10 10 12 0204 067980 1048 Coughlin V Northwinds Ncs RPD Wcso RJC RMC Superior

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Document Code:
Zach Coughlin,Esq.
NV Bar No: 9473 currentl! sus"ended#
$% B%& 39'(
)eno, NV *9+,+
-el and .a/: 949 ''7 74,0
ZachCoughlin1hotmail.com
$lainti2234u56-enant
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7N <ND .%) -8E C%:N-= %. ;<48%E, 4-<-E %. NEV<D<
<C>6<$?7, 7NC. DB< N%)-8;7ND4
<$<)-?EN-4@ D;<=NE 9<A%B,
7ndiBiduall! and in his ca"acit! as "ro"ert!
manager 2or N%)-8;7ND4 <$<)-?EN-4@
NEV<D< C%:)-4 4E)V7CE4, CCC NC4#@
9E.. C8<NDCE), 7ndiBiduall! and in his
ca"acit! as oDner and CE% o2 NC4@). ;)<=,
7ndiBiduall! and in his ca"acit! as licensed
"rocess serBer 2or NC4@N%)-8;7ND
<$<)-?EN- <44%C CCC (,3( &$)E44
N%)-8;7ND CCC ((, ((,-8 <VE NE
4-E ++, BECCEV:E, ;< 9*,,4 Descri"tion
4ummar! .ictitious .irm Name 6
Counter 74,4, ,43,(3(997 (0:,,:,, <?
E/"iration Date: ,43,(30,,0 Business Name:
N%)-8;7ND <$<)-?EN-4 %Dners:
N%)-8;7ND <$<)-?EN- <44%C7<-E4,
CCC
Candlord,
Bs.
Z<C8<)= B<)AE) C%:>8C7N@
-enant
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C<4E N%: )9C )eB0,(06,,(,4*
DE$-. N%: 4
REQUEST FOR SUBMISSION OF COUGHLIN'S MOTION TO SET ASIDE ORDER OF
SUMMARY EVICTION OF JUNE 27TH, 2012; or, !"#$ %& '(" #!'"r&#'%)", S*!"+"&' 'o
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)EE:E4- .%) 4:B?7447%N %. C%:>8C7NF4 ?%-7%N -% 4E- <47DE %)DE) %. 4:??<)= EV7C-7%N %. 9:NE
07-8, 0,(0@ or, "lead in the alternatiBe, 4u""lement to CoughlinFs ?otion to 4et <side 4ummar! EBiction %rder and %)der 2ollDing
8earing on 9ul! 3(st, 0,((
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Co*,(!%&'- Mo'%o& 'o S"' A-%$" S*++#r. E)%/'%o& Or$"r #&$ OR$"r 0o!!1%&, H"#r%&, o& J*!.
21-', 2011
C%?E4 N%;, Z<C8 C%:>8C7N, E4E., and 2iles the a5oBe titled document and request
that the ?otion to 4et <side the 9une 0*th, 0,(0 CocGout %rder 5! su5mitted to the 9udge 2or a
decision. he and him and him and him and 9e22 Chandler NeBada court serBices are maGing o2 the
court Dait a second thatFs loBel! to this the! "ut the Dord court in the name and their 5usiness then
the! 5ang on "eo"leFs doors and leaBe out the NeBada 5ed and Hust sa! court serBices in and alloDed
angr! tone Dhile dressed u" looGing liGe 4heri22s,,, !ou reall! haBe to hand it to this gu! 9e22
Chandler he is a master o2 mani"ulation and intimidation u"on ha"less tenants he has his creD and
himsel2 dress u" looGing liGe the!Fre the got damn 4heri22 then the!Fd "ut the Dord court in there a2ter
name Dho Dould "ossi5l! not do eBer!thing the! sa! and eBen i2 !ou do 2ailed to do it the! sa! the!
Dill tr! and 5reaG into !our rental and all Dere rental as the! haBe on Coughlin on numerous
occasions Dill Coughlin got arrested 2or tres"assing Barious made u" charges that the laD local laD
en2orcement haBe 5rought Coughlin Dhether to a2raid to charge in the tres"ass NeBada court serBices
his esca"e "rosecution des"ite that date and can this ca"tured on ta"e Dhen 5ehind o2 a closed
5acG!ard gate CoughlinFs laD o22ice and 5anged on ;indoDs 2or 3, and 4, min. at a time three times
a da! Dhile the! haBe another gu! ringing the door5ell oBer and oBer and oBer and issued taunts to
an!one inside CoughlinFs 2ormer laD o22ice. <hen ). ;ra!9ul! 3(st, 0,(0 8earing Das not noticed
2or the "ur"oses o2 dis"osing o2 an! such ?otion, and 2urther, the %rder 2olloDing that hearing
"ur"orted to rule on matters not connected to :nit 09 mentioning unit 4+ in the %rder#, Dhich,
Dould necessaril! maGe the %rder, under N)4 4,.4,, and N)C$ ',5#4#, Boid 2or lacG Hurisdiction.
Being that a tolling ?otion has not 5een dis"osed o2 in this matter, there ma! still 5e an a""eal, as
the deadline to 2ile one has not run. Cegislatures maGe the laD. N)C$ (( "roBides cor"orations,
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such as the ones that oDn and run NorthDinds <"artments doing 5usiness in (, states, not some
?om Fn $o" o"eration# cannot a""ear "ro se...and nothing in N)4 ((*<, N)4 ((*, or N)4 4,
changes that. -here might 5e something alloDing a IlandlordFs agentI to "ost a notice ma!5e,
ma!5e not#, 5ut there is nothing alloDing one to "ractice laD. But...i2 CoughlinFs laD license is
sus"ended...does that mean he can o"en u" sho" and start re"resenting clients in landlord tenants
matter 5e2ore the )9C 2or a 2eeJ 9ust liGe NorthDindsJ NorthDindFs ;e5 site contains the 2olloDing
te/t: I NeBada Court 4erBices...<n EBiction, $rocess 4erBice K Consulting Com"an!,,,Northern
NeBada EBiction 4erBice Northern NeBadaFs onl! $ro2essionall! Cicensed, .ull! 7nsured and
:ni2ormed EBiction <genc!...)eno 3 4"arGs EBiction 4erBices $ro2essionall! Cicensed and .ull!
7nsured $riBate <genc! ;e "roBide !our "ro"ert! Dith ;orGers Com". 7nsurance and 4tate o2
NeBada Cicensing N%N6 $<=?EN- %. )EN- N%-7CE4 $re"are K 4erBice $acGage ;e Dill
$re"are 4erBe 3 $ost !our notice. ;e Dill 2a/ !our notice to !our o22ice and hold the original or mail
the original Dith the a22idaBit to !ou u"on request. N%-E: =ou must calendar !our CocG %ut date
and call our o22ice should !ou need the CocG %ut. L4,.,, "er notice M mileage i2 a""lica5le .ull
4erBice $acGage ;e Dill "re"are !our notices. 7ncluding all -!"es o2 Notices to meet !our needs#
;e Dill 4erBe 3 $ost !our notice. $re"are the return o2 serBice 2or the court should !our Notice go to
CocG %ut. -racG 5! com"uter the num5er o2 da!s "rior to the 2irst aBaila5le CocG %ut date. ;e Dill
"re"are !our CocG %ut <22idaBit, "icG u" !our checGs i2 necessar! and 2ile Dith the court . ;e Dill
maGe the arrangements Dith the 4heri22Fs %22ice and a""ear on !our 5ehal2 at the CocG %ut.I. -here
is nothing Drong Dith Coughlin. <nd mincing e/"lanations that these %rders are not I"ersonall!...7
am sorr! !ou are in this situation, its nothing "ersonal....I do not change the 2act that 9udges a""l!
the laD, Dhile legislatures enact the laD, and that the laD must 5e so a""lied 2aith2ull! and Dithout
"reHudice or con2lict, eBen Dhere Coughlin is currentl! at odds Dith some in the ;ashoe Count!
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District <ttorne!Fs %22ice and some indiBidualFs s"ent most o2 their career so 2ar there. .urther, it
Das im"ermissi5le to 5ase CoughlinFs 5ail in the arrest incident to this matter )C)0,(06,'79*, on
pending criminal charges under some totalit! o2 the circumstances theor!. Bench BooG Courts o2
Cimited 9urisdiction 0,,* and 0,(, 4u""lement. Bail ma! 5e 2or one thing and one thing onl!, to
ensure the de2endantFs a""earance at trial.
incident to the N%tice serBed on m! rental at NorthDind <"artments ('*,
4G! ?ountin DriBe unit 09 on 9une 0*th, 0,(0. 7 5elieBe the tenantFs
a22idaBit 7 2iled in res"onse to that + da! notice should 5e giBen a 5rand neD
case num5er, though the designation 5! ncs that it Das an I<mended
N%ticeI "ursuant to is is is is is is is isis it is as i2 the isthe '3(43(0 one the
one ). ;ra! lied a5out e22ecting I"ersonal serBiceI on me o2, Dhich got me
arrested Hust 5e2ore 7 Das to 2a/ to the )9C, 5! noon, a -enantFs <nsDer or
?%tion to Dismiss 2or 2ailure to state a cause o2 action or de2icien! o2
serBice o2 "rocess or something 7 argua5l! neednFt haBe eBen 2iled
an!thing in the )9C Dhere the '3(43(0 notice listed 4"arGs 9ustice Court.
%h, it gets 5etter...NeBada Courts serBices 2iled a CandlordFs <22idaBit
attesting to haBe rented Coughlin a IdDellingI Dhich is de2ined as a
Islee"ing "lace or residenceI in N)4 ((*<...and "ursued an eBiction under
N)4 ((*<...citing a 5reach 5! Coughlin 2or allegedl! using the unit 09 2or
a residence or slee"ing "lace, instead o2 "ursuing N)4 4,.7', or N)4
((*.47+ eBiction remedies Dhich, 5! the Da!, ma! result in the 4heri22
eBicting Coughlin or 2orcing him to quit an! alleged use o2 :nit 09 as a
IdDelling "lace or residenceI, 5ut =%: ;7CC N%- -8<- :NDE)
-8%4E 4-<-:-E4 C%:>8C7N ;%:CD BE <CC%;ED, :NDE)
-8E C<; -% C%N7N:-E 4-%)7N> <ND <CCE447N> 874
$)%$E)-= -8E)ENNNNC<NF- 8<VE 7- B%-8 ;<=4 <CC -8E
-7?E, >:=4. %h, also, Dho in the hell signed the CandlordFs a22idaBitJ
-here is no te/tual indication o2 Dhom the solitar! letter o2 a IsignatureI
5elongs to....ma!5e 5ecause it Dould 5e a N)C$ (( Biolation 2or a
cor"oration to a""ear I"ro seI, es"eciall! Dhere re"resented 5! someone
committing the unauthoried "ractice o2 laDJ
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). ;ra! made some interesting statements on the Bideo o2 the '30*3(0
arrest 2ilmed 5! Coughlin, es"eciall! concerning CoughlinFs contention that
;ra! and N%rthDindFs DDane 9aGo5Fs attem"ts to 5reaG and enter and
tres"ass into :nit 09 constituted I"ersonall! serBingI Coughlin a + da!
:nlaD2ul Detainer Notice on '3(43(0. 72 NC4 did not I"ersonall! serBeI
Coughlin, then Coughlin Dould haBe had until 9une 0*th, 0,(0 at noon at
the earliest and argua5l! until the close o2 5usiness at +"m on '30*3(0 to
2ile a res"onse ie -enantFs <nsDer or ?%tion to Dismiss, etc#, in 4"arGs
9ustice Court %) EVEN in )Eno 9ustice Court. Coughlin Das arrested at
(,:3, am on '30*3(0, there5!, under color o2 laD, the ;C4%, NC4 and
N%rthDind and 9aGo5 2raudulentl! "reBented Coughlin 2rom 2iling i2 he
did not alread! "reBiousl!, es"eicall! in the '3(33(0 2a/es that are
m!steriousl! unaccounted 2or in r9C 2iles# a -enanFts )es"onse tEnanFts
ansDer, or -enantFs <.2idaBit or ?otion to Dismiss, etc.#.
4o, ). ;ra! and NC4, its Gind o2 a 5ig deal that !ou lied a5out e22ecting
"ersonal serBice on '3(43(0 o2 the + da! notice.
Coughlin has three di22erent Bersion o2 that notice or IDeclaration o2
4reBice 5! Cicense $)ocess 4ErBerI ). ;ra!. in one, a time o2 9:03
"resuma5l! am, 5ut that is not circled, nor is "m# on '3(43(0 is listed, and
a ru55er stam" indicating Ir. Dra!I, is there, along Dith a hadnDritten Ireg
Or6,4394*I is there. that Declaration indicates that ). ;)a! I"ersonall!
serBedI the "arte! named, Coughlin. %ddl!, this 2irst Bersion and all three
o2 these are in the )9C 2ile in reB0,(06,,(,4*# instead o2 IHenni2er
ChandlerI 5eing in , 7 guess, the signature line 2or the IagentI o2 the
landlrod and she alDa!s Hust "laces a Iru55er stam"I o2 her name
an!Da!s..I, instead o2 9enni2er Chandler, on the one '3(43(0 + da! N%tice
and all Bersion so2 this notice haBe checGs on 5o/ 3 and ', Dhich read I3.
)ecieBed a + da! notice o2 "ossi5le unlaD2ul detiner 2or 2ailure to com"l!
Dith the rental agreement....'. )emained in "ossesion o2 the "remises
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su5Hect to the "roBision o2 Ch"ater ((*< o2 the N)4 a2ter haBing 2ailed to
"er2orm the 5asic or contractual o5ligations im"osed u"on !ou 5! that
Cha"ter, name! 4EE <--<Ched#I though the Iattached Hust seems to
include a co"! o2 the I)ental <greementI Dith no real indication o2 hoD
Coughlin Das in Biolation o2 it, and no indication o2 Dh! N%rthDinds 2eels
Coughlin remained in Biolation thereo2 des"ite CoughlinFs Dritten
communications indicating that he Das not in 5reach. <n!Da!s, rather tha
a ru55er stam" indicating IHenni2er ChandlerI on that one + da! notice, the
one Dhere ;)a! actuall! a22i/es his actual signature, 2olloD 5! a handDritt
r6,4394* his licensed "rocess seBer num5er#, the s"ot usuall! 5aring the
I9enni2er ChandlerI ru55er stam" is instead taGen u" 5! a signature 5!
NeBada Court 4erBices resient notar! "u5lic 8B Cedomio....<>ain, there is
no time listed on that 2irst Bersion o2 the N%tice or Dhich includeds at the
5ottom the IDeclaration o2 4erBice....I
7n the second Bersion o2 the Inotice o2 :nlaD2ul detainer...I serBed on 9une (4th, 0,(0, in his
IDeclaration o2 4erBice 5! Cicnese "rocess 4erBerI Dhich, argua5l! inoBGes the I"enalt! o2
"erHur! dicate o2 N)4 +3.,4+...# ;ra! against declares he "ersonall! serBed Coughlin, Dith a
time o2 9:03 indicated, and a ru55er stam" o2 I). ;ra!I on the signature line, Dith a
handDritten I)Eg O)6,4394*I and that Bersion Das 2a/ed 5! the 4"arGs 9ustice Court to the
)eno 9ustice Court on 9une 0*th, 0,(0 at ((:,+ am, in a (3 "age 2a/, man! "ages o2 Dhich are
not in the )9C 2ile, though that 2a/ does included the header 2rom the 2a/ 2rom Coughlin to the
I4"arGs 9ustice Court on ' 0' (0 at (0:,,"m, Dhich Das a (, "age 2a/, and the Bersio o2 the
'3(43(0 + da! notice Dith Declartion o2 4erBice 5! r. ;ra! indicating a time o2 9:03 is "age ' o2
(, o2 CoguhlinFs 2a/ to the 4"arGs 9ustice Couer according to the 2a/ hearders# Dhile also 5eing
"age (0 o2 teh 9une 0*th, 0,(0 2a/ 2rom the 4"arGs 9ustice court to the )eno 9ustice Court. right
a5out the moment Coughlin Das 5eing "laced in ;C4% De"ut! ?achen squad or "atrol Behicle
2or trans"rot to the Hail, Dhere Coughlin Dould 5e 2orced to 2orG oBer some more 5ail, etc., etc.
7N the -hird Bersion o2 the IDeclaration o2 4erBiceI on the same 9une (4th, 0,(0 IN%-7CE %.
:NC<;.:C DE-<7NE) .%) .<7C:)E -% V<C<-E $)E?74E4 ..-his third Bersion o2
his '3(43(0 Declaration o2 4erBice 5! Cicensed $)ocess 4erBe ). ;ra! has the t!"ical IHenni2er
chandlerI ru55er stam" 2or the N%tice hal2 o2 the "age, and has a ru55er stam" 2or IJ).Dra!I,
along Dith a clearl! di22ert handDrirtn note o2 IregO r,43I o5Biousl!, aside 2rom the
handDriting Ianal!sisI the handDrittn num5erical indication o2 the "rocess serBicer num5er is
truncated on this third Bersion 5! 3 num5ers#. <dditional! this third Bersion indicates it Das
I"ersonall! serBedI at (0:+4 "m.
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;h! all the di22erent BersionsJ Dh!, i2 "ersonall! serBice Das e22ect at 9:03 am, Doud ). ;ra!
need to return and do it again, all 2or :nit 09, nmin !ou onl! all the other Declartions o2
4erBice 2rom that date o2 '3(43(0 , ie 2or units 4+ and 7(, indicate that ;ra! merel! "osted teh
notice to the rented "ro"ert! and there2ore Dould entail 3 more da!s 2ro mailing to get
IconstrutiBe noticeI under N)C$ 'e# and N)C$ +5#0#, Dhich landlordFs liGe NorthDinds Hust
hate.
-hen there is the 2act that NC4 snucG into the 2ile later a Dhole nother t!"e
o2 notice, one under N)4 4,.7',...Dhich, o2 course, changes eBer!thing..
%. course, ;ra! did not I"ersonall! serBeI Coughlin. ;ra! attem"ts to
maGe some hal265aGed argument a5out hoD he slid a2ter 2ailing in his
attem"ts to 5reaG and enter and tres"ass in to :nit 09 on '3(4309# the + da!
:D Notice into a cracG in the door o2 the rental, and "erceiBed it to ImoBeI
a2ter he let go o2 it, there5!, a""arentl!, entitling him to assert that he
e22ected I"ersonal serBiceI u"on tenant Zach Coughlin, or, a""arentl!,
otherDise com"lied Dith N)C$ +, and there2ore cut short the time 2or
Coughlin to res"ond as a tenant and secure a hearing rather than 5e
incarcerated a2ter haBing unGnoDn Biolent sounding 2igures 2lash5acGs to
other interactions Dith NeBada Court 4erBices# 5anging on his doors,
re2using to indenti2! themselBes, then ultimatel! taGing a chainsaD or
saDP6all# to a metal door to a con2ined DindoDless rental.
N)4 4,.4,, maGes N)C$ the a""lica5le rules here, not 9C)C$, nor
9C))-:
):CE +. 4E)V7CE <ND .7C7N> %. $CE<D7N>4 <ND %-8E) $<$E)4
)ule
Dra2terQs Note
Commentar!
a# 4erBice: ;hen )equired. E/ce"t as otherDise "roBided in these rules, eBer! order required
5! its terms to 5e serBed, eBer! "leading su5sequent to the original com"laint unless the court
otherDise orders 5ecause o2 numerous de2endants, eBer! "a"er relating to discoBer! required to
5e serBed u"on a "art! unless the court otherDise orders, eBer! Dritten motion other than one
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Dhich ma! 5e heard e/ "arte, and eBer! Dritten notice, a""earance, demand, o22er o2 Hudgment,
designation o2 record on a""eal, and similar "a"er shall 5e serBed u"on each o2 the "arties. No
serBice need 5e made on "arties in de2ault 2or 2ailure to a""ear e/ce"t that "leadings asserting
neD or additional claims 2or relie2 against them shall 5e serBed u"on them in the manner
"roBided 2or serBice o2 summons in )ule 4.
R<s amended@ e22ectiBe 4e"tem5er 07, (97(.S
5# 4ame: 8oD ?ade.
(# ;heneBer under these rules serBice is required or "ermitted to 5e made u"on a "art!
re"resented 5! an attorne!, the serBice shall 5e made u"on the attorne! unless the court orders
that serBice 5e made u"on the "art!.
0# 4erBice under this rule is made 5!:
<# DeliBering a co"! to the attorne! or the "art! 5!:
i# handing it to the attorne! or to the "art!@
ii# leaBing it at the attorne!Qs or "art!Qs o22ice Dith a clerG or other "erson in charge, or i2 there
is no one in charge, leaBing it in a cons"icuous "lace in the o22ice@ or
iii# i2 the o22ice is closed or the "erson to 5e serBed has no o22ice, leaBing it at the "ersonQs
dDelling house or usual "lace o2 a5ode Dith some "erson o2 suita5le age and discretion residing
there.
B# ?ailing a co"! to the attorne! or the "art! at his or her last GnoDn address. 4erBice 5! mail
is com"lete on mailing@ "roBided, hoDeBer, a motion, ansDer or other document constituting the
initial a""earance o2 a "art! must also, i2 serBed 5! mail, 5e 2iled Dithin the time alloDed 2or
serBice@ and "roBided 2urther, that a2ter such initial a""earance, serBice 5! mail 5e made onl! 5!
mailing 2rom a "oint Dithin the 4tate o2 NeBada.
C# 72 the attorne! or the "art! has no GnoDn address, leaBing a co"! Dith the clerG o2 the court.
D# DeliBering a co"! 5! electronic means i2 the attorne! or the "art! serBed has consented to
serBice 5! electronic means. 4erBice 5! electronic means is com"lete on transmission "roBided,
hoDeBer, a motion, ansDer or other document constituting the initial a""earance o2 a "art! must
also, i2 serBed 5! electronic means, 5e 2iled Dithin the time alloDed 2or serBice. -he serBed
attorne!Qs or "art!Qs consent to serBice 5! electronic means shall 5e e/"ressl! stated and 2iled in
Driting Dith the clerG o2 the court and serBed on the other "arties to the action. -he Dritten
consent shall identi2!:
i# the "ersons u"on Dhom serBice must 5e made@
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ii# the a""ro"riate address or location 2or such serBice, such as the electronic6mail address or
2acsimile num5er@
iii# the 2ormat to 5e used 2or attachments@ and
iB# an! other limits on the sco"e or duration o2 the consent.
<n attorne!Qs or "art!Qs consent shall remain e22ectiBe until e/"ressl! reBoGed or until the
re"resentation o2 a "art! changes through entr!, DithdraDal, or su5stitution o2 counsel. <n
attorne! or "art! Dho has consented to serBice 5! electronic means shall, Dithin (, da!s a2ter
an! change o2 electronic6mail address or 2acsimile num5er, serBe and 2ile notice o2 the neD
electronic6mail address or 2acsimile num5er.
3# 4erBice 5! electronic means under )ule +5#0#D# is not e22ectiBe i2 the "art! maGing
serBice learns that the attem"ted serBice did not reach the "erson to 5e serBed.
4# $roo2 o2 serBice ma! 5e made 5! certi2icate o2 an attorne! or o2 the attorne!Qs em"lo!ee, or
5! Dritten admission, or 3. #00%$#)%', or other "roo2 satis2actor! to the court. .ailure to maGe
"roo2 o2 serBice shall not a22ect the Balidit! o2 serBiceI
7n the legal DorG dra2ted and 2iled 5! a non6attorne!, a criminal Biolation in NC4Fs and 9e22
ChandlerFs committing the authoriPed "ractice o2 laD Dhat ha""ens to "eo"le doing "lastic
surger! Dithout a licenseJ Hail time, lots o2 it...5ecause something could go 5adl!, 5adl! Drong
and "eo"le could get hurt...liGe Coughlin got hurt, damaged, arrested, 2inanciall! destro!ed, etc.,
etc. here. thin sGull "lainti22, consequential damages ;inchell B 4chi22 0,,* case sea2ood,
storage "lace lost 5usiness and lost "ro2its L3,,A damages, etc.. Dhile in Hail Coughlin Das
"reBented 2rom 2iling in matters that ultimatel! Dound u" Dith a L4,,,+, Hudgment against
Coughlin, and thereFs more, 2or Dhich N%rthDind, and NC4, Chandler and ;)a!, and "erha"s,
some others, Dill 5e lia5le.#. 7n the I<22idaBit o2 Candlord 2or BreachI 2iled on 9une 07th, 0,(0
5! ,Dell, Dho GnoDs, giBen it Hust sa!s ICanldordI and has Dhat a""ear s to 5e a handDritten
I4I in the signature line...5ut, lets sa! it Das 2iled 5! 9e22 Chandler, Dhom crossed the 5ar and
argued 5e2ore 9udge $earson on 9ul! 3(st, 0,(( in )EB0,(06,,(,4* on 5ehal2 o2 his IclientF
NorthDind <"artments, <ssociates CCC see acg6am"i.com, doing 5usiness in (, states, Ginda
seems liGe the! could a22ord and attorne! rather than destro! our communit! Dith hacG "retend
laD!ers Dho "la! dress as a 4heri22 and 5ull! "eo"el Dhile attem"ting to 5reaG and enter and
tres"ass...and then )$D <lan ;eaBer and 4<rgent %liBer ?iller, and ;C4% De"ut! 9ohn
?achen and De"ut! >omeP chi" in some 4oldal B. CooG Count! Biolating (9*3 Biolations as
Dell...."uGe, "uGe. "uGe... 7N the I<22idaBit o2 Candlord 2or BreachI that Chandler dra2ted and
2iled, he Drote, at "aragra"h 4. Ihim and nation surrender o2 the "remises Das to haBe taGen
"lace on or 5e2ore 9une (3, 0,(0. -hat legal notice has 5een serBed on the tenantFs in accordance
Dith the "roBisions o2 N)4 cha"ter 4,.0*, as amended on '3(43(0.I
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ChandlerFs <22idaBit o2 Candlord 2or Breach demonstrates a lacG o2 candor to the tri5unal, Dhich
Dould 5e "ro2essional misconduct to re"ort to the 4BN, 5ut, Chadler aint a laD!er, so,and Dhat
are !a goinF ta doJ DD< =oundJ DD< Aandaras, isnFt that !our HurisdictionJ -hat is a
criminal laD Biolation, right, unauthoriPed "ractice o2 laD...and in that 9une 07th, 0,(0 <22idaBit
o2 Candlord Chandler sneaGil! lists IN3aI in the 5lanG 2or the Ioriginal "eriod o2 is 5lanG#
terminating on o 2orr trans2erring to a "eriodic tenanc! on that date. < co"! o2 the Dritten
rental agreement, i2 an! , is attached hereto.I....:"on in2ormation and 5elie2, chandler 2ailed to
inlcude a co"! o2 the )ental <greement in at least one o2 these N%rthDind 2iles not sure i2 it
Das in the one 2or unit 09, reB0,(06,,(,4*, 5ut it Doudl maGe sense, as NorthDindFs eggs Dere
all in that 5asGet in a sense.# <n!Da!s, the )ental <>reement maGes clear the "eriod is not
In3aI...Dh! Dould Chandler do thatJ Coudl it 5e that N)4 4,.0+3 has di22er atent laDs 2or
tenancies Dhere the rent is reserBed 5! a "eriod o2 ( DeeG or lessJ Coughlin "aid 2or one
monthFs rent u" 2ront at the time the )enal <greement Das signed. <lso, see isthe craigslist ad
Coughlin res"onded to "laced 5! NorthDind, and incor"orated into an I)ental <greementI,
along Dith Ber5al indications, argua5l!, under N)4 ((*<.(', Dhich onl! a""lies to IdDelling
"lacesI, 5ut the CandlordFs <22idaBit inidcates this rental Das, in "aragra"h 0 such, as it states
I0. -hat !or a22iant isrented a certain dDelling or a"artment to Zach Coughlin, located at ('*,
sG! mountain dr...O09, )eno, NV on +343(0 2or an original "eriod o2 N3a terminating on or
trans2errinto a "eriodic tenanc! on that date. a co"! o2 the Dritten rental agreemet i2 an!, is
attached hereto.I.. Chandler seems to Dant to taGe adBanteg o2 N)4 4,.0+30#Fs quicGie serBice
a""roach 2or DeeG to DeeG rentals, Dhich unit 09, 5! Birtue o2 the terms o2 the )ental
<greement, clearl! Das not. as him and him and him this 5ut the neD the signatures is Dritten
in the amount o2 L7+ is due no later than the 2irst o2 late a2ter the 2or eBer! month late is asGed
Bo5 Co5laD clearl! this Das a "eriodic tenanc! o2 month to month 2or Bariet! 2urther one
"roBision and this one is rental agreements has Dritten 3, da!s notice to Bacate is required or
rental Dill 5e res"onsi5le the ne/t months rent coBered Chandler tends to one characteriPe this
as a DeeG to DeeG or less t!"e tenanc! to taGe adBantage o2 the lessons serBice requirements
there and 2ound in N)4 4,.0+3(#60#:
.urther, the )ental <greement is not necessaril! limited to the document that N%rthDind
<"artments "ur"orts to 5e the I><)<>E 3 C<)$%)- )EN-<C <>)EE?EN-I as their
e/ists no limitation in that document that a22irmatiBel! disclaims an! incor"oration o2
statements 5! then ?anage Deede Call Dhom m!steriousl! disa""eared u"on current ?anager
DDa!ne 9aGo5 shoDing u"# or incor"orated into the )ental <greement or Cease 5! Birtue o2 the
adBertisements that NorthDinds held out to the "u5lic on Craigslist, Dhich is hoD Coughlin
learned o2 their o22er, u"on Dhich Coughlin called then ?anager Deede Call and met Dith her in
"erson. <ttached in E/hi5it ( is the Craigslist ad that NorthDinds Das running at the time, and
it read:
IL7+ %ne 4iPe Car G#r#," .or )ent NorthDest )eno, NV#
Date: 0,(06,46,0, (,:,0<? $D-
)e"l! to: see 5eloD
;elcome to NorthDind <"artments. ;e o22er storage units to non6NorthDind )esidentsN I0 .o*
&""$ +or" -'or#,", De o22er garages to rent 2or L7+ "er month. -he! are a 2ull siPe single car
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garage. ?ost "u5lic storages Dould charge oBer L(+, dollars 2or the same siPeN %ur communit!
is located in northDest )eno, right
o22 o2 ?cCarran. $lease call us at 77+# 747690,, or come 5!. ;e are located at ('*, 4G!
?ountain DriBe in NorthDest )eno.I
AND IT GETS BETTER4 T(" '(%&, #3o*' NRS 506770 %- '(#' %' -"/%0%/#!!. %&$%/#'"- '(#'
%' $o"- &o' #!. 'o 8,#r#,"-86 <nd 9udges donFt legislate 2rom the 5ench, the! Hust a""l! the
laD as Dritten, so "eo"le can de"end on notice "roBided 5! "recedent and "u5lished laDs. -o do
otherDise is Hudicial misconduct argua5l! requiring a Com"laint Dith the 9udicial Disci"line
Commission.
.urther Coughlin asGed and then ?anager Deede Call she is listed as the manager on the
I)EN-<C <>)EE?EN-I o2 ?a! 4th, 0,(0, and it 5ears hers and CoguhlinFs signature,
numerous questions Bis a Bis the use o2 the rental, and clearl!, Deede Call gaBe Coughlin
"ermission and actuall!, Call did not indicate an! Is"ecial "ermissionI to use the rentals 2or
something other than "arGing a car Das necessar! to o5tain an!Da!s, and no one has esta5lished
that Coughlin did not use the rentals 2or "arGing an!Da!s, and an! .ourth <mendment Biolating
tres"ass and Bideoing o2 CoughlinFs rentals is not admissi5le an!Da!s. 4oldal B. CooG Co.
C8<$-E) 4, 6 <C-7%N4 <ND $)%CEED7N>4 7N $<)-7C:C<) C<4E4 C%NCE)N7N>
$)%$E)-= 4:??<)= $)%CEED7N>4 .%) %B-<7N7N> $%44E447%N %. )E<C
$)%$E)-=, )EC)E<-7%N<C VE87CCE %) ?%B7CE 8%?E
N)4 4,.0+3 :nlaD2ul detainer: 4u""lemental remed! o2 summar! eBiction and e/clusion o2
tenant 2or de2ault in "a!ment o2 rent.
N)4 4,.0*, 4erBice o2 notices to quit@ "roo2 required 5e2ore issuance o2 order to remoBe.
N)4 4,.4,, )ules o2 "ractice.
C8<$-E) (,* 6 4-<-:-%)= C7EN4
LIENS OF O9NERS OF FACILITIES FOR STORAGE
N)4 (,*.47+ :se o2 storage s"ace 2or residence "rohi5ited@ eBiction@ nature o2 2acilit!@
e22ect o2 issuance o2 document o2 title 2or "ro"ert!.
C8<$-E) ((*< 6 C<NDC%)D <ND -EN<N-: D;ECC7N>4
CHA:TER 1;7 < CRIMES BY AND AGAINST THE E=ECUTIVE :O9ER OF
THIS STATE
NRS 1;760;0 I&'"r0"r%&, 1%'( *3!%/ o00%/"r6
NRS 1;76100 I&0!*"&/%&, *3!%/ o00%/"r6
NRS 1;76110 M%-/o&$*/' o0 *3!%/ o00%/"r6
N)4 (97.(0, .alse im"ersonation o2 "u5lic o22icer@ %&'r*-%o& %&'o #&$
r"0*-#! 'o -*rr"&$"r *3!%/ o00%/"6
NRS 1;76120 F#!-" r"or' 3. *3!%/ o00%/"r6
NRS 1;76150 :*3!%/ o00%/"r +#>%&, 0#!-" /"r'%0%/#'"6
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NRS 1;76170 Fr#*$*!"&'!. r"-"&'%&, /!#%+ 'o *3!%/ o00%/"r6
NRS 1;761?0 9ro&,0*! "@"r/%-" o0 o00%/%#! o1"r6
NRS 1;761;0 O3-'r*/'%&, *3!%/ o00%/"r6

-he arrest o2 Coughlin at NorthDinds <"artments on 9une 0*th, 0,(0 5! the same ;C4%
De"ut! ?achen Dho 2iled a 2alse a22idaBit attesting to haBe I"ersonall! serBedI Coughlin the
4ummar! EBiction %)der 2rom CoughlinFs 2ormer home laD o22ice on NoBem5er (st, 0,((,
Dhen in realit!, ?achen Hust "osted the %rder to the door Dhen no5od! Das home and
there2ore committed tres"ass under color o2 laD, as he 2ailed to com"l! Dith N)C$ +5#0#
made a""lica5le to landlord tenant matters 5! N)4 4,.4,,# and N)C$ 'e#.
4o, ;C4% ?achen arrested Coughlin 2or a Biolation o2 N)4 (97.(9,:
N)4 (97.(9, %5structing "u5lic o22icer. EBer! "erson Dho, a2ter due notice, shall
re2use or neglect to maGe or 2urnish an! statement, re"ort or in2ormation laD2ull!
required o2 the "erson 5! an! "u5lic o22icer, or Dho, in such statement, re"ort or
in2ormation shall maGe an! Dill2ull! untrue, misleading or e/aggerated statement, or
Dho shall Dill2ull! hinder, dela! or o5struct an! "u5lic o22icer in the discharge o2
o22icial "oDers or duties, shall, Dhere no other "roBision o2 laD a""lies, 5e guilt! o2 a
misdemeanor.
=et DD< charged Coughlin in the Criminal Com"laint in )9C )C)0,(06,'79*, Dith
a di22erent crime, N)4 (99.0*,:
IN)4: C8<$-E) (99 6 CRIMES AGAINST :UBLIC JUSTICE
OTHER OFFENSES
N)4 (99.0*, )esisting "u5lic o22icer.
< "erson Dho, in an! case or under an! circumstances &o' o'("r1%-" -"/%#!!.
ro)%$"$ 0or, Dill2ull! resists, dela!s or o5structs a "u5lic o22icer in discharging or
attem"ting to discharge an! legal dut! o2 his or her o22ice shall 5e "unished:
(. ;here a 2irearm is used in the course o2 such resistance, o5struction or dela!, or
the "erson intentionall! remoBes, taGes or attem"ts to remoBe or taGe a 2irearm 2rom
the "erson o2, or the immediate "resence o2, the "u5lic o22icer in the course o2 such
resistance, o5struction or dela!, 2or a categor! C 2elon! as "roBided in N)4 (93.(3,.
0. ;here a dangerous Dea"on, other than a 2irearm, is used in the course o2 such
resistance, o5struction or dela!, or the "erson intentionall! remoBes, taGes or attem"ts
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to remoBe or taGe a Dea"on, other than a 2irearm, 2rom the "erson o2, or the immediate
"resence o2, the "u5lic o22icer in the course o2 such resistance, o5struction or dela!, 2or
a categor! D 2elon! as "roBided in N)4 (93.(3,.
3. ;here no dangerous Dea"on is used in the course o2 such resistance, o5struction
or dela!, 2or a misdemeanor.I
;h! the change 2rom DD< =oungJ 7t couldnFt 5e 5ecuase N)4 (99.0*, is more
damaging to CoughlinFs laD license, in light o2 4C) ((('#, than Dould 5e a sim"le
little N)4 (97.(9, charge, could itJ 7s that "ermissi5le Dhere the ;CD< and ;C4%
haBe a Bested interest in discrediting and demolishing Coughlin in light o2 allegation
o2 misconduct 5! 5oth o2 those o22ices Dith res"ect to its treatment o2 Coughlin, in
addition to misconduct against Coughlin 5! the ;CDCJ
NeBada 4u"reme Court )ule ((('#: I'. De2inition o2 T-"r%o*- /r%+"6A -he term
Tserious crimeU means (# a 2elon! and 0# an! crime less than a 2elon! a necessar!
element o2 Dhich is, as determined 5! the statutor! or common6laD de2inition o2 the
crime, im"ro"er conduct as an attorne!, %&'"r0"r"&/" 1%'( '(" #$+%&%-'r#'%o& o0
B*-'%/", 0#!-" -1"#r%&,, misre"resentation, 2raud, Dill2ul 2ailure to 2ile an income ta/
return, $"/"%', 5ri5er!, e/tortion, misa""ro"riation,I. ConBictions o2 a Iserious crimeI
require Bar Counsel to 2ile a 4C) ((( $etition against the attorne!.
Could there 5e an! clear demonstration o2 the retaliator! animus against Coughlin 5!
the ;ashoe Count! District <ttorne!Fs %22iceJ <re "rosecutors "aid to "la! out
grudges and sanction misconduct 5! local laD en2orcementJ )ather than Hust a
IresistingI charge, DD< =oung and the ;CD< Dant to tr! to glom on a I2alse
sDearingI and Iinte2erring Dith the administration o2 HusticeI claim, eBen Dhere the
GnoD o2 the '30'3(0 Dritten corres"ondence 5! Coughlin to 5oth the 4"arGs and )eno
9ustice Courts and the CiBil DiBision o2 the ;ashoe Count! 4heri22Fs %22ice. Enough
is Enough. -his "rosecutorial misconduct must not stand.
But, reall! Coughlin is here5! com"laining to the landlord, "ursuant to N4 ((*<.+(,
o2 a Biolation o2 the criminal laD 5! one Dho is argua5l! an IagentI o2 the landlord
not maGing a 5ri5er! allegation here, to 5e clear, though#:
NRS 1;76200 Or"--%o& *&$"r /o!or o0 o00%/"6
(. <n o22icer, or a "erson "retending to 5e an o22icer, Dho unlaD2ull! and
maliciousl!, under "retense or color o2 o22icial authorit!:
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a# <rrests or detains a "erson against the "ersonQs Dill@
5# 4eiPes or leBies u"on anotherQs "ro"ert!@
c# Dis"ossesses another o2 an! lands or tenements@ or
d# Does an! act Dhere5! the "erson, "ro"ert! or rights o2 another "erson are
inHured,
commits o""ression.
0. <n o22icer or "erson committing o""ression shall 5e "unished:
a# ;here "h!sical 2orce or the immediate threat o2 "h!sical 2orce is used, 2or a
categor! D 2elon! as "roBided in N)4 (93.(3,.
5# ;here no "h!sical 2orce or immediate threat o2 "h!sical 2orce is used, 2or a
gross misdemeanor.
.urther, this is an o22icil Dritten com"laint against ;C4% De"ut! ?achen and
>omeP, "lease "lace a co"! o2 this Com"laint in their em"lo!ment and "ersonnel 2iles,
and "lease do the same Dith res"ect to )$D %22icer <lan ;eaBer, 4argent D!e,
4argent %liBer ?iller, and %22icer ;elch 2or their gross misdemeanor, consisting o2
doing that Dhich is the domain o2 the 4heri22 under N)4 4,.7', in conection Dith the
matter at 4u"erior ?ini 4torage on or around 4e"tem5er 0(st, 0,(0 under the
2olloDing laD, in light o2 teh language in N)4 4,.7', and N)4 (,*.47+, Dhich 7
made the )$D aDare o2 at the time, and 4oldal B. CooG Co. CouldnFt 5e too much o2 a
5udget crunch Dhen local laD en2orcement acts the Da! the! do, Berita5l! goading
ciBil rights tenantFs right attorne!Fs into suing them through their recGless and tacG!
5ehaBior: NRS 1;761?0 9ro&,0*! "@"r/%-" o0 o00%/%#! o1"r6 <n! "erson Dho
Dill2ull! taGes u"on himsel2 or hersel2 to e/ercise or o22iciate in an! o22ice or "lace o2
another, Dithout 5eing laD2ull! authoriPed thereto, is guilt! o2 a gross misdemeanor.
<lso, uner N)4 ((*<.+(,, 7 am com"laining o2 the 2olloDing Biolations o2 criminal
laD on NorthDindFs 5ehal2:
NRS 1;76120 F#!-" %+"r-o&#'%o& o0 *3!%/ o00%/"r; %&'r*-%o& %&'o #&$ r"0*-#! 'o
-*rr"&$"r *3!%/ o00%/"6 EBer! "erson Dho shall 2alsel! "ersonate or re"resent an!
"u5lic o22icer, or Dho shall Dill2ull! intrude into a "u5lic o22ice to Dhich the "erson
has not 5een dul! elected or a""ointed, or Dho shall Dill2ull! e/ercise an! o2 the
2unctions or "er2orm an! o2 the duties o2 such o22icer, Dithout haBing dul! quali2ied
there2or, as required 5! laD, or Dho, haBing 5een an e/ecutiBe or administratiBe
o22icer, shall Dill2ull! e/ercise an! o2 the 2unctions o2 o22ice a2ter his or her right to do
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so has ceased, or Drong2ull! re2use to surrender the o22icial seal or an! 5ooGs or
"a"ers a""ertaining to such o22ice, u"on the demand o2 his or her laD2ul successor,
shall 5e guilt! o2 a gross misdemeanor.
R(9(( CK$ V '7@ )C V '330@ NCC V (,,('S
NRS 1;76120 F#!-" r"or' 3. *3!%/ o00%/"r6 EBer! "u5lic o22icer Dho shall
GnoDingl! maGe an! 2alse or misleading statement in an! o22icial re"ort or statement,
under circumstances not otherDise "rohi5ited 5! laD, shall 5e guilt! o2 a gross
misdemeanor.
NEBada Court 4erBices regularl! attem"ts to mislead tenantFs into thinGing the act Dith color o2 laD. .rom 9oel Durden
5arGing at me in his 4heri22 looG6a6liGe getu" that he is an Io22icer o2 the courtI and 2rom ICourt 4erBicesI to haBing the
Dord ICourtI in their name,etc., etc. NEBad Court 4erBices im"ersonates "u5lic o22icers. <dditionall!, ?achenFs "olice
re"ort is 2alse to the e/tent that it 2ails to indicate that, at least at some "oint, ?achen and or De"ut! >omeP re2used to
idneti2! themsleBs. -he! donFt GnoD Dhat someone is doing inside Dhen the! "ur"ort to IGnocG and announceI and the
must reasona5l! 5e e/"ected to assume one could haBe not heard their initial announcing their idneti2! Dhether 5ecause
the! had head"hones or, Dere in the 5athroom, DhateBer...and ?achen and his coD5o! "artner >omeP re2used to identi2!
themselBes in res"onse to a request that the! do so 5! Coughlin, and similarl! re2used to slide through the door an!
"a"erDorG or Darrant descri5ing the "ur"ose o2 their Bisit.
;C4% is that ?achemFs <22idaBit o2 4erBice indicates that he I"ersonall!
serBedI me, Dhich Gind o2 reminds me o2 all that ro5o6signing and ?E)4
2raud 7 come across in m! da! Ho5 and do !ou Donder hoD man! attorne!s
in the 2oreclosure de2ense game 7 am in constant contact Dith Dho are
Datching and Ditness the "otential )7C% Biolations this Driting mentionsJ#,
Dhich includes 5eing a 2oreclosure de2ense attorne!. 4o Dhich is itJ Did
?achem I"ersonall! serBeI me the 4ummar! EBiction %rderJ )ichard >.
8ill, Esq. liGes to argue that 7 Das IserBedI in com"liance Dith all time
related rules 5ecause it Das done in the Iusual custom and "ractice o2 the
;C4%. ;hat, e/actl!, is the Iusual custom and "ractice o2 the ;C4%J 7
hear a lot a5out this IDithin 04 hoursI stu22. 4o, 7 go hunting 2or some
5lacG letter laD to su""ort Dhat those at the )9C and in the clueless
communit! at large Dhich o2ten includes NeBada Cegal 4erBices and
;ashoe Cegal 4erBices, the "eo"le !ou gu!s had such trou5le actuall!
serBing in the laDsuits 7 2iled, Dhich ma! haBe actuall! hel"ed im"roBed
legal serBices in this communit!, i2 the! Dere not dismissed due to
insu22icienc! o2 serBice o2 "rocess, eBen Dhere the 7.$ required the ;C4%
to serBed the de2endants....#. <n!Da!, 5acG to the IDithin 04 hoursI
"hraseolog!: I

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-his Dhole 5usiness a5out T-he court ma! thereu"on issue an order
directing the sheri22 or consta5le o2 the count! to remoBe the tenant Dithin
04 hours a2ter recei"t o2 the order...U is ina""lica5le to this situation, Dhere
an %rder >ranting 4ummar! EBiction Das signed 5! %cto5er 07th, 0,((.
-hat language is onl! 2ound in situations ina""lica5le to the current one.
N)4 4,.0+33#5#0#, and N)4 4,.0+3+#a# are the onl! sections o2 N)4
4, Dhere this TDithin 04 hoursU language occurs, and those situations onl!
a""l! Dhere, in:
4,.0+33#5#0#: T 3. < notice serBed "ursuant to su5section ( or 0 must: ...
5# <dBise the tenant: W. 0# -hat i2 the court determines that the tenant is
guilt! o2 an unlaD2ul detainer, the court ma! issue a summar! order 2or
remoBal o2 the tenant or an order "roBiding 2or the nonadmittance o2 the
tenant, directing the sheri22 or consta5le o2 the count! to remoBe the tenant
Dithin 04 hours a2ter recei"t o2 the orderU
and,
4,.0+3+#a#: T+. :"on noncom"liance Dith the notice: a# -he landlord
or the landlordQs agent ma! a""l! 5! a22idaBit o2 com"laint 2or eBiction to
the Hustice court o2 the toDnshi" in Dhich the dDelling, a"artment, mo5ile
home or commercial "remises are located or to the district court o2 the
count! in Dhich the dDelling, a"artment, mo5ile home or commercial
"remises are located, DhicheBer has Hurisdiction oBer the matter. -he court
ma! thereu"on issue an order directing the sheri22 or consta5le o2 the
count! to remoBe the tenant Dithin 04 hours a2ter recei"t o2 the order.U -he
Da! these summar! eBiction "roceedings are 5eing carried out in )eno
9ustice Court "resentl! shocGs the conscience and Biolates NeBada laD.
-here is not 5asis 2or e22ectuating a locGout the Da! ;C4%Fs De"ut!
?achem did in this case. -he a5oBe tDo sections containing the TDithin 04
hours o2 recei"tU language are ina""lica5le, as those situations do not
inBoGe the "resent circumstances, Dhere the -enant did 2ile an <22idaBit
and did contest this matter to a degree not o2ten seen. -o require NeBadaFs
tenants to get u" and get out TDithin 04 hoursU o2 Trecei"t o2 the orderU
Dhat does that eBen meanJ -he use o2 terms liGe TrenditionU, TrenderedU,
Tnotice o2 entr!U, T"ronouncedU, is a5sent here, and this Trecei"t o2 the
orderU language is something rarel! 2ound elseDhere in NeBada laD6see
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attached D?V statutor! citations, and in em"lo!ment laD litigations Dhere
one must 2ile a Com"laint Dithin 9, da!s o2 Trecei"tU o2 a )ight -o 4ue
Cetter, a situation Dhich 2olloDs N)C$ +5#, and N)C$ 'e# in im"uting
recei"t o2 such a letter, Dhen actual recei"t is not shoDn, 5! a""l!ing a
TconstructiBe noticeU standard that relies u"on the da!s 2or mailing
e/tension o2 time 2or items serBed in the mailing, etc.#. 7n <5raham B.
;oods 8ole %ceanogra"hic 7nstitute, ++3 ..3d ((4 (st Cir. 0,,9#, the
record did not re2lect Dhen the "lainti22 receiBed his right6to6sue letter. -he
letter Das issued on NoBem5er 04, 0,,'. -he court calculated that the 9,6
da! "eriod commenced on NoBem5er 3,, 0,,', 5ased on three da!s 2or
mailing a2ter e/cluding 4aturda!s and 4unda!s. 7n order to 5ring a claim
under either -itle V77 or the <D<, a "lainti22 must e/haust administratiBe
remedies and sue Dithin 9, da!s o2 recei"t o2 a right to sue letter. 4ee 40
:.4.C. V 0,,,e6+2#(#. 4ee BaldDin Count! ;elcome Center B. BroDn,
4'' :.4. (47, (4* n.(, (,4 4.Ct. (703, *, C.Ed.0d (9' (9*4#granting
"lainti22 an additional three da!s 2or mailing "ursuant to )ule '#.
.urther, des"ite Dhat the inaccurate handouts o2 NeBada Cegal 4erBices
ma! sa! a5out this T04 hoursU and the a""lica5ilit! o2 the 9C)C$ to cases
liGe these, NRS 506500 R*!"- o0 r#/'%/", holds that :U-he "roBisions o2
N)4, NeBada )ules o2 CiBil $rocedure and NeBada )ules o2 <""ellate
$rocedure relatiBe to ciBil actions, a""eals and neD trials, so 2ar as the! are
not inconsistent Dith the "roBisions o2 N)4 4,.00, to 4,.40,, inclusiBe,
a""l! to the "roceedings mentioned in those sections. <s such N)C$ 'a#,
e# a""lies to the %rder o2 4ummar! EBiction that ;C4% De"ut! ?achem
alleged, under "enalt! o2 "erHur!, that he I"ersonall! serBedI u"on me on
NoBem5er (, 0,((. -hat is a lie 5! ?r. ?achem, unless I"ersonall!
serBedI is de2ined in a rather im"ersonal Da! and or ?achem and 7 haBe
totall! di22erent understanding o2 the de2inition o2 I"ersonall! serBedI,
Dhich ma! 5e the case. %r, "erha"s the 4heri22Fs %22ice is 5us! and doesnFt
Dant to Dait around to I"ersonall! serBeI eBer! tenant it Dishes to eBict.
.ine, then Hust use the Imail it and alloD three da!sI rule in N)C$ 'e#...the
landlordFs might not liGe it, 5ut the! can use that 2rustration as an incentiBe
not to Hum" to litigating eBer! disagreement a5out ha5ita5ilit! that a tenant
5rings to them. =ou ma! not realiPe hoD ridiculous some landlordFs get.
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7n m! case, 7 o22ered to 2i/ 5asic things that clearl! im"licated the
ha5ita5ilit! rules in N)4 ((*<.09, and the Cali2ornian neurosurgeon,
BeBerl! 8ill 8igh 4chool graduate landlord 5alGed and com"lained then
hired and attorne! 2our da!s into a dis"ute.....at Dhich "oint the rules
against contacting re"resented "arties "reBented much in the Da! o2 real
settlement discussion, "articularl! Dhere o""osing counsel has
continuousl! demonstrated a com"lete indi22erence to "ursuing settlement
Dh! Dould he at the rates he 5ills hours atJ#. 7 Hust donFt thinG the
4heri22Fs %22ice needs to sull! its image or damage the citiPen tenants o2
;ashoe Count! in the name o2 "leasing "eo"le liGe Dr. ?att ?erliss or
)ichard >. 8ill, Esq.
7 am here5! com"laining to NorthDind <"artments o2 a Biolation o2 the criminal laD 5! one o2
its agents ). ;ra! and other "rocess serBers Dith NC4 %h, and )$D %22icer ;eaBer also
threatened to use Ih!draulic e/"losiBesI to gain entr! to one o2 m! three rentals at NorthDind,
though no e/igent circumstance e/isted and though he lacGed a Darrant. 7 haBe "reBiousl!
com"lained o2 Cou Cadia, ?ilan Are5s, 5oth NorthDind ?aintenance $ersonnel, and NorthDind
$ro"ert! ?anager or <"artment ?anager DDa!ne 9aGo5 attem"t to 5reaG and enter into m!
rentals Dh! is it Dhen )ichard >. 8ill, Esq. calls the )$D and alleges 7 am tres"assing, 7 get
su5Hect to a custodial arrest and 8ill gets the 4tate Bar o2 NeBada to tr! to "rosecute me 2or
I5reaGing an enteringI, eBen though ;C4% ?achen lied in his <22idaBit o2 4erBice in )9C
reB0,((6,,(,7,*, and the Court had 2ailed to return to me at the time o2 arrest the L0,07+ it
DasnFt "ermitted to require 7 de"osit in a Irent escroDI account in the 2irst "lace, and Dhere 8ill
and his contractor are caught on Bideo admitting to haBing remoBe m! ladder 2rom the 2ormer
laD o22ice in a Bideo o2 Decem5er 03rd, 0,((...Dh! doesnFt the )$D arrest 8ill and $hil
4teDart 2or larcen! o2 m! ladderJ Do 7 haBe to 5e ;al6?art or )ichard >. 8ill or NorthDinds
<"artments ie, rich, connected# to get the )$D to en2orce the laD Dhen 7 com"lain o2 a
BiolationJ
NRS 5062?0 S"r)%/" o0 &o'%/"- 'o C*%'; roo0 r"C*%r"$ 3"0or" %--*#&/" o0 or$"r 'o r"+o)"6
(. E/ce"t as otherDise "roBided in N)4 4,.0+3, the notices required 5! N)4 4,.0+( to 4,.0',, inclusiBe, ma! 5e serBed:
a# B! deliBering a co"! to the '"&#&' "r-o&#!!., %& '(" r"-"&/" o0 # 1%'&"--@
5# 72 the tenant is a5sent 2rom the tenantQs !#/" o0 r"-%$"&/" or 2rom the '"&#&'D- *-*#! !#/" o0 3*-%&"--, 3. !"#)%&,
# /o. 1%'( # "r-o& o0 -*%'#3!" #," #&$ $%-/r"'%o& #' "%'("r !#/" #&$ +#%!%&, # /o. 'o '(" '"&#&' #' '(" '"&#&'D-
!#/" o0 r"-%$"&/" or !#/" o0 3*-%&"--; or
c# 72 the "lace o2 residence or 5usiness cannot 5e ascertained, or # "r-o& o0 -*%'#3!" #," or $%-/r"'%o& /#&&o' 3"
0o*&$ '("r", 5! "osting a co"! in a cons"icuous "lace on the leased "ro"ert!, $"!%)"r%&, # /o. 'o # "r-o& '("r"
r"-%$%&,, %0 '(" "r-o& /#& 3" 0o*&$, and mailing a co"! to the tenant at the "lace Dhere the leased "ro"ert! is situated.
0. 4erBice u"on a su5tenant ma! 5e made in the same manner as "roBided in su5section (.
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3. B"0or" #& or$"r 'o r"+o)" a tenant is issued "ursuant to su5section + o2 N)4 4,.0+3, a landlord shall 2ile Dith the
court a "roo2 o2 serBice o2 an! notice required 5! that -"/'%o&6 B"0or" # "r-o& +#. 3" r"+o)"$ #- r"-/r%3"$ %& NRS
5062;0 'o 506520, %&/!*-%)", # !#&$!or$ -(#!! 0%!" 1%'( '(" /o*r' roo0 o0 -"r)%/" o0 #&. &o'%/" r"C*%r"$ *r-*#&' 'o
NRS 5062EE6 E@/"' #- o'("r1%-" ro)%$"$ %& -*3-"/'%o& 5, '(%- roo0 +*-' /o&-%-' o04
a# < statement, signed 5! the tenant and a Ditness, acGnoDledging that the tenant receiBed the notice on a s"eci2ied date@
5# < certi2icate o2 mailing issued 5! the :nited 4tates $ostal 4erBice@ or
c# -he endorsement o2 a sheri22, consta5le or other "rocess serBer stating the time and manner o2 serBice.
4. 72 serBice o2 the notice Das not deliBered in "erson to a tenant Dhose rent is reserBed 5! a "eriod o2 ( DeeG or less and
the tenanc! has not continued 2or more than 4+ da!s, "roo2 o2 serBice must include:
a# < certi2icate o2 mailing issued 5! the :nited 4tates $ostal 4erBice or 5! a "riBate "ostal serBice to the landlord or the
landlordQs agent@ or
5# -he endorsement o2 a sheri22 or consta5le stating the:
(# -ime and date the request 2or serBice Das made 5! the landlord or the landlordQs agent@
0# -ime, date and manner o2 the serBice@ and
3# .ees "aid 2or the serBice.I
R
N)4 ((*<.43, .ailure o2 tenant to com"l! Dith rental agreement or "er2orm 5asic o5ligations:
-ermination o2 rental agreement.
(. E/ce"t as otherDise "roBided in this cha"ter, i2 the tenant 2ails to com"l! Dith the rental
agreement or 2ails to "er2orm his or her 5asic o5ligations under this cha"ter, the landlord ma!
deliBer a Dritten notice to the tenant s"eci2!ing the acts and omissions constituting the 5reach
and that the rental agreement Dill terminate as "roBided in this section. 72 the 5reach is
remedia5le and the tenant does not adequatel! remed! the 5reach or use his or her 5est e22orts to
remed! the 5reach Dithin + da!s a2ter recei"t o2 the notice, or i2 the 5reach cannot 5e remedied,
the landlord ma! terminate the rental agreement.
0. 72 the tenant is not reasona5l! a5le to remed! the 5reach, the tenant ma! aBoid termination
o2 the rental agreement 5! authoriPing the landlord to enter and remed! the 5reach and 5!
"a!ing an! reasona5le e/"enses or damages resulting 2rom the 5reach or the remed! thereo2.
NorthDinds and NC4 2ailed to com"l! Dith N)4 ((*<.43,(# to the e/tent it eBen a""lies her#
in that in no Da! did it IdeliBer a Dritten notice to the tenant -"/%0.%&, '(" #/'- #&$ o+%--%o&-
constituting the 5reachI. NorthDinds sim"l! Drote Isee attachedI, a2ter "aragra"h ' o2 teh
'3(43(0 Notice, Dhich reads I'. )emained in "osssession o2 the "remises su5Hect to the
"roBisions o2 Cha"ter ((*< o2 the N)4 a2ter haBing 2ailed ot "er2rom the 5asic or contractual
o5ligations im"osed u"on !ou 5! that Cha"ter, namel!: 4EE <--<C8ED#I and then NC4, at
most, include a co"! o2 the I)ental <greementI Dith its 2iling o2 this Notice to the )9C, Dhich
in no Da! s"eci2ies Dhat as"ect o2 that )ental <greement Coughlin is "ur"ortedl! in 5reach o2,
or Dhat 2acts su""orts such an allegation.
<n! %rder he is Boid or su5Hect oa N)C$ ',5 set aside 5ased u"on the 2raud o2 NC4 and ;ra!
in l!ing Dhere he declares under "enalt! o2 "erHur!# to haBe I"ersonall! serBedI Coughlin the +
da! notie on '3(43(0, and under N)C$ ',54 Boid 2or lacG o2 Hurisdiction Dhere NC4 2ailed to
s"eci2! in the CanldordFs <22idaBit all that required under N)4 4,.0+3. and 2or so man! other
reasons, such at ((*< does not a""l! i2 the rental is deemed to 5e not e IdDellingI, and that an
illegal locGout is not aBaila5le eBen i2 Coughlin is ruled to haBe 5een Iusing as a residenceI the
rental, should the rental 5e a Istorage 2acilit!I Dhich Cit! o2 )eno Code En2orcement does not
BieD it to 5e...and .urther, 5! NorthDinds Ber! oDn descri"tiBes, it is a garage, one the! held
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out to the "u5lic 2or more than mere I"arGing a carI, and as such, under N)4 4,.7', and
(,*.4733, (,*.47+ and N)4 4,.7', are not eBen aBaila5le to NorthDind. -he!. <re. 4tucG.
Deal ;ith 7t.
NRS 10?65722 TF#/%!%'.A $"0%&"$6 T.acilit!U means real "ro"ert! diBided into indiBidual storage s"aces. -he term does not include a garage or
storage area in a "riBate residence.
NRS 10?65757 TS'or#," -#/"A $"0%&"$6 T4torage s"aceU means a s"ace used 2or storing "ersonal "ro"ert!, Dhich is rented or leased to an indiBidual
occu"ant Dho has access to the s"ace.
NRS 10?657E U-" o0 -'or#," -#/" 0or r"-%$"&/" ro(%3%'"$; ")%/'%o&; &#'*r" o0 0#/%!%'.; "00"/' o0 %--*#&/" o0
$o/*+"&' o0 '%'!" 0or ro"r'.6
(. < "erson shall not use a storage s"ace at a 2acilit! 2or a residence. -he oDner o2 such a 2acilit! shall eBict an!
"erson Dho uses a storage s"ace at the 2acilit! as a residence in the manner "roBided 2or in N)4 4,.7',.
NRS 10?657EE Co&'"&'- o0 r"&'#! #,r""+"&'6
(. Each rental agreement must 5e in Driting and must contain:
a# < "roBision "rinted in a siPe equal to at least (,6"oint t!"e that states, T7- 74 :NC<;.:C -% :4E < 4-%)<>E
4$<CE 7N -874 .<C7C7-= <4 < )E47DENCE.U
MISCELLANEOUS :ROVISIONS
NRS 40.760 Summary eviction of person using facility for storage as residence.
(. ;hen a "erson is using a storage s"ace at a 2acilit! as a residence, the oDner or the oDnerQs agent shall serBe or haBe
serBed a notice in Driting Dhich directs the "erson to cease using the storage s"ace as a residence no later than 04 hours
a2ter receiBing the notice. -he notice must adBise the "erson that:
a# N)4 (,*.47+ requires the oDner to asG the court to haBe the "erson eBicted i2 the "erson has not ceased using the
storage s"ace as a residence Dithin 04 hours@ and
5# -he "erson ma! continue to use the storage s"ace to store the "ersonQs "ersonal "ro"ert! in accordance Dith the
rental agreement.
0. 72 the "erson does not cease using the storage s"ace as a residence Dithin 04 hours a2ter receiBing the notice to do
so, the oDner o2 the 2acilit! or the oDnerQs agent shall a""l! 5! a22idaBit 2or summar! eBiction to the Hustice o2 the "eace
o2 the toDnshi" Dherein the 2acilit! is located. -he a22idaBit must contain:
a# -he date the rental agreement 5ecame e22ectiBe.
5# < statement that the "erson is using the storage s"ace as a residence.
c# -he date and time the "erson Das serBed Dith Dritten notice to cease using the storage s"ace as a residence.
d# < statement that the "erson has not ceased using the 2acilit! as a residence Dithin 04 hours a2ter receiBing the
notice.
3. :"on recei"t o2 such an a22idaBit the Hustice o2 the "eace shall issue an order directing the sheri22 or consta5le o2
the count! to remoBe the "erson Dithin 04 hours a2ter recei"t o2 the order. -he sheri22 or consta5le shall not remoBe the
"ersonQs "ersonal "ro"ert! 2rom the 2acilit!.
4. .or the "ur"oses o2 this section:
a# T.acilit!U means real "ro"ert! diBided into indiBidual storage s"aces. -he term does not include a garage or
storage area in a "riBate residence.
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5# T4torage s"aceU means a s"ace used 2or storing "ersonal "ro"ert!, Dhich is rented or leased to an indiBidual
occu"ant Dho has access to the s"ace.
<dded to N)4 5! (9*9, 0(3@ < 0,((, (*3,#
Nevada Process Server Licensing Requirements
It is required that all process servers are licensed and 2! or over! t"o#years e$perience as a process server and insurance against
lia%ility to third persons "ith limits of no less then &200!000. No %onding is required. 'o"ever! applicants must deposit &7(0 upon
su%mitting their application to pay for a %ac)ground investigation! the ma$imum an applicant can %e charged for a %ac)ground chec)
is &(00. *pplicants must also pass a "ritten application and may %e required to pass an oral e$am as "ell. +icenses are issued %y
the Nevada ,rivate Investigator-s +icensing .oard. Nevada is the most e$pensive state in the nation to get licensed. /Nevada Revised
Statutes 0641.0 and 0641.2(3
4N)4 4,.0+3 :nlaD2ul detainer: 4u""lemental remed! o2 summar! eBiction and e/clusion o2
tenant 2or de2ault in "a!ment o2 rent.
(. E/ce"t as otherDise "roBided in su5section (,, in addition to the remed! "roBided in N)4
4,.0+(0 and 4,.09, to 4,.40,, inclusiBe, Dhen the tenant o2 an! dDelling, a"artment, mo5ile
home, recreational Behicle or commercial "remises Dith "eriodic rent reserBed 5! the month or
an! shorter "eriod is in de2ault in "a!ment o2 the rent, the landlord or the landlordQs agent,
unless otherDise agreed in Driting, ma! serBe or haBe serBed a notice in Driting, requiring in the
alternatiBe the "a!ment o2 the rent or the surrender o2 the "remises:
a# <t or 5e2ore noon o2 the 2i2th 2ull da! 2olloDing the da! o2 serBice@ or
5# 72 the landlord chooses not to "roceed in the manner set 2orth in "aragra"h a# and the rent is
reserBed 5! a "eriod o2 ( DeeG or less and the tenanc! has not continued 2or more than 4+ da!s,
at or 5e2ore noon o2 the 2ourth 2ull da! 2olloDing the da! o2 serBice.
X <s used in this su5section, Tda! o2 serBiceU means the da! the landlord or the landlordQs agent
"ersonall! deliBers the notice to the tenant. 72 "ersonal serBice Das not so deliBered, the Tda! o2
serBiceU means the da! the notice is deliBered, a2ter "osting and mailing "ursuant to su5section
0, to the sheri22 or consta5le 2or serBice i2 the request 2or serBice is made 5e2ore noon. 72 the
request 2or serBice 5! the sheri22 or consta5le is made a2ter noon, the Tda! o2 serBiceU shall 5e
deemed to 5e the da! ne/t 2olloDing the da! that the request is made 2or serBice 5! the sheri22 or
consta5le.
0. < landlord or the landlordQs agent Dho serBes a notice to a tenant "ursuant to "aragra"h 5# o2
su5section ( shall attem"t to deliBer the notice in "erson in the manner set 2orth in "aragra"h a#
o2 su5section ( o2 N)4 4,.0*,. 72 the notice cannot 5e deliBered in "erson, the landlord or the
landlordQs agent:
a# 4hall "ost a co"! o2 the notice in a cons"icuous "lace on the "remises and mail the notice 5!
oBernight mail@ and
5# <2ter the notice has 5een "osted and mailed, ma! deliBer the notice to the sheri22 or
consta5le 2or serBice in the manner set 2orth in su5section ( o2 N)4 4,.0*,. -he sheri22 or
consta5le shall not acce"t the notice 2or serBice unless it is accom"anied 5! Dritten eBidence,
signed 5! the tenant Dhen the tenant tooG "ossession o2 the "remises, that the landlord or the
landlordQs agent in2ormed the tenant o2 the "roBisions o2 this section Dhich set 2orth the laD2ul
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"rocedures 2or eBiction 2rom a short6term tenanc!. :"on acce"tance, the sheri22 or consta5le
shall serBe the notice Dithin 4* hours a2ter the request 2or serBice Das made 5! the landlord or
the landlordQs agent.
3. < notice serBed "ursuant to su5section ( or 0 must:
a# 7denti2! the court that has Hurisdiction oBer the matter@ and
5# <dBise the tenant:
(# %2 the tenantQs right to contest the matter 5! 2iling, Dithin the time s"eci2ied in su5section (
2or the "a!ment o2 the rent or surrender o2 the "remises, an a22idaBit Dith the court that has
Hurisdiction oBer the matter stating that the tenant has tendered "a!ment or is not in de2ault in
the "a!ment o2 the rent@
0# -hat i2 the court determines that the tenant is guilt! o2 an unlaD2ul detainer, the court ma!
issue a summar! order 2or remoBal o2 the tenant or an order "roBiding 2or the nonadmittance o2
the tenant, directing the sheri22 or consta5le o2 the count! to remoBe the tenant Dithin 04 hours
a2ter recei"t o2 the order@ and
3# -hat, "ursuant to N)4 ((*<.39,, a tenant ma! seeG relie2 i2 a landlord unlaD2ull! remoBes
the tenant 2rom the "remises or e/cludes the tenant 5! 5locGing or attem"ting to 5locG the
tenantQs entr! u"on the "remises or Dill2ull! interru"ts or causes or "ermits the interru"tion o2
an essential serBice required 5! the rental agreement or cha"ter ((*< o2 N)4.
4. 72 the tenant 2iles such an a22idaBit at or 5e2ore the time stated in the notice, the landlord or the
landlordQs agent, a2ter recei"t o2 a 2ile6stam"ed co"! o2 the a22idaBit Dhich Das 2iled, shall not
"roBide 2or the nonadmittance o2 the tenant to the "remises 5! locGing or otherDise.
+. :"on noncom"liance Dith the notice:
a# -he landlord or the landlordQs agent ma! a""l! 5! a22idaBit o2 com"laint 2or eBiction to the
Hustice court o2 the toDnshi" in Dhich the dDelling, a"artment, mo5ile home or commercial
"remises are located or to the district court o2 the count! in Dhich the dDelling, a"artment,
mo5ile home or commercial "remises are located, DhicheBer has Hurisdiction oBer the matter.
-he court ma! thereu"on issue an order directing the sheri22 or consta5le o2 the count! to
remoBe the tenant Dithin 04 hours a2ter recei"t o2 the order. -he a22idaBit must state or contain:
(# -he date the tenanc! commenced.
0# -he amount o2 "eriodic rent reserBed.
3# -he amounts o2 an! cleaning, securit! or rent de"osits "aid in adBance, in e/cess o2 the 2irst
monthQs rent, 5! the tenant.
4# -he date the rental "a!ments 5ecame delinquent.
+# -he length o2 time the tenant has remained in "ossession Dithout "a!ing rent.
'# -he amount o2 rent claimed due and delinquent.
7# < statement that the Dritten notice Das serBed on the tenant in accordance Dith N)4 4,.0*,.
*# < co"! o2 the Dritten notice serBed on the tenant.
9# < co"! o2 the signed Dritten rental agreement, i2 an!.
5# E/ce"t Dhen the tenant has timel! 2iled the a22idaBit descri5ed in su5section 3 and a 2ile6
stam"ed co"! o2 it has 5een receiBed 5! the landlord or the landlordQs agent, and e/ce"t Dhen
the landlord is "rohi5ited "ursuant to N)4 ((*<.4*,, the landlord or the landlordQs agent ma!,
in a "eacea5le manner, "roBide 2or the nonadmittance o2 the tenant to the "remises 5! locGing or
otherDise.
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'. :"on the 2iling 5! the tenant o2 the a22idaBit "ermitted in su5section 3, regardless o2 the
in2ormation contained in the a22idaBit, and the 2iling 5! the landlord o2 the a22idaBit "ermitted 5!
su5section +, the Hustice court or the district court shall hold a hearing, a2ter serBice o2 notice o2
the hearing u"on the "arties, to determine the truth2ulness and su22icienc! o2 an! a22idaBit or
notice "roBided 2or in this section. 72 the court determines that there is no legal de2ense as to the
alleged unlaD2ul detainer and the tenant is guilt! o2 an unlaD2ul detainer, the court ma! issue a
summar! order 2or remoBal o2 the tenant or an order "roBiding 2or the nonadmittance o2 the
tenant. 72 the court determines that there is a legal de2ense as to the alleged unlaD2ul detainer,
the court shall re2use to grant either "art! an! relie2, and, e/ce"t as otherDise "roBided in this
su5section, shall require that an! 2urther "roceedings 5e conducted "ursuant to N)4 4,.09, to
4,.40,, inclusiBe. -he issuance o2 a summar! order 2or remoBal o2 the tenant does not "reclude
an action 5! the tenant 2or an! damages or other relie2 to Dhich the tenant ma! 5e entitled. 72 the
alleged unlaD2ul detainer Das 5ased u"on su5section + o2 N)4 4,.0+(4, the re2usal 5! the court
to grant relie2 does not "reclude the landlord therea2ter 2rom "ursuing an action 2or unlaD2ul
detainer in accordance Dith N)4 4,.0+(.
7. -he tenant ma!, u"on "a!ment o2 the a""ro"riate 2ees relating to the 2iling and serBice o2 a
motion, 2ile a motion Dith the court, on a 2orm "roBided 5! the clerG o2 the court, to dis"ute the
amount o2 the costs, i2 an!, claimed 5! the landlord "ursuant to N)4 ((*<.4', or ((*C.03, 2or
the inBentor!, moBing and storage o2 "ersonal "ro"ert! le2t on the "remises. -he motion must 5e
2iled Dithin 0, da!s a2ter the summar! order 2or remoBal o2 the tenant or the a5andonment o2
the "remises 5! the tenant, or Dithin 0, da!s a2ter:
a# -he tenant has Bacated or 5een remoBed 2rom the "remises@ and
5# < co"! o2 those charges has 5een requested 5! or "roBided to the tenant,
X DhicheBer is later.
*. :"on the 2iling o2 a motion "ursuant to su5section 7, the court shall schedule a hearing on the
motion. -he hearing must 5e held Dithin (, da!s a2ter the 2iling o2 the motion. -he court shall
a22i/ the date o2 the hearing to the motion and order a co"! serBed u"on the landlord 5! the
sheri22, consta5le or other "rocess serBer. <t the hearing, the court ma!:
a# Determine the costs, i2 an!, claimed 5! the landlord "ursuant to N)4 ((*<.4', or ((*C.03,
and an! accumulating dail! costs@ and
5# %rder the release o2 the tenantQs "ro"ert! u"on the "a!ment o2 the charges determined to 5e
due or i2 no charges are determined to 5e due.
9. < landlord shall not re2use to acce"t rent 2rom a tenant that is su5mitted a2ter the landlord or
the landlordQs agent has serBed or had serBed a notice "ursuant to su5section ( i2 the re2usal is
5ased on the 2act that the tenant has not "aid collection 2ees, attorne!Qs 2ees or other costs other
than rent, a reasona5le charge 2or late "a!ments o2 rent or dishonored checGs, or a securit!. <s
used in this su5section, Tsecurit!U has the meaning ascri5ed to it in N)4 ((*<.04,.
(,. -his section does not a""l! to the tenant o2 a mo5ile home lot in a mo5ile home "arG or to
the tenant o2 a recreational Behicle lot in an area o2 a mo5ile home "arG in this 4tate other than
an area designated as a recreational Behicle lot "ursuant to the "roBisions o2 su5section ' o2
N)4 4,.0(+.
<dded to N)4 5! (9'7, (9+@ < (9'9, 0'3, +7+@ (973, (,*+@ (97+, (0,0@ (977, 4(*, (34'@
(979, (39*, (*79@ (9*+, 009@ (9*7, (039@ (9*9, (,*0, (030@ (99(, ((3@ (99+, (*+(@ (997,
3+((@ (999, 9*(@ 0,,9, (9''@ 0,((, 03+, (4*9#
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N)4 4,.0+4 :nlaD2ul detainer: 4u""lemental remed! o2 summar! eBiction and e/clusion o2
tenant 2rom certain t!"es o2 "ro"ert!. E/ce"t as otherDise "roBided 5! s"eci2ic statute, in
addition to the remed! "roBided in N)4 4,.0+( and in N)4 4,.09, to 4,.40,, inclusiBe, Dhen
the tenant o2 a dDelling unit Dhich is su5Hect to the "roBisions o2 cha"ter ((*< o2 N)4, "art o2 a
loD6rent housing "rogram o"erated 5! a "u5lic housing authorit!, a mo5ile home or a
recreational Behicle is guilt! o2 an unlaD2ul detainer, the landlord is entitled to the summar!
"rocedures "roBided in N)4 4,.0+3 e/ce"t that:
(. ;ritten notice to surrender the "remises must:
a# Be giBen to the tenant in accordance Dith the "roBisions o2 N)4 4,.0*,@
5# <dBise the tenant o2 the court that has Hurisdiction oBer the matter@ and
c# <dBise the tenant o2 the tenantQs right to contest the notice 5! 2iling Dithin + da!s an
a22idaBit Dith the court that has Hurisdiction oBer the matter that the tenant is not guilt! o2 an
unlaD2ul detainer.
0. -he a22idaBit o2 the landlord or the landlordQs agent su5mitted to the Hustice court or the
district court must contain:
a# -he date Dhen the tenanc! commenced, the term o2 the tenanc!, and, i2 an!, a co"! o2 the
rental agreement.
5# -he date Dhen the tenanc! or rental agreement allegedl! terminated.
c# -he date Dhen the tenant 5ecame su5Hect to the "roBisions o2 N)4 4,.0+( to 4,.0+(',
inclusiBe, together Dith an! su""orting 2acts.
d# -he date Dhen the Dritten notice Das giBen, a co"! o2 the notice and a statement that notice
Das serBed in accordance Dith N)4 4,.0*,.
e# < statement that the claim 2or relie2 Das authoriPed 5! laD.
3. 72 the tenant is 2ound guilt! o2 unlaD2ul detainer as a result o2 the tenantQs Biolation o2 an! o2
the "roBisions o2 N)4 4+3.,(( to 4+3.++0, inclusiBe, e/ce"t N)4 4+3.33', the landlord is
entitled to 5e aDarded an! reasona5le attorne!Qs 2ees incurred 5! the landlord or the landlordQs
agent as a result o2 a hearing, i2 an!, held "ursuant to su5section ' o2 N)4 4,.0+3 Dherein the
tenant contested the eBiction.
<dded to N)4 5! (9*+, 007@ < (9*9, (,*4, (034@ (99(, ((+@ (99+, (*+3@ 0,,(, (,'+@ 0,,3,
+'(#I
7 ;%:CD C7AE -% AN%; ;8= -8E .7CE 7N )9C )EV0,(06,,(,4*
8<4 ?= ' $<>E .<& %. 9:NE 3,-8, 0,(0 <ND $CE<4E N%-E
-8E C7?7-ED %) 4$EC7<C <$$E<)<NCE N<-:)E %. -8<-
.7C7N> 7N -8E N%-E <- -8E B%--%? %. -8E .7)4- $<>E....=E-
7- 74 N%- .7CE 4-<?$ED, <ND 7 ;<4 NEVE) C<CCED, %)
.<&ED, %) N%-7.7ED 7N <N= ;<= C%NCE)N7N> -8E
4C8ED:C7N> %. ?= C%N4-7-:-7%N<CC= >:<)<N-EED
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8E<)7N> BE.%)E < 4:??<)= EV7C-7%N %) 4-<-:4 %. ?=
7.$ )EE:E4-.
?= $%47-7%N 74 -8<- 7 <? EN-7-CED -% < 4:??<)=
EV7C-7%N 8E<)7N> %N :N7- 09 <ND -8<- 7- 74 C%N>
%VE)D:E. $CE<4E CE- ?E AN%; ;8EN -8<- 8E<)7N> C<N
-<AE $C<CE. 7 D% N%- BEC7EVE <N= 9:D>E C:))EN-C= 8<4
9:)74D7C-7%N %N 7-, <ND -8<- -8E NE; C<4E, ;7-8 < NE;
C<4E N:?BE) 48%:CD BE I)<ND%?C= <447>NEDI
.urther in the )eno Hustice court 2ile 2or rHc reB0,(06,,(,4* is a tenant a22idaBit and declaration 2rom Coughlin 2a/ed to
the court on 9une 3,, 0,(0 contain si/ "ages it is unclear Dh! Coughlin Das not granted a summar! eBiction hearing as
required 5! laD and Coughlin is here5! demanding one and a Hur! trial Dhich he is entitled to one "ursuant the (9
4eBenties the Court decision and .)C$ rule 3, a.m. that Coughlin is requesting one "rior to the time set 2or hearing thatFs
right 2olGs Dere going to a Hur! trial Dhen NeBada court serBices serBed an amended eBiction notice on 9une 0* Coughlin
there and had 2iBe da!s to 2ile 2or an eBiction summar! eBiction hearing and he did so on 9une 3, Hust 2or the )eno $D
managed commit another Drong2ul arrest o2 Coughlin 2urther there Das Count! Hail 2ailed to trans2er Coughlin 2or the
9ul! + hearing on CoughlinFs motion to set aside the original 9une 07 order hoDeBer the 9une 07 order in this case Das
e/tinguished 5! that "osting o2 an amended locGout notice there2ore and eight itFs not 2ile stam" 5ut it should 5e 5! the
)eno Hustice court the si/ "age 2a/ 5! Coughlin on 9une 3,, 0,(0, though Aaren 4tancil a""ears to haBe handDritten in
the case num5er )9C reB0,(06,,(,4*
$CE<4E N%-E 7 <? :47N> <:D7% D7C-<-7%N -)<N4C)7$-7%N 4%.-;<)E .%) -874
C%))E4$%NDENCE <ND 7- ?7>8- 8<VE 4%?E E))%)4, ;87C8 C%:CD >)E<-C= <C-E) -8E
?E<N7N>, <4 7 D%NF- 8<VE -7?E -% C%))EC- -8E? )7>8- N%;.
additional! -8E)E ;<4 4EVE)<C .<&E4 -% -8E )9C C7V7C D7V747%N B= C%:>8C7N %N %) <B%:-
9:NE (3-8, 0,(0, <ND C%:>8C7N )EE:E4-4 < C%$= %. -8%4E %) 4%?E 7ND7C<-7%N %. ;8= -8E=
;E)E N%- .7CED <ND C%:>8C7N ;7CC C8ECA 874 %;N )EC%)D4 7N -8<- )E><)D ;8EN 8E 8<4
-7?E...8%;EVE), -% -8E E&-EN- %NE %. -8%4E .7C7N>4 ;<4 < -EN<N-F4 <..7D<V7- D7)EC-ED
-%;<)D4 :N7- 09, C%-4 %. $)%CED:)<C 7?$C7C<-7%N4 ;7CC 4-E?.
N%)-8;7ND <$<)-?EN-
<44%C CCC
(,3( &$)E44
N%)-8;7ND CCC
((, ((,-8 <VE NE 4-E
++,
BECCEV:E, ;< 9*,,4
Descri"tion 4ummar!
.ictitious .irm Name 6 Counter
74,4,
,43,(3(997 (0:,,:,, <? E/"iration Date: ,43,(30,,0
Business Name: N%)-8;7ND <$<)-?EN-4 %Dners: N%)-8;7ND <$<)-?EN- <44%C7<-E4, CCC
s .irm Name 6 Counter 6 (,93+(
.iling 7n2ormation
.iling Num5er
(,93+(
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.iling Date
,33('30,,' (0:,,:,, <?
E/"iration Date
,33('30,((
Business 7n2ormation
Business Name
)EN% )ED B%%A
%Dner 7n2ormation
%Dner3Cor"orate Name
9E..)E= > C8<NDCE) u
(,4,*+
(03,*30,,4 (0:,,:,, <? E/"iration Date: (03,*30,,9
Business Name: B%--4 C<ND= C%?$<N= %Dners: 9ENN7.E) V C8<NDCE), C7ND= ) V<NDE)Z7EC
8im and him and him and him motion a set o2 societ! eBiction order o2 the num5er o2 5ases one it Dent uno""osed and
hundred $olG case Coughlin Dins in that regard to the notice o2 hearing 5! the )eno Hustice court is dated 9ul! 3(,
0,(0 are not as o2 the hearing on 9ul! 0(, 0,(0 stated 9ul! 04, 0,(0 and him notices on Dhat the hearing is limited
to quote !ou ma! a""ear on the data shoD cause Dh! the court should or should not grant motion to sta! the eBiction
order in the motion 2or e/"edited relie2 2olloDing legal lot coBerage utilit! shut o22. 72 !ou the. ?ust 5e "re"ared
to "roBide testimonial documentar! eBidence the court Dhich torture "osition i2 he 2ailed to a""ear Garmic
renoBation Dould 2orm a dismiss case. ;ith Dhat the notice does not sa! is that the hearing Dill address the motion
to set aside eBiction order Coughlin 2iled on 9ul! 04, 0,(0 and that Dhich and 2or Dhich noD he request the court to
rule in his 2aBor or at least "roBide hearing or at the Ber! and 2or or at the Ber! least require NorthDind and3or
their quali2ied attorne!s or DhoeBer to 2ile an o""osition something under o2 e/"laining Dh! their are three
se"arate notices 2or her three se"arate "rocess a22idaBits o2 serBice 2or the 9une (4, 0,(0 "ersonal serBice o2 a
2iBe6da! unlaD2ul detainer a22idaBit 5! )o5ert )a! o2 NeBada court serBices thatFs right thereFs three se"arate ones
and CoughlinFs "ossession noD and the! 5ear di22erent things as Dell isnFt that interesting hal2 add to that the
2act that NeBada court serBices agreed Dith CoughlinFs assessment that its original on 9une (4 notice o2 unlaD2ul
detainer 2ailure to Bacate "remises Das ine22ectiBe and that it listed the Drong 2orum is or court 2or the tenant to
2ile a tenant at search engines a22idaBit as required 5! laD under 4,.0+3 thatFs not something the Hudge "iercing
can e/cised 2rom the laD or legislate 2rom the 5ench out o2 e/istence that is a laD. -he )eno Hustice court does not
haBe Hurisdiction Dith the notice last 4"arGs Hustice court the 2ugitiBe document 2or the landlord to 2ile it
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landlordFs a22idaBit and then to manage to get Coughlin arrested 5ased u"on a Boid order that should neBer issued
Hudge 4hrader "articularl! Dhere su"erBisor o2 the s!lla5le diBision Aaren 4tancil Das alerted and Dell in adBance
5! Coughlin through "hone calls and mid69une in that 9une 0' o2 Dritten corres"ondence to the court that included in
the 2ile on the le2t side o2 the corres"ondence and Dhere the 4"arGs Hustice court itsel2 2a/ the )eno Hustice court
that a 2a/ alerting it to the "ro5lematic as"ects o2 the 9une (4 notice Coughlin Das arrested he Dent to Hail he
"aid 5ail he did time incurred massiBe damages itFs a""alling 2or Hudge "iercing to ignore all this Dhile also
sanctioning the unauthoriPed "ractice o2 laD 5! 9e22 Chandler NeBada court serBices Dho dress u" liGe the! are
4heri22Fs and managed to the Dord court into their name and 5ang on "eo"le store and leaBe o22 the NeBada "art so
much so that it and it seems as though the! are actuall! acting Dith color o2 laD in the screening !ou to come out
o2 !our house and 5ang on the door "arted sounds liGe the! are cost o2 the 4heri22 and haBe to do e/actl! Dhat !ou
said. -hose 2eD Dho donFt NeBada court serBices has something u" their sleeBe in the 2orm o2 attem"ting to 5reaG and
enter and oneFs residence or se/ serBice o2 "rocess 5! as NeBada court serBices has done to Coughlin on numerous
occasions sometimes ca"tured on Bideota"e 2urther NeBada court serBices is tres"assed on numerous occasions liGe
o22ice "ro"ert! Coughlin hoDeBer is the onl! one DhoFs arrested and conBicted tres"assing and had re"orted rehashes
"atent trademarG o22ice and had im"act his a5ilit! to "ractice his chosen "ro2ession 2or Dhich he has to does haBe a
laD license and actuall! did that a lot 2our. .urther thereFs initial con2lict in the Hudge "iercing DorG to the
district attorne!s o22ice 2irst (0 !ears o2 his career and the ;ashoe Count! 4heri22 and "otentiall! ;ashoe Count!
District <ttorne!Fs %22ice ma! haBe it engages the misconduct in connection Dith the a""ro/imatel! (, di22erent
incarcerations Coughlin s"ace this !ear most all connected one Dhere another -o the ;a!, )eno Hustice court handles
landlord6tenant matters or 2ails to a""l! the laD as Dritten and created 5! the assem5l! the 4enate i.e. the
legislature NeBada and Carson Cit! to 5e clear NeBada court serBices recogniPe the Balidit! o2 CoughlinFs argument
that Dhen he announced to them on 9une 0* at a""ro/imatel! (, <? to (,:4+ <? is Dhere Coughlin "ointed out that
the
the 9une (4 notice listed 4"arGs Hustice court that NeBada court serBices res"onded 5! serBing in the amended
declaration o2 serBice 5! license "rocess serBer on 9une 0* there5! Bitiate in an! order locGout order rescinding
and DaBing it etc. etc. 9une 0*, 0,(0 2a/ 2rom the 4"arGs Hustice court to the )eno Hustice court contains a 2a/
Coughlin sent the 4"arGs Hustice court on 9une 0' that at (0 $? noon o2 that date that 2action Coughlin Das (, "ages
the 2acts 2rom the 4"arGs Hustice court the )eno Hustice court Das a""arentl! (3 "ages no num5er o2 those "ages are
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not included in the 2ile o2 this matter and the )eno Hustice court 5acG to the three di22erent notices o2 unlaD2ul
detainer either stam"ed 5! D Dhich doesnFt count 5! the Da! one needs to sign something attorne!s donFt get a stam"
things and 2ile them and then later on claim the! didnFt commit commit misconduct or her "erHur! or rule ((
Biolation merel! 5ecause it is sign something NeBada court serBices continues to Hust "ut stam"s instead o2 actual
signatures and thatFs an a""ro"riate and under the <iGen case is in NeBada and summar! o2 "roceedings the technical
as"ects o2 notice and due "rocess requirements must 5e strictl! adhered to not run out Dith the 5athDater 5! Hudge
$earson 5ecause he either doesnFt liGe o226line or thinGs Coughlin doesnFt deserBe due "rocess o2 the laD article
"rotection 5ecause CoughlinFs an attorne! !ou GnoD CoughlinFs not a license attorne! currentl! needs not a5le to
maGe attorne! mone! or do attorne! things or eBen commit the unauthoriPed "ractice o2 laD Dith im"unit! liGe NeBada
court serBices 5ecause GnoD Coughlin !ou GnoD o2 Coughlin Das to do so the 4tate Bar Dould 2ind it to 5e a contem"t.
.urther Hudge $earsonFs order 2or summar! eBiction o2 9ul! 3( is Boid in seBeral res"ects one it "ur"orts rule one
units 097( Dhen unit 7( is not "ro"erl! 5e2ore the court unit 7( has its oDn case num5ers o2 reB0,(06,,'7 and
reB0,(06,,(,*0 the multi"lict! is due to, as here, -8E )9C shortcutting due "rocess as"ects o2 the "rocess,
Dhererin I%rdersI 5! 9udges "aid quite a 5it o2 mone! are nothing more than handDritten notes on CoughlinFs oDn
2ilings...4ome o2 those such Inote %)dersI 5! 9udge 4chroeder resulte in con2using Bis a Bis Dhether CoguhlinFs
7.$Fs Dere granted, and necessitated the 2iling o2 com"anion cases 2or units 4+ and 7( in reB0,(06,,'7 and reB0,(6
,,'* in reB0,(06,,(,*0 and reB0,(06,,(*3. -o sim"l! maGe Coughlin sca"egoated all medicine 5lame him 2or taGing
o2
regardless the 9ul! 3( order 5! Hudge $earson in reB 0,(0 Y ,, (,4* "ur"orts rule on matters not noticed in the 9ul!
04 notice s"eci2icall! in that order Dhich reads the court 2inds eBiction Das a""ro"riate motion to sta! eBiction
order denied motion to set aside eBiction order denies motion to contest "ersonal "ro"ert! lien denied motion on
illegal locGout denied tenant haBe alDa!s "ro"ert! remoBed is 097( 5! + $? on <ugust +, 0,(0 onl! a5out hal2 o2 that
order Das "ro"erl! 5e2ore the court notice litigants that 7Fm Dhat Das notice to the litigants in the 9ul! 04 notice
Das that the hearing Dould 5e limited to the motion to sta! eBiction order in a motion 2or e/"edited relie2
2olloDing illegal locGout utilit! shuto22 hoDeBer the order Dent on to rule on matters non6there and noticed
including the motion to set aside the eBiction order the motion to contest "ersonal "ro"ert! lien and that matters
related to the "ro"ert! o2 a unit not eBen inBolBed in a case num5er unit 7( 2urther there required Coughlin a hu5
<llis "ro"ert! remoBed eBen earlier than the laD requires giBen that a2ter the 3, da! "lan under N)4 ((* <.4', the
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landlord ma! not dis"ose o2 the "ro"ert! until (4 da!s o2 "ass 2rom mailing to the tenant last GnoDn address a
certi2ied letter. 4o there and again Hudge $earson is Biolating the laD in 2ailing to a""l! eBenl! to Coughlin in
2act heFs attem"ting to e/Cise "rotections accorded and Coughlin under NeBadaFs landlord tenant laD Dhich is the
most "ro6landlord laD set o2 laDs in the countr! 5ut thatFs not good enough 2or Hudge "iercing he Dants to cut eBen
more "rotections out o2 it Dhen it comes to Coughlin and the reasoning 5ehind that is not clear though Coughlin has
had some issues Dith ;ashoe Count! District <ttorne!Fs %22ice this !ear in Hudge $earson did s"end the 2irst (0
!ears o2 his career there.
<ttached in e/hi5it a are the three di22erent 9une (4 declarations o2 serBice 5! license "rocess serBer )o5ert or )!anJ#
;ra! ..-hatFs right, Coughlin has in his "ossession three di22erent N%tice o2 :D dated '3(43(0 and either Istam"edI Dith
I). ;a!I or actuall! containing a handDritten signature 5! ). ;ra! though the one actuall! signed lacGs a time
indication, and the! all lacG a Imanner o2 serBiceI or an! other "articular 5e!ond 2alsel! attesting to haBe 5een
I"ersonall! serBedI. ;)a! and N%)thDinds manager attem"ted to 5reaG and enter into unit 09 in ho"es o2 e22ecting
I"ersonal serBiceI u"on Coughlin in a unit that had not DindoDs and that had the door closed and locGed and or 5arred.
-hat is a criminal act and Coughlin is noD again here5! com"laining a5out it to the landlrod, so haBe 2un reading N)4
((*<.+(,Fs and N)4 ((*<.39, and 7Fll see !ou in Court, and ;)a!, !ou should "ro5a5l! sel2 re"ort to the "rocess serBer
licensing 5od! and ho"e 2or the 5est. ChecG out the Bideo 2o the '30*3(0 arrest Dherein the ;C4%Fs >omeP and ?achen
tell Chandler to Ilet us do the talGing, 9e22I, then Chandler, dressed u" in an out2it and Dith a com"an! name intended to
connote color o2 laD t!"e authorit!, "ur"orts to tres"ass Coughlin 2rom the Dhole "lace, ie, the entire "remises at ('*,
4G! ?ountain Dr., de"sit Coughlin still haBing, at the time, one, and "erha"s tDo Balid leases, to units 4+ and 7(.
.urther, the ;ashoe Count! Detention Center or Hail tooG a tenanFts a22idaBit 2rom Coughlin on or aoround 9ul! (+th,
0,(0 2or units 4+ and another 2or unit 7( and due to CoughlinFs indigenc!, the Hail li5rar! indicate it Dould 5e 2iled Dith
the rHc....;<s itJ
he Court Dith Hurisdiction. N)4 4,.0+33#a#. %Ne cannot 5e tres"assing in a "lacDe Dhere the!
haBe a Balid reason 2or 5eing or a laD2ul right to 5e. N)4 0,7.0,,, )?C *.(,.,4,.
Aikins v. Andrews, 9( NeB. 74', +40 $.0d 734 (97+#, the 4u"reme C%:li construed the
"redecessor statute to N)4 4,.0+(' to mean that the alternatiBe 2iBe +# da! notice must 5e giBen
'
5e2ore the tenants can 5e dis"ossed and a lease can 5e Balidl! terminated. -he court stated that this
2iBe +# da! notice requirement I ... neither can 5e DaBed nor neglected.I 9( NeB. at 74*.
tt":33DDD.constitution.org3ussc3+,'6,+'a.htm

:.4. 4u"reme Court
4%CD<C B. C%%A C%:N-=, +,' :.4. +' (990#
E07 U6S6 E7 4%CD<C, E- :&. B. C%%A C%:N-=, 7CC7N%74 E- <C.
CE)-7%)<)7 -% -8E :N7-ED 4-<-E4 C%:)- %. <$$E<C4 .%) -8E
4EVEN-8 C7)C:7-
No. 9(6'+('
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CONCLUSION
-he undersigned here5! request this Court consider these materials "resented herein in
deciding u"on this matter.
AFFIRMATION AND DECLARATION
I $"/!#r", *r-*#&' 'o NRS E2605E, *&$"r "&#!'. o0 "rB*r. *&$"r '(" !#1- o0 '(" S'#'"
o0 N")#$# '(#' '(" 0or",o%&, %- 'r*" #&$ /orr"/' #&$ '(#' '(%- $o/*+"&' $o"- &o' /o&'#%& #&.
-o/%#! -"/*r%'. &*+3"r-, *r-*#&' 'o NRS 22;B6020, #& #00%r+#'%o& 'o '(#' "00"/' '(%- ("r"3. %-6
D<-ED this 9th o2 %cto5er, 0,(0:
Z3s3 Zach Coughlin
Zach Coughlin,
"ro se tenant
- 30/34 -
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$)%%. %. 4E)V7CE
%n this date, 7 caused a co"! o2 the 2oregoing document s to 5e serBed u"on the 2olloDing 5!
2a/ing and emailing to those Dho haBe consented to such serBice and or 5! hand deliBer! to dro"slot
or 2ront desG, and 5! "lacing a true and correct co"! o2 the 2oregoing document in the :.4. mail
addressed to:
N%)-8;7ND <$<)-?EN-
<44%C CCC
(,3( &$)E44
N%)-8;7ND CCC
((, ((,-8 <VE NE 4-E
++,
BECCEV:E, ;< 9*,,4
Descri"tion 4ummar!
74,4,
,43,(3(997 (0:,,:,, <? E/"iration Date: ,43,(30,,0
Business Name: N%)-8;7ND <$<)-?EN-4 %Dners: N%)-8;7ND <$<)-?EN-
<44%C7<-E4, CCC
NeBada Court 4erBices
CeD -aitel, Esq., 4ta22 <ttorne!
9e22 Chandler, %Dner and CE%
)o5ert ;ra!, Cicensed $rocess 4erBer
47+ 4. <rlington <Benue, 4uite (<
)eno, NV *9+,(
77+# 34*67+',
CeDis 4. -aitel, Esq.
<ttorne! at CaD
57E S6 Ar!%&,'o& S*%'" 1A
)eno, NeBada *9+,(
77+# 30060070
F#@4 F77EG 25?<7;77
NeBada 4tate Bar No. 4397
Not sure Dho ?r. -aitel re"resents in this matter, i2 an!one...
CeD -aitel, Esq., 4ta22 <ttorne!
9e22 Chandler, %Dner and CE%
- 31/34 -
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)o5ert ;ra!, Cicensed $rocess 4erBer
57E So6 Ar!%&,'o& S*%'" 1A
)eno, NeBada *9+,(
77+# 34*67+',
-oll .ree# *,,6+7,6++*3
F#@4 F77EG 25?<7;77
Email: neBcs1neBcs.com
J unauthoriPed "ractitioner o2 laD 2or NorthDinds <"artmentsJ
<C>6<?$7, 7N
NorthDinds <"artments
D<-ED this 9th o2 %cto5er, 0,(0:
3s3 Zach Coughlin
Zach Coughlin, "ro se tenant
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inde/ to e/hi5its:
e/hi5it ( ++ "ages
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e/hi5it (
- 34/34 -
One Size Car Garage For Rent
file:///R|/jackieboy/Documents/$75%20garage%20747-9200%201600%20sky%20mountain%20dr..html[10/10/2012 2:50:35 AM]
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$75 One Size Car Garage For Rent (Northwest Reno, NV)
Date: 2012-04-02, 10:02AM PDT
Reply to: see below
[Errors when replying to ads?]
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)
One Size Car Garage For Rent
file:///R|/jackieboy/Documents/$75%20garage%20747-9200%201600%20sky%20mountain%20dr..html[10/10/2012 2:50:35 AM]
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file:///C|/...012%20email%20to%20stuttle@washoecounty.us%20regarding%20ncs%20rev2012-001048%20etc%20ncs.htm[10/10/2012 6:23:17 AM]
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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
From: Zach Coughlin (zachcoughlin@hotmail.com)
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 J ustice 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 J une 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 RJ C, 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 RJ C where the 6/14/12 notice listed
Sparks J ustice 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
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 J akob'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 J une 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
J ustice Court OR EVEN in REno J ustice Court. Coughlin was arrested at 10:30 am
on 6/28/12, thereby, under color of law, the WCSO, NCS and NOrthwind and J akob
fraudulently prevented Coughlin from filing (if he did not already previously,
espeically in the 6/13/12 faxes that are mysteriously unaccounted for in rJ C 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 RJ C 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
J ennifer 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
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
"J ennifer 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 J une 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 J ustice Court to the Reno J ustice Court on J une 28th, 2012 at
11:05 am, (in a 13 page fax, many pages of which are not in the RJ C file, though that
fax does included the header from the fax from Coughlin to the "Sparks J ustice 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 J ustice Couer (according to the fax hearders) while
also being page 12 of teh J une 28th, 2012 fax from the Sparks J ustice court to the
Reno J ustice 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 J une 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
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 J CRCP, nor J CRRT:
RULE 5. SERVICE AND FILING OF PLEADINGS AND OTHER PAPERS
Rule
Drafters Note
Commentary
(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.
(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 J eff 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
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 J une 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 J eff Chandler, whom
crossed the bar and argued before J udge Pearson on J uly 31st, 2011 in REv2012-
001048 on behalf of his "client' Northwind Apartments, Associates LLC (see acg-
ampi.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 J ohn 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 J une 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 J une 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
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 J akob 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
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 J udges 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 J udicial 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
NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and
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.
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 J une 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,
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 RJ C 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?
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 J ustice 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
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 J oel
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 RJ C 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
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 of the county to remove the tenant within 24 hours after receipt of
the order. The way these summary eviction proceedings are being carried out in Reno
J ustice 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 J CRCP to cases like these, NRS 40.400
Rules of practice, holds that :The provisions of NRS, Nevada Rules of Civil
Procedure and Nevada Rules of Appellate Procedure relative to civil actions, appeals
and new trials, so far as they are not inconsistent with the provisions 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 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 J akob 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
RJ C 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
(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
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 RJ C, 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.
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
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]
"NRS 40.253 Unlawful detainer: Supplemental remedy of summary eviction and
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
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.
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.
(7) A statement that the written notice was served on the tenant in accordance with
NRS 40.280.
(8) A copy of the written notice served on the tenant.
(9) A copy of the signed written rental agreement, if any.
(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
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 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.
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)
NRS 40.254 Unlawful detainer: Supplemental remedy of summary eviction and
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.
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 RJ C REV2012-001048 HAS MY 6
PAGE FAX OF J UNE 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.
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
J UDGE CURRENTLY HAS J URISDICTION 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 J une 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 J une 28 Coughlin there
and had five days to file for an eviction summary eviction hearing and he did so on J une 30 just for
the Reno PD managed commit another wrongful arrest of Coughlin further there was County jail failed
to transfer Coughlin for the J uly 5 hearing on Coughlin's motion to set aside the original J une 27 order
however the J une 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 J une 30, 2012, though Karen Stancil appears to have handwritten in the case
number RJ C 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 RJ C CIVIL DIVISION BY COUGHLIN ON OR ABOUT
J UNE 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
RENO RED BOOK
Owner Information
Owner/Corporate Name
J EFFREY 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: J ENNIFER 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 J uly 31,
2012 are not as of the hearing on J uly 21, 2012 stated J uly 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 J uly 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 J une 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 J une 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
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-J une in that J une 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 J une 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 J eff 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
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 J une 28 at approximately 10 AM to 10:45 AM is where Coughlin
pointed out that the
the J une 14 notice listed Sparks justice court that Nevada court services responded by serving in the
amended
declaration of service by license process server on J une 28 thereby vitiate in any order lockout order
rescinding
and waving it etc. etc. J une 28, 2012 fax from the Sparks justice court to the Reno justice court
contains a fax
Coughlin sent the Sparks justice court on J une 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
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 J uly 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 RJ C shortcutting due process aspects of the
process,
whererin "Orders" by J udges paid quite a bit of money are nothing more than handwritten notes on
Coughlin's own
filings...Some of those such "note ORders" by J udge 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 rev2012-
0067 and rev201-
0068 in rev2012-001082 and rev2012-00183. To simply make Coughlin scapegoated all medicine
blame him for taking of
regardless the J uly 31 order by judge Pearson in rev 2012 00 1048 purports rule on matters not
noticed in the J uly
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 J uly
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
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 J une 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, J eff", 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 J uly 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 J AIL AND THE RJ C.
From: zachcoughlin@hotmail.com
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
Fax 949 667 7402
ZachCoughlin@hotmail.com
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
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
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
9/21/12
Reply

Zach Coughlin
To stuttle@washoecounty.us, millero@reno.gov, jmachen@washoecounty.us, brownk@reno.gov, renodire
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
J uly 29th, 2012"...giving me five days to get my stuff out of unit 29 (the one the subject of J udge
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"
Hotmail Active View
2 attachments (total 1164.6 KB)
coughlin ...pdf
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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 J ustice Court on Greenbrae" as the place for the tenant to file a Tenan'ts Answer
or Affidavit. Doing so will make the RJ C Order by J udge Schroeder null and void (Karen Stancil,
Chief Civil Clerk at RJ C admits this, but really, the fault lies with NCS and Northwind, not the
committed professional at the RJ C).
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

10 10 12 0204 067980 1048 Coughlin V Northwinds Ncs RPD Wcso RJC RMC Superior

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