001418
16-JAN-2012
03:18 PM
Entry:
Page 25 of 52

QUASH SERVICE AND TO DISMISS - CRISIS INTERVENTION SERVICES
16-JAN-2012
03:20 PM
Entry:
17-JAN-2012
03:50 PM
Notice of Entry ...
Entry:

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS - KATHY
BRECKENRIDGE Transaction 2703178 - Approved By: NOREVIEW : 01-172012:15:56:19
17-JAN-2012
03:53 PM
Entry:
17-JAN-2012
03:55 PM
Entry:
17-JAN-2012
03:57 PM
Entry:

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS - TODD
TORVINEN Transaction 2703217 - Approved By: NOREVIEW : 01-172012:16:00:59

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS -MELISSA
MANGIARACINA Transaction 2703225 - Approved By: NOREVIEW : 01-172012:16:01:03
17-JAN-2012
04:01 PM
Entry:
001419
17-JAN-2012
04:01 PM
Entry:
Page 26 of 52

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS - JON SASSER
17-JAN-2012
04:02 PM
Entry:
17-JAN-2012
04:03 PM
Entry:
17-JAN-2012
04:05 PM
Entry:
17-JAN-2012
04:09 PM
Entry:

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS - MARC ASHLEY
NOTICE OF ENTRY OF ORDER - ORDER DENYING MOTION TO

DISMISS FOR INSUFFICIENT SERVICE OF PROCESS - PAUL ELCANO
NOTICE OF ENTRY OF ORDER - ORDER DENYING PLAINTIFF'S

MOTION FOR RECONSIDERATION AND MOTION TO SET ASIDE OR
VACATE ORDER GRANTING DISMISSAL; MOTION TO TAX COSTS;
MOTION FOR EXTENSION OF TIME; AND ADDITIONAL MOTIONS FILED
ON JANUARY 13, 2012. Transaction 2703285 - Approved By: NOREVIEW :
01-17-2012:16:12:37
17-JAN-2012
04:09 PM
Entry:
17-JAN-2012
04:09 PM
001420
Page 27 of 52
Entry:
17-JAN-2012
04:12 PM
Entry:
17-JAN-2012
04:13 PM
Entry:
17-JAN-2012
04:14 PM
Entry:
17-JAN-2012
04:21 PM
Entry:
18-JAN-2012
03:59 PM
Mtn to Dismiss ...
Entry:
18-JAN-2012
03:59 PM
Entry:
18-JAN-2012
04:14 PM
Entry:
DEFENDANT CARYN STERNLICHT'S MOTION TO DISMISS FOR NONSERVICE OF PROCESS AND, IN THE ALTERNATIVE, INSUFFICIENT
PROCESS - Transaction 2705900 - Approved By: MCHOLICO : 01-182012:16:24:16
$Def 1st Appearance - CV
CARYN STERNLICHT - Transaction 2705900 - Approved By: MCHOLICO :

01-18-2012:16:24:16
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANOS MOTION FOR

ATTORNEYS FEES - Transaction 2706028 - Approved By: MLAWRENC :
01-19-2012:08:17:51 DOCUMENT TITLE: DEFTS WASHOE LEGAL
SERVICES AND PAUL ELCANOS MOTION FOR ATTORNEYS FEES
PARTY SUBMITTING: JOSEPH GARIN ESQ DATE SUBMITTED: 01-19-12
001421
Page 28 of 52
SUBMITTED BY: MLAWRENCE DATE RECEIVED JUDGE OFFICE:
18-JAN-2012
04:25 PM
**Payment Receipted
Entry:
18-JAN-2012
04:26 PM
Entry:
19-JAN-2012
08:19 AM
Entry:
19-JAN-2012
03:10 PM
Affidavit of Mailing
Entry:
19-JAN-2012
03:11 PM
Entry:
19-JAN-2012
04:17 PM
Amended ...
Entry:
Fuller, Esq., Gary

Michael
Fuller, Esq., Gary

Michael
AMENDED AFFIDAVIT OF MAILING - Transaction 2708843 - Approved By:

MCHOLICO : 01-19-2012:16:52:39
19-JAN-2012
04:53 PM
Entry:
20-JAN-2012
07:45 AM
Entry:
PLTF'S MOTION TO ALTER OR AMEND PER NRCP 59 - Transaction

2709250 - Approved By: AZION : 01-20-2012:14:24:05
001422
Page 29 of 52
20-JAN-2012
02:27 PM
Entry:
22-JAN-2012
11:42 AM
Entry:
OPPOSITION TO MOTION TO ALTER OR AMEND - Transaction 2712337 Approved By: AZION : 01-23-2012:08:19:30
23-JAN-2012
08:20 AM
Entry:
25-JAN-2012
12:09 AM
Mtn to Retax Costs
Entry:
25-JAN-2012
12:20 AM
Entry:
OPPOSITION TO MOTION TO TAX COSTS, OR, PLED IN THE

ALTERNATIVE MOTION TO RETAX COSTS - Transaction 2718259 Approved By: LMATHEUS : 01-25-2012:11:48:46
OPPOSITION TO ELCANO'S MOTION FOR ATTORNEY'S FEES Transaction 2718260 - Approved By: LMATHEUS : 01-25-2012:11:47:08
25-JAN-2012
11:48 AM
Entry:
25-JAN-2012
11:49 AM
Entry:
27-JAN-2012
02:06 PM
Memorandum of Costs
DEFTS VERIFIED MEMORANDUM OF COSTS - Transaction 2726572 001423
Page 30 of 52
Entry:
Approved By: MLAWRENC : 01-27-2012:14:09:07
27-JAN-2012
02:11 PM
Entry:
30-JAN-2012
01:41 PM
Opposition to ...
Entry:
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANOS OPPOSITION

TO MOTION TO RETAX COSTS - Transaction 2729847 - Approved By:
MLAWRENC : 01-30-2012:13:52:26
30-JAN-2012
01:54 PM
Entry:
31-JAN-2012
12:18 AM
Entry:
REPLY TO OPPOSITION - Transaction 2731133 - Approved By:

LMATHEUS : 01-31-2012:14:12:08
31-JAN-2012
02:14 PM
Entry:
31-JAN-2012
06:03 PM
Entry:
DEFT'S OPPOSITION TO PLTF'S MOTION TO ALTER OR AMEND Transaction 2734305 - Approved By: AZION : 02-01-2012:08:18:16
01-FEB-2012 Mtn Alter or Amend Judgment

12:02 AM
Entry:
MOTION TO ALTER OR AMEND JUDMGNET; OR, PLED IN THE

ALTERNATIVE, MOTION FOR NUNC PRO TUNC ORDER - Transaction
2734354 - Approved By: LMATHEUS : 02-01-2012:14:07:33
001424
Page 31 of 52

08:19 AM
Entry:

02:08 PM
Entry:
02-FEB-2012 Mtn for Attorney's Fee

12:46 PM
Entry:
DEFTS MOTION FOR ATTORNEYS FEES - Transaction 2738508 Approved By: MLAWRENC : 02-02-2012:13:21:52

01:37 PM
Entry:
02-FEB-2012 Summons Filed

02:31 PM
Entry:
COMPLAINT SERVED ON TODD TORVINEN AND PAUL ELCANO ON

10/27/11 - Transaction 2739033 - Approved By: LMATHEUS : 02-022012:14:44:40

02:46 PM
Entry:
06-FEB-2012 Motion ...

01:36 PM
Entry:
DEFTS MOTION TO STRIKE PLTFS REPLY TO OPPOSITION Transaction 2745385 - Approved By: MLAWRENC : 02-06-2012:14:06:38
06-FEB-2012 Reply...
01:42 PM
Entry:
DEFTS WASHOE LEGAL SERVICES AND PAUL ELCANO'S REPLY IN

SUPPORT OF MOTION FOR ATTY'S FEES - Transaction 2745425 001425
Page 32 of 52
Approved By: AZION : 02-06-2012:13:57:39

02:01 PM
Entry:

02:08 PM
Entry:
07-FEB-2012 Request for Submission

09:57 AM
Entry:
DEFT CAYN STERNLICHT'S MOTION TO DISMISS FOR NON-SERVICE

OF PROCESS AND IN THE ALTERNATIVE INSUFFICIENT PROCESS Transaction 2747946 - Approved By: AZION : 02-07-2012:10:05:46
DOCUMENT TITLE: DEFT CAYN STERNLICHT'S MOTION TO DISMISS
FOR NON-SERVICE OF PROCESS AND IN THE ALTERNATIVE
INSUFFICIENT PROCESS PARTY SUBMITTING: JOSEPH GARIN ESQ
DATE SUBMITTED: 02-07-12 SUBMITTED BY: AZION DATE RECEIVED
JUDGE OFFICE:

10:07 AM
Entry:

10:08 AM
Entry:
DEFENDANTS WASHOE LEGAL SERVICES AND PAUL ELCANO'S

MOTION FOR ATTORNEY'S FEES (NO PAPER ORDER PROVIDED) Transaction 2748003 - Approved By: MCHOLICO : 02-07-2012:10:11:07

10:12 AM
Entry:
001426
08-FEB-2012 Motion ...

07:33 PM
Entry:
Page 33 of 52
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE OPPOSITION

TO STERNLICHT ET AL'S MOTION TO DISMISS; OR PLEAD IN THE
ALTERNATIVE, OPPOSITION TO MOTION TO DISMISS - Transaction
09-FEB-2012 Ord Granting Mtn ...

01:30 PM
Entry:
TO DISMISS FOR NON-SERVICE OF PROCESS (AS TO DEFENDANT

CARYN STERNLICHT) - Transaction 2755063 - Approved By: NOREVIEW :
02-09-2012:13:31:10

01:32 PM
Entry:

03:02 PM
Entry:
10-FEB-2012 Opposition to Mtn ...

12:08 AM
Entry:
OPPOSITION TO MOTION TO TAX COSTS, OR PLED IN THE

ALTERNATIVE, MOTION TO RETAX COST - Transaction 2756753 Approved By: LMATHEUS : 02-10-2012:10:17:08

10:18 AM
Entry:
10-FEB-2012 Request for Submission Complet

02:48 PM
Entry:
none.
10-FEB-2012 Reply to/in Opposition

11:56 PM
001427
Entry:
REPLY TO OPPOSITION; OR IN THE ALTERNATIVE, MOTION FOR

EXTENSION OF TIME TO FILE REPLY TO OPPOSITION - Transaction

12:02 AM
Entry:
OPPOSITION TO ALL MOTION FOR ATTORNEYS FEES - Transaction


08:52 AM
Entry:
Page 34 of 52
Transaction 2759279 - Approved By: LMATHEUS : 02-13-2012:08:47:50

DOCUMENT TITLE: REQUEST FOR SUBMISSION OF OCTOBER 5TH
MOTION TO CONSOLIDATE ( NO PAPER ORDER PROVIDED) PARTY
SUBMITTING: ZACH COUGHLIN, ESQ. DATE SUBMITTED: 02/11/12
SUBMITTED BY: LMATHEUS DATE RECEIVED JUDGE OFFICE:

08:51 AM
Entry:

09:01 AM
Entry:

09:03 AM
Entry:
15-FEB-2012 Notice of Appeal Supreme Court Coughlin, Esq., Zachary

12:01 AM
Entry:
APPELLANT, ZACHARY COUGHLIN - Transaction 2765532 - Approved By:

LMATHEUS : 02-15-2012:12:20:24

12:21 PM
Entry:

001428

02:14 PM
Entry:
CRISIT INTERVENTION SERVICES' OPPOSITION TO PLAINTIFF'S

MOTIONS
15-FEB-2012 Mtn Proceed Forma Pauperis

11:21 PM
Entry:
Page 35 of 52
MOTION TO PROCEED INFORMA PAUPERIS ON APPEAL (NO PAPER

ORDER PROVIDED) - Transaction 2768362 - Approved By: LMATHEUS :
02-16-2012:13:51:09

01:53 PM
Entry:

11:08 AM
Entry:

DOCUMENT TITLE: PLAINTIFF'S OPPOSITION TO MOTION TO TAX
COSTS, OR PLED IN THE ALTERNATIVE, MOTION TO RETAX COSTS
(NO PAPER ORDER PROVIDED) PARTY SUBMITTING: Joseph Garin,
Esq. DATE SUBMITTED: 02/21*12 SUBMITTED BY: LMATHEUS DATE

11:09 AM
Entry:

DOCUMENT TITLE: PLAINTIFF'S MOTION TO ALTER OR AMEND PER
NRCP 59 (NO PAPER ORDER PROVIDED) PARTY SUBMITTING:
JOSEPH GARIN, ESQ. DATE SUBMITTED: 02/21/12 SUBMITTED BY:
LMATHEUS DATE RECEIVED JUDGE OFFICE:
20-FEB-2012 Notice of Entry of Ord

11:12 AM
Entry:
NOTICE OF ENTRY OF ORDER GRANTING MOTION TO DISMISS FOR

NON-SERVICE OF PROCESS Transaction 2775051 - Approved By:
NOREVIEW : 02-20-2012:11:12:28
001429
Page 36 of 52

11:13 AM
Entry:

04:13 PM
Entry:
DEFENDANT'S OPPOSITION TO MOTION TO RETAX COSTS Transaction 2775097 - Approved By: LMATHEUS : 02-21-2012:09:44:13

04:25 PM
Entry:

DOCUMENT TITLE: DEFENDANT'S MOTION FOR ATTORNEY'S FEES
(NO PAPER ORDER PROVIDED) PARTY SUBMITTING: JOSEPH GARIN,
ESQ. DATE SUBMITTED: 02/21/12 SUBMITTED BY: LMATHEUS DATE

08:55 AM
Entry:
21-FEB-2012 ** Case Reopened

08:56 AM
Entry:
none.

08:56 AM
Entry:

09:45 AM
Entry:

09:47 AM
Entry:
001430
12:59 PM
Entry:
DEFENDANT'S REPLY IN SUPPORT OF MOTION FOR ATTORNEY'S

FEES - Transaction 2776786 - Approved By: LMATHEUS : 02-212012:13:36:48

01:10 PM
Entry:
Page 37 of 52
DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO ALTER OR

AMEND - Transaction 2776809 - Approved By: LMATHEUS : 02-212012:13:33:00

01:35 PM
Entry:

01:39 PM
Entry:
21-FEB-2012 Joinder...
04:42 PM
Entry:
COMMITTEE TO AID ABUSED WOMEN'S JOINDER IN DEFENDANTS'

OPPOSITION TO PLAINTIFF'S MNOTION TO ALTER OR AMEND Transaction 2778135 - Approved By: LMATHEUS : 02-22-2012:08:35:30

12:20 AM
Entry:
Fuller, Esq., Gary

Michael
OPPOSITION TO ALL MOTIONS FOR ATTONEYS FEES - Transaction


08:37 AM
Entry:
001431
Page 38 of 52

11:59 AM
Entry:
23-FEB-2012 Supreme Ct Deficiency Notice

09:32 AM
Entry:
23-FEB-2012 Certificate of Clerk

09:32 AM
Entry:
CERTIFICATE OF CLERK AND TRANSMITTAL - NOTICE OF APPEAL Transaction 2782236 - Approved By: NOREVIEW : 02-23-2012:09:35:08

09:43 AM
Entry:

12:25 PM
Entry:
CRISIS INTERVENTION SERVICES' OPPOSITION TO PLAINTIFF'S

MOTION TO PROCEED IN FORMA PAUPERIS ON APPEAL
12:19 AM
Entry:
SURREPLY TO DEFENDATN'S WASHOE LEGAL SERVICES AND PAUL

ELCANO'S REPLY IN SUPPORT OF MOTION FOR ATTORNEY'S FEES Transaction 2787320 - Approved By: LMATHEUS : 02-27-2012:13:31:31

12:06 PM
Entry:
DEFENDANT'S MOTION TO STRIKE PLAINTIFF'S REPLY TO

OPPOSITION (NO PAPER ORDER PROVIDED) - Transaction 2788531 Approved By: LMATHEUS : 02-27-2012:14:58:28 PARTY SUBMITTING:
JOSEPH GARIN, ESQ. DATE SUBMITTED: 02/27/12 SUBMITTED BY:
LMATHEUS DATE RECEIVED JUDGE OFFICE:

001432
Page 39 of 52
01:33 PM
Entry:

02:59 PM
Entry:
02-MAR-2012 Memorandum of Costs

02:41 PM
Entry:
DEFENDANT CARYN STERNLICHT'S VERIFIED MEMORANDUM OF

COSTS - Transaction 2800528 - Approved By: LMATHEUS : 03-022012:16:06:26
02-MAR-2012 Proof of Electronic Service

04:12 PM
Entry:
05-MAR-2012 Supreme Court Receipt for Doc

10:50 AM
Entry:
SUPREME COURT ORDER NO. 60317/RECEIPT FOR DOCUMENTS Transaction 2802764 - Approved By: NOREVIEW : 03-05-2012:10:52:09

10:55 AM
Entry:
05-MAR-2012 Opposition to Mtn ...

04:51 PM
Entry:
DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO PROCEED IN

FORMA PAUPERIS ON APPEAL - Transaction 2804912 - Approved By:
LMATHEUS : 03-06-2012:10:18:07

10:25 AM
Entry:
001433
06-MAR-2012 Request for Submission

12:38 PM
Entry:
PLAINTIFF'S OPPOSITION TO MOTIOIN TO TAX COSTS, OR PLED IN

THE ALTERNATIVE, MOTION TO RETAX COSTS (NO PAPER ORDER
PROVIDED) - Transaction 2806646 - Approved By: LMATHEUS : 03-062012:14:00:03 PARTY SUBMITTING: JOSEPH GARIN, ESQ. DATE
SUBMITTED: 03/06/12 SUBMITTED BY: LMATHEUS DATE RECEIVED
JUDGE OFFICE:

12:40 PM
Entry:
Page 40 of 52
PLAINTIFF'S MOTION TO ALTER OR AMEND (NO PAPER ORDER

PROVIDED) - Transaction 2806648 - Approved By: LMATHEUS : 03-062012:14:00:33 PARTY SUBMITTING: JOSEPH GARIN, ESQ. DATE
JUDGE OFFICE:

02:03 PM
Entry:

02:04 PM
Entry:
07-MAR-2012 Mtn for Extension of Time

12:27 AM
Entry:
MOTION FOR EXTENSION OF TIME TO PERFORM SERVICE OF

PROCESS - Transaction 2808251 - Approved By: LMATHEUS : 03-072012:09:20:51

09:23 AM
Entry:
08-MAR-2012 Case Appeal Statement

12:20 AM
CASE APPEAL STATEMENT OR, PLED IN THE ALTERNATIVE, MOTION

001434
Entry:
Page 41 of 52
FOR EXTENSION OF TIME TO CORRECT DEFICIENCIES IN APPEAL

PAPERS - Transaction 2811756 - Approved By: LMATHEUS : 03-082012:10:46:48

10:49 AM
Entry:
08-MAR-2012 Mtn for Attorney's Fee

03:29 PM
Entry:
DEFENDANT CARYN STERNLICHT'S MOTION FOR ATTORNEY'S FEES Transaction 2813595 - Approved By: LMATHEUS : 03-08-2012:17:04:32
08-MAR-2012 Ord Denying Motion

03:58 PM
Entry:
ORDER DENYING MOTION TO PROCEED IN FORMA PAUPERIS Transaction 2813698 - Approved By: NOREVIEW : 03-08-2012:15:59:03

03:59 PM
Entry:

05:08 PM
Entry:
09-MAR-2012 Certificate of Clerk

01:07 PM
Entry:
CERTIFICATE OF CLERK AND TRANSMITTAL - Transaction 2815627 Approved By: NOREVIEW : 03-09-2012:13:08:30

01:09 PM
Entry:
12-MAR-2012 Notice of Entry of Ord

001435
Page 42 of 52
04:36 PM
Entry:

04:38 PM
Entry:

09:09 AM
Entry:
CRISIS INTERVENTION SERVICES OPPOSITION TO PLAINTIFFS

MOTION TO EXTEND TIME FOR SERVICE
20-MAR-2012 Ord Granting Mtn ...

04:25 PM
Entry:
DEFENDANTS' MOTIONS FOR ATTORNEY'S FEES (WASHOE LEGAL

SERVICES AND PAUL ELCANO) - Transaction 2837978 - Approved By:
NOREVIEW : 03-20-2012:16:27:32
20-MAR-2012 Ord Denying ...

04:25 PM
Entry:
REQUEST FOR SUBMISSION - Transaction 2837978 - Approved By:

NOREVIEW : 03-20-2012:16:27:32

04:25 PM
Entry:
PLAINTIFF'S MOTIONS TO RETAX COSTS - Transaction 2837978 Approved By: NOREVIEW : 03-20-2012:16:27:32

04:25 PM
Entry:
PLAINTIFF'S MOTIONS TO ALTER OR AMEND - Transaction 2837978 Approved By: NOREVIEW : 03-20-2012:16:27:32
20-MAR-2012 Ord Granting Mtn ...

04:25 PM
DEFENDANTS' MOTION TO STRIKE PLAINTIFF'S REPLY TO
001436
Entry:
Page 43 of 52
OPPOSITION - Transaction 2837978 - Approved By: NOREVIEW : 03-202012:16:27:32

04:32 PM
Entry:
20-MAR-2012 Request for Submission Complet

05:55 PM
Entry:
none.

05:55 PM
Entry:
none.

05:55 PM
Entry:
none.

05:55 PM
Entry:
none.

05:55 PM
Entry:
none.

05:55 PM
Entry:
none.

05:55 PM
Entry:
none.
001437
Page 44 of 52

05:55 PM
Entry:
none.

11:47 AM
Entry:

11:48 AM
Entry:

11:53 AM
Entry:

11:55 AM
Entry:

11:56 AM
Entry:

11:58 AM
Entry:

11:58 AM
Entry:
001438
Page 45 of 52
12:00 PM
Entry:

12:01 PM
Entry:

12:02 PM
Entry:

04:20 PM
Entry:
DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTIN FOR EXTENSION

OF TIME TO PERFORM SERVICE OF PROCESS - Transaction 2849182 Approved By: LMATHEUS : 03-26-2012:16:36:26

04:40 PM
Entry:
27-MAR-2012 Mtn Alter or Amend Judgment

12:17 AM
Entry:
MOTION FOR NEW TRIAL, OR PLED IN THE ALTERNATIVE, MOTION TO

ALTER OR AMEND - Transaction 2849618 - Approved By: LMATHEUS : 0327-2012:11:52:56

11:53 AM
Entry:

05:02 PM
Entry:

DOCUMENT TITLE: DEFENDANT CARYN STERNLICHT'S MOTION FOR
ATTORNEY'S FEES PARTY SUBMITTING: JOSEPH GARIN, ESQ. DATE
001439
Page 46 of 52

JUDGE OFFICE:

10:53 AM
Entry:
03-APR-2012 Mtn Alter or Amend Judgment

12:21 AM
Entry:
MOTION TO ALTER OR AMEND ORDER DENYING MOTION TO

PROCEED IN FORMA PAUPERIS - Transaction 2863862 - Approved By:
LMATHEUS : 04-03-2012:08:41:09

08:42 AM
Entry:
04-APR-2012 Notice ...

11:33 AM
Entry:
Olson, Esq., James R.
NOTICE OF ASSOCIATION OF COUNSEL - JAMES R. OLSON, ESQ. OF

THE LAW FIRM OLSON, CANNON, GORMLEY & DESRUISSEAUS
ASSOCIATES WITH GARY MICHAEL FULLER, ESQ. OF HTE LAW FIRM
GUILD RUSSELL & GALLAGER & FULLER AS CO-COUNSEL Transaction 2868475 - Approved By: LMATHEUS : 04-04-2012:13:58:03

01:59 PM
Entry:
04-APR-2012 Opposition to Mtn ...

02:51 PM
Entry:
Olson, Esq., James R.
DEFENDANT COMMITTEE TO AID ABUSED WOMEN'S OPPOSITION TO

PLAINTIFF'S MOTION TO ALTER OR AMEND ORDER DENYING MOTION
TO PROCEED IN FORMA PAUPERIS - Transaction 2869607 - Approved
By: LMATHEUS : 04-05-2012:12:08:40
001440
Page 47 of 52
12:09 PM
Entry:

01:28 PM
Entry:
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO PERFORM

SERVICE OF PROCESS (NO PAPER ORDER PROVIDED)- Transaction
2874547 - Approved By: LMATHEUS : 04-06-2012:14:39:32 PARTY
SUBMITTING: JOSEPH GARIN, ESQ. DATE SUBMITTED: 04/06/12

02:40 PM
Entry:
06-APR-2012 ** Case Reopened

04:22 PM
Entry:
none.

02:38 PM
Entry:
OPPOSITION TO PLTF'S MOTION FOR NEW TRIAL - Transaction 2883649

- Approved By: AZION : 04-11-2012:14:48:48

02:52 PM
Entry:
11-APR-2012 Joinder...
02:57 PM
Entry:
JOINDER TO OPPOSITION TO PLAINTIFF'S MOTOIN TO ALTER OR

AMEND ORDER DENYING MOTION TO PROCEED IN FORMA PAUPERIS
- Transaction 2883834 - Approved By: LMATHEUS : 04-11-2012:15:54:46

03:57 PM
001441
Entry:
12-APR-2012 Case Appeal Statement

11:40 PM
Entry:
Page 48 of 52

09:20 AM
Entry:

03:41 PM
Entry:
DEFT'S OPPOSITION TO PLTF'S MOTION FOR NEW TRIAL OR PLED IN

THE ALTERNATIVE, MOTION TO ALTER OR AMEND - Transaction
2889314 - Approved By: ASMITH : 04-13-2012:16:12:17
13-APR-2012 Certificate of Clerk

03:51 PM
Entry:
CERTIFICATE OF CLERK AND TRANSMITTAL - NRAP 3(g)(1)(B) Transaction 2889369 - Approved By: NOREVIEW : 04-13-2012:15:52:34

03:55 PM
Entry:

04:13 PM
Entry:

03:23 PM
Entry:
DEFENDANTS' OPPOSITION TO PLAINTIFF'S MOTION TO ALTER OR

AMEND ORDER DENYING MOTION TO PROCEED IN FORMA PAUPERIS
- Transaction 2903778 - Approved By: JYOST : 04-20-2012:15:55:44

001442
Page 49 of 52
03:56 PM
Entry:

01:26 PM
Entry:
PLAINTIFF'S MOTION FOR NEW TRIAL, OR PLED IN THE ALTERNATIVE,

MOTION TO ALTER OR AMEND - Transaction 2912059 - Approved By:
LMATHEUS : 04-25-2012:15:08:24 PARTY SUBMITTING: JOSEPH GARIN,
ESQ. DATE SUBMITTED: 4/25/12 SUBMITTED BY: LMATHEUS DATE

03:09 PM
Entry:

11:33 AM
Entry:

TO PROCEED IN FORMA PAUPERIS - Transaction 2938501 - Approved
By: LMATHEUS : 05-08-2012:12:34:42 PARTY SUBMITTING: JOSEPH
GARIN, ESQ. DATE SUBMITTED: 5/8/12 SUBMITTED BY: LMATHEUS
DATE RECEIVED JUDGE OFFICE:

12:35 PM
Entry:
09-MAY-2012 Ord Denying ...

05:18 PM
Entry:
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO PERFORM

SERVICE OF PROCESS - Transaction 2943757 - Approved By:
NOREVIEW : 05-09-2012:17:20:05
09-MAY-2012 Ord Granting Mtn ...

05:18 PM
Entry:
DEFENDANT CARYN STERNLICHT'S MOTION FOR ATTORNEY'S FEES Transaction 2943757 - Approved By: NOREVIEW : 05-09-2012:17:20:05
001443
Page 50 of 52

05:21 PM
Entry:

09:18 AM
Entry:

TO PROCEED IN FORMA PAUPERIS - (NO PAPER ORDER PROVIDED)
PARTY SUBMITTING: JOSEPH GARIN, ESQ. DATE SUBMITTED: 05/10/12

10:23 AM
Entry:

05:14 PM
Entry:
none.

05:14 PM
Entry:
none.
11-MAY-2012 Notice of Entry of Ord

11:59 AM
Entry:

12:01 PM
Entry:

12:02 PM
Entry:

001444
Page 51 of 52

12:04 PM
Entry:

11:56 AM
Entry:
none.

11:56 AM
Entry:
none.

11:56 AM
Entry:
none.
29-MAY-2012 Order ...

11:19 AM
Entry:

11:22 AM
Entry:

11:53 AM
Entry:

11:55 AM
Entry:
28-NOV-2012 Supreme Ct Ord Dismis Appeal
001445
Page 52 of 52
11:29 AM
Entry:
SUPREME COURT NO. 60317/ORDER DISMISSING APPEAL Transaction 3371705 - Approved By: NOREVIEW : 11-28-2012:11:30:08

11:31 AM
Entry:
001446

Sent: Tue 3/13/12 10:49 AM
To:

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

To: Campbell, Debra
1 of 17
3/29/2012 2:18 PM

Date: Tue, 13 Mar 2012 10:14:59 -0700
Mr. Coughlin:

Sent: Mon 3/05/12 8:43 AM
To:
Cc:
Dear Mr. Coughlin:
328-2971.
11TR26800.
Regards,
911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

To: SheriffWeb

001447
2 of 17
3/29/2012 2:18 PM
3 of 17
3/29/2012 2:18 PM
really helped that the Sheriff's Office let Mr. Eastman get my keys to feed my
dog, thank you!).
However, Mr. Eastman indicates to me that he did not receive either cell phone
or the micro sd card upon picking up my secured property.
If possible please reply by fax or email as I, obviously, do not have my phones
and there is a problem right now with my usps mailbox.

To: Campbell, Debra
Is a micro sd card listed on the property sheet at intake?


Date: Tue, 13 Mar 2012 10:48:59 -0700

Sent: Tue 3/13/12 1:57 PM
To:

Yes, a micro sd card was listed on the inventory at intake and was released with the rest of your property on
2-29-12 to Peter Eastman. I will scan and email you a copy of the intake property form and the release form
signed by Mr. Eastman.

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)


4 of 17
3/29/2012 2:18 PM
5 of 17
3/29/2012 2:18 PM
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
To: Campbell, Debra

Did these items that were placed into evidence include a micro sd
card?

Date: Tue, 13 Mar 2012 10:14:59 -0700
Mr. Coughlin:

Sent: Tue 3/13/12 2:50 PM
To:
1 attachment
Coughlin Property Docs 0312.doc (2.6 MB)
The two documents I referred to in my last email are aached.
11TR26800.

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

911 Parr Blvd
001448
6 of 17
3/29/2012 2:18 PM
7 of 17
3/29/2012 2:18 PM

To: Campbell, Debra
To: Campbell, Debra
card?


Date: Tue, 13 Mar 2012 10:14:59 -0700

Date: Tue, 13 Mar 2012 10:48:59 -0700
Mr. Coughlin:

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
11TR26800.
8 of 17
3/29/2012 2:18 PM
9 of 17
3/29/2012 2:18 PM

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

Sent: Tuesday, March 13, 2012 9:23 PM
To: Campbell, Debra; Kandaras, Mary

Sent: Wed 3/14/12 6:52 AM
To:
So, are you saying you or your office currently have an "evidence envelope" that contains
these items placed into "evidence" . Do you whether that comprots with previous
assertions made by your office or agents, or, if, in fact, it contradicts representations as to
whom came and took what? If you still have any of this property in your possession,
please consider whether it is legal for you to allow the RMC or the Reno Marshal to come
check it out like a book from the library, or whether you have some liability if, oopsie,
something "disappears". Please ask Deputy Cheung about all of these circumstances
detailed in our correspondences and provide written documentation detailing his
responses. Further, please provide pictures of the evidence envelope and all the "evidence"
within such an envelope, including whether a micro sd card in within such materials or
whether such a card is somehow contained in one of the phones or otherwise instereted
into the same. Additionally, please indicate whether a phone battery or two is present.
Please ask yourself who is running what and whether that is appropriate.
I am saying that two cell phones and an electric razor were placed into evidence at the instrucon of Judge
Nash-Holmes and the evidence envelope states that is what is in the envelope. As I do not work in or have
access to the evidence unit, I am relaying what they told me when they checked the envelope.
In response to your prior email, the property record form stated that there was a micro sd card. The
Authorizaon for Release of Property/Money was dated 2-29-12 and signed by Mr. Eastman. The statement
he signed states that he acknowledged that he received the items listed on the property record form. I can
only assume that is the case as he signed the form and you authorized him to pick up the property.
Since I am not an aorney I will send your last two emails to the Assistant District Aorney assigned to the
Sheris Oce for response.
Sincerely,
001449
10 of 17
3/29/2012 2:18 PM
11 of 17
3/29/2012 2:18 PM

Date: Tue, 13 Mar 2012 10:14:59 -0700

Date: Tue, 13 Mar 2012 10:48:59 -0700
Mr. Coughlin:


911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

11TR26800.


911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

To: Campbell, Debra

card?
12 of 17
3/29/2012 2:18 PM
13 of 17
3/29/2012 2:18 PM
Sincerely,
RE: request for written response regarding property being

held in evidence

held in evidence
From: Beckman, Trish (TBeckman@washoecounty.us)

Sent: Tue 3/20/12 8:49 AM
To:

Sent: Tue 3/20/12 11:12 AM
Mr. Coughlin, Aached is the wrien response to your email. Per our phone conversaon a copy of this
response has been sent to the fax number you gave me (949-667-7402).
To:
1 attachment
COUGHLIN.docx (145.4 KB)
Trish

To: Beckman, Trish

To: Beckman, Trish
Dear Ms. Beckman,

A WCSO Deputy informed me that my property was being held in evidence, including a
flip phone style cell phone, and an HTC g2 smartphone in addition to a micro sd memory
card, and an electric shaved. He indicated the items were booked into evidence on
2/27/12, then taken by the City of Reno Marshal Division on 2/28/12. A WCSO Deputy
also indicated these items in evidence were release again to the City of Reno Marshal
Division on 3/14/12 because "its just easier to get it back to you that way"....However, now
it appears once again your office has the property.
Dear Ms. Beckman,

There was nothing attached to your email. Would you please resend and attach the file
you referenced below?
Thanks,
001450
14 of 17
3/29/2012 2:18 PM
15 of 17
3/29/2012 2:18 PM
Date: Tue, 20 Mar 2012 08:49:52 -0700
Trish

To: Beckman, Trish
Dear Ms. Beckman,

A WCSO Deputy informed me that my property was being held in evidence,
including a flip phone style cell phone, and an HTC g2 smartphone in addition to a
micro sd memory card, and an electric shaved. He indicated the items were booked
into evidence on 2/27/12, then taken by the City of Reno Marshal Division on
2/28/12. A WCSO Deputy also indicated these items in evidence were release again
to the City of Reno Marshal Division on 3/14/12 because "its just easier to get it
back to you that way"....However, now it appears once again your office has the
property.
I would like a written response detailing the chain of custody of all the property for
all times since the arrest, and itemized listing of the property, and an indication of
when, if ever, I will be informed of why it is being held and when, if ever, it will be
returned to me, and and indication of what exactly has been done with this
property, including whether an viewing or copying of the contents has been
undertaken or will remain in anyone's possession other than mine.
Sincerely,
16 of 17
3/29/2012 2:18 PM
17 of 17
3/29/2012 2:18 PM
001451
001452
001453
001454
001455
001456
001457
001458
Page 1 of 6

Case ID:
CR12-0376
Docket Start Date:
Docket Ending Date:
Case Description
Case ID:
Filing Date:
Type:
Status:
CR12-0376 - STATE VS ZACHARY BARKER COUGHLIN (D10)

Tuesday , February 28th, 2012
CR - CRIMINAL
Related Cases
CR11-2064
FV12-00122
FV12-00187
FV12-00188
FV12-01011
FV12-01012
Case Event Schedule

Case Parties
Seq #
Assoc Expn Date
2
3,4,9

Reno NV 89503
Address: 75 Court Street

Reno NV 89501
ID
Name
Judge
Type
D10
ELLIOTT, HONORABLE
STEVEN P.
Aliases: none
Plaintiff
STATE
STATE OF NEVADA
Aliases: STATE OF NEVADA
District
Attorney
4059
Stralla, Esq., Roy L.
Aliases: none
District
Attorney
6668
Halstead, Esq., Patricia

C.
001459
Address: HALE LANE PEEK

DENNISON
AND HOWARD
5441 KIETZKE LANE,
2ND FLR.
RENO NV 89511
6,7
Address: Washoe Co. PD's Office

350 S. Center St., 5th Fl
P.O. Box 30083
Reno NV 89501
7
Address: Office of the Attorney

General
100 N. Carson St.
Carson City NV 89701
Aliases: none
Defendant
Address: WASHOE COUNTY

DISTRICT ATTY
P.O. BOX 30083-3083
RENO NV 89520

CAUGHLIN, ZACHARY
COUGHLIN, ZACHARY
COUGHLIN, ZACH
COUGHLIN, ZACKARY
Public
Defender
6976
Fortier, Esq., Chris
Aliases: none
Public
Defender
10566
Dogan, Esq., Biray
Aliases: none
Parole &
Probation
Address: 10 State Street

Reno NV 89501
Page 2 of 6
DPNP
Parole & Probation, Div.

of
Aliases: none
District
Attorney
9227
Young, Esq., Zach
Aliases: YOUNG, ZACH

Young, Esq., Zach
001460
Page 3 of 6
Docket Entries
Filing Date
Description
Name
Monetary
28-FEB-2012 Ord Psychiatric Evaluation

02:43 PM
Entry:
none.
29-FEB-2012 Court Services Report

09:17 AM
Entry:

09:23 AM
Entry:
29-FEB-2012 Vacated
10:16 AM
Entry:
MOVED BY THE COURT TO 4/3 - COUNSEL NOTIFIED
30-MAR-2012 Application for Setting

04:14 PM
Entry:
Dogan, Esq., Biray
COMP EVAL HEARING: 4-19-12 AT 8:30 - Transaction 2859998 - Approved

By: SHAMBRIG : 04-02-2012:08:05:13

08:07 AM
Entry:
02-APR-2012 Vacated
10:55 AM
Entry:
RESET FOR 4/19/12
001461
Page 4 of 6

02:34 PM
Entry:
LETTER FROM LAKE'S CROSSING RE TERMINATION OF COURT

ORDERED PSYCH EVAL - Transaction 2897316 - Approved By: ASMITH :
04-18-2012:14:40:49

02:42 PM
Entry:
19-APR-2012 Heard-Continued Court

11:23 AM
Entry:
none.
24-APR-2012 Vacated
09:00 AM
Entry:
RESET FOR 4/26/12
24-APR-2012 Application for Setting

10:43 AM
Entry:
Dogan, Esq., Biray
SB89 COMP EVAL 04-26-12 @ 08:30AM - Transaction 2908436 - Approved

By: ASMITH : 04-24-2012:11:01:16

11:04 AM
Entry:

03:07 PM
Entry:
4/23/12 COMPETENCY EVALUATION BY DR. MARY VIETH, PH.D. Transaction 2909741 - Approved By: LMATHEUS : 04-24-2012:15:52:32

03:07 PM
Entry:
4/23/12 COMPETENCY EVALUATION BY DR. RICHARD BISSETT, PH.D. Transaction 2909741 - Approved By: LMATHEUS : 04-24-2012:15:52:32
001462
Page 5 of 6

03:54 PM
Entry:
25-APR-2012 ***Minutes
09:43 AM
Entry:

09:46 AM
Entry:
25-APR-2012 Motion ...

12:07 PM
Entry:
Dogan, Esq., Biray
MOTION TO RELEASE ZACHARY COUGHLIN FROM CUSTODY Transaction 2911936 - Approved By: SHAMBRIG : 04-25-2012:12:25:23

12:26 PM
Entry:
26-APR-2012 Found Competent Returned to JC

08:30 AM
Entry:
none.
02-MAY-2012 ***Minutes
03:02 PM
Entry:

03:03 PM
Entry:
001463
Page 6 of 6
09:42 AM
Entry:

By: NOREVIEW : 05-09-2012:09:46:24

09:48 AM
Entry:
09-MAY-2012 Order of Competency/Return JC

05:17 PM
Entry:

05:19 PM
Entry:
09:10 PM
Entry:

By: NOREVIEW : 05-17-2012:21:11:14

09:12 PM
Entry:
18-MAY-2012 General Receipt

09:19 AM
Entry:
none.
001464
001465
1 of 17

Sent: Tue 3/13/12 10:49 AM
To:

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

To: Campbell, Debra
001466
3/29/2012 2:18 PM

Date: Tue, 13 Mar 2012 10:14:59 -0700
Mr. Coughlin:
11TR26800.

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
001467
2 of 17
3/29/2012 2:18 PM

Sent: Mon 3/05/12 8:43 AM
To:
Cc:
Dear Mr. Coughlin:
328-2971.
Regards,

To: SheriffWeb

001468
3 of 17
3/29/2012 2:18 PM
4 of 17
really helped that the Sheriff's Office let Mr. Eastman get my keys to feed my
dog, thank you!).
However, Mr. Eastman indicates to me that he did not receive either cell phone
or the micro sd card upon picking up my secured property.
If possible please reply by fax or email as I, obviously, do not have my phones
and there is a problem right now with my usps mailbox.

Sent: Tue 3/13/12 1:57 PM
To:
Yes, a micro sd card was listed on the inventory at intake and was released with the rest of your property on
2-29-12 to Peter Eastman. I will scan and email you a copy of the intake property form and the release form
signed by Mr. Eastman.

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
001469
3/29/2012 2:18 PM
5 of 17

To: Campbell, Debra


Date: Tue, 13 Mar 2012 10:48:59 -0700

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
001470
3/29/2012 2:18 PM
6 of 17

To: Campbell, Debra
card?

Date: Tue, 13 Mar 2012 10:14:59 -0700
Mr. Coughlin:
11TR26800.

911 Parr Blvd
001471
3/29/2012 2:18 PM
7 of 17
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

Sent: Tue 3/13/12 2:50 PM
To:
1 attachment
Coughlin Property Docs 0312.doc (2.6 MB)
The two documents I referred to in my last email are aached.

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
001472
3/29/2012 2:18 PM
8 of 17

To: Campbell, Debra


Date: Tue, 13 Mar 2012 10:48:59 -0700

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
001473
3/29/2012 2:18 PM
9 of 17

To: Campbell, Debra
card?

Date: Tue, 13 Mar 2012 10:14:59 -0700
Mr. Coughlin:
11TR26800.

001474
3/29/2012 2:18 PM

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

Sent: Wed 3/14/12 6:52 AM
To:
I am saying that two cell phones and an electric razor were placed into evidence at the instrucon of Judge
Nash-Holmes and the evidence envelope states that is what is in the envelope. As I do not work in or have
access to the evidence unit, I am relaying what they told me when they checked the envelope.
In response to your prior email, the property record form stated that there was a micro sd card. The
Authorizaon for Release of Property/Money was dated 2-29-12 and signed by Mr. Eastman. The statement
he signed states that he acknowledged that he received the items listed on the property record form. I can
only assume that is the case as he signed the form and you authorized him to pick up the property.
Since I am not an aorney I will send your last two emails to the Assistant District Aorney assigned to the
Sheris Oce for response.
001475
10 of 17
3/29/2012 2:18 PM

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

Sent: Tuesday, March 13, 2012 9:23 PM
To: Campbell, Debra; Kandaras, Mary
So, are you saying you or your office currently have an "evidence envelope" that contains
these items placed into "evidence" . Do you whether that comprots with previous
assertions made by your office or agents, or, if, in fact, it contradicts representations as to
whom came and took what? If you still have any of this property in your possession,
please consider whether it is legal for you to allow the RMC or the Reno Marshal to come
check it out like a book from the library, or whether you have some liability if, oopsie,
something "disappears". Please ask Deputy Cheung about all of these circumstances
detailed in our correspondences and provide written documentation detailing his
responses. Further, please provide pictures of the evidence envelope and all the "evidence"
within such an envelope, including whether a micro sd card in within such materials or
whether such a card is somehow contained in one of the phones or otherwise instereted
into the same. Additionally, please indicate whether a phone battery or two is present.
Please ask yourself who is running what and whether that is appropriate.
Sincerely,
001476
11 of 17
3/29/2012 2:18 PM

Date: Tue, 13 Mar 2012 10:48:59 -0700

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)

To: Campbell, Debra
card?
001477
12 of 17
3/29/2012 2:18 PM

Date: Tue, 13 Mar 2012 10:14:59 -0700
Mr. Coughlin:
11TR26800.

911 Parr Blvd
Reno, NV 89512-1000
(775) 328-2893 (Office)
(775) 328-6305 (FAX)
001478
13 of 17
3/29/2012 2:18 PM

held in evidence
Sent: Tue 3/20/12 8:49 AM
To:
Trish

To: Beckman, Trish
Dear Ms. Beckman,

A WCSO Deputy informed me that my property was being held in evidence, including a
flip phone style cell phone, and an HTC g2 smartphone in addition to a micro sd memory
card, and an electric shaved. He indicated the items were booked into evidence on
2/27/12, then taken by the City of Reno Marshal Division on 2/28/12. A WCSO Deputy
also indicated these items in evidence were release again to the City of Reno Marshal
Division on 3/14/12 because "its just easier to get it back to you that way"....However, now
it appears once again your office has the property.
001479
14 of 17
3/29/2012 2:18 PM
15 of 17
Sincerely,

held in evidence
Sent: Tue 3/20/12 11:12 AM
To:
1 attachment
COUGHLIN.docx (145.4 KB)

To: Beckman, Trish
Dear Ms. Beckman,

There was nothing attached to your email. Would you please resend and attach the file
you referenced below?
Thanks,
001480
3/29/2012 2:18 PM
16 of 17
Date: Tue, 20 Mar 2012 08:49:52 -0700
Trish

To: Beckman, Trish
Dear Ms. Beckman,

A WCSO Deputy informed me that my property was being held in evidence,
including a flip phone style cell phone, and an HTC g2 smartphone in addition to a
micro sd memory card, and an electric shaved. He indicated the items were booked
into evidence on 2/27/12, then taken by the City of Reno Marshal Division on
2/28/12. A WCSO Deputy also indicated these items in evidence were release again
to the City of Reno Marshal Division on 3/14/12 because "its just easier to get it
back to you that way"....However, now it appears once again your office has the
property.
I would like a written response detailing the chain of custody of all the property for
all times since the arrest, and itemized listing of the property, and an indication of
when, if ever, I will be informed of why it is being held and when, if ever, it will be
returned to me, and and indication of what exactly has been done with this
property, including whether an viewing or copying of the contents has been
undertaken or will remain in anyone's possession other than mine.
Sincerely,
001481
3/29/2012 2:18 PM
001482
17 of 17
3/29/2012 2:18 PM
FILED
Electronically
03-20-2012:04:25:19 PM
Clerk of the Court
001483
001484
001485
001486
FILED
Electronically
03-20-2012:04:25:19 PM
Clerk of the Court
001487
001488
001489
FILED
Electronically
03-27-2012:12:17:09 AM
Clerk of the Court

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Note: the following Motion was submitted for

filing on 2/27/12, but rejected, again, though
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03-07-2012 Plaintiff Mtn for
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Extension of Time Filed by or in
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for Extension of Time - Exhibit 1
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on 2/27/12 in RCR2012-065630 an Order for

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Judge Nash Holmes 11 TR 268000 summary
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Page 1 of 13

Case ID:
CR11-2064
Docket Start Date:
Docket Ending Date:
Case Description
Case ID:
Filing Date:
Type:
Status:
CR11-2064 - ZACH COUGHLIN VS. CITY OF RENO (D10)

Friday , December 23rd, 2011
MO - OTHER MUNICIPAL COURT CRIMINAL
Related Cases
CR12-0376
FV12-00122
FV12-00187
FV12-00188
FV12-01011
FV12-01012
Case Event Schedule

Case Parties
Seq #
Assoc Expn Date
2
5,6

Office of the City
Attorney
Reno NV 89505
ID
Name
Judge
Type
D10
ELLIOTT, HONORABLE
STEVEN P.
Aliases: none
Appellant

CAUGHLIN, ZACHARY
COUGHLIN, ZACHARY
COUGHLIN, ZACH
COUGHLIN, ZACKARY
Respondent RENO
CITY OF RENO
Aliases: none
001540
3,3
City
Attorney
Address: 1325 Airmotive Way

Suite 340
Reno NV 89502
5
Page 2 of 13
4041
Roberts, Esq., Pamela G.
Aliases: none
Attorney
Address: 121 River Rock St.

Reno NV 89501
9473
Aliases: none
Docket Entries
Filing Date
Description
Name
Monetary
23-DEC-2011 Appeal from Municipal's Court

09:19 AM
Entry:
(SCANNED IMAGE REFLECTS MANNER IN WHICH DOCUMENT WAS

RECEIVED - 12-23-2011 - SC)
05-JAN-2012
05:38 PM
Entry:
05-JAN-2012
05:39 PM
Entry:
10-JAN-2012
01:29 AM
Entry:
Coughlin, Esq.,
Zachary
ZACH COUGHLIN, ESQ. ON BEHALF OF ZACH COUGHLIN - Transaction

10-JAN-2012
09:02 AM
Entry:

001541
19-JAN-2012
01:37 PM
Entry:
Mtn to Dismiss ...
Page 3 of 13
Roberts, Esq.,
Pamela G.
MOTION TO DISMISS APPEAL - Transaction 2708055 - Approved By:

SHAMBRIG : 01-19-2012:14:45:34
19-JAN-2012
02:46 PM
Entry:
30-JAN-2012
12:18 PM
Notice to Set
Entry:
Coughlin, Esq.,
Zachary
NOTICE TO SET HEARING - Transaction 2729610 - Approved By:

LMATHEUS : 01-30-2012:15:37:49
30-JAN-2012
03:41 PM
Entry:
30-JAN-2012
04:48 PM
Entry:
Coughlin, Esq.,
Zachary
OPPOSITION TO NMOTION TO DISMISS APPEAL - Transaction 2730987 Approved By: LMATHEUS : 01-30-2012:16:58:15
30-JAN-2012
05:00 PM
Entry:
01-FEB-2012 Supplemental ...

08:32 AM
Entry:
SUPPLEMENT TO MOTION TO DISMISS

04:46 PM
Entry:
Coughlin, Esq.,
Zachary
Coughlin, Esq.,
Zachary
SUPPLEMENT TO MOTION TO DISMISS - Transaction 2736761 Approved By: LMATHEUS : 02-02-2012:08:31:50

001542
Page 4 of 13

08:33 AM
Entry:
02-FEB-2012 Notice to Set

02:38 PM
Entry:
Coughlin, Esq.,
Zachary

03:01 PM
Entry:
06-FEB-2012 Reply to/in Opposition

04:41 PM
Entry:
REPLY IN SUPPORT OF MOTION TO DISMISS - Transaction 2747102 Approved By: LMATHEUS : 02-06-2012:16:47:23

04:42 PM
Entry:
Roberts, Esq.,
Pamela G.
Roberts, Esq.,
Pamela G.

DOCUMENT TITLE: MOTION TO DISMISS (NO PAPER ORDER) PARTY
SUBMITTING: PAMELA ROBERTS, ESQ. DATE SUBMITTED: 02-06-12
SUBMITTED BY: JYOST DATE RECEIVED JUDGE OFFICE:

04:49 PM
Entry:

04:50 PM
Entry:
07-FEB-2012 Opening Brief

12:19 AM
Coughlin, Esq.,
Zachary
APPELLANT'S OPENING BRIEF - Transaction 2747319 - Approved By:

001543
Entry:
LMATHEUS : 02-07-2012:10:32:32
07-FEB-2012 Mtn for Extension of Time

09:44 AM
Entry:
Page 5 of 13
Coughlin, Esq.,
Zachary
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE OPENING

BRIEFG - Transaction 2747886 - Approved By: LMATHEUS : 02-072012:10:38:21

10:37 AM
Entry:

10:40 AM
Entry:
09-FEB-2012 Application for Setting eFile

12:22 PM
Entry:
HEARING ON APPEAL SET FOR 4/26/12 AT 10:00 A.M. (TO BE VACATED

UPON WRITTEN DECISION ON APPEAL) - Transaction 2754868 Approved By: NOREVIEW : 02-09-2012:12:22:48

12:23 PM
Entry:
15-FEB-2012 Mtn Proceed Forma Pauperis

11:42 PM
Entry:
Coughlin, Esq.,
Zachary
MOTION FOR APPOINTMENT OF COUNSEL; OR ATERNATIVELY,

MOTION TO PROCEED INFORMA PAUPERS ON APPEAL (NO PAPER
ORDER PROVIDED) - Transaction 2768364 - Approved By: LMATHEUS :
02-16-2012:13:55:26

01:57 PM
Entry:
001544

05:47 AM
Entry:
Page 6 of 13
Coughlin, Esq.,
Zachary
SUPPLEMENT TO APPEALLANT'S OPENING BRIEF - Transaction


11:24 AM
Entry:
23-FEB-2012 Answering Brief

01:17 PM
Entry:
Roberts, Esq.,
Pamela G.

02:16 PM
Entry:

08:22 AM
Entry:
Coughlin, Esq.,
Zachary
SUPPLEMENT TO APPELLANT'S OPENING BRIEF; OR PLEAD IN THE

ALTERNATIVE, NOTICE OF INSUFFICIENCY OF THE RECORD ON
APPEAL - Transaction 2784715 - Approved By: LMATHEUS : 02-242012:10:46:09

10:47 AM
Entry:

04:41 PM
Entry:
ORDER DENYING MOTION TO PROCEED IN FORMA PAUPERIS Transaction 2813932 - Approved By: NOREVIEW : 03-08-2012:16:42:00

04:44 PM
001545
Entry:
Page 7 of 13

02:04 PM
Entry:
none.

04:04 PM
Entry:
none.
15-MAR-2012 Vacated
04:44 PM
Entry:
APPEAL DISMISSED

06:21 PM
Entry:
TO DISMISS APPEAL - Transaction 2829786 - Approved By: NOREVIEW :

03-15-2012:18:22:10
15-MAR-2012 Ord Affirm/Judg/Dism/Remand

06:21 PM
Entry:

REMANDED 03/20/12 - CERTIFIED COPY OF ORDER AFFIRMING
RULING OF THE RENO MUNICIPAL COURT & APPELLANT'S CD - EX 1
11CR22176 12/12/11 - MCHOLICO

06:23 PM
Entry:
15-MAR-2012 ** Case Closed

06:35 PM
Entry:
none.
15-MAR-2012 Transferred
06:45 PM
001546
Entry:
Page 8 of 13
none.
20-MAR-2012 ** Notes ...

11:42 AM
Entry:
REMANDED 03/20/12 - CERTIFIED COPY OF ORDER AFFIRMING

RULING OF THE RENO MUNICIPAL COURT & APPELLANT'S CD - EX 1
11CR22176 12/12/11 - MCHOLICO
20-MAR-2012 General Receipt

02:34 PM
Entry:
none.
21-MAR-2012 Amended ...

10:38 AM
Entry:
AMENDED GENERAL RECEIPT FORM
26-MAR-2012 Mtn Alter or Amend Judgment

11:33 PM
Entry:
Coughlin, Esq.,
Zachary
MOTION FOR NEW TRIAL, OR PLED IN THE ALTERNATIVE, MOTION TO

ALTER OR AMEND - Transaction 2849615 - Approved By: LMATHEUS : 0327-2012:11:55:29

11:56 AM
Entry:
27-MAR-2012 Mtn to Strike...

02:55 PM
Entry:
Roberts, Esq.,
Pamela G.
MOTION TO STRIKE APPELLANT'S MOTION FOR NEW TRIAL Transaction 2851733 - Approved By: LMATHEUS : 03-28-2012:08:01:02

08:02 AM
Entry:
05-APR-2012 Notice of Appeal Supreme Court
Coughlin, Esq.,
001547
12:23 AM
Entry:
Page 9 of 13
Zachary
APPELLANT, ZACH COUGHLIN - Transaction 2870917 - Approved By:
LMATHEUS : 04-05-2012:12:09:10

12:11 PM
Entry:
06-APR-2012 Supreme Ct Deficiency Notice

11:30 AM
Entry:
06-APR-2012 Certificate of Clerk

11:30 AM
Entry:
CERTIFICATE OF CLERK AND TRANSMITTAL - NOTICE OF APPEAL Transaction 2874041 - Approved By: NOREVIEW : 04-06-2012:11:31:20

11:32 AM
Entry:
07-APR-2012 Mtn Proceed Forma Pauperis

12:33 AM
Entry:
Coughlin, Esq.,
Zachary
MOTION TO PROCEED INFORMA PAUPERIS - Transaction 2875623 Approved By: LMATHEUS : 04-09-2012:11:19:47
09-APR-2012 ** Case Reopened

11:23 AM
Entry:
none.
09-APR-2012 **Submit regarding Appeals

11:23 AM
Entry:
DOCUMENT TITLE: MOTION TO PROCEED IN FORMA PAUPERIS ON

APPEAL PARTY SUBMITTING: ZACH COUGHLIN, ESQ. DATE
JUDGE OFFICE:
001548
Page 10 of 13

11:50 AM
Entry:
13-APR-2012 Supreme Court Receipt for Doc

08:46 AM
Entry:
SUPREME COURT CASE NO. 60630 - Transaction 2887685 - Approved By:

NOREVIEW : 04-13-2012:08:47:32

08:49 AM
Entry:
09-JUN-2012 Case Appeal Statement

06:33 PM
Entry:
Coughlin, Esq.,
Zachary
APPEALANT - ZACHARY COUGHLIN - Transaction 3007000 - Approved

By: MFERNAND : 06-11-2012:08:26:51
11-JUN-2012 Proof of Electronic Service

08:28 AM
Entry:
14-JUN-2012 Certificate of Clerk

10:11 AM
Entry:
CERTIFICATE OF CLERK AND TRANSMITTAL - NRAP 3(g)(1)(B) Transaction 3018161 - Approved By: NOREVIEW : 06-14-2012:10:12:09
14-JUN-2012 Proof of Electronic Service

10:13 AM
Entry:
24-JUL-2012
02:38 PM
Supreme Ct Ord Dismis Appeal
Entry:
SUPREME COURT CASE NO. 60630 - Transaction 3105259 - Approved By:

NOREVIEW : 07-24-2012:14:39:32
001549
Page 11 of 13
24-JUL-2012
02:41 PM
Entry:
25-JUL-2012
05:09 PM
Entry:
Coughlin, Esq.,
Zachary
MOTION TO SET ASIDE OR VACATE CONVICTION AND OR ORDER

AFFIRMING IT - Transaction 3108680 - Approved By: AZION : 07-262012:08:16:25
26-JUL-2012
08:20 AM
Entry:
26-JUL-2012
10:18 AM
** Case Reopened
Entry:
none.
26-JUL-2012
02:01 PM
Supplemental ...
Entry:
26-JUL-2012
02:22 PM
Entry:
Coughlin, Esq.,
Zachary
SUPPLEMENTAL MOTION TO SET ASIDE OR VACATE CONVICTION

AND OR ORDER AFFIRMING IT - Transaction 3110356 - Approved By:
AZION : 07-26-2012:14:22:39
Coughlin, Esq.,
Zachary
APPELANT'S MOTION FOR NEW TRIAL - Transaction 3110453 - Approved

By: AZION : 07-26-2012:14:24:31 DOCUMENT TITLE: APPELANT'S
MOTION FOR NEW TRIAL PARTY SUBMITTING: ZACHARY COUGHLIN
ESQ DATE SUBMITTED: 07-26-12 SUBMITTED BY: AZION DATE
26-JUL-2012
02:24 PM
Entry:
001550
Page 12 of 13
26-JUL-2012
02:26 PM
Entry:
22-AUG-2012 Supreme Court Remittitur

02:52 PM
Entry:
SUPREME COURT CASE NO. 60630/REMITTITUR - Transaction 3168972 Approved By: NOREVIEW : 08-22-2012:14:53:37
22-AUG-2012 Supreme Ct Clk's Cert & Judg

02:52 PM
Entry:
SUPREME COURT CASE NO. 60630/CLERK'S CERTIFICATE &

JUDGMENT - Transaction 3168972 - Approved By: NOREVIEW : 08-222012:14:53:37
22-AUG-2012 Supreme Ct Ord Dismis Appeal

02:52 PM
Entry:
SUPREME COURT CASE NO. 60630/ORDER DISMISSING APPEAL Transaction 3168972 - Approved By: NOREVIEW : 08-22-2012:14:53:37

02:56 PM
Entry:
27-AUG-2012 Request for Submission Complet

10:14 AM
Entry:
none.
27-AUG-2012 Ord Denying Motion

10:15 AM
Entry:
APPELLANT'S MOTION FOR A NEW TRIAL - Transaction 3176064 Approved By: NOREVIEW : 08-27-2012:10:15:44

10:17 AM
Entry:
001551
Page 13 of 13
27-AUG-2012 Other Manner of Disposition

10:18 AM
Entry:
none.
001552

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001586
reno craigslist > housing > parking & storage
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$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
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Welcome to Northwind Apartments. We offer storage units to non-Northwind Residents!

If you need more storage, we offer garages to rent for $75 per month. They are a full size single car garage. Most
public storages would charge over $150 dollars for the same size! Our community is located in northwest Reno, right
off of McCarran.
Please call us at (775) 747-9200 or come by. We are located at 1680 Sky Mountain Drive in Northwest Reno.
1680 Sky Mountain Dr. (google map) (yahoo map)

001587
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I demand my summary eviction hearing, before a jury based

upon 6 28 12 notice and my faxed Tenants Answer of 6 30 12
i
Sent: Wed 10/10/12 5:38 AM
To: stuttle@washoecounty.us; kstancil@washoecounty.us; rjcweb@wasoecounty.us;
037nor2@acg.com; 037nor4@acg.com; nevcs@nevcs.com; chansen@washoecounty.us;
renodirect@reno.gov; rjcweb@washoecounty.us; cwood@washoecounty.us;
william@hornelawfirm.com; pilbinfo@ag.nv.gov; tsegerblom@asm.state.nv.us
Dear Mr. Tuttle and Supervisor, Civil Division Stancil and Supervisor of the Civil
Division at Sparks Justice Court Hansen,
Mr. Hansen, I believe I am entitled to a hearing in your court. I would like one. May I
have a date. Mr. Tuttle and Ms. Stancil, I believe I am entitled to several hearings in
your court, may I have such and a date and time for them?
I am writing to demand respectfully my hearing incident to the NOtice served on my
rental at Northwind Apartments 1680 Sky Mountin Drive unit 29 on June 28th, 2012.
I believe the tenant's affidavit I filed in response to that 5 day notice should be given
a brand new case number, though the designation by ncs that it was an "Amended
NOtice" pursuant to is is is is is is is isis it is as if the isthe 6/14/12 one (the one R.
Wray lied about effecting "personal service" on me of, which got me arrested just
before I was to fax to the RJC, by noon, a Tenant's Answer or MOtion to Dismiss for
failure to state a cause of action or deficieny of service of process or something (I
arguably needn't have even filed anything in the RJC where the 6/14/12 notice listed
Sparks Justice Court.
Oh, it gets better...Nevada Courts services filed a Landlord's Affidavit attesting to
have rented Coughlin a "dwelling" which is defined as a "sleeping place or residence"
in NRS 118A...and pursued an eviction under NRS 118A...citing a breach by Coughlin
for allegedly using the unit 29 for a residence or sleeping place, instead of pursuing
NRS 40.760 or NRS 118.475 eviction remedies (which, by the way, may result in the
Sheriff evicting Coughlin or forcing him to quit any alleged use of Unit 29 as a
"dwelling place or residence", but YOU WILL NOT THAT UNDER THOSE
001607
file:///C|/...012%20email%20to%20stuttle@washoecounty.us%20regarding%20ncs%20rev2012-001048%20etc%20ncs.htm[10/10/2012 6:23:17 AM]
STATUTES COUGHLIN WOULD BE ALLOWED, UNDER THE LAW TO

CONINUTE STORING AND ACCESSING HIS PROPERTY THERE!!!!CAN'T
HAVE IT BOTH WAYS ALL THE TIME, GUYS. Oh, also, who in the hell signed
the Landlord's affidavit? There is no textual indication of whom the solitary letter of a
"signature" belongs to....maybe because it would be a NRCP 11 violation for a
corporation to appear "pro se", especially where represented by someone committing
the unauthoried practice of law?
R. Wray made some interesting statements on the video of the 6/28/12 arrest filmed by
Coughlin, especially concerning Coughlin's contention that Wray and NOrthwind's
Dwane Jakob's attempts to break and enter and trespass into Unit 29 constituted
"personally serving" Coughlin a 5 day Unlawful Detainer Notice on 6/14/12. If NCS
did not "personally serve" Coughlin, then Coughlin would have had until June 28th,
2012 at noon at the earliest (and arguably until the close of business at 5pm on
6/28/12 to file a response (ie Tenant's Answer or MOtion to Dismiss, etc), in Sparks
Justice Court OR EVEN in REno Justice Court. Coughlin was arrested at 10:30 am
on 6/28/12, thereby, under color of law, the WCSO, NCS and NOrthwind and Jakob
fraudulently prevented Coughlin from filing (if he did not already previously,
espeically in the 6/13/12 faxes that are mysteriously unaccounted for in rJC files) a
Tenan'ts Response (tEnan'ts answer, or Tenant's AFfidavit or Motion to Dismiss, etc.).
So, R. Wray and NCS, its kind of a big deal that you lied about effecting personal
service on 6/14/12 of the 5 day notice.
Coughlin has three different version of that notice or "Declaration of Srevice by

License PRocess SErver" R. Wray. in one, a time of 9:23 (presumably am, but that is
not circled, nor is pm) on 6/14/12 is listed, and a rubber stamp indicating "r. wray", is
there, along with a hadnwritten "reg #r-043948" is there. that Declaration indicates
that R. WRay "personally served" the partey named, Coughlin. Oddly, this first
version (and all three of these are in the RJC file in rev2012-001048) instead of
"jennifer Chandler" being in , I guess, the signature line for the "agent" of the landlrod
(and she always just places a "rubber stamp" of her name anyways..", instead of
Jennifer Chandler, on the one 6/14/12 5 day NOtice (and all version sof this notice
have checks on box 3 and 6, which read "3. Recieved a 5 day notice of possible
unlawful detiner for failure to comply with the rental agreement....6. Remained in
001608
possesion of the premises subject to the provision of Chpater 118A of the NRS after
having failed to perform the basic or contractual obligations imposed upon you by that
Chapter, namey (SEE ATTAChed)" though the "attached just seems to include a
copy of the "Rental Agreement" with no real indication of how Coughlin was in
violation of it, and no indication of why NOrthwinds feels Coughlin remained in
violation thereof despite Coughlin's written communications indicating that he was not
in breach. Anyways, rather tha a rubber stamp indicating "jennifer Chandler" on that
one 5 day notice, the one where WRay actually affixes his actual signature, follow by
a handwritt r-043948 (his licensed process sever number), the spot usually baring the
"Jennifer Chandler" rubber stamp is instead taken up by a signature by Nevada Court
Services resient notary public HB Cedomio....AGain, there is no time listed on that
first version of the NOtice or which includeds at the bottom the "Declaration of
Service...."
In the second version of the "notice of Unlawful detainer..." served on June 14th,
2012, in his "Declaration of Service by Licnese process Server" (which, arguably
inovkes the "penalty of perjury dicate of NRS 53.045...) Wray against declares he
personally served Coughlin, with a time of 9:23 indicated, and a rubber stamp of "R.
Wray" on the signature line, with a handwritten "REg #R-043948" (and that version
was faxed by the Sparks Justice Court to the Reno Justice Court on June 28th, 2012 at
11:05 am, (in a 13 page fax, many pages of which are not in the RJC file, though that
fax does included the header from the fax from Coughlin to the "Sparks Justice Court
on 6 26 12 at 12:00pm, which was a 10 page fax, and the versio of the 6/14/12 5 day
notice with Declartion of Service by r. Wray indicating a time of 9:23 is page 6 of 10
of Coguhlin's fax to the Sparks Justice Couer (according to the fax hearders) while
also being page 12 of teh June 28th, 2012 fax from the Sparks Justice court to the
Reno Justice Court. right about the moment Coughlin was being placed in WCSO
Deputy Machen squad or patrol vehicle for transprot to the jail, where Coughlin would
be forced to fork over some more bail, etc., etc.
IN the Third version of the "Declaration of Service" on the same June 14th, 2012
"NOTICE OF UNLAWFUL DETAINER FOR FAILURE TO VACATE PREMISES
..This third version of his 6/14/12 Declaration of Service by Licensed PRocess Serve
R. Wray has the typical "jennifer chandler" rubber stamp for the NOtice half of the
page, and has a rubber stamp for "?R.wray", along with a clearly differt handwrirtn
note of "reg# r043" (obviously, aside from the handwriting "analysis" the handwrittn
001609
numberical indication of the process servicer number is truncated on this third version
by 3 numbers). Additionaly this third version indicates it was "personally served" at
12:54 pm.
Why all the different versions? why, if personally service was effect at 9:23 am, woud
R. Wray need to return and do it again, all for Unit 29, nmin you only (all the other
Declartions of Service from that date of 6/14/12 , ie for units 45 and 71, indicate that
Wray merely posted teh notice to the rented property (and therefore would entail 3
more days fro mailing to get "construtive notice" under NRCP 6(e) and NRCP 5(b)(2),
which landlord's like Northwinds just hate.
Then there is the fact that NCS snuck into the file later a whole nother type of notice,
one under NRS 40.760...which, of course, changes everything..
OF course, Wray did not "personally serve" Coughlin. Wray attempts to make some
half-baked argument about how he slid (after failing in his attempts to break and enter
and trespass in to Unit 29 on 6/14/29) the 5 day UD Notice into a crack in the door of
the rental, and perceived it to "move" after he let go of it, thereby, apparently, entitling
him to assert that he effected "personal service" upon tenant Zach Coughlin, or,
apparently, otherwise complied with NRCP 5, and therefore cut short the time for
Coughlin to respond as a tenant and secure a hearing (rather than be incarcerated after
having unknown violent sounding figures (flashbacks to other interactions with
Nevada Court Services) banging on his doors, refusing to indentify themselves, then
ultimately taking a chainsaw (or sawz-all) to a metal door to a confined windowless
rental.
NRS 40.400 makes NRCP the applicable rules here, not JCRCP, nor JCRRT:
RULE 5. SERVICE AND FILING OF PLEADINGS AND OTHER PAPERS
Rule
Drafters Note
Commentary
001610
(a) Service: When Required. Except as otherwise provided in these rules, every order
required by its terms to be served, every pleading subsequent to the original complaint
unless the court otherwise orders because of numerous defendants, every paper
relating to discovery required to be served upon a party unless the court otherwise
orders, every written motion other than one which may be heard ex parte, and every
written notice, appearance, demand, offer of judgment, designation of record on
appeal, and similar paper shall be served upon each of the parties. No service need be
made on parties in default for failure to appear except that pleadings asserting new or
additional claims for relief against them shall be served upon them in the manner
provided for service of summons in Rule 4.
[As amended; effective September 27, 1971.]
(b) Same: How Made.
(1) Whenever under these rules service is required or permitted to be made upon a
party represented by an attorney, the service shall be made upon the attorney unless
the court orders that service be made upon the party.
(2) Service under this rule is made by:
(A) Delivering a copy to the attorney or the party by:
(i) handing it to the attorney or to the party;
(ii) leaving it at the attorneys or partys office with a clerk or other person in charge,
or if there is no one in charge, leaving it in a conspicuous place in the office; or
(iii) if the office is closed or the person to be served has no office, leaving it at the
persons dwelling house or usual place of abode with some person of suitable age and
discretion residing there.
(B) Mailing a copy to the attorney or the party at his or her last known address.
Service by mail is complete on mailing; provided, however, a motion, answer or other
document constituting the initial appearance of a party must also, if served by mail, be
filed within the time allowed for service; and provided further, that after such initial
appearance, service by mail be made only by mailing from a point within the State of
Nevada.
001611
(C) If the attorney or the party has no known address, leaving a copy with the clerk of
the court.
(D) Delivering a copy by electronic means if the attorney or the party served has
consented to service by electronic means. Service by electronic means is complete on
transmission provided, however, a motion, answer or other document constituting the
initial appearance of a party must also, if served by electronic means, be filed within
the time allowed for service. The served attorneys or partys consent to service by
electronic means shall be expressly stated and filed in writing with the clerk of the
court and served on the other parties to the action. The written consent shall identify:
(i) the persons upon whom service must be made;
(ii) the appropriate address or location for such service, such as the electronic-mail
address or facsimile number;
(iii) the format to be used for attachments; and
(iv) any other limits on the scope or duration of the consent.
An attorneys or partys consent shall remain effective until expressly revoked or until
the representation of a party changes through entry, withdrawal, or substitution of
counsel. An attorney or party who has consented to service by electronic means shall,
within 10 days after any change of electronic-mail address or facsimile number, serve
and file notice of the new electronic-mail address or facsimile number.
(3) Service by electronic means under Rule 5(b)(2)(D) is not effective if the party
making service learns that the attempted service did not reach the person to be served.
(4) Proof of service may be made by certificate of an attorney or of the attorneys
employee, or by written admission, or by affidavit, or other proof satisfactory to the
court. Failure to make proof of service shall not affect the validity of service"
In the legal work drafted and filed by a non-attorney, a criminal violation in NCS's
and Jeff Chandler's committing the authorized practice of law (what happens to people
doing plastic surgery without a license? jail time, lots of it...because something could
001612
go badly, badly wrong and people could get hurt...like Coughlin got hurt, damaged,
arrested, financially destroyed, etc., etc. here. thin skull plaintiff, consequential
damages Winchell v Schiff 2008 case seafood, storage place lost business and lost
profits $300K damages, etc.. while in jail Coughlin was prevented from filing in
matters that ultimately wound up with a $40,050 judgment against Coughlin, and
there's more, for which NOrthwind, and NCS, Chandler and WRay, and perhaps, some
others, will be liable.). In the "Affidavit of Landlord for Breach" filed on June 27th,
2012 by ,well, who knows, given it just says "Lanldord" and has what appear s to be a
handwritten "S" in the signature line...but, lets say it was filed by Jeff Chandler, whom
crossed the bar and argued before Judge Pearson on July 31st, 2011 in REv2012001048 on behalf of his "client' Northwind Apartments, Associates LLC (see acgampi.com, doing business in 10 states, kinda seems like they could afford and attorney
rather than destroy our community with hack pretend lawyers who play dress as a
Sheriff and bully peopel while attempting to break and enter and trespass...and then
RPD Alan Weaver and SArgent Oliver Miller, and WCSO Deputy John Machen and
Deputy Gomez chip in some Soldal v. Cook County violating 1983 violations as
well....puke, puke. puke... IN the "Affidavit of Landlord for Breach" that Chandler
drafted and filed, he wrote, at paragraph 4. "him and nation surrender of the premises
was to have taken place on or before June 13, 2012. That legal notice has been served
on the tenant's in accordance with the provisions of NRS chapter 40.280 as amended
on 6/14/12."
Chandler's Affidavit of Landlord for Breach demonstrates a lack of candor to the

tribunal, which would be professional misconduct to report to the SBN, but, Chadler
aint a lawyer, so,and what are ya goin' ta do? DDA Yound? DDA Kandaras, isn't that
your jurisdiction? That is a criminal law violation, right, unauthorized practice of
law...and in that June 27th, 2012 Affidavit of Landlord Chandler sneakily lists "N/a" in
the blank for the "original period of is (blank) terminating on o forr transferring to a
periodic tenancy on that date. A copy of the written rental agreement, if any , is
attached hereto."....Upon information and belief, chandler failed to inlcude a copy of
the Rental Agreement in at least one of these NOrthwind files (not sure if it was in the
one for unit 29, rev2012-001048, but it woudl make sense, as Northwind's eggs were
all in that basket in a sense.) Anyways, the Rental AGreement makes clear the period
is not "n/a"...why would Chandler do that? Coudl it be that NRS 40.253 has differ
atent laws for tenancies where the rent is reserved by a period of 1 week or less?
Coughlin paid for one month's rent up front at the time the Renal Agreement was
001613
signed. Also, see isthe craigslist ad Coughlin responded to placed by Northwind, and
incorporated into an "Rental Agreement", along with verbal indications, arguably,
under NRS 118A.160 (which only applies to "dwelling places", but the Landlord's
Affidavit inidcates this rental was, in paragraph 2 such, as it states "2. That yor
affiant isrented a certain dwelling or apartment to Zach Coughlin, located at 1680 sky
mountain dr...#29, Reno, NV on 5/4/12 for an original period of N/a terminating on or
transferrinto a periodic tenancy on that date. a copy of the written rental agreemet if
any, is attached hereto.".. Chandler seems to want to take advanteg of NRS
40.253(2)'s quickie service approach for week to week rentals, which unit 29, by
virtue of the terms of the Rental Agreement, clearly was not. as him and him and him
this but the new the signatures is written in the amount of $75 is due no later than the
first of late after the for every month late is asked Bob Loblaw clearly this was a
periodic tenancy of month to month for variety further one provision and this one is
rental agreements has written 30 days notice to vacate is required or rental will be
responsible the next months rent covered Chandler tends to one characterize this as a
week to week or less type tenancy to take advantage of the lessons service
requirements there and found in NRS 40.253(1)-(2):
Further, the Rental Agreement is not necessarily limited to the document that
NOrthwind Apartments purports to be the "GARAGE / CARPORT RENTAL
AGREEMENT" as their exists no limitation in that document that affirmatively
disclaims any incorporation of statements by then Manage Deede Call (whom
mysteriously disappeared upon current Manager Dwayne Jakob showing up) or
incorporated into the Rental Agreement or Lease by virtue of the advertisements that
Northwinds held out to the public on Craigslist, which is how Coughlin learned of
their offer, upon which Coughlin called then Manager Deede Call and met with her in
person. Attached in Exhibit 1 is the Craigslist ad that Northwinds was running at the
time, and it read:
"$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
Reply to: see below
Welcome to Northwind Apartments. We offer storage units to non-Northwind
Residents! If you need more storage, we offer garages to rent for $75 per month.
They are a full size single car garage. Most public storages would charge over $150
dollars for the same size! Our community is located in northwest Reno, right
off of McCarran. Please call us at (775) 747-9200 or come by. We are located at 1680
001614
Sky Mountain Drive in Northwest Reno."

AND IT GETS BETTER: The thing about NRS 40.760 is that it specifically
indicates that it does not apply to "garages". And Judges don't legislate from the
bench, they just apply the law as written, so people can depend on notice provided by
precedent and published laws. To do otherwise is judicial misconduct arguably
requiring a Complaint with the Judicial Discipline Commission.
Further Coughlin asked and then Manager Deede Call (she is listed as the manager on
the "RENTAL AGREEMENT" of May 4th, 2012, and it bears hers and Coguhlin's
signature, numerous questions vis a vis the use of the rental, and clearly, Deede Call
gave Coughlin permission (and actually, Call did not indicate any "special permission"
to use the rentals for something other than parking a car was necessary to obtain
anyways, and no one has established that Coughlin did not use the rentals for parking
anyways, and any Fourth Amendment violating trespass and videoing of Coughlin's
rentals is not admissible anyways. Soldal v. Cook Co.
CHAPTER 40 - ACTIONS AND PROCEEDINGS IN PARTICULAR CASES

CONCERNING PROPERTY SUMMARY PROCEEDINGS FOR OBTAINING
POSSESSION OF REAL PROPERTY, RECREATIONAL VEHICLE OR MOBILE
HOME
exclusion of tenant for default in payment of rent.
NRS 40.280 Service of notices to quit; proof required before issuance of order to
remove.
NRS 40.400 Rules of practice.
CHAPTER 108 - STATUTORY LIENS
LIENS OF OWNERS OF FACILITIES FOR STORAGE
NRS 108.475
Use of storage space for residence prohibited; eviction; nature of
facility; effect of issuance of document of title for property.
001615
CHAPTER 118A - LANDLORD AND TENANT: DWELLINGS
CHAPTER 197 - CRIMES BY AND AGAINST THE EXECUTIVE POWER OF THIS

STATE
NRS 197.090
Interfering with public officer.
NRS 197.100
Influencing public officer.
NRS 197.110
Misconduct of public officer.
NRS 197.120
False impersonation of public officer; intrusion into and refusal to
surrender public office.
NRS 197.130
False report by public officer.
NRS 197.140
Public officer making false certificate.
NRS 197.160
Fraudulently presenting claim to public officer.
NRS 197.180
Wrongful exercise of official power.
NRS 197.190
Obstructing public officer.
The arrest of Coughlin at Northwinds Apartments on June 28th, 2012 by the same
WCSO Deputy Machen who filed a false affidavit attesting to have "personally
served" Coughlin the Summary Eviction ORder from Coughlin's former home law
office on November 1st, 2011, when in reality, Machen just posted the Order to the
door when nobody was home (and therefore committed trespass under color of law, as
he failed to comply with NRCP 5(b)(2) (made applicable to landlord tenant matters by
NRS 40.400) and NRCP 6(e).
So, WCSO Machen arrested Coughlin for a violation of NRS 197.190:
NRS 197.190 Obstructing public officer. Every person who, after due notice, shall refuse or
neglect to make or furnish any statement, report or information lawfully required of the person by
any public officer, or who, in such statement, report or information shall make any willfully untrue,
001616
misleading or exaggerated statement, or who shall willfully hinder, delay or obstruct any public
officer in the discharge of official powers or duties, shall, where no other provision of law applies,
be guilty of a misdemeanor.
Yet DDA charged Coughlin in the Criminal Complaint in RJC RCR2012-067980 with a different
crime, NRS 199.280:
"NRS: CHAPTER 199 - CRIMES AGAINST PUBLIC JUSTICE
OTHER OFFENSES
NRS 199.280
Resisting public officer.
A person who, in any case or under any circumstances not otherwise specially provided for,
willfully resists, delays or obstructs a public officer in discharging or attempting to discharge any
legal duty of his or her office shall be punished:
1. Where a firearm is used in the course of such resistance, obstruction or delay, or the person
intentionally removes, takes or attempts to remove or take a firearm from the person of, or the
immediate presence of, the public officer in the course of such resistance, obstruction or delay, for a
category C felony as provided in NRS 193.130.
2. Where a dangerous weapon, other than a firearm, is used in the course of such resistance,
obstruction or delay, or the person intentionally removes, takes or attempts to remove or take a
weapon, other than a firearm, from the person of, or the immediate presence of, the public officer in
the course of such resistance, obstruction or delay, for a category D felony as provided in NRS
193.130.
3. Where no dangerous weapon is used in the course of such resistance, obstruction or delay,
for a misdemeanor."
Why the change from DDA Young? It couldn't be becuase NRS 199.280 is more damaging to
Coughlin's law license, in light of SCR 111(6), than would be a simple little NRS 197.190 charge,
could it? Is that permissible where the WCDA and WCSO have a vested interest in discrediting
and demolishing Coughlin in light of allegation of misconduct by both of those offices with respect
to its treatment of Coughlin, in addition to misconduct against Coughlin by the WCDC?
001617
Nevada Supreme Court Rule 111(6): "6. Definition of serious crime. The term serious crime
means (1) a felony and (2) any crime less than a felony a necessary element of which is, as
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,".
Convictions of a "serious crime" require Bar Counsel to file a SCR 111 Petition against the
attorney.
Could there be any clear demonstration of the retaliatory animus against Coughlin by the Washoe
County District Attorney's Office? Are prosecutors paid to play out grudges and sanction
misconduct by local law enforcement? Rather than just a "resisting" charge, DDA Young and the
WCDA want to try to glom on a "false swearing" and "inteferring with the administration of
justice" claim, even where the know of the 6/26/12 written correspondence by Coughlin to both the
Sparks and Reno Justice Courts and the Civil Division of the Washoe County Sheriff's Office.
Enough is Enough. This prosecutorial misconduct must not stand.
But, really Coughlin is hereby complaining to the landlord, pursuant to NS 118A.510 of a violation
of the criminal law by one who is arguably an "agent" of the landlord (not making a bribery
allegation here, to be clear, though):
NRS 197.200 Oppression under color of office.
1. An officer, or a person pretending to be an officer, who unlawfully and maliciously, under
pretense or color of official authority:
(a) Arrests or detains a person against the persons will;
(b) Seizes or levies upon anothers property;
(c) Dispossesses another of any lands or tenements; or
(d) Does any act whereby the person, property or rights of another person are injured,
commits oppression.
2. An officer or person committing oppression shall be punished:
(a) Where physical force or the immediate threat of physical force is used, for a category D
felony as provided in NRS 193.130.
(b) Where no physical force or immediate threat of physical force is used, for a gross
misdemeanor.
Further, this is an officil written complaint against WCSO Deputy Machen and Gomez, please place
a copy of this Complaint in their employment and personnel files, and please do the same with
respect to RPD Officer Alan Weaver, Sargent Dye, Sargent Oliver Miller, and Officer Welch for
their gross misdemeanor, consisting of doing that which is the domain of the Sheriff under NRS
40.760 in conection with the matter at Superior Mini Storage on or around September 21st, 2012
under the following law, in light of teh language in NRS 40.760 and NRS 108.475, which I made
the RPD aware of at the time, and Soldal v. Cook Co. Couldn't be too much of a budget crunch
001618
when local law enforcement acts the way they do, veritably goading civil rights tenant's right
attorney's into suing them through their reckless and tacky behavior: NRS 197.180 Wrongful
exercise of official power. Any person who willfully takes upon himself or herself to exercise or
officiate in any office or place of another, without being lawfully authorized thereto, is guilty of a
gross misdemeanor.
Also, uner NRS 118A.510, I am complaining of the following violations of criminal law on
Northwind's behalf:
NRS 197.120 False impersonation of public officer; intrusion into and refusal to surrender
public office. Every person who shall falsely personate or represent any public officer, or who
shall willfully intrude into a public office to which the person has not been duly elected or
appointed, or who shall willfully exercise any of the functions or perform any of the duties of such
officer, without having duly qualified therefor, as required by law, or who, having been an
executive or administrative officer, shall willfully exercise any of the functions of office after his or
her right to do so has ceased, or wrongfully refuse to surrender the official seal or any books or
papers appertaining to such office, upon the demand of his or her lawful successor, shall be guilty
of a gross misdemeanor.
[1911 C&P 67; RL 6332; NCL 10016]
NRS 197.130 False report by public officer. Every public officer who shall knowingly make
any false or misleading statement in any official report or statement, under circumstances not
otherwise prohibited by law, shall be guilty of a gross misdemeanor.
NEvada Court Services regularly attempts to mislead tenant's into thinking the act with color of law. From Joel
Durden barking at me in his Sheriff look-a-like getup that he is an "officer of the court" and from "Court
Services" to having the word "Court" in their name,etc., etc. NEvad Court Services impersonates public officers.
Additionally, Machen's police report is false to the extent that it fails to indicate that, at least at some point,
Machen and or Deputy Gomez refused to idnetify themslevs. They don't know what someone is doing inside
when they purport to "knock and announce" and the must reasonably be expected to assume one could have not
heard their initial announcing their idnetify (whether because they had headphones or, were in the bathroom,
whatever...and Machen and his cowboy partner Gomez refused to identify themselves in response to a request
that they do so by Coughlin, and similarly refused to slide through the door any paperwork or warrant describing
the purpose of their visit.
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 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 "served" in compliance with all
time related rules because it was done in 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
001619
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: "
and,
001620
001621
I am hereby complaining to Northwind Apartments of a violation of the criminal law

by one of its agents R. Wray and other process servers with NCS (Oh, and RPD
Officer Weaver also threatened to use "hydraulic explosives" to gain entry to one of
my three rentals at Northwind, though no exigent circumstance existed and though he
lacked a warrant. I have previously complained of Lou Cadia, Milan Krebs, both
Northwind Maintenance Personnel, and Northwind Property Manager or Apartment
Manager Dwayne Jakob attempt to break and enter into my rentals (why is it when
Richard G. Hill, Esq. calls the RPD and alleges I am trespassing, I get subject to a
custodial arrest and Hill gets the State Bar of Nevada to try to prosecute me for
"breaking an entering", even though WCSO Machen lied in his Affidavit of Service in
RJC rev2011-0010708, and the Court had failed to return to me at the time of arrest
the $2,275 it wasn't permitted to require I deposit in a "rent escrow" account in the
first place, and where Hill and his contractor are caught on video admitting to having
remove my ladder from the former law office (in a video of December 23rd,
2011...why doesn't the RPD arrest Hill and Phil Stewart for larceny of my ladder? Do
I have to be Wal-Mart or Richard G. Hill or Northwinds Apartments (ie, rich,
connected) to get the RPD to enforce the law when I complain of a violation?
NRS 40.280 Service of notices to quit; proof required before issuance of order to remove.
1. Except as otherwise provided in NRS 40.253, the notices required by NRS 40.251 to 40.260, inclusive, may
be served:
(a) By delivering a copy to the tenant personally, in the presence of a witness;
(b) If the tenant is absent from the tenants place of residence or from the tenants usual place of business, by
leaving a copy with a person of suitable age and discretion at either place and mailing a copy to the tenant
at the tenants place of residence or place of business; or
001622
(c) If the place of residence or business cannot be ascertained, or a person of suitable age or discretion cannot
be found there, by posting a copy in a conspicuous place on the leased property, delivering a copy to a person
there residing, if the person can be found, and mailing a copy to the tenant at the place where the leased
property is situated.
2. Service upon a subtenant may be made in the same manner as provided in subsection 1.
3. Before an order to remove a tenant is issued pursuant to subsection 5 of NRS 40.253, a landlord shall file
with the court a proof of service of any notice required by that section. Before a person may be removed as
prescribed in NRS 40.290 to 40.420, inclusive, a landlord shall file with the court proof of service of any
notice required pursuant to NRS 40.255. Except as otherwise provided in subsection 4, this proof must
consist of:
(a) A statement, signed by the tenant and a witness, acknowledging that the tenant received the notice on a
specified date;
(b) A certificate of mailing issued by the United States Postal Service; or
(c) The endorsement of a sheriff, constable or other process server stating the time and manner of service.
4. If service of the notice was not delivered in person to a tenant whose rent is reserved by a period of 1 week or
less and the tenancy has not continued for more than 45 days, proof of service must include:
(a) A certificate of mailing issued by the United States Postal Service or by a private postal service to the
landlord or the landlords agent; or
(b) The endorsement of a sheriff or constable stating the:
(1) Time and date the request for service was made by the landlord or the landlords agent;
(2) Time, date and manner of the service; and
(3) Fees paid for the service."
[
NRS 118A.430 Failure of tenant to comply with rental agreement or perform basic
obligations: Termination of rental agreement.
1. Except as otherwise provided in this chapter, if the tenant fails to comply with
the rental agreement or fails to perform his or her basic obligations under this chapter,
the landlord may deliver a written notice to the tenant specifying the acts and
omissions constituting the breach and that the rental agreement will terminate as
provided in this section. If the breach is remediable and the tenant does not adequately
remedy the breach or use his or her best efforts to remedy the breach within 5 days
after receipt of the notice, or if the breach cannot be remedied, the landlord may
terminate the rental agreement.
2. If the tenant is not reasonably able to remedy the breach, the tenant may avoid
001623
termination of the rental agreement by authorizing the landlord to enter and remedy
the breach and by paying any reasonable expenses or damages resulting from the
breach or the remedy thereof.
Northwinds and NCS failed to comply with NRS 118A.430(1) (to the extent it even
applies her) in that in no way did it "deliver a written notice to the tenant specifying
the acts and omissions constituting the breach". Northwinds simply wrote "see
attached", after paragraph 6 of teh 6/14/12 Notice, which reads "6. Remained in
posssession of the premises subject to the provisions of Chapter 118A of the NRS
after having failed ot perfrom the basic or contractual obligations imposed upon you
by that Chapter, namely: (SEE ATTACHED)" and then NCS, at most, include a copy
of the "Rental Agreement" with its filing of this Notice to the RJC, which in no way
specifies what aspect of that Rental Agreement Coughlin is purportedly in breach of,
or what facts supports such an allegation.
Any Order he is void or subject oa NRCP 60b set aside based upon the fraud of NCS
and Wray in lying where he declares (under penalty of perjury) to have "personally
served" Coughlin the 5 day notie on 6/14/12, and under NRCP 60b4 void for lack of
jurisdiction where NCS failed to specify in the Lanldord's Affidavit all that required
under NRS 40.253. and for so many other reasons, such at 118A does not apply if the
rental is deemed to be not e "dwelling", and that an illegal lockout is not available
even if Coughlin is ruled to have been "using as a residence" the rental, should the
rental be a "storage facility" which City of Reno Code Enforcement does not view it
to be...and Further, by Northwinds very own descriptives, it is a garage, one they held
out to the public for more than mere "parking a car", and as such, under NRS 40.760
and 108.4733, 108.475 and NRS 40.760 are not even available to Northwind. They.
Are. Stuck. Deal With It.
NRS 108.4733 Facility defined. Facility means real property divided into individual storage spaces. The term does not include a
garage or storage area in a private residence.
001624
NRS 108.4746 Storage space defined. Storage space means a space used for storing personal property, which is rented or leased to
an individual occupant who has access to the space.
NRS 108.475 Use of storage space for residence prohibited; eviction; nature of facility; effect of issuance of document of title for
property.
1. A person shall not use a storage space at a facility for a residence. The owner of such a facility shall evict any person who uses a
storage space at the facility as a residence in the manner provided for in NRS 40.760.
NRS 108.4755 Contents of rental agreement.

1. Each rental agreement must be in writing and must contain:
(a) A provision printed in a size equal to at least 10-point type that states, IT IS UNLAWFUL TO USE A STORAGE SPACE IN THIS
FACILITY AS A RESIDENCE.
MISCELLANEOUS PROVISIONS
NRS 40.760 Summary eviction of person using facility for storage as residence.
1. When a person is using a storage space at a facility as a residence, the owner or the owners agent shall serve or have served a notice in
writing which directs the person to cease using the storage space as a residence no later than 24 hours after receiving the notice. The notice
must advise the person that:
(a) NRS 108.475 requires the owner to ask the court to have the person evicted if the person has not ceased using the storage space as a
residence within 24 hours; and
(b) The person may continue to use the storage space to store the persons personal property in accordance with the rental agreement.
2. If the person does not cease using the storage space as a residence within 24 hours after receiving the notice to do so, the owner of the
facility or the owners agent shall apply by affidavit for summary eviction to the justice of the peace of the township wherein the facility is
located. The affidavit must contain:
(a) The date the rental agreement became effective.
(b) A statement that the person is using the storage space as a residence.
(c) The date and time the person was served with written notice to cease using the storage space as a residence.
(d) A statement that the person has not ceased using the facility as a residence within 24 hours after receiving the notice.
3. Upon receipt of such an affidavit the justice of the peace shall issue an order directing the sheriff or constable of the county to remove
the person within 24 hours after receipt of the order. The sheriff or constable shall not remove the persons personal property from the
facility.
4. For the purposes of this section:
(a) Facility means real property divided into individual storage spaces. The term does not include a garage or storage area in a private
residence.
(b) Storage space means a space used for storing personal property, which is rented or leased to an individual occupant who has
access to the space.
(Added to NRS by 1989, 213; A 2011, 1830)
Nevada Process Server Licensing Requirements

It is required that all process servers are licensed and 21, or over, two-years experience as a process server and
001625

insurance against liability to third persons with limits of no less then $200,000. No bonding is required. However,
applicants must deposit $750 upon submitting their application to pay for a background investigation, the maximum an
applicant can be charged for a background check is $1500. Applicants must also pass a written application and may be
required to pass an oral exam as well. Licenses are issued by the Nevada Private Investigators Licensing Board.
Nevada is the most expensive state in the nation to get licensed. [Nevada Revised Statutes 648.110 and 648.135]

exclusion of tenant for default in payment of rent.
"
1. Except as otherwise provided in subsection 10, in addition to the remedy provided

in NRS 40.2512 and 40.290 to 40.420, inclusive, when the tenant of any dwelling,
apartment, mobile home, recreational vehicle or commercial premises with periodic
rent reserved by the month or any shorter period is in default in payment of the rent,
the landlord or the landlords agent, unless otherwise agreed in writing, may serve or
have served a notice in writing, requiring in the alternative the payment of the rent or
the surrender of the premises:
(a) At or before noon of the fifth full day following the day of service; or
(b) If the landlord chooses not to proceed in the manner set forth in paragraph (a) and
the rent is reserved by a period of 1 week or less and the tenancy has not continued for
more than 45 days, at or before noon of the fourth full day following the day of
service.
As used in this subsection, day of service means the day the landlord or the
landlords agent personally delivers the notice to the tenant. If personal service was
not so delivered, the day of service means the day the notice is delivered, after
posting and mailing pursuant to subsection 2, to the sheriff or constable for service if
the request for service is made before noon. If the request for service by the sheriff or
constable is made after noon, the day of service shall be deemed to be the day next
following the day that the request is made for service by the sheriff or constable.
2. A landlord or the landlords agent who serves a notice to a tenant pursuant to
paragraph (b) of subsection 1 shall attempt to deliver the notice in person in the
manner set forth in paragraph (a) of subsection 1 of NRS 40.280. If the notice cannot
be delivered in person, the landlord or the landlords agent:
(a) Shall post a copy of the notice in a conspicuous place on the premises and mail the
001626
notice by overnight mail; and

(b) After the notice has been posted and mailed, may deliver the notice to the sheriff
or constable for service in the manner set forth in subsection 1 of NRS 40.280. The
sheriff or constable shall not accept the notice for service unless it is accompanied by
written evidence, signed by the tenant when the tenant took possession of the
premises, that the landlord or the landlords agent informed the tenant of the
provisions of this section which set forth the lawful procedures for eviction from a
short-term tenancy. Upon acceptance, the sheriff or constable shall serve the notice
within 48 hours after the request for service was made by the landlord or the
landlords agent.
3. A notice served pursuant to subsection 1 or 2 must:
(a) Identify the court that has jurisdiction over the matter; and
(b) Advise the tenant:
(1) Of the tenants right to contest the matter by filing, within the time specified in
subsection 1 for the payment of the rent or surrender of the premises, an affidavit with
the court that has jurisdiction over the matter stating that the tenant has tendered
payment or is not in default in the payment of the rent;
(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; and
(3) That, pursuant to NRS 118A.390, a tenant may seek relief if a landlord unlawfully
removes the tenant from the premises or excludes the tenant by blocking or attempting
to block the tenants entry upon the premises or willfully interrupts or causes or
permits the interruption of an essential service required by the rental agreement or
chapter 118A of NRS.
4. If the tenant files such an affidavit at or before the time stated in the notice, the
landlord or the landlords agent, after receipt of a file-stamped copy of the affidavit
which was filed, shall not provide for the nonadmittance of the tenant to the premises
by locking or otherwise.
001627

(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 remove the tenant within 24 hours
after receipt of the order. The affidavit must state or contain:
(3) The amounts of any cleaning, security or rent deposits paid in advance, in excess
of the first months rent, by the tenant.
(7) A statement that the written notice was served on the tenant in accordance with
NRS 40.280.
(b) Except when the tenant has timely filed the affidavit described in subsection 3 and
a file-stamped 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.
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
001628
hearing, after service of notice of the hearing upon the parties, to determine the
for removal of the tenant or an order providing for the nonadmittance of the tenant. If
the court determines that there is a legal defense as to the alleged unlawful detainer,
the court shall refuse to grant either party any relief, and, except as otherwise provided
in this subsection, shall require that any further proceedings be conducted pursuant to
NRS 40.290 to 40.420, inclusive. The issuance of a summary order for removal of the
tenant does not preclude an action by the tenant for any damages or other relief to
which the tenant may be entitled. If the alleged unlawful detainer was based upon
subsection 5 of NRS 40.2514, the refusal by the court to grant relief does not preclude
the landlord thereafter from pursuing an action for unlawful detainer in accordance
with NRS 40.251.
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 10 days after the filing of the
motion. The court shall affix the date of the hearing to the motion and order a copy
served upon the landlord by the sheriff, constable or other process server. At the
hearing, the court may:
(a) Determine the costs, if any, claimed by the landlord pursuant to NRS 118A.460 or
118C.230 and any accumulating daily costs; and
001629
determined to be due or if no charges are determined to be due.
9. A landlord shall not refuse to accept rent from a tenant that is submitted after the
landlord or the landlords agent has served or had served a notice pursuant to
subsection 1 if the refusal is based on the fact that the tenant has not paid collection
fees, attorneys fees or other costs other than rent, a reasonable charge for late
payments of rent or dishonored checks, or a security. As used in this subsection,
security has the meaning ascribed to it in NRS 118A.240.
10. This section does not apply to the tenant of a mobile home lot in a mobile home
park or to the tenant of a recreational vehicle lot in an area of a mobile home park in
this State other than an area designated as a recreational vehicle lot pursuant to the
provisions of subsection 6 of NRS 40.215.
(Added to NRS by 1967, 195; A 1969, 263, 575; 1973, 1085; 1975, 1202; 1977, 418,
1346; 1979, 1398, 1879; 1985, 229; 1987, 1239; 1989, 1082, 1232; 1991, 113; 1995,
1851; 1997, 3511; 1999, 981; 2009, 1966; 2011, 235, 1489)

exclusion of tenant from certain types of property. Except as otherwise provided by
specific statute, in addition to the remedy provided in NRS 40.251 and in NRS 40.290
to 40.420, inclusive, when the tenant of a dwelling unit which is subject to the
provisions of chapter 118A of NRS, part of a low-rent housing program operated by a
public housing authority, a mobile home or a recreational vehicle is guilty of an
unlawful detainer, the landlord is entitled to the summary procedures provided in NRS
40.253 except that:
1. Written notice to surrender the premises must:
(a) Be given to the tenant in accordance with the provisions of NRS 40.280;
(b) Advise the tenant of the court that has jurisdiction over the matter; and
(c) Advise the tenant of the tenants right to contest the notice by filing within 5 days
an affidavit with the court that has jurisdiction over the matter that the tenant is not
guilty of an unlawful detainer.
001630
2. The affidavit of the landlord or the landlords agent submitted to the justice court or
the district court must contain:
(a) The date when the tenancy commenced, the term of the tenancy, and, if any, a copy
of the rental agreement.
(b) The date when the tenancy or rental agreement allegedly terminated.
(c) The date when the tenant became subject to the provisions of NRS 40.251 to
40.2516, inclusive, together with any supporting facts.
(d) The date when the written notice was given, a copy of the notice and a statement
that notice was served in accordance with NRS 40.280.
(e) A statement that the claim for relief was authorized by law.
3. If the tenant is found guilty of unlawful detainer as a result of the tenants violation
of any of the provisions of NRS 453.011 to 453.552, inclusive, except NRS 453.336,
the landlord is entitled to be awarded any reasonable attorneys fees incurred by the
landlord or the landlords agent as a result of a hearing, if any, held pursuant to
subsection 6 of NRS 40.253 wherein the tenant contested the eviction.
(Added to NRS by 1985, 227; A 1989, 1084, 1234; 1991, 115; 1995, 1853; 2001,
1065; 2003, 561)"
I WOULD LIKE TO KNOW WHY THE FILE IN RJC REV2012-001048 HAS MY 6

PAGE FAX OF JUNE 30TH, 2012 (AND PLEASE NOTE THE LIMITED OR
SPECIAL APPEARANCE NATURE OF THAT FILING IN THE NOTE AT THE
BOTTOM OF THE FIRST PAGE....YET IT IS NOT FILE STAMPED, AND I WAS
NEVER CALLED, OR FAXED, OR NOTIFIED IN ANY WAY CONCERNING
THE SCHEDULING OF MY CONSTITUTIONALLY GUARANTEED HEARING
BEFORE A SUMMARY EVICTION OR STATUS OF MY IFP REQUEST.
001631
MY POSITION IS THAT I AM ENTITLED TO A SUMMARY EVICTION

HEARING ON UNIT 29 AND THAT IT IS LONG OVERDUE. PLEASE LET ME
KNOW WHEN THAT HEARING CAN TAKE PLACE. I DO NOT BELIEVE ANY
JUDGE CURRENTLY HAS JURISDICTION ON IT, AND THAT THE NEW
CASE, WITH A NEW CASE NUMBER SHOULD BE "RANDOMLY ASSIGNED"
Further in the Reno justice court file for rjc rev2012-001048 is a tenant affidavit and declaration from
Coughlin faxed to the court on June 30, 2012 contain six pages it is unclear why Coughlin was not
granted a summary eviction hearing as required by law and Coughlin is hereby demanding one and a
jury trial which he is entitled to one pursuant the 19 Seventies the Court decision and FRCP rule 30
a.m. that Coughlin is requesting one prior to the time set for hearing that's right folks were going to a
jury trial when Nevada court services served an amended eviction notice on June 28 Coughlin there
and had five days to file for an eviction summary eviction hearing and he did so on June 30 just for
the Reno PD managed commit another wrongful arrest of Coughlin further there was County jail failed
to transfer Coughlin for the July 5 hearing on Coughlin's motion to set aside the original June 27 order
however the June 27 order in this case was extinguished by that posting of an amended lockout
notice therefore and eight it's not file stamp but it should be by the Reno justice court the six page
fax by Coughlin on June 30, 2012, though Karen Stancil appears to have handwritten in the case
number RJC rev2012-001048
PLEASE NOTE I AM USING AUDIO DICTATION TRANSCRIPTION SOFTWARE FOR THIS
CORRESPONDENCE AND IT MIGHT HAVE SOME ERRORS, WHICH COULD GREATLY ALTER THE
MEANING, AS I DON'T HAVE TIME TO CORRECT THEM RIGHT NOW.
additionaly THERE WAS SEVERAL FAXES TO THE RJC CIVIL DIVISION BY COUGHLIN ON OR ABOUT
JUNE 13TH, 2012, AND COUGHLIN REQUESTS A COPY OF THOSE OR SOME INDICATION OF WHY
THEY WERE NOT FILED AND COUGHLIN WILL CHECK HIS OWN RECORDS IN THAT REGARD WHEN
HE HAS TIME...HOWEVER, TO THE EXTENT ONE OF THOSE FILINGS WAS A TENANT'S AFFIDAVIT
DIRECTED TOWARDS UNIT 29, LOTS OF PROCEDURAL IMPLICATIONS WILL STEM.
NORTHWIND APARTMENT
ASSOC LLC
1031 XPRESS
NORTHWIND LLC
110 110TH AVE NE STE
550
BELLEVUE, WA 98004
Description
Summary
Fictitious Firm Name - Counter
74040
04/01/1997 12:00:00 AM Expiration Date: 04/01/2002
Business Name: NORTHWIND APARTMENTS Owners: NORTHWIND APARTMENT ASSOCIATES, LLC
s Firm Name - Counter - 109351
Filing Information
Filing Number
109351
Filing Date
03/16/2006 12:00:00 AM
Expiration Date
03/16/2011
Business Information
Business Name
001632
RENO RED BOOK

Owner Information
Owner/Corporate Name
JEFFREY G CHANDLER u
Fictitious Firm Name - Counter
104085
12/08/2004 12:00:00 AM Expiration Date: 12/08/2009
Business Name: BOTTS CANDY COMPANY Owners: JENNIFER V CHANDLER, CINDY R VANDERZIEL
Him and him and him and him motion a set of society eviction order of the number of bases one it
went unopposed and
hundred Polk case Coughlin wins in that regard to the notice of hearing by the Reno justice court is
dated July 31,
2012 are not as of the hearing on July 21, 2012 stated July 24, 2012 and him notices on what the
hearing is limited
to quote you may appear on the data show cause why the court should or should not grant motion to
stay the eviction
order in the motion for expedited relief following legal lot coverage utility shut off. If you the. Must be
prepared
to provide testimonial documentary evidence the court which torture position if he failed to appear
karmic
renovation would form a dismiss case. With what the notice does not say is that the hearing will
address the motion
to set aside eviction order Coughlin filed on July 24, 2012 and that which and for which now he
request the court to
rule in his favor or at least provide hearing or at the very and for or at the very least require
Northwind and/or
their qualified attorneys or whoever to file an opposition something under of explaining why their are
three
separate notices for her three separate process affidavits of service for the June 14, 2012 personal
service of a
five-day unlawful detainer affidavit by Robert Ray of Nevada court services that's right there's three
separate ones
and Coughlin's possession now and they bear different things as well isn't that interesting half add to
that the
fact that Nevada court services agreed with Coughlin's assessment that its original on June 14 notice
of unlawful
detainer failure to vacate premises was ineffective and that it listed the wrong forum is or court for
the tenant to
001633
file a tenant at search engines affidavit as required by law under 40.253 that's not something the
judge piercing
can excised from the law or legislate from the bench out of existence that is a law. The Reno justice
court does not
have jurisdiction with the notice last Sparks justice court the fugitive document for the landlord to file
it
landlord's affidavit and then to manage to get Coughlin arrested based upon a void order that should
never issued
judge Shrader particularly where supervisor of the syllable division Karen Stancil was alerted and well
in advance
by Coughlin through phone calls and mid-June in that June 26 of written correspondence to the court
that included in
the file on the left side of the correspondence and where the Sparks justice court itself fax the Reno
justice court
that a fax alerting it to the problematic aspects of the June 14 notice Coughlin was arrested he went
to jail he
paid bail he did time incurred massive damages it's appalling for judge piercing to ignore all this while
also
sanctioning the unauthorized practice of law by Jeff Chandler Nevada court services who dress up like
they are
Sheriff's and managed to the word court into their name and bang on people store and leave off the
Nevada part so
much so that it and it seems as though they are actually acting with color of law in the screening you
to come out
of your house and bang on the door parted sounds like they are cost of the Sheriff and have to do
exactly what you
said. Those few who don't Nevada court services has something up their sleeve in the form of
attempting to break and
enter and one's residence or sex service of process by as Nevada court services has done to Coughlin
on numerous
occasions sometimes captured on videotape further Nevada court services is trespassed on numerous
occasions like
office property Coughlin however is the only one who's arrested and convicted trespassing and had
reported rehashes
patent trademark office and had impact his ability to practice his chosen profession for which he has
to does have a
law license and actually did that a lot four. Further there's initial conflict in the judge piercing work to
the
001634
district attorneys office first 12 years of his career and the Washoe County Sheriff and potentially
Washoe County
District Attorney's Office may have it engages the misconduct in connection with the approximately 10
different
incarcerations Coughlin space this year most all connected one where another To the Way, Reno
justice court handles
landlord-tenant matters or fails to apply the law as written and created by the assembly the Senate
i.e. the
legislature Nevada and Carson City to be clear Nevada court services recognize the validity of
Coughlin's argument
that when he announced to them on June 28 at approximately 10 AM to 10:45 AM is where Coughlin
pointed out that the
the June 14 notice listed Sparks justice court that Nevada court services responded by serving in the
amended
declaration of service by license process server on June 28 thereby vitiate in any order lockout order
rescinding
and waving it etc. etc. June 28, 2012 fax from the Sparks justice court to the Reno justice court
contains a fax
Coughlin sent the Sparks justice court on June 26 that at 12 PM noon of that date that faction
Coughlin was 10 pages
the facts from the Sparks justice court the Reno justice court was apparently 13 pages no number of
those pages are
not included in the file of this matter and the Reno justice court back to the three different notices of
unlawful
detainer either stamped by w which doesn't count by the way one needs to sign something attorneys
don't get a stamp
things and file them and then later on claim they didn't commit commit misconduct or her perjury or
rule 11
violation merely because it is sign something Nevada court services continues to just put stamps
instead of actual
signatures and that's an appropriate and under the Aiken case is in Nevada and summary of
proceedings the technical
aspects of notice and due process requirements must be strictly adhered to not run out with the
bathwater by judge
Pearson because he either doesn't like off-line or thinks Coughlin doesn't deserve due process of the
law article
protection because Coughlin's an attorney you know Coughlin's not a license attorney currently needs
not able to
001635
make attorney money or do attorney things or even commit the unauthorized practice of law with
impunity like Nevada
court services because know Coughlin you know of Coughlin was to do so the State Bar would find it
to be a contempt.
Further judge Pearson's order for summary eviction of July 31 is void in several respects one it
purports rule one
units 2971 when unit 71 is not properly before the court unit 71 has its own case numbers of
rev2012-0067 and
rev2012-001082 (the multiplicty is due to, as here, THE RJC shortcutting due process aspects of the
process,
whererin "Orders" by Judges paid quite a bit of money are nothing more than handwritten notes on
Coughlin's own
filings...Some of those such "note ORders" by Judge Schroeder resulte in confusing vis a vis whether
Coguhlin's
IFP's were granted, and necessitated the filing of companion cases for units 45 and 71 in rev20120067 and rev2010068 in rev2012-001082 and rev2012-00183. To simply make Coughlin scapegoated all medicine
blame him for taking of
regardless the July 31 order by judge Pearson in rev 2012 00 1048 purports rule on matters not
noticed in the July
24 notice specifically in that order which reads the court finds eviction was appropriate motion to stay
eviction
order denied motion to set aside eviction order denies motion to contest personal property lien denied
motion on
illegal lockout denied tenant have always property removed is 2971 by 5 PM on August 5, 2012 only
about half of that
order was properly before the court notice litigants that I'm what was notice to the litigants in the July
24 notice
was that the hearing would be limited to the motion to stay eviction order in a motion for expedited
relief
following illegal lockout utility shutoff however the order went on to rule on matters non-there and
noticed
including the motion to set aside the eviction order the motion to contest personal property lien and
that matters
related to the property of a unit not even involved in a case number unit 71 further there required
Coughlin a hub
Allis property removed even earlier than the law requires given that after the 30 day plan under NRS
118 A.460 the
001636
landlord may not dispose of the property until 14 days of pass from mailing to the tenant last known
address a
certified letter. So there and again judge Pearson is violating the law in failing to apply evenly to
Coughlin in
fact he's attempting to exCise protections accorded and Coughlin under Nevada's landlord tenant law
which is the
most pro-landlord law set of laws in the country but that's not good enough for judge piercing he
wants to cut even
more protections out of it when it comes to Coughlin and the reasoning behind that is not clear
though Coughlin has
had some issues with Washoe County District Attorney's Office this year in judge Pearson did spend
the first 12
years of his career there.
Attached in exhibit a are the three different June 14 declarations of service by license process server
Robert (or Ryan?) Wray ..That's right, Coughlin has in his possession three different NOtice of UD
dated 6/14/12 and either "stamped" with "R. Way" or actually containing a handwritten signature by
R. Wray (though the one actually signed lacks a time indication, and they all lack a "manner of
service" or any other particular beyond falsely attesting to have been "personally served". WRay and
NORthwinds manager attempted to break and enter into unit 29 in hopes of effecting "personal
service" upon Coughlin in a unit that had not windows and that had the door closed and locked and
or barred. That is a criminal act and Coughlin is now again hereby complaining about it to the
landlrod, so have fun reading NRS 118A.510's and NRS 118A.390 and I'll see you in Court, and WRay,
you should probably self report to the process server licensing body and hope for the best. Check out
the video fo the 6/28/12 arrest wherein the WCSO's Gomez and Machen tell Chandler to "let us do the
talking, Jeff", then Chandler, dressed up in an outfit and with a company name intended to connote
color of law type authority, purports to trespass Coughlin from the whole place, ie, the entire premises
at 1680 Sky Mountain Dr., depsit Coughlin still having, at the time, one, and perhaps two valid leases,
to units 45 and 71. Further, the Washoe County Detention Center or jail took a tenan'ts affidavit from
Coughlin on or aoround July 15th, 2012 for units 45 and another for unit 71 and due to Coughlin's
indigency, the jail library indicate it would be filed with the rjc....WAs it? LITIGATION HOLD NOTIE
TO THE JAIL AND THE RJC.
To: chansen@washoecounty.us
Subject: Reno eviction noticed for Sparks Justice Court
Date: Tue, 26 Jun 2012 09:10:14 -0700
Dear Civil Supervisor Hansen

Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
001637
Fax 949 667 7402

Dear Sparks Justice Court,
I called and received permission to file this by fax...I am indigent and request a fee waiver, and failing
that, an opportunity to cure any filing fee deficiency.
To: sheriffweb@washoecounty.us; lstuchell@washoecounty.us; kstancil@washoecounty.us;
chansen@washoecounty.us; milllerr@reno.gov
Subject: Reno eviction noticed for Sparks Justice Court
Date: Tue, 26 Jun 2012 07:58:36 -0700
Dear Sparks Justice Court, WCSO, RPD, and Reno Justice Court.
I have received (though not personally served) what appears to be an eviction notice (5 day unlawful
detainer?) for rentals located at 1680 Sky Mountain Drive, Reno, 89523, but the notice indicates that I
must file a Tenant's Answer with the Sparks Justice Court.
Am I mistaken in viewing this matter to be outside the jurisdiction of the Sparks Justice Court, and
rather, a matter to be handled in Reno Justice Court?
Given Sparks Justice Court is open 5 days a week (closes at noon on Fridays) and Reno Justice Court
has 4 judicial days a week, the deadline for filing a special appearance (to contest jurisdiction) and or a
Tenant's Answer of Affidavit is difficult to measure.
I spoke with a Reno Police Department who identified himself as Sargent Miller last week and he
indicated the WCSO planned to come effectuate an eviction on this date, June 26, 2012. I believe that
would be premature, as Nevada Landlord Tenant law provides for filing a Tenant's Answer or Affidavit
by noon after the fifth full day (judicial days) and Fridays in Sparks Justice Court are not full days in that
sense, and regardless, Sparks Justice Court, I believe, is not the appropriate forum where, as here, the
situs is located in Reno (Ward 1-nap?)
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
tel 775 338 8118
fax 949 667 7403
001638
Civil Division
630 Greenbrae Drive
Sparks, Nevada 89431
(775)353.7603 Phone
(775)352.3004 Fax
Civil Department Supervisor
Chris Hansen
chansen@washoecounty.us
The Civil Division of Sparks Justice Court is made up of three major functions:
Civil
Civil Complaints for damages in excess of $5000 or if a suit involves a breach of contract, punitive
damages, an action to obtain possession of property, a writ of restitution, or other like actions, legal
counsel is suggested for these types of actions.
Evictions
An act or process of legally dispossessing a person of land or rental property.
Small Claims
An action filed in order to obtain a monetary judgment. Claims must not exceed $5000. A small claims
action may be filed with the Sparks Justice Court if one of the following applies to the defendant:
1. They reside within the boundaries of the Sparks Township;
2. They are employed within the boundaries of the Sparks Township; and/or,
3. They do business within the boundaries of the Sparks Township.
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
LITIGATION HOLD NOTICE FW: Reno eviction noticed for Sparks Justice Court
9/21/12
Zach Coughlin
To stuttle@washoecounty.us, millero@reno.gov, jmachen@washoecounty.us, brownk@reno.gov, renodire Reply
From: Zach Coughlin(zachcoughlin@hotmail.com)

Sent: Fri 9/21/12 2:36 PM
To:
stuttle@washoecounty.us; millero@reno.gov; jmachen@washoecounty.us; brownk@reno.gov; renodirect@reno.gov;
lstuchell@washoecounty.us; kadlicj@reno.gov; christensend@reno.gov; mkandaras@da.washoecounty.us; apminfo@acg.com;
apminfo@yahoo.com; superior.storage@yahoo.com; 037nor4@acg.com; info@acg-apmi.com; chansen@washoecounty.us;
kstancil@washoecounty.us
001639
2 attachments (total 1164.6 KB)
coughlin ...pdf
Download (78.3 KB)
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combined ...pdf
Download (1086.2 KB)
Download all as zip
Dear Sirs and Madams,

Please accept this as a LITIGATION HOLD NOTICE REQUIRING THE PRODUCTION AND MAINTENANCE OF ALL MATERIALS,
RECORDINGS, DOCUMENTATION, OR OTHER MATERIALS IN ANY WAY RELATED TO ZACHARY BARKER COUGHLIN AND HIS
TRIALS AND TRIBULATIONS WITH LOCAL LAW ENFORCEMENT, EMERGENCY SERVICES, ET AL WITHIN THE PAST COUPLE
YEARS WITHIN BOTH CIVIL AND CRIMINAL CASES, MATTERS, AND INCIDENTS AND WITHIN ANY OTHER SETTINGS.
Sincerely,
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
To: kbrown@nvbar.org; milllerr@reno.gov; millerr@reno.gov; stuttle@washoecounty.gov; rsilva@washoecounty.us;
stuttle@washoecounty.us; jamchen@washoecounty.us; 037nor4@acg.com; info@acg-apmi.com; rjcweb@wasoecounty.us;
jboles@callatg.com; apminfo@acg.com
Subject: FW: Reno eviction noticed for Sparks Justice Court
Date: Mon, 2 Jul 2012 17:21:54 -0700
NOrthwind and Nevada Court Services served and "amended 5 day notice of unlawful detainer on
July 29th, 2012"...giving me five days to get my stuff out of unit 29 (the one the subject of Judge
Schroeer's Eviction Order, which was effectively rescinded by their serving a new 5 day unlawful
detainer notice....) as well as units 71 and 45...whicih are two units to which i still have valide lease
agreements, ie, I cannot be trespassing for accessing them (the Reno PD has indicated they will
arrest me for criminal trespass for accessing any units in the complex, including those to which I
still have a valid possessory or property interest, in violation of 42 usc 1983).
why does Sargent Miller have to give me a hard time? Isn't it enough for him to have his "Denzel"
001640
good looks and a much higher paying job than I will ever have? What up wit that?
Northwind and Nevada Court Services (which is practicing eviction law without a license) screwed
up and put "Sparks Justice Court on Greenbrae" as the place for the tenant to file a Tenan'ts Answer
or Affidavit. Doing so will make the RJC Order by Judge Schroeder null and void (Karen Stancil,
Chief Civil Clerk at RJC admits this, but really, the fault lies with NCS and Northwind, not the
committed professional at the RJC).
The Notice must identify the Court with jurisdiction. NRS 40.253(3)(a). ONe cannot be trespassing in a placwe
where they have a valid reason for being or a lawful right to be. NRS 207.200, RMC 8.10.040.
In
Aikins v. Andrews, 91 Nev. 746, 542 P.2d 734 (1975), the Supreme COUli construed the
predecessor statute to NRS 40.2516 to mean that the alternative five (5) day notice must be given
6
before the tenants can be dispossed and a lease can be validly terminated. The court stated that this
five (5) day notice requirement " ... neither can be waved nor neglected." 91 Nev. at 748.
ttp://www.constitution.org/ussc/506-056a.htm
U.S. Supreme Court
SOLDAL v. COOK COUNTY, 506 U.S. 56 (1992)
506 U.S. 56 SOLDAL, ET UX. v. COOK COUNTY, ILLINOIS ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
SEVENTH CIRCUIT
No. 91-6516
Argued October 5, 1992
Decided December 8, 1992
001641
001642
Minutes ID: 314
*M1*
C34
The Committee on Judiciary was called to order by Chairman Bernie Anderson

at 8:07 a.m. on Monday, March 2, 2009, in Room 3138 of the Legislative
Building, 401 South Carson Street, Carson City, Nevada. The meeting was
videoconferenced to Room 4401 of the Grant Sawyer State Office Building,
555 East Washington Avenue, Las Vegas, Nevada. Copies of the minutes,
including the Agenda (Exhibit A), the Attendance Roster (Exhibit B), and other
substantive exhibits, are available and on file in the Research Library of the
Legislative Counsel Bureau and on the Nevada Legislature's website at
www.leg.state.nv.us/75th2009/committees/. In addition, copies of the audio
record may be purchased through the Legislative Counsel Bureau's Publications
Office (email: publications@lcb.state.nv.us; telephone: 775-684-6835).
COMMITTEE MEMBERS PRESENT:
Assemblyman Bernie Anderson, Chairman
Assemblyman Tick Segerblom, Vice Chair
Assemblyman John C. Carpenter
Assemblyman Ty Cobb
Assemblywoman Marilyn Dondero Loop
Assemblyman Don Gustavson
Assemblyman John Hambrick
Assemblyman William C. Horne
Assemblyman Ruben J. Kihuen
Assemblyman Mark A. Manendo
Assemblyman Richard McArthur
Assemblyman Harry Mortenson
Assemblyman James Ohrenschall
Assemblywoman Bonnie Parnell
COMMITTEE MEMBERS ABSENT:
None
MINUTES OF THE MEETING

OF THE
ASSEMBLY COMMITTEE ON JUDICIARY
Seventy-Fifth Session
March 2, 2009
Chairman Anderson:
[Roll called. Opening remarks on protocol on testifying before the Committee.]
We will open the hearing on Assembly Bill 164.
Assembly Committee on Judiciary

March 2, 2009
Page 2
GUEST LEGISLATORS PRESENT:
Heidi Gansert, Washoe County Assembly District No. 25
STAFF MEMBERS PRESENT:
Jennifer M. Chisel, Committee Policy Analyst
Katherine Malzahn-Bass, Committee Manager
Sean McDonald, Committee Secretary
Nichole Bailey, Committee Assistant
OTHERS PRESENT:
Tom Roberts, Lieutenant, Las Vegas Metropolitan Police Department,
Las Vegas, Nevada
Vincent Cannito, Captain, Las Vegas Metropolitan Police Department,
Las Vegas, Nevada
Kristin Erickson, representing the Nevada District Attorneys Association,
Reno, Nevada
David W. Clifton, Chief Deputy District Attorney, Washoe County District
Attorney, Reno, Nevada
Ellen Clark, Chief Medical Examiner and Coroner, Washoe County, Reno,
Nevada
Nancy Hart, representing Nevada Network Against Domestic Violence,
Reno, Nevada
Jason Frierson, Clark County Public Defender's Office, Las Vegas,
Nevada
Cotter C. Conway, Alternate Public Defenders Office, Washoe County,
Reno, Nevada
Orrin Johnson, Deputy Public Defender, Washoe County Public
Defender's Office, Reno, Nevada
Lee Rowland, Northern Coordinator, American Civil Liberties Union of
Nevada, Reno, Nevada
Brett Kandt, Executive Director, Advisory Council for Prosecuting
Attorneys
001643
It is entirely consistent with what this Legislature has previously done with
substantial bodily harm, and what has been done before that with deadly
weapons. If you commit a battery that involves a deadly weapon, it becomes
enhanced to a felony. If you commit a battery that includes substantial bodily
harm, it enhances to a felony. And now with this bill, it takes strangulation and
does the same thing: if you commit a battery and it includes intentional
strangulation, it enhances it from a simple misdemeanor battery to a felony.
To my right is Lieutenant Roberts from the Las Vegas Metropolitan Police

Department (Metro) who presented me with the suggestion on this piece of
legislation. Also, for the Committee's edification, there are some issues with
the bill, particularly with some definitions and its intent: what we are trying to
achieve with the bill. The defense bar, particularly Mr. Frierson, approached me
with some concerns, as did, later, the American Civil Liberties Union (ACLU).
They did not provide me with written amendments, but the amendments that
were suggested in our conversations seem to be something we can work with.
I did not have much concern about them at all.
Assemblyman Horne:
Mr. Chairman, as you know, in my other life I am a criminal defense attorney,
primarily, and am in a position of representing those who are charged with
battery and domestic violence. However, that has never stopped me in past
legislative sessions from bringing bills addressing the problem of domestic
violence. I do so today. There is an expert down south whom I believe
Assemblywoman Heidi Gansert, Washoe County Assembly District No. 25:

Assemblyman Horne and I did have the same bill, and I was able be a primary
cosponsor, which I appreciate, on his bill. I think this is a very important issue.
I can tell you that everybody has been touched somehow by domestic violence.
I have a member of my family who had a relationship with a man who was very
violent, and what he always did was strangulation. A lot of times you cannot
see it. It does not leave marks. Suffocation and strangulation are very
threatening, and that is why this bill is so important. It happens so frequently,
and a lot times the individuals get away with it. This bill was brought to me by
someone from the Attorney General's Office. I did talk to different
organizations who work with people who have experienced domestic violence,
and I realized how critical it was. I am in full support of this bill, and I trust
Assemblyman Horne with the amendments that will be coming. Again,
domestic violence by strangulation is very prevalent, and we need to make sure
that we capture this in our law.
You have unlawful and willful conduct. It would not include horseplay or
accidents, and it certainly would not include consensual conduct. That is
ridiculous; no battery is consensual. We already have the elements of battery,
and now we are adding intentional strangulation to make it a felony.
The opponents, if there are any, to this bill are suggesting that it is too broad: it
should not include, as they think it does, horseplay, wrestling, consensual
conduct, or when you shush somebody by putting your hand over his mouth
and nose. What is being missed, with all due respect, is the fact that it still has
to be a battery to start with. Battery is defined by the Nevada Revised Statutes
(NRS) in NRS 200.481 as "willful and unlawful. Further, it has to be "forceful
or violent. We propose that strangulation involves a violent act. So, it already
has to be a battery. It already has to be violent or forceful. If you leave the
definition of battery out, then these proposals for these amendments might
make some sense. But we do not. We look at intentional strangulation along
with the definition of battery.
Why is it so important to make clear that the bill makes battery, which includes
strangulation a felony, the same as deadly weapon and substantial bodily harm?
We are seeing a lot of amendments being proposed to this bill to include other
things, such as more intent, more substantial bodily harm, or more physical
injury. With all due respect, the point is being missed: the act of strangulation
itself is what is dangerous, not just the physical injury.

Attorney, Reno, Nevada:
I would like to clear up something about A.B. 164 that I have seen troubling a
few people. This bill was never intended to make strangulation a crime. I think
that is a very important distinction. A lot of people think that this bill makes
strangulation a crime in and of itself; it does not. It takes battery and makes a
battery that includes intentional strangulation a more severe offense than simple
misdemeanor battery. You first have to have battery, and then it has to include
intentional strangulation before you will get to the felony status.
Assembly Bill 164: Revises certain provisions concerning the crime of battery.
(BDR 15-251)
Assemblyman William C. Horne, Clark County Assembly District No. 34:

Assembly Bill 164 deals with strangulation. It was brought to my attention that
Nevada law needed to specifically address domestic violence perpetrators using
strangulation. As you are aware, Mr. Chairman, Ms. Gansert and I submitted
identical bills, and she was gracious enough to cosign with me on this bill, and I
appreciate that.

March 2, 2009
Page 9

March 2, 2009
Page 3
001644
As you will see when you hear from Dr. Clark, the reason we need this bill is
because of the dangers inherent in strangulation. This is another important
distinction: it is not the injury that strangulation causes, because that can be
secondaryyou can have strangulation that can cause death and leave no signs
of physical injury. What we are looking for is not substantial bodily harm. Not
What we look for, Assemblyman Carpenter, as a prosecutor is some way to

corroborate what the victim is telling us. If I were to prove strangulation and
battery as a felony or a misdemeanor, I would look at if there is anything
corroborating what the victim is telling us. Certainly, the victim's statement is
enough as a matter of law in court; however, as a practical matter as a
prosecutor, I would always look for more to make sure somebody is not framing
somebody. We would then look for any red marks on the victim's neck that
may be some physical sign of injury. But even if we do not have red marks on
the neck, there are many other things you can look for to corroborate the
victim. Some examples: difficulty breathing or swallowing, raspy voice or
coughing, dizziness or headachesthese are signs that the officer and
prosecutor can see and use as evidence, even though there is no physical sign
of injury. You can have urination or defecation. That is very consistent with
someone who has been strangled. Vomiting and neck pain are all consistent.
So, even if there are no physical signs, there are a lot of ways we can
corroborate what the victim is telling us.
Assemblyman Carpenter had a very good question earlier about how a

prosecutor would prove strangulation when we do not have physical signs in
almost half of the strangulations. From the statistics I have read, approximately
42 percent of the cases of strangulation would not leave signs. Sometimes
even on homicide cases we do not know if strangulation was involved. I had
one case myself that I worked on with Dr. Clark, and we did not know if
strangulation was involved until the autopsy was conducted and we saw the
internal signs in the neck.
The captain said 10, Mr. Chairman. I have many others. He did not include
Idaho or Minnesota.
David Clifton:
I think we heard in the original testimony that there are six states that have this
law?
Chairman Anderson:
The definition of strangulation in this bill is based substantially on the definition

used in Minnesota, one of many states that include strangulation in their laws.
We urge you to adopt this bill entirely. We do not think that there is anything
unnecessary or overbroad in this bill whatsoever. It is certainly needed to assist
the prosecutors of the State of Nevada. For victims and prosecutors, we urge
you to adopt this law.
In Idaho statute, which is Penal Code 18-923, it says, in subsection 2, that no

injuries are required to prove it. Second, the prosecution is not required to
show that the defendant intended to kill or injure the victim. The only intent
required is the intent to choke or the intent to strangle. Again, a problem with
the prosecution in Nevada, right now, is we cannot prove strangulation as a
felony because it does not meet substantial bodily harm. If we have to prove,
as some opponents of the bill are saying, that the suspect intended harm to the
victim we might as well charge attempted murder. If you have to prove that the
person in his mind attempted to harm, when we know that it does not always
harm or it does not always leave physical signs of harm, it is tantamount to
having to prove attempted murder. Those are the two problems we have in
Nevada right now.
As a prosecutor, in order to prove substantial bodily harm, you have to prove

that it is an injury that creates a substantial risk of death. The problem is we
may not have that injury. The act of strangulation is what is causing the
serious risk of death. We are going to hear about that from Dr. Clark. It is not
a secondary injury that is causing the substantial bodily harm or the substantial
risk of death. That is the critical distinction and another thing that I think is
being lost.
being able to prove substantial bodily harm is one of the reasons we cannot
make strangulation a felony right now. If you look at the definition of
substantial bodily harm in NRS 0.060, it says it has to be "bodily injury which
creates a serious risk of death. That is the problem the prosecutors are having,
and why we are trying to follow many other statesI count a lot more than the
10 that the captain was mentioning. Idaho and Minnesota are the two that I
think this bill is following, and I am very supportive of their approach.
There has also been a suggestion that if somebody gets into a fight with a
sports official and gets him in a headlock, that would be felony strangling under
this bill. That is not true at all, for many reasons. We will get to what
strangling is and the dangers of strangulation when we have Dr. Clark speak.
The distinction between strangulation and battery which includes strangulation,
I think, is being lost.
Next, the definition of strangulation in this bill also includes the word
"intentional"intentionally impeding somebody's oxygen or somebody's
circulation and blood flow. The act must be intentional. It would not include
accidental conduct.

March 2, 2009
Page 11

March 2, 2009
Page 10
001645
David Clifton:
In brief, this is a trauma that we often see accompanying domestic violence and
battery cases that may be very difficult to document based upon physical injury,
but that we well recognize causes death.
In forensic pathology, we have long identified strangulation as a potentially

lethal form of trauma. One of the things that has changed within the clinical
setting, because we find cases that have minimal evidence of trauma externally
but profound injury internally, is that clinical physicians, emergency room
Ellen Clark:
Has the advent of any new tools changed this particular crime or the potential
for it? Obviously, several states have moved in this direction. Is there a
willingness to recognize this particular aspect of domestic violence?
Chairman Anderson:
Assemblywoman Dondero Loop:
There are many forms of strangulation, and you, Ms. Dondero Loop, make
reference primarily to manual throttling or placement of the hands around the
neck. In fact, a good number of the cases that we see are strangulation by
ligature. Ligature can range from a very small cord, a shoelace, an electric cord
or rope, all the way up to what we refer to often as a soft, or broad, ligature,
such as a sheet. It is relatively easy to put a sheet, for example, around
Ellen Clark:
There are a lot of holds you can do around the neck that would not leave any
marks and could even kill. I will let Dr. Clark describe the severity of some of
these physical acts.
I am just curious. It seems to me if somebody was holding somebody that

firmly by their neck, it would leave a mark. Why does it not leave a mark?
Another need for this bill is when we do not have death but we still have
strangulation. The person may not have intended to kill, but the act was just as
potentially lethal by strangling and cutting off the oxygen or blood flow to the
brain. We rarely could charge that as attempted murder, so there was a hole
there.
Yes. I have prosecuted strangulation cases and homicides where we often do

not see any physical signs until the internal injuries are detected at autopsy.
Sometimes, a case is not even investigated as a homicide or strangulation. I
had one case where we thought it was an overdose on drugs and, days later at
the autopsy, the pathologist determined it was homicide by strangulation.
David Clifton:
Mr. Clifton, I want to make sure, have you been able to charge strangulation,
but only in the most grievous cases where you have had an opportunity for a
pathological examination because of the invisible nature of this particular crime?
I am here today to speak in support of A.B. 164, which seeks to increase the
penalty for battery committed by strangulation from a misdemeanor to a felony.
As a medical doctor specializing in forensic pathology, I have for many years
recognized strangulation as a particularly violent, and potentially lethal, form of
injury. Strangulation produces occlusion of the blood vessels and potentially
occlusion of the airway that causes severe asphyxia, or breathlessness, that is
lack of oxygen to the brain. As an injury, we recognize in forensic pathology
that this is particularly a silent form of trauma that produces lethal and serious
life-threatening injury. The injury is produced by inflicting pressure of force
upon the neck that potentially obstructs or restricts the flow of blood via the
jugular vein or the carotid arteries to the brain. Even over a course of
approximately 5 to 10 seconds, this type of injury produces loss of
consciousness, abnormal vision, seizure, collapse, and loss of sphincter control,
resulting in urination and defecation. The injuries reported by survivors include
similar symptoms and may produce no external physical signs. In fact, for the
forensic pathologist, one of the challenges of these cases is they very often do
not have external trauma or physical injury signs, and it takes a rather
extensive, detailed, and persistent examination to identify, even internally, the
physical injury that has caused death.
Ellen Clark, Chief Medical Examiner and Coroner, Washoe County, Reno,
Nevada:
My information is from 2006, so maybe his information was a little bit older
than that.
David Clifton:
Chairman Anderson:
physicians, and trauma specialists are now conducting entirely different

workups when they encounter survivors of strangulation. It can be exceedingly
difficult to identify internal injury, and it makes the investigation and evaluation
of the circumstances of trauma even more important. We also are utilizing to
some extent newer technologies, such as DNA analysis based upon swabbings
of the neck or body areas potentially touched by an assailant, and this process
has achieved some amazingly good and productive results in identifying
perpetrators in such cases.
Chairman Anderson:
I was under the impression he did.

March 2, 2009
Page 13

March 2, 2009
Page 12
001646
Assembly Bill 33 is intended to fix a legal problem in Nevada's domestic

violence laws dealing with repeat or serial offenders. It mirrors what the
Legislature did with the DUI laws in 2005. It is often referred to as "once a
felon, always a felon. Our current repeat offender law can be a prosecutor's
and a victim's nightmare. Presently, if a third-time felony offender gets out of
prison and reoffends a fourth or fifth time, the new offenses can only be
charged as misdemeanors if his priors are more than seven years old. So, after

Attorney, Reno, Nevada:
With all due respect, in this instance I would defer to the frontline prosecutor,
and perhaps you could address that question to Mr. Clifton. After 25 years of
prosecuting these cases, I think he has learned how to discern, in reviewing the
totality of the circumstances, the facts, and the evidence available, what is
appropriate to charge. I would defer to him.
Brett Kandt:
What would happen if you have a girl and a boy, and one of them is interested
in the other, and the other one is not interested, is that domestic or is that
considered outside the scope?
Correct.
Brett Kandt:
Okay. Under this new law, his next one, regardless of when, would also be a
felony?
Chairman Anderson:
Just to clarify, if we are speaking under the current operation of the statute, the
third offense within a seven year window would be a felony.
Brett Kandt:
So now we would be at a felony because it is his third, right?
Chairman Anderson:
If I am following you correctly, I believe that would be correct.
Brett Kandt:
This bill changes subsections 2 and 4 of NRS 200.485. There is a slight change
in subsection 1, but it is very minute. The two have to work together. You
cannot have one without the other, as you will see. Subsection 2 says what
the Legislature used to provide in 1997 when they devised a domestic battery
bill: a third or subsequent offense is a felony. I think this was the actual intent
of the Legislature to begin with in 1997. However, they had language that said
within seven years as still applying to any subsequent offense. We have
separated that out. A third offense has to be within seven years of the first
two, but with respect to any subsequent offense after the third, we do not care
about the time anymore. The seven years is now moot. It is the fact that you
are a repeat offender: you just keep doing it. After you have already done your
one-year mandatory prison sentence, you got out and did it again. I do not care
whether it is a day later, one year later, or seven years later, it should stay as a
felony. Subsection 2 breaks it down by the felonies that are within seven
years, which means subsection 1 applies there and has to be a first and second
offense within seven years. Then subsection 2(a) says that if you already have
that felony in Nevada, your next domestic battery charge will stay a felony
regardless of the time limit. Subsection 2(b) says we are not going to let
somebody skate just because they have three, four, or five Colorado or
California prior convictions Then they come to Nevada and expect to get a
misdemeanor for their fourth offense because Colorado's offense was in 1999.
The same applies to our out-of-state batterers who come to our state and
commit another offense. That offense is going to be treated as a felony also.
our current law takes a third offense and makes it a felony, then it goes back to
misdemeanors for fourth, fifth, and sixth offenses if that time limit of seven
years has gone by. What this bill does, like the DUI law did, is say, wait, we
gave you your chances as a first and second offender. Now, we told you a
third offense is going to be a felony. We are not going to give you a fourth
chance and a fifth chance and make those misdemeanors; we are going to make
the fourth and fifth convictions felonies. Once a felon, always a felon. That is
exactly how it works right now with Nevada's law in all other crimes. If
somebody gets an armed robbery, does their prison time, and comes out and
gets another armed robbery, we do not say, oh, we will treat you less severely.
The judge and the prosecutor hit them more harshly and severely. He gets more
of a sentence on the subsequent armed robbery or any other crime. You can
list any crime you want. The judge is going to give them a harsher sentence if
he sees he is a repeat offender. Here, this loophole in NRS 200.485 actually
lets a repeat offender, or a habitual offender, get less of a sentence, get a lower
crime, a misdemeanor, for fourth, fifth, and sixth offenses, just because seven
years have gone by.
Chairman Anderson:
Because there is a relationship. Now, if we are talking about the same person
and there is a fight between a him and his wife, and it happens within the seven
years of the previous events, that would be his third, right?

March 2, 2009
Page 26

March 2, 2009
Page 25
001647
I am certainly willing, as a prosecutor, to look at every case's circumstances

and facts. If they were nondomestic all three times, whether it be the same
victim or not, they would still be prosecuted as nondomestic misdemeanor
battery, and that judge could give that person up to six months in jail on a third
offense. But yes, the Legislature has made only domestic battery enhanced to a
felony for a third offense. If the prosecutor cannot prove domestic relationship
David Clifton:
Although we know it is not always male, I am concerned that someone would

not fit under this statute just because it was a first date or just because sexual
relations were not intended by one of the parties, and they can batter over and
over again. Could that happen?
It was covered in previous legislation. When we drafted the domestic violence

bill back in 1997, we defined "dating relationship" because all prosecutors and
defense attorneys knew that was going to be a legal gray area. From memory,
a dating relationship includes expectation of sexual relations. I cannot tell you
exactly what that is, but I can tell you that if two people are on their first date,
they are going to a bar or a restaurant, and she had no expectation of sexual
relations, we probably would not charge that as domestic. The issue sometimes
comes up, what if one of them expected sexual relationssay the guyand the
other did not? Prosecutors generally will not prosecute that. We are looking at
when both of them are in a relationship long enough to be domestic. If they
both had expectations of sexual relations, or if the victim gets up and testifies
that they have had sexual relations before, then it would be a domestic.
David Clifton:
Would you address Ms. Dondero Loop's question?
Chairman Anderson:
on any of those priors, yes, it would have to either go back down to a

misdemeanor domestic battery or a misdemeanor simple battery. It could
happen.
Then, if you get to subsection 4, it is perfectly worded and not redundant and
not unnecessary, if you read it carefully. It says a third offense is a felony,
where you have the two priors within seven years. That is referring to priors
under subsection 1(c). The second sentence is our amendment. It says any
offense which is listed in paragraph (a) or (b) of subsection 2 that occurred on
any date preceding the date of the principal offense. That has to be in there.
If you get rid of that sentence, as has been proposed by Nevada Attorneys for
Criminal Justice (NACJ), you gut the entire intent of this bill. You have to work
with both sentences together; they mean two different things. One is for the
seven-year priors, the other one is for the fourth- and fifth-time offender, we do
not care how old your priors are. That is a critical distinction. We would ask
that you adopt the bill as proposed.
Mr. Clinger's office indicates that the effect on future bienniums is $315,119.
It is not part of the budget. Cost is not the concern of this Committee.
Chairman Anderson:
I did not know if it was 10 or 110, and I appreciate a little data.
Assemblyman Manendo:
I asked the district attorneys' offices and the city attorneys' offices to give me
some estimates of how many cases would be affected if this bill were passed.
The best estimates were that in Washoe County there may be as many as
10 cases a year. Clark County had a little more difficult time quantifying it.
Suffice it to say, it would be more than 10 because of the population. In the
rural communities, those prosecutors indicated they may see an occasional
repeat offender who does not get it. That was the basis for my saying that we
are not talking about a large number in terms of fiscal impact, but we are talking
about some dangerous people.
Brett Kandt:
You said that this would not have a huge fiscal impact. Are you saying that
there are not many people in Nevada currently with two on the record where
this would not apply to them on a third?
So our record is clear, Mr. Clifton is referring to paragraph (b) of subsection 2 of

section 1 of the bill, which is on page 2 at lines 30 and 31 of the bill.
Chairman Anderson:
Subsection 2(b) does apply to out-of-state convictions, and three or more

out-of-state convictions, at any time, would then escalate the person up to a
category B felony. It would be a category C felony anyway, if it was a third
offense within seven years. This bill escalates it from a C to a B.
David Clifton:
For clarification, would domestic violence priors count toward people out of
state, as well?

March 2, 2009
Page 28

March 2, 2009
Page 27
001648
David Clifton:
Yes, we do that in our guilty plea memos. The problem is, as I think I have
alluded to, imagine somebody that got a Nevada first or second conviction and
then goes to New York, and, there, a second offender gets a felony. He tells
the New York judge that the judge in Nevada did not tell me about New York's
law. There is no way we could ever inform them what the laws are in every
state and what the judge is going to do. In Nevada, we do it just out of the
goodness of our hearts to try to prevent further repeat offenders or further
domestic or DUI cases. There is no legal requirement. We will continue to do
it, though, in my opinion, for that very reason: to prevent people from
reoffending. It is a deterrence factor.
Assemblyman Segerblom:
Would it be your intent in Nevada, when someone pleads guilty to one of these
misdemeanors, that they would be advised that the consequences down the
road could be a felony?
Assemblyman Horne:
Mr. Segerblom touched on one of my questions. This deals particularly with the
priors in our state. Mr. Clifton, you mentioned that there is no legal requirement
in this state to do this; however, we have formal admonishments that the
attorneys have to read and go overevery section of that admonishmentwith
the client, and we focus on the enhancements for subsequent convictions for
domestic violence. The client has to sign that, as well as the attorneyat least
in Clark Countyand then the judge asks the defendant, did your attorney go
over it with you? do you understand it? do you understand subsequent
convictions and the penalties that come with them? et cetera, and they state
on the record that they do. The judge will not even move forward until all of
this is done. Even assuming that there is nothing in statute saying that we are
required to do that, over the years that I have been practicing, we have been
doing it. Is there not an argument that we have created a legality because now
these persons in our jurisdictions have been told by a judge that this is what
Chairman Anderson:
So our record is clear, Mr. Kandt is referring to paragraph (b) of subsection 2 of
section 2 of the bill, lines 19 through 21 on page 5 of the bill.
Brett Kandt:
If you refer to the proposed new section 2, I wanted to make a clarification
because the discussion involved out-of-state convictions and then priors
in-state. The way the section is written, they would not be combined. You
would either have three out-of-state priors that could subject you to a felony
conviction for a fourth or subsequent offense in Nevada, or you would have
your priors here in Nevada, but the way the bill is written they would not be
combined.
My concern is a lot of times people plead guilty to misdemeanors, they do not
have an attorney, and given the domestic violence laws, they pled without
knowing the consequences. So, I would like to figure out a way, if possible, to
make sure that people, when they have these kind of convictions on their
record, knowingly did the crime and they deserved the punishment.
Chairman Anderson:
So, if I am to follow the argument from Mr. Segerblom, we can only control the
actions of the courts here in Nevada. We could put in a requirement at
canvassing, if we wished. However, that also creates a potential question
about the past. If I am to understand in section 1, subsection 4, you will be
reaching back in time so that this bill would apply to convictions prior to the
effective date of the bill. This is a retrospective bill. That is somewhat unusual.
I am concerned about bringing in convictions from other states. Where you
plead guilty to a misdemeanor, do you not have to be told that that might lead
to a felony down the road? I know that is how it is in our DUI laws. What if
they plead guilty to a misdemeanor in another state but were not told that the
guilty plea might result in a felony?
David Clifton:
It is actually a misunderstanding. Many people believe because we do it, that it
is a legal requirement. There is no legal requirement that we notify you that
your third offense, or even your second offense, will have enhanced penalties.
The only legal requirement, when you plead guilty to a domestic battery first or
a DUI first, is that we tell you about the direct consequences of your plea: you
could be sentenced up to $1,000 and six months in jail. However, when we
devised the plea negotiation memorandums and the guilty plea canvassing, we
said we might as well put this notice in there in Nevada. Immediately after we
did thatwhen we notified people that the second offense could be mandatory
10 days in jail instead of mandatory two days, and a third offense is a
mandatory prison sentence of one yearwe got questions from people that had
out-of-state prior convictions. They said, well, nobody notified me that a third
offense in Nevada is a felony. When we did the research, we found out that we
were not required to give notice; we just did it to be complete or to be nice
because our intent was to try to keep people from committing repeat DUIs and
repeat domestic batteries. There is no legal requirement, even though we do it.

March 2, 2009
Page 30

March 2, 2009
Page 29
001649
Assemblyman Horne:
Also, one of my concerns is that it takes away that discretion from the judges
at the end, for the fourth conviction on, regardless of time. I had a client whose
daughter and her boyfriend were living with him, falling on some hard times,
Another way to answer your question is: I have an armed robbery, a grand
larceny, and a burglary conviction, and on none of those three guilty plea
canvassing or admonishments did they ever tell me that habitual criminal could
be a life sentence for me if I commit it again. You know that as a defense
attorney. You have never seen that notice in a guilty plea memo or
admonishment because we could not possibly admonish a defendant about
every collateral consequence. What you are talking about is clearly collateral
consequences, not direct consequences. This is the same as the right to vote,
the right to carry weapons, and all of these things. We keep throwing them
into our guilty plea canvass little by little just to be nice, to have a good heart,
to help the defendant with some kind of notice, but it is not required. All it
does is create more problems because then, like you are saying, a defense
attorney comes up and says, "My client was not warned of this. Bull! He was
warned of it by the statute, just like every other crime. You have a statute
telling you what your collateral consequences for future conduct are going to
be. So, when he is canvassed, he is only required, by constitutional due
process and by the statutes, to be told what the direct consequences are.
However, back in the 1980s, we did the same thing with DUI. We do not put
in collateral consequences in the guilty plea memo, or we should not. When we
started doing it, like we have done with DUI and domestic battery, we have this
same argument that you are making, but it is an expectation that you are
arguing, not a legal requirement. It is not a detrimental reliance.
Assemblyman Ohrenschall:
I remember some of the hearings back when Attorney General Del Papa started
the council, and I remember one of the hearings where this gentleman, who was
a batterer, came and talked; he went around talking to other men who had been
convicted of battering their wives and girlfriends; he talked about the treatment
and all that. One of the things I recall is that I thought the seven years was put
David Clifton:
Yes, absolutely, and rightfully so. If he had three prior burglaries from 10 or
20 years ago, and the judge and the prosecutor now get him on a fourth, he is
not going to get less of a sentence than he got on the third one; he is going to
get more. The judge will hear the arguments from the defense counsel that he
was clean and sober and did well for 10 or 20 years, but it is still his fourth
offense.
Assemblyman Ohrenschall:
Let us say you have John Smith, who had been a very violent husband, and
within two years he managed to become a category C felon. He serves his
time, he and Mrs. Smith get divorced, he seeks treatment, and he has a decade
of being pretty good at controlling his anger and not having any subsequent
convictions. Eleven years later, he is in a new relationship, and there is an
argument, a fight. The police come. There is no substantial harm, but let us
say there was a shove or a push, and he gets taken away. Would he be a
category B felon under this bill?
David Clifton:
It would not apply in Nevada unless he already had the seven-year felony third
offense. If he stayed in Nevada all that time, he would not have a problem
because he could never get to the third offense unless he had two priors within
seven years. Even under this bill, if he gets a fourth, then it becomes a
category B felony. Even without the bill, it would still be a category C felony
unless the priors became too old. But he has to have the first felony.
and the boyfriend got a little more aggressive toward his daughter, which my
client did not appreciate. He threw the boyfriend out on his ear. The boyfriend
called the police from his cell phone, and my client got arrested for a battery
domestic violence. He was concerned because he had a prior one about a
decade before. I told him it was beyond the seven years and did not matter,
but it was a concern of his at the time. I think of a situation like that where he
had actually been in no trouble at all over that 10-year period, and the
circumstances changed in his home. If it had been a third or a fourth under this
law, he may be going away for a very long time. I am concerned about those
instances.
your future holds. Now, they come back and they are told that it is something
different. I would say that there is at least that argument that these people, to
mix civil and criminal, have an expectation. It seems to start getting murky. I
just want some clarity on why this is not going to be a legal fight down the
road.
David Clifton:
I can answer your question a couple of ways, and think it will make sense either
way. One way is to take the flip side and show you what happens: a defense
attorney gets up and argues that the client was convicted in Colorado of two
prior offenses, and he was not told that the third would be a felony in Nevada
because in Colorado it is not, hypothetically. You would lose that argument as
a defense attorney because it is not a due process requirement to be told the
collateral effects of your guilty plea. It is a due process requirement to be told
the direct effects of your guilty plea.

March 2, 2009
Page 32

March 2, 2009
Page 31
001650
Orrin Johnson, Deputy Public Defender, Washoe County Public Defender's

Office, Reno, Nevada:
Brett Kandt:
Certainly, this statute and this bill only apply to subsections 2 and 4. We have
not changed anything dealing with prosecutorial ability to use their discretion to
plea bargain. The same plea bargaining rules would apply. My answer is, no,
there would be no discretion allowed to prosecute the case. We would
prosecute as a category B felony. However, it should not be plea-bargained
down if we can prove that it is a fourth offense and that he did domestic
battery. The police have some limited discretion under Chapter 171 of NRS to
arrest the primary physical aggressor. When they look at it, they will have to
determine that he was the primary physical aggressor. If he was, and he
committed domestic battery, and he had at least the three priors, either in
Nevada or some other jurisdiction, we would charge it as a category B felony.
And it should not be plea-bargained down if we can prove the case. If the facts
go south, or one of the priors looks like it was not constitutional, then it would
be plea-bargained down. And by facts going south, I mean a victim that may be
recanting. That might hurt my case enough to where I feel I have to plea
bargain it. I try not to do that. We know victims can recant, but there can be
other proof problems with the case, and we will look at the totality of the
circumstances to determine whether we can plea bargain it down or not so we
do not violate the requirements that were put into the domestic battery law
years ago, taking away some of our discretion to plea bargain.
David Clifton:
On the situation that was just described, is it mandatory that the person be
charged with this other offense, and if he was found guilty, would he then have
to be classed as a category B felon, or could the judge give him a lesser
offense?
Assemblyman Carpenter:
I think you are correct. I think that was part of the concept behind the
Legislature's decision to impose the seven year window. I just wanted to
clarify, once again, even if you pass this bill, for the purpose of that third
offense rising to a felony, it would still have to happen within the seven year
window. You still have, in essence, the carrot, as you put it, for an individual to
get treatment and to understand that battering in intimate relationships is
wrong. And if they have not figured that out after being in the court system
and convicted three times in seven years, our concern is they are not getting it,
and at that point in time the carrot has not worked.
Chairman Anderson:
in there as a carrot to batterers to try to get treatment and not recidivate. Do

you think this still works as a carrot, or is there new data that shows the
treatment does not really work, that if you have those tendencies you will
continue being a batterer forever?
Several people, including the Chairman, referenced these minor cases, brothers
scuffling and that sort of thing. Sometimes it is even more than that. When I
was in the Navy, I had a sailor who served about 12 years in the Navy. His
In all the time that I have done this as a public defenderand even before
where I dealt with people being accused of domestic violence when I was in the
NavyI can count on one hand the amount of times that the domestic violence,
actually perpetrated, fit the stereotype of the power and control issues. Far
more often it was a dating relationship, even a casual dating relationship, where
a couple of people had too much to drink and there was a little bit of shoving
going on. Oftentimes, that situation absolutely fit the definition of domestic
violence under the statute. If the domestic violence statutes only caught the
stereotypical wife batterers that everybody thinks about when they think about
domestic violence, we probably would not have an issue. Unfortunately,
because that net has been cast so wide, and because so many more people get
caught up in it, we are very concerned that people are now going to sit in our
prison system, spending our money, who do not deserve to go to prison. That
results in the injustice.
We are opposed to the bill. We understand the thrust of it, but the realities of
domestic violence, as it is prosecuted in the statutory scheme that currently
exists, makes it very problematic. The analogy here, of course, is to drunk
driving: once a felon, always a felon. It is a bad analogy to draw between
drunk driving and domestic battery. The primary reason is that for drunk driving
there is a clear standard: like the ads say, if you are over the limit, you are
under arrest. Period. You are over a 0.08 blood alcohol content (BAC), that is
a DUI. There are no ifs, ands, or buts about it. For other common drugs it is
the same thing. There are per se limits. There is no question that it is a DUI.
Domestic battery, as some people alluded to earlier, escapes that clear
definition. What is a dating relationship? What amount of force constitutes
domestic violence? Was there self defense? Is it a mutual affray? These are
the questions that we deal with all the time in domestic battery, and this is why
it is very difficult. Because of those unfortunate loose definitions, there are the
problems of a potential substantial injustice, where even though something is a
crime and probably ought to be punished, it is not necessarily a felony where
somebody ought to go to prison for years and years, under the circumstances.
Ms. Hart, you did not indicate a desire to speak, but I do know there is a writing
from you. Did you wish that submitted for the record? We will ask that
Ms. Hart's writing be distributed and made a part of the record (Exhibit F).

March 2, 2009
Page 34

March 2, 2009
Page 33
001651
Jason Frierson, Clark County Public Defender's Office, Las Vegas, Nevada :
I will be brief, and I will spare the Committee from my reiterating the points that
Mr. Johnson has made. I agree wholeheartedly with him. Some things that
were brought up on the presentation of the bill, comparisons to armed robbery
and burglary, and the fact that subsequent offenses do not get treated lighter
than the original offenses, those are felonies to start with, so they are treated
as felonies in subsequent offenses, unlike the current battery domestic violence
which is not originally treated as a felony.
Something that Ms. Dondero Loop brought up is the dating relationship. All too
often because these cases are misdemeanors, they are actually charged by the
least experienced DAs because that is where the stakes are a little bit lower.
That is fine, they do a great job, they are conscientious folks, but they are new
and they sometimes are overzealous. The definition of dating relationship is a
fairly broad one. It is NRS 33.018(2): "As used in this section, 'dating
relationship' means frequent, intimate associations primarily characterized by
the expectation of affectional or sexual involvement. The term does not include
a casual relationship or an ordinary association between persons in a business or
social context. You can also see that on a first date, where there is an
expectation, the definition would apply. I have seen cases prosecuted, and
even people found guilty, where they had not been dating all that long. It was a
fairly casual relationship, and those are the things that do not fit the rubric and
the stereotype that we all are concerned about: the actual repeat offenders who
ought to go to prison. Those are the ones that get dragged in there along with
the rest of them.
There was a lot of discussion about out-of-state convictions. Currently, we

consider out-of-state convictions. That is not a deviation from the current law.
We consider them for the purposes of reaching the third offenses for
enhancements.
wife was about twice his sizeand I am being generousand she was very
aggressive and dominant. One day, she shoved him. He shoved her back. He
left. She called the police. He was arrested. Fortunately, in Washington state
where this took place, the prosecutor had more discretion than they have here
in Nevada, so his prosecution was deferred so long as he went to domestic
violence classes. A year later, on the night before Thanksgiving, she started
throwing things at him. He kicked over a garbage can and left the house. He
was arrested once again. Because no judge was working on Thanksgiving day,
he spent Thanksgiving night in jail. Fortunately, the prosecutor did not charge
because the wife later recanted. The idea that this sailor, who had spent
12 years of his life in dedication to his country and intended to make a career
out of it, would have lost his security clearance and would have been looking at
a felony had he gotten into a scuffle with a roommate another six years down
the road, is very troubling. Unfortunately, these are the cases that we often see
and that we need to protect against. That is why we oppose, with the broad
language, these particular amendments.
We do oppose A.B. 33 for many of the reasons that Mr. Frierson and
Mr. Johnson spoke about. My concerns, specifically, deal with what I call the
fringe cases. I was before this Committee two sessions ago dealing with the
civil compromise statute, where we were denied that right to use civil
compromise to deal with some of those fringe cases, which was my concern
back then. It is still my concern. One example: I have a case pending for trial
in May involving two brothers. They were involved in a fight. My client is
alleged to have simply thrown a beer bottle, and he is now facing a felony. I
heard the proponents of this bill talking about domestic relationships, the dating
relationships, the husband and wife, and if that was as broad as the net was, I
would probably be more willing to consider this piece of legislation. I am still
concerned about the fringe cases involving brothers, distant relatives, in-laws,
roommates. I think it was broad when it was passed, and I am concerned that,
as we continue to pile on additional penalties and take away some of the tools
that were available, we are going to be catching a lot of people that should not
Cotter C. Conway, Alternate Public Defender's Office, Washoe County, Reno

Nevada:
I think that Mr. Johnson has made all the points that we have as far as our
concerns about this. We have discretion right now with respect to prosecutors
and how they treat their offenses. They are not allowed to deviate from battery
domestic violence, but they are allowed to look at the facts. I think the ability
to look at the facts at that level is appropriate, and they certainly are harsh in
treating people who are the traditional batterers. But they have the opportunity
after seven years to avoid subjecting those, who are not the typical and
traditional batterers, to mandatory prison and felony treatment.
Mr. Johnson brought up a few examples. I think some concerns were

expressed. Some of the types of cases that I have had concerned defendants
that had some battery domestic violence convictions in their 20s, and a
subsequent event occurred much later on. I literally had an 80-year-old client
who used a tree switch on his 83-year-old wife, and that was charged as a
battery domestic violence. I do not think that is the kind of conduct that the
sponsors of the bill are targeting for the purposes of mandatory prison and
felony treatment, yet those, as a practical matter, are the kinds of things that
end up being engulfed in such a broad and sweeping bill as this one.

March 2, 2009
Page 36

March 2, 2009
Page 35

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Dear Office of Bar Counsel,

"Fwd: FW: Case No. RCR2011-063341

Creighton C. Skau (skauc@reno.gov)

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Dear Judge Sferrazza and DDA Young,

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the 911 call by Coughlin

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unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,

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11 19 12 063341 MOTION FOR MISTRIAL OR CONTINAUCNE.pdf

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

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101211coughlin CRC 11-063341 Competency Evaluation Hearing that got continued.wmv

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Dear Judge Sferrazza and DDA Young,

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the 911 call by Coughlin

file:///R|/1%20a%20NEW%20temp/12%204%2012%20063341%20formal%20written%20grievance%20against%20dda%20young%20city%20attorney%20skau%20wcpd%20dogan%20and%20leslie%200204.htm[12/10/2012 4:18:43 PM]

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The judgment is, therefore, reversed....

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unused, untimely eviction warrant needs to be reissued, Green, 344 SE 2d 507,

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Filed: 3/30/2012, in NVB Adversary Proceeding Cadle Company v. Keller 10-05104

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