12 13 12 0204 607 599 Email To WCDA Leslie, Panel, Bar and Others BW

3/4/13 Outlook Print Message
https://bay002.mail.live.com/mail/PrintMessages.aspx?cpids=0ac402a4-0dbb-4e2b-a40d-54370c003a8e,m&isSafe=false&FolderID=66666666-6666-6666-6666 1/36
The Three E's; wcpd failure to provide essential 911 call cd discovery of
8/13 and 8/17, 2012 to Coughlin in rcr2012-065630
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 12/13/12 9:34 AM
To: jleslie@washoecounty.us (jleslie@washoecounty.us); jbosler@washoecounty.us (jbosler@washoecounty.us);
bdogan@washoecounty.us (bdogan@washoecounty.us); jgoodnight@washoecounty.us
(jgoodnight@washoecounty.us); cfortier@washoecounty.us (cfortier@washoecounty.us);
stuttle@washoecounty.us (stuttle@washoecounty.us); mkandaras@da.washoecounty.us
(mkandaras@da.washoecounty.us); zyoung@da.washoecounty.us (zyoung@da.washoecounty.us);
skauc@reno.gov (skauc@reno.gov); wongd@reno.gov (wongd@reno.gov); kadlicj@reno.gov
(kadlicj@reno.gov); complaints@nvbar.org (complaints@nvbar.org); cvellis@bhfs.com (cvellis@bhfs.com);
je@eloreno.com (je@eloreno.com); patrickk@nvbar.org (patrickk@nvbar.org); davidc@nvbar.org
(davidc@nvbar.org); rosec@nvbar.org (rosec@nvbar.org); laurap@nvbar.org (laurap@nvbar.org);
skent@skentlaw.com (skent@skentlaw.com); mike@tahoelawyer.com (mike@tahoelawyer.com);
eifert.nta@att.net (eifert.nta@att.net); nevtelassn@sbcglobal.net (nevtelassn@sbcglobal.net);
fflaherty@dlpfd.com (fflaherty@dlpfd.com); fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com)
28 attachments
12 7 12 declaration of zach coughlin 0204.pdf (81.2 KB) , 2 6 12 email from Fortier regarding Dogan
065630.pdf (30.3 KB) , 10 11 12 email fw misue of 911 case 065630 fortier et al.htm (347.1 KB) ,
transparent nevada Veronica Lopez Marcia Lopez 26405 22176 00696 065630 0204.pdf (104.2 KB) , 1 12
12 rpd police report 12 cr 00696 sifre leedy look nash young kandaras bradshaw 0204 065630 redacted
ocrd.pdf (3.2 MB) , Beckett_RI20110404 0204 065630.pdf (117.7 KB) , Beckett and Tanner examples
special treatement for prosecutor and tanner petty theft involve s16K 0204
Bar_Counsel_Report__June_2011.pdf (284.4 KB) , 11 22 12 26405 Motion for Continuance because Hill
on vacation Hazlett Declaration 0204 065630.pdf (407.6 KB) , 12 6 12 not authorized by Clifton Custodian
of Records WCPD 065630.pdf (1791.3 KB) , coughlin nsct docket search as of 12 7 12 0204 065630.pdf
(48.6 KB) , 8 20 11 unredacted dispatch logs 063341 back from tiff.jpg.pdf (229.0 KB) , 9 7 12 063341
Order For Competency Evaluation 0204 065630 12420.pdf (1573.5 KB) , 12 19 11 063341
GOODNIGHT'S REQUEST FOR DISCOVERY 0204 065630.pdf (2.4 MB) , nsct docket 54844 coughlin v
dist ct joshi 01168 0204 26405 61901.pdf (33.5 KB) , 11 27 12 065630 fax cover page post it clifton 11 28
12 don't file this in stays w case file however 1 of 69 pages.pdf (265.7 KB) , 12 6 12 26405 Notice of
Deficiency of Record on Appeal and Filing of Judicial Discipline Commission Complaint 0204 - Copy.pdf
(777.9 KB) , 12 6 12 stamped 065630 emergency Motion for Mistrial and Continuance Given state's failure
timely provide discovery exculpatory - Copy.pdf (765.2 KB) , 12 4 12 Affidavit of Service RJC Bailiff
John Reyes lacks a lack number, lacks a notary 065630 063341 067980 has no Order attached to it or
incorporated by reference.pdf (492.2 KB) , paes 1 to 17 from first fax judicial discipline commission
complaints 0204 gardner elliot howard nash holmes sferrazza clifton final-2-2.pdf (596.6 KB) , Paul-D-
Elcano-Jr--1070555-a stanford 0204 elliot echeverria.pdf (67.3 KB) , 01955 docket coughlin elliot gardner
elcano.pdf (152.4 KB) , cr12-0376 coughlin judge steven elliot 0204 docket ccwashoe.pdf (23.9 KB) ,
cr11-2064 docket coughlin v city of reno judge elliot city attorney roberts 0204.pdf (42.7 KB) , paul elcano
suing rutherform chiropractice and dr ross and nichols 0204 60317.pdf (18.7 KB) , 2 3 12 22176 60838
0204 roberts Gmail - courtesy copy of audio of trail exhibit 1 to Supplement to Opposition to Motion to
Dismiss.pdf (16.8 KB) , 11 10 12 063341 nrs 174.345 sbupoena on Duralde Rosa Alaksa and others rrr
certified 1045 skau 0204.pdf (10.5 KB) , 11 26 12 5 big recent emails 60302 60317 Garin WLS Gardner
0204 60331 61383 063341 etc.pdf (645.8 KB) , 54844 COUGHLIN VS. DIST. CT. and Linda Gardner
0204 0435 26405.pdf (5.1 MB)
The Trial yesterday in RCR2012-065630 featured extended discussions regarding the failure of the WCPD,
Dogan, and Leslie, to turn over discovery propounded by DDA Young in the form of cd's featuring 911 calls
DDA Young provided to the WCPD on 8/13/12 and 8/17/12... And the heavy hitters were there, too (Elliot
Sattler).....despite numerous written requests from Coughlin that the WCPD do so, and multiple trips to the
WCPD personally by Coughlin to pick such materials up, and despite more flip flopping on their story by Leslie
and Dogan regarding whether they ever gave Coughlin some package of materials responsive to Coughlin's
request for his "file"...But, Jim Leslie is stuck with the 7/27/12 date he mentions in his email, then he is stuck
with what his recent email wherein he purports to have therein digitally transmitted Coughlin his "file", which
obviously does not include the cd's of 911 calls (the one's DDA Young took up an enormous amount of court
time playing, over and over (well, Young only played over and over the particular calls he felt were strongest for
his case and most prejudicial, claiming some "cutting room floor mishap" for the reoccurrence of certain calls,
arguing that such a "happy accident" justified playing them again and again, at ever increasing volumes, etc., etc.).
Apparently, I am here to subsidize Young's baby making, just like I was with Ms. Gorman, as a continuance of
prejudicial length of afforded to the State where none was forthcoming to Coughlin, despite Leslie and Dogan's
obstructionist tantrums, ones of a quality that would. I remember when my life featured happy moments like the
birth of twins...but that was before your leviathan legal system wrecked shop on my existence. What, sir, shall be
my compensation? Do you mind if I put my arm around....http://tinyurl.com/bgmlfdr
This is a formal grievance against Dogan, Leslie, Bosler, Young...etc.
If Svengali/Diann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases, and gag order them, he
better be sure not to screw up the cases requiring a mistrial by failing to provide the client the cd's of 911 calls DDA Young
gave the wcpd on 8/13 and 8/17/12 in rjc rev2011-065630, and clearly, any packet from 7/27/12 wouldn't have them (not
to even get into the flip flopping contradictory accounts by Leslie and Dogan as to who gave Coughlin the packet, or who
didn't or blah blah blah)...and certainly Leslie email below only contained a 57 page pdf...way to close to the 12/11/12 trial
date, and containing materials Coughlin had never been given before....so much easier, Jimmy Sleazy to email the client a
"digital transmittal" proving what you gave and when"....but, no, that would make it so hard to fudge the accounts of what
was contained therein, or who handed what to whom, or who failed to pick up this or that, or Dogan's slippery nonsense:
"From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
CC: BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:

Attached are the discovery materials in the above-referenced case that you had requested and we had made an additional copy of for you in response to
your request. Please note that the July 27, 2012, cover letter was for your pick up and you never picked it up. Note also that the July 27, 2012, packet
encloses a copy of the April 17, 2012, hand delivery transmittal of the very same documents which you received.

Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front desk. Since you failed to
retrieve them, we provide the attached courtesy copy before final closure of our file.

No response to this transmittal is required from you.

James B. Lesl i e, Esq."
So, while Dogan states on 7/27/12 in 65630 "Your Honor, I have never even spoken with Judge Dorothy Nash
Holmes"...he coyly fails to indicate whether he spoke with anyone with the RMC, Marilyn Tognoni, included, or
why his 2/28/12 fax to Coughlin was so insistent that it was "Lake's Crossing's Bill Davis, Ph.D." who must
conduct the "Competency Evaluation", or how it was Judge Clifton's 2/27/12 Order for Competency Evaluation
could have possibly known and included Judge Elliott as the "randomly assigned judge" to that Competency Case
in CR12-0376 (Judge Elliott on Committee to Aid Abused Women's Board, (CAAW)...Judge Elliott presiding
over Coughlin's wrongful termination lawsuit against WCDA's Office ECR Partner, Washoe Legal Services, its
Executive Director Paul Elcano, and CAAW, in CV11-01955...Judge Elliott fails to disclose conflict or recuse
himself, Judge Elliott manages to "randomly" be assigned Coughlin's two criminal appeals from RMC
convictions (the Wal-Mart "candy bar" petty larceny leading to a 6 months, so far, temporary suspension of
Coughlin's law license in 11 cr 22176 in the RMC, then cr11-2064 in the appeal Judge Elliott canned based upon
a civil statute requiring a down payment for the preparation of transcripts and Elliott's contention that he need not
address the merits of Coughlin's appeal given the lack of a written transcript (Coughlin paid for the audio cd, and
its not even clear that the RMC is a court of record anyways, and the RMC distributes to defendants instructions
sheets and enforces "house rules" regarding the preparation of transcripts that require one utilizing the services of
RMC "official transcriptionist Pam Longoni (whom hung up on Coughlin twice, and refused to prepare the
transcript in 11 cr 22176/cr11-2064, failed to return emails/faxes, etc.)" and where the RMC refused to even give
Coughlin the audio recording for some time, insisting Coughlin could merely have it made available to
Longoni....Oh, Coughlin didn't get no continuance from Judge Howard in that 11 cr 22176 (even where he was
wrongfully evicted in Rev2011-001708 (now on appeal in 60331 and 61383) on 11/1/11, then wrongfully
arrested on 11/13/12 in 11 cr 26405 (now feature in 61901, 62104, 54844, 60302, 60317, etc..) and
incarcerated between 11/13/12 and 11/15/12, no continuance for the 11/30/12 Trial in 11 cr 22176, despite an
agreement in writing with City Attorney Pamela Roberts (whom put on perjured testimony by three witnesses
where she possess a video and other evidence conclusively proving that Coughlin did provide his driver's license
to RSIC Officer Crawford...and where Robert's prosecuted based on an arrest for a misdemeanor by tribal officers
where NRS 178.1255 bars such an arrest, and where Wal-Mart's Thomas Frontino and Roberts herself admit no
citizen's arrest was effectuated....so, about that RPC 3.8 violation...). Then there is the appeal in cr12-1262 that
Judge Elliott, again, was "randomly" assigned from the conviction by RMC Judge William Gardner in 11 cr
26405 based upon the criminal trespass complaint signed by Richard G. Hill, Esq. (opposing counsel in the
summary eviction from Coughlin's former home law office in rjc rev2011-001708, presided over by Judge
Sferrazza, though Hill and his associate Casey D. Baker, Esq. fax, on October 17th, 2011 to Judge Clifton (who
was not Chief Judge at the time, or anything) an Emergency Ex Parte Motion for Inspection of Coughlin's Law
Office, and where in his October 19th, 2011 Order in that matter 001708, Judge Clifton ruled as "moot"
Coughlin' 11/17/12 Motion to Set Aside the 11/13/12 Order following Summary Eviction Proceeding by Judge
Sferrazza setting the matter for "Trial" on 10/25/12, on the condition that Coughlin deposit a rent escrow of
$2,275 with the RJC (though Judge Sferrazza admitted later on the record on 11/7/12 that the RJC Judges had a
meeting wherein they all had to agree that Coughlin was absolutely correct that the RJC was violating Nevada
law in having an unpublished "house rule" corollary to JCRLV 44 requiring such rent escrow deposits in landlord
tenants matter here JCRCP 83 had not been followed in that the RJC had not published and had approved by the
N. S. Ct. any such deviation from the statutory remedies set forth in NRS 40 and 118A. Judge Elliott managed to
torpedo that appeal of the criminal trespass conviction stemming from the criminal complaint and custodial arrest
at Coughlin's former home law office by co-signing RMC Judicial Assistant Lisa Wagner's and the RMC's
nonsense about not having received Coughlin's Notice of Appeal timely under NRS 189.010. The proof of
delivery fax confirmation indicates otherwise, Lisa. And regardless. the conveniently timed arrest of Coughlin
on 6/28/12, and the tolling nature of Coughlin's 6/26/12 Motion for New Trial in that matter, and the kited, dated
7/10/12 jailhouse Notice of Appeal by Coughlin, and the curiously failure to grant Coughlin tier time in the
interim while Judge Gardner manageed to push through his 7/11/12 Order Denying Coughlin's Motion for New
Trial, is all the more reason to apply consternation to Judge Elliott's work on the appeal on CR12-01262.. Then
there is Judge Linda Gardner being Judge Peter Breen, MD's law clerk, and Breen kicking Coughlin out of the
Mental Health Court based upon Sharon Dollarhid, Rene Biondo, and Breen and the MHC's own breach of
contract (if they provide program materials, acceptance, and a contract that list certain medications as disallowed,
how is it they can claim non-compliance or "failure to abide" by the rules for taking a medication not listed
therein? Don't ask WCPD Joe Goodnight or Jennifer Rains...they know what side their bread is buttered
on....MH12-0032...so DDA Young tries to jam through a trial in 063341 on May 7th, 2012, despite the
mandatory stay in NRS 178.405 and the then still pending Order for Competency Evaluation in rjc 2012-065630
from the clandestine status conference Dogan and Young never quite seem to refute happening on 2/27/12...Oh,
and Judge Clifton, then DA Dorothy Nash Holmes, and Judge Linda Gardner were all co-workers once upon a
time, working closely with then Sparks City Attorney/prosecutor Steven Elliott, whom worked for the law firm of
the father of the Panel Chair for Coughlin's 11/14/12 SBN v. Coughlin formal Disciplinary Hearing in NG12-
0204, 0434, 0435 (the last two being grievances against Coughlin filed, in part, by RMC Judge William Gardner,
prior to Gardner failing to recuse himself from the criminal trespass case against Coughlin before him in 11 CR
26405...even where Judge Gardner's sister Judge Linda Gardner's April 2009 Order sanctioning Coughlin was
cited by WLS's Elcano as the sole basis for firing Coughlin, and where Coughlin filed a Mandamus Petition in
54844 challenging those sanctions, and where ng12-0435 was one of three grievances forming the 8/23/12 SCR
105 Complaint against Coughlin (strangely...the Wal-Mar "candy bar" petty larceny conviction and the formal
hearing for the "sole purpose" of determining Coughlin's punishment for such required by SCR 111(8) and the
Court's 6/7/12 Order got particularly short shrift in the 8/23/12 triple grievance numbered SCR 105 Complaint
by Bar Counsel Pat "Patty Ice" King, a/k/a Pat Salieri, whom wants no part of explaining his statements to
Coughlin during the 3/26/12 appearance at the SBN by Coughlin, for the sole purpose of taking King up on his
offer to let Coughlin review the materials submitted along with the grievances (therein King claimed to have
received grievances against Coughlin from three different Judges....though, by 3/26/12, it couldn't have been
Beesley, as Coughlin only filed the exhibits detailing Judge Nash Holmes and the WCSO and WCDA
impermissibly confiscating Coughlin's smart phone without a warrant or court order and well after the end of the
period to do a search incident to arrest (the arrest was 2/27/12 for some pastiche of summary plenary civil
criminal contempts statuts that Judge Nash Holmes whipped up...though she avoid NRS 22.030 and definitely
there wasn't no affidavit signin' by ol' RMC Marshal Harley for alleged conduct in a restroom or restroom stall,
which assuredly was not "under the watchful eye of the court" or "in the immediate presence" of the court....so
much easier for Bar Counsel to feed Judge Nash Holmes the "clear and convicing evidence" standard from
Schaefer required to prove an ethical violation, have here copy and paste some RPC's into a second bite at the
apple and more than 10 days later (civil statute, NRS 22.010, NRCP and JCRCP 59 allow sua sponte amending
within 10 days, no 12 days...2/27/12 to 3/12/12....void Order of 3/12/12 by Judge Nash Holmes, so, sorry Patty
Ice, nice try, no SCR 111(5) "an Order or conviction is conclusive proof of guilt and I don't recognize
Claiborne as binding authority because it makes my job harder...."....
Thank You Jim for continuing to prevaricate in writing, your recent email combined with some, uh, other
materials that have been culled, will surely be helpful in exposing you for the fraud that you are. And Biray
Dogan too...Oh, by the way, that 11/7/12 fax confirmation page or proof of faxing? How is that coming along,
because I need to see it from you. My records show absolutely no receipt of any fax of that sort, not on that day,
not on any day...which means the ball is in your court to show how Dogan's representations to Judge Sferrazza on
11/19/12 in court were not displaying a lack of candor to the tribunal and How Leslie Tibbals' certificate on
service therein is not fraud.
Oh, attached is Goodnight's 12 19 11 Request for Discovery, which includes:
"REQUEST FOR DISCOVERY
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph
W. Goodnight, Deputy Public Defender, and hereby requests the following discovery pursuant to NRS 174.235
to NRS 174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or
confessions made by the Defendant or any witness, or copies thereof, within the possession, custody or control of
the State, the existence of which is known or by the exercise of due diligence may become known to the
prosecutor. NRS 174.235(1)(a). This request includes any video and audio recordings, including those preserved
on pocket recording devices, 9-1-1 emergency calls, and any dispatch logs, written or recorded, generated in
connection with this case."
Jim, then there is you chiming in, in your role as "standby counsel", attempting to aid the Court and DDA Young
in coercing from me my Fifth Amendment rights at the 9:06 am mark on the transcript from 11/20/12 ("Your
Honor, I'll remind the Court that I am here to jump in in my role as standby counsel anytime the Court's feels he
is dragging his feet....He is wasting County assets!"...very Atticus Finch, Jim).
So, then there is Jim's 10/3/12 subpoena to Ecomm/Kelley Wood...and given he was counsel of record until
10/22/12, yet completely failed to turn over anything (responsive or not) in relation to that subpoena, and the fact
that the entire Suppression Motion turned on "what information the RPD received from dispatch", and the fact
that the audio of the "radio traffic" between the RPD and Dispatch on that night (or at least the portions of it I
have been able to extract from the powers that be) reveal, one, no report of a possible fight was received by RPD
(they were on the scene by the time the 11:27:11 pm text was sent to the displays in their vehicles, and the one
audible "radio traffic" recording contains no mention of anything beyond "check for possible larceny of a cell
phone that just occurred, suspect still on the scene, also reports of a loud verbal disturbance...". Then there is Jim
and Goodnight completely whiffing on the detaining argument, in addition to the whole "assuming we win on the
pat down, make sure to oppose the notation that there was sufficient probable cause for an arrest and search
incident thereto....", not to mention that it was Coughlin (whose filings Jim managed to cheerfully announce "The
Public Defender's Office is not joining in on those fugitive documents...", despite the 2/21/12 Filings by
Goodnight that do just that....) that pointed out the whole NRS 171.360 basis for throwing out the search (which
Jim managed to not cite to or quote from in his closing argument as the Suppression Hearing...where Jim did
manage to ask Cory Goble questions on cross that were designed to do nothing more than establish a citizen's
arrest sufficient to rebut the NRS 171.360 basis for throwing out the arrest and fruits culled therefrom...).
Oh, then there is your office blacking out the numbers of the callers on the dispatch logs and refusing to turn over
even a redacted version of the alleged victim's call records for the time in question, thereby completely
obstructing the defendant's ability to impeach the various lies testified to by all the witnesses. And "Coach" DDA
Young can tell you all about his 40 minutes coaching sessions visible through the plexiglass in the Justice Court
lobby with Zarate, Goble, Lichty, and Templeton, and their constant parroting (along with RPD Duralde) of
"prosecutor buzzwords" ("willfully withheld", "report from dispatch of a possible fight", "my training and
experience", "detained", "I don't remember who made the call", "I can't remember which one of my friends it was
who was with me", etc., etc.) Also, the WCPD practice of blacking out locations and addresses sure makes it
difficult to establish inconsistencies between testimony and the reports/Witness Statements or otherwise utilize
them for impeachment purposes.
So, now today, we get this Jim Leslie email with all it's revisionist history...which only contradicts the position
Leslie and Dogan have taken that Coughlin already picked up this 7/27/12 packet (at first Dogan claimed to have
personally handed it to Coughlin, then changed his story 2 minutes later and said he saw Leslie personally hand it
to Coughlin....and Dogan asserts to the Court at the 11/27/12 Hearing in rcr2012-065630 that he has never
spoken with Judge Dorothy Nash Holmes (see materials regarding clandestine status conference of 2/27/12 and
subsequent fallout with Judge Nash Holmes of 2/27/12 a couple hours after Dogan secured his 2/27/12 1:31 pm
Order for Competeny Evaluation in 065630 from Judge Clifton).
The SBN v. Coughlin Complaint of 8/23/12 specifically mentions the arrest of 1/14/12 that theis 065630 case is
based on, in addition to the 063341 iPhone arrest, and RJC Judicial Secretary Lori Townsend sent Coughlin's
2/21/12 in 065630 to the SBN, and offered to send Coughlin's 2/15/12 filing in 063341 to the SBN...and Judge
Nash Holme's 3/12/12 Order in 11 TR 26800 mentions Coughlin quoting "rock lyrics" in a filing as a basis for
her transmogrifying a "simple traffic citation" to a "formal disciplinary hearing on an ethics violation" wherein
she quotes the Schaefer standard for an ethical violation that Bar Counsel had fed her earlier in the day...and that
window between the 1:00 pm noticed start time of the traffic citation trial in 11 tr 26800 and the 3:30 pm
eventual start time includes the 1:25 pm courthouse sanctuary doctrine violating service upon Coughlin (by RMC
Marshal Joel Harley, on behalf of WCSO Deputy Machen, hired by Richard G. Hill, Esq., at whose office
Coughlin was retaliated against by RPD Sargent Tarter with the three traffic citations shortly after Coughlin
reported to Tarter the admissions regarding bribery by Richard G. Hill, Esq. by RPD Officer Chris Carter, Jr....and
Marshal Harley was serving the Order to Show Cause for the 3/23/12 Hearing in the appeal of the summary
eviction from Coughlin's former law office (where RPD Carter made the trespass arrest now detailed in N. S. Ct.
case 61901), on behalf of Deputy Machen, in the conference room within the Courtroom B of the RMC, despite
Coughlin, an efiler, having already been served it). However, the only filing by Coughlin that could be said to
quote "rock lyrics" is the 2/21/12 filing in Dogan's case 065630 (the one where Dogan had appeared as attorney
of record then failed to show up for a hearing on 2/13/12, then retaliated against Coughlin for Coughlin's
2/21/12 filing in 065630 by moving for a Competency Evaluation and basically doing absolutely nothing on the
case for the next 9 months besides raping from Coughlin his medical privacy rights along with Judge Steven
Elliot and DDA Zach Young at the 4/19/12 hearing in CR12-0376 (one of 3 criminal appeals Judge Elliot was
"randomly" assigned in which Coughlin is a party...to go along with the wrongful termination suit by Coughlin
that Judge Elliot presided over in CV11-01955 wherein Coughlin sued CAAW and WLS, despite Judge Elliot
sitting on CAAW's Board, and where Judge Elliot, the Panel Chair at Coughlin's formal disciplinary hearing of
11/14/12, and Washoe Legal Service's Paul Elcano all went to Stanford together, and where Judge Elliot worked
for Panel Chair John Echeverria's father's law firm, Echeverria and Osborne). Then there is Linda Gardner being
Judge Breen's law clerk, and Judge Breen removing Coughlin from Mental Health Court in MH12-0032, where
the MHC's Rene Biondo and Sharon Dollarhide lied about what medications were listed as accepted or not in the
materials provided by Goodnight and or the MHC along with the contract entered into with Coughlin, whom was
accepted into the MHC. Then there is WCPD Joe Goodnight and Jennifer Rains refusal to file anything directed
towards enforcing the MHC's contract with Coughlin, wherein they both demonstrated they know what side their
bread is buttered on and indicated "there just isn't a basis for seeking reconsideration of Judge Breen's Order".
Judge Peter Breen, MD.
Funny how Dogan did not state to Judge Clifton that he never spoke with anyone else at the Reno
Municipal Court about Coughlin....including Marilyn Tognoni...but, rather Dogan just indicated he
never spoke with Judge Nash Holmes, in his best innocent little boy voice that he cops when he isn't
busy tittering away with Jim Leslie in the spectator area during the 11/19 and 11/20 Trial in 063341
(where he failed to apprise Judge Sferrazza of the fraud attendant to his earlier attestations regarding
proof of service (by fax no less) of his 11/7/12 Motion to Quash Coughlin's Subpoena....
Also, its a bit strange how Dogan and the WCPD redact or black out the names of the RPD Officers
and Dispatch Operators beginning on page 16 of the 56 page file Jim Leslie finally emailed me today
titled "Coughlin Discovery 911 Case", which, as is their wont, he and Dogan have continued to
change their stories about whether they had or had not provided to me already until the last possible
minute before trial, whereupon, with a Trial date of December 11th, 2012 in rcr2012-065630, Jim
Leslie finally emails me a 56 page pdf purporting it to be my "file". One wonders where any audio
recordings, dispatch recordings, 911 call recordings or other media are any why Leslie and Dogan did
not provide them. Coughlin appeared at the WCPD's Office today and asked for the hard copy of his
file, yet was told by front desk receptionist "Paula" (of course, no last name provided) that she "spoke
with an associate" and they told her that Jim Leslie had already provided Coughlin his file and that
he, therefore, would not be given the hard copy. "Paula" eventually seemed to have to admit that
the misleading use of the term "associate" actually did not connote her having spoken with an
attorney about the matter...but rather Linda Gray, whom has been curiously silent as to the apparent
misconduct attendant to her admitting that she did not mail out any written notice to Coughlin of
the August 6th, 2012 "combo-hearing" in rcr2012-067980 or rcr2012-065630 (Leslie glossed over that
fact by sending Coughlin a note about how he "saved the day" with his "advocacy"...skipping past the
part about how the client, Coughlin, was not noticed on the hearing in any matter, much less in
writing....Leslie later refused to indicate with any specificity whatsoever how he "knew" Coughlin had
been noticed on the 8/6/12 hearing in writing...and RJC Judges are only too willing to "believe" Jim
Leslie, Esq. when he explains away vaguely such things...
Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have continued in your way
(similar to how you approached the rcr2011-063341 case where Joe Goodnight, Esq. was counsel of
record until you had him removed on 7/16/12, the morning of Trial...after Mr. Goodnight and I have
completed a video conference final trial preparation at 4:30 pm on Friday, July 13th, 2012 while I was
in custody (pursuant to an arrest on July 3rd, 2012, ordered by RPD Sargent Kim Bradshaw, she of the
1/12/12 custodial jaywalking arrest along with RPD Sargent Paul Sifre)....Things fall through the
cracks, Mr. Leslie, when you place a gag order on the associates you claim to supervise, then
stubbornly, petulantly, and retaliatorily refuse to work the cases you have snatched back from your
associates....Similarly, WCPD Fortier's email to me of February 6th, 2012 may have contributed to Mr.
Dogan's confusion in failing to attend the Hearing on Feburary 13th, 2012, which begat my filing of
February 21st, 2012, which begat Mr. Dogan's procurring the February 27th, 2012 Order for
Competency Evaluation, which begat the 5 day summary incarceration for
summary/plenary/criminal/civil/transmogrified disciplinary hearing on an ethics violation/what is
jurisdiction? Order by RMC Judge Nash Holmes on 2/27/12 at 4:40 pm...which begat NG12-0434, and
probably 0435 (the SBN v. Coughlin SCR 105 Complaint of 8/23/12).
However, Mr. Dogan, you are not off the hook just because Jim Leslie places a gag order on you. Mr.
Leslie sent this email today with a 56 page pdf file purporting to be my "file". I, as now a former
client, have rights to "my file". I have requested my file in writing from your office on numerous
occasions, and given your removal as counsel of record on 11/22/12 (amazingly Mr. Dogan probably
managed to say 200 words on a case that he had been counsel of record on for nearly a year, and
had not managed to file a single document in that case, RCR2012-065630, and had managed to get
upset that a client would take issue with his missing the 2/13/12 Hearing, even though WCPD
Fortier's 2/6/12 email makes clear, the matter was assigned to Mr. Dogan at that point, and he had
already sat down and discussed the case with Coughlin for over one hour on or about February 8th,
2012, where Coughlin went to check in with Mary Watson, whom was then represented by WCPD
Branzell, who dragged Watson over to the Sparks Justice Court Bailiff and demanded they
breathalyze her client. They did, she was taken into custody.
So, after sitting down with Dogan for at least an hour and discussing various things, some including
matters related to the case he was then attorney of record on RCR2012-065630, the February 13th,
2012 court date (Dogan and Coughlin have conflicting views as to what was agreed upon and the
applications of NRS 178.388).
NRS 17 8.388 provides that the defendant must be present at arraignment, trial, and sentencing and provides that the defendant may waive his
appearance when certain conditions are met.
Its kind of odd how Judge Clifton (whose attached bio indicates he has deep and longstanding ties to
the domestic violence industry infrastructure) knew instantaneous to signing the Order for
Competency Evaluation of 2/27/12 at 1:31 pm that the matter would be randomly assigned to District
Court Judge Steven Elliot (also a lifelong prosecutor with deep and longstanding ties to the domestic
violence industrial complex, and a member of the Committee to Aid Abused Women's (CAAW, one
of the named defendants in the wrongful termination lawsuit Coughlin brought and over which
Judge Steven Elliot presided in CV11-01955, where he failed to point out his per se conflict of interest
to plaintiff Coughlin at any time, and where he ultimately pulled out just about every wrinkle in the
insufficiency of service and or process and or service of process (a movie showing a non party over
18 years of age serving a senior paralegal at Washoe Legal Services, whose Executive Director Paul
Elcano went to Stanford with Judge Elliot and the Panel Chair of Coughlin's 11/14/12 Formal
Disciplinary Hearing before the State Bar of Nevada, John Echeverria in the late 1960s...and Judge
Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne Board of Directors, in
addition to being a former ass
In CV11-01955, Coughlin sued his former employer Washoe Legal Services, whose Executive Director
Paul Elcano went to Stanford in the late 1960s with Judge Steven Elliot and John Echeverria, the
Panel Chair of Coughlin's 11/14/12 Formal Disciplinary Hearing before the State Bar of Nevada..and
Judge Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne, and Judge Elliot
served on the Board for CAAW, and was a prosecutor as the Sparks City Attorney.
Also, Mr. Leslie, while the 56 page pdf you finally sent me (gosh, was it that hard to click "attach",
load a 2 mb pdf file and hit "send" on an email to me? No debatin', no arguing about whether Leslie
and Dogan left the package at the desk, whether Dogan already gave it to Coughlin, or whether
Dogan then changed his story and said Leslie gave it to Coughlin, whether Coughlin already picked it
up, no claims by Jessica the Receptionist of anyone kickin' furniture...nothing like that, just a digitally
verifiable means of ascertaining what you transmitted and when...was that so hard? Heck, Jim, you
could probably just email those ECOMM recordings too...and if attachment size is an issue, sign up
for a www.outlook.com (the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive
functionality, and up to 100 mb attachments via plan email, and over 25 free gb of storage on the
Skydrive, etc., etc...). But its Leslie finally sent the 56 page "client's file" on or about 12/7/12, yet he
failed to include the insipid Motion of 11/26/12 by DDA Young (wherein, just after Judge Clifton
finishes telling Coughlin at the 11/27/12 Hearing that Coughlin is not allowed to even think about the
other two RJC shotgunnin' style splatter paint prosecutions by DDA Young, as "they are just not
relevant to this proceeding"...and anytime Coughlin would point out specific basis for undertaking a
recusal or conflict analysis vis a vis either Judge Clifton, the RJC, DDA Young, the WCPD, or the
WCDA, Judge Clifton would say "your're losing me...your're losing me..." as if Coughlin was speaking
in tongues all the sudden...
So, while Coughlin is reportedly not even allowed to email DDA Young about cases not even before
Judge Clifton, or something like that...DDA Young is able to get an unnoticed, ex parte, emergency
Motion to Prho
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
CC: BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:

Attached are the discovery materials in the above-referenced case that you had requested and we had made an additional copy of for you in response to
your request. Please note that the July 27, 2012, cover letter was for your pick up and you never picked it up. Note also that the July 27, 2012, packet
encloses a copy of the April 17, 2012, hand delivery transmittal of the very same documents which you received.

Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front desk. Since you failed to
retrieve them, we provide the attached courtesy copy before final closure of our file.

No response to this transmittal is required from you.

James B. Lesl i e, Esq.
Chi ef Deputy Publ i c Defender
Washoe County Publ i c Defenders Offi ce
350 South Center Street
Fi fth Fl oor
Reno, NV 89509
1-800-762-8031
Di rect Di al : 775-337-4828
Fax: 775-337-4856
Emai l : jl esl i e@washoecounty.us

The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL INFORMATION, are legally privileged, and are intended for use and review only by the party sending same
and the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly
prohibited. If you received this communication in error, please immediately notify us at 775-337-4800 to arrange return of the original transmittal. Thank you.

--Forwarded Message Attachment--
Close Print
FW: misue of 911 case
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Thu 10/11/12 2:34 PM
To:
jrains@washoecounty.us; cfortier@washoecounty.us; jgoodnight@washoecounty.us; ltibbals@washoeconty.us;
lgray@washoecounty.us
5 attachments
011412 RJC RCR2012-065630 RCR2011-063341 RCR2012-067980 Reno Police Department Sargent Paul Sifre
arrests Reno Attorney for misuse of 911 second arrest in 2 days by Sifre of Attorney.3gp (11.8 MB) , Mental
Health Court mh-0032 contract coughlin rcr2012-065630 rcr2011-065630 5 5 2012.pdf (596.5 KB) , email to
bdogan@washoecounty.us 4 11 2012 had the Sifre arrest video.htm (262.5 KB) , PAUL SIFRE
TransparentNevada 185k per year.htm (3.3 KB) , rcr2012-065630 4 19 12 letter from dogan with Complaint and
discovery attached and Order for Competency evaluation from 2 27 12 sifre schaur pthoa misue 911.pdf (3.6
MB)
Zach Coughlin
PO BOX 3961
Reno, NV 89505
Tel 775 338 8118
Fax 949 667 7402
ZachCoughlin@hotmail.com
From: zachcoughlin@hotmail.com
To: bdogan@washoecounty.us; jbosler@washoecounty.us; jleslie@washoecounty.us
Subject: misue of 911 case
Date: Thu, 20 Sep 2012 02:20:22 -0700
Mr. Dogan,

Oh, look at that, there is the MHC contract with Coughlin that fails to exclude the medication
Coughlin was taking and which the MHC and Biondo cited as their rationale for expelling
Coughlin, libelling him, in fact. Not that old Jennifer Rains was going to advocate anything
about that? I have no idea what the purpose of even having an attorney there is? And Judge
Elliot was really thrown for a loop when Biray mentioned a "social worker" on staff at the
WCPD, in that transcript of the April 27th, 2011 Hearing that I finally gots my hands on.

I am curious to hear yoru theory of the case (whether the charge be resisting or obstructing
arrest or whatever it was Young sought to amend the Complaint to (something more in line
with a '"erious crime" vis a vis a SCR 111(6) analysis, or if the charge remaisn misue of
emergency services. Please provide me with any novel legal research you culled for this case.
Additionally, yoru were already provided these videos, but here they are again, videos of both
arrests made or ordered by Sargent Sifre (who gets $185K a year and about our age, Biray)
within a 36 hour period of each other, with an intervening pullover by Officer Duralde and 5
other RPD personnel late at night after Coughlin bonded out on the custodial arrest for
jaywalking on January 12th, 2012.
Biray, some people might say that DDA Young has used you, the WCDA Office has used you,
the RMC and Judge Nash Holmes have used you, and perhpas even that Mr. Bosler and Mr.
Leslie are using you. Maybe you like it. Maybe you like being used. Maybe you like being
pushed around. Maybe you love it. Maybe that is what you are good at.

Biray, please tell me how true any of the following strikes you as being:

SCR 111(6): "Definition of serious crime. The term serious
crime means (1) a felony and (2) any crime less than a felony a
necessary element of which is, as determined by the statutory or
common-law definition of the crime, improper conduct as an
attorney, interference with the administration of justice, false
swearing, misrepresentation, fraud, willful failure to file an
income tax return, deceit, bribery, extortion, misappropriation,
theft, or an attempt or a conspiracy or solicitation of another
to commit a serious crime.

Coughlin's WCPD, Biray Dogan, Esq. and DDA Young, in the RJC
prosecution for "misuse of emergency services" (911 calls), when
considering their lack of candor to the tribunal, fairness to
opposing counsel (given Coughlin filed a Notice of Appearance and
has the right to represent himself, and is an attorney),
DDAYoung's repeated instances of violating NRS with respect to
all matters being stayed upon an Order for Competency Evaluation
being entered against a party, such a Coughlin, and the failure
of Dogan to alert Coughlin to, or provide any copy of (depsite
Coughlin's repeated written demands) the July 31st, 2012 Motion
to Amend Complaint (that, upon Judge Sferrazza querrying DDA
Young as to whether the DA even needed seek an Order allowing it
to so amend such a Complaint, responded that the DA did not, but
that he was just seeking one "for purposes of keeping the record
'clean'", whatever in the world that means. When viewed with
Dogan, Young and Leslie's attempts to shuffle Coughlin on through
the MSC process (DDA Young indicated, to Judge Sferrazza, on the
record, while attempting to check of the MSC box minutes before
the Start of the August 29th, 2012 iPhone petty larceny Trial,
that he anticipated the MSC "only taking a couple minutes, at
most" and felt it was Coughlin's "obstructionist" and "difficult"
attitude of "non-compliance" that was preventing him from
effecting his stated goal. DDA Young clearly subscribes to the
RPD Ron Rosa/Nick Duralde school of "How's that runnin' for ya"
style retaliation, intimidation, and misconduct.
Most troubling about Dogan and DDA Young's apparent conspiracy to
get an Order for Competency Evaluation against Coughlin during
their clandestine MSC of 2/27/12 (which, again, Coughlin was
noticed, in writing, had been continued out to March 29th, 2012),
including impermissible communications to the RMC and Judge Nash
Holmes (who arguably violated NRS by continuing on with the
traffic Trial just minutes after being made aware of the 2/27/12
Order for Competency Evaluation in the RJC by Dogan and, perhaps,
by DDA Young as well, is Dogan's failure to inform Coughlin of
DDA Young's RPC 3.8 violating Motion to Amend Criminal Complaint,
wherein DDA Young seeks to alter the charge to one that would
invoke a mandatory SCR 111 Petition in light of SCR 111(6)'s
definition of a "serious crime" and the "statutory or common law
definition" of the crime for which DDA Young, though lacking
"probable cause" sufficient to satisfy his RPC 3.8 duty, sought
to have so amended to an "obstructing or resisting a public
officer" charge, which of course fits squarely in the "serious
crime" definition set forth in SCR 111(6). So, no, Judge
Sferrazza, Coughlin was not "over-lawyering it" on August 29th,
2012 during the "only take a minute at most" MSC Dogan and DDA
Young (and Leslie) sought to slip past Judge Sferrazza right
kstancil@washoecounty.us; rbaker@washoecounty.us
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Dear Mr. Bosler,
Mr. Dogan's malpractice and violations of the RPD are bad enough. Your compounding them with your mincing, nonsensical interpretation of Dogan's tacky
commentary on my suit and tie ("so, are you workin' construction these days?") is something much worse. As was supervisor Jim Leslie's painful attempts at
humor prior to a hearing wherein he attempted to mitigate risk from behind the bar, from gallery, after admittedly muzzling Joe Goodnight, who I respected
at one time. Mr. Goodnight, please do not speak with Biray Dogan about my case ever, at all. I am formally requesting under FOIA and the Nevada Open
Records law copies of all emails and other correspondence between anyone with the WCPD and anyone with the WCDA. Mr. Dogan, your commentary
regarding Ms. Halstead was especially troubling. I am formally forbidding anyone with the WCPD from speaking with anyone with the Reno Municipal Court
or otherwise sharing any documentation, any copies of micro sd card data that was seized from an attorney in open court under a search incident to arrest
following a pretexutal summary contempt arrest (which came just moments after the Judge began a sua sponte interrogation of the attorney in an apparent
attempt to protect Reno City Attorney Ormaas and RMC Marshal Harley from their own misconduct and intentional failure to document admissions of
bribery by the RPD's Officer Chris Carter involving Richard G. Hill, Esq. incident to a pathetic criminal trespass arrest in the context of a civil eviction
proceeding, especially where Hill admits on film and in writing that he was seeking to charge the same $900 "fair rental value" of the tenant, that was
attendant to full use and occupancy, in violation of the prohibition of such unlawful rent distraints under NRS 118A.520 and in a perverted interpretation of
NRS 118A.460.
RJC Court Administrator Steve Tuttle assures me that he will get to the bottom of these retaliatory competency evaluation requests and the complete and
utter lack of documentation in these files setting forth any reasonable basis for so seeking such and evaluation, and the apparent dishonesty attendant to
filings which indicate that a hearing and motion exist in that regard where no such hearing or motion was ever conducted. Further, Mr. Goodnight, the file int
he RJC for the matter you are attached to indicates that I need to be arraigned on the second charged. That has not been done. Please have the Trial date
vacated, and file a Motion to Dismiss based upon the right to a speedy trial found in the Sixth Amendment. Further, Mr. Dogan and Mr. Goodnight
constantly quote me the "basis in fact and law" language in NRCP Rule 11 when explaining their complete failure and refusal to do anything I ask be done in
my case (subpoena officer's personnel file, file a motion in limine, etc., etc.) then turn right around and indicate that NRCP Rule 11 is inapplicable in a criminal
setting when explaining their refusal to move for sanctions or file any sort of motion or grievance against DDA Zach Young, Esq., and the WCDA's office for
continuing to prosecute this pathetic gross misdemeanor "misuse of 911" charge against a victim of domestic violence (according to Master Edmondson in
FV12-00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a video of the arresting RPD Sargent Sifre admitting he was engaging
in classic "blame the victim" police work wherein Sifre admits, on film, that he is making the arrest because the victim keeps putting their self into situations
where they are victimized. Further troubling is that RPD Sargent Zach Thew had directed the victim to make such a call, though Sifre curtly and dismissively
rebuked such involvement by Sargent Thew. About six weeks later, Sargent Sifre then subsequently went on to detain Coughlin for over an hour (after Sifre
had, in his own word, screwed up and let out Coughlin's dog during a subsequent and legitimate "misuse of 911" violation by someone other than Coughlin,
who could articulate no basis whatsoever for their apparent "fear" sufficient to support at least two 911 calls within a couple hours.
The wrongful arrest for which a gross misdemeanor charge is still being Nifonged by DDA Zach Young and for which DPD Biray Dogan has sought a
retaliatory competency evaluation after Coughlin reported and criticized Dogan's failure to appear for a court date:
http://www.youtube.com/watch?v=oU3t_kRR0RA
The jaywalking arrest of Coughlin for which Hill was awarded a Protection Order by the RJC:
http://www.youtube.com/watch?v=gBu9zflGALE
Further, DPD Goodnight. You have failed to provide me with the recent motion work in RJC RCR 2012-063341, including the disclosure of witnesses.
Amazingly, you have disclosed a "Colton Templeton" while refusing to disclose Nicole Watson or Lucy Byington, two individuals who were there when the
unidentified man threatened to "throw this phone in the river if somebody doesn't claim it right now". This "Lawyer Kevorkian" approach needs to cease,
Mr. Goodnight.
The Arrest:
http://www.youtube.com/watch?v=5PR7q4OI5b0
Nicole Watson admitting that she heard the man saying he would throw this phone in the river if somebody doesn't claim it right now:
http://www.youtube.com/watch?v=to_UOFIccLw
Biray Dogan is not very fond of individuals recording events and conversations, however, without the above recordings, it is a very different landscape here.
Further, your WCPD office has repeatedly refused to indicate, in writing, why an SB89 form and or "motion" for Order for Competency Evaluation was
sought, after a "hearing" for BOTH of the competency evaluations I have been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was held,
however, the record at the RJC filing office indicates "upon motion of Defendants counsel and after a hearing on the matter an Order for Competency
Evaluation....". There was no hearing. There was no motion. There was a retaliatory motive. There is an impermissible quid pro quo between Lake's
Crossing and the WCPD, and an illegal tying arrangement with Lake's Crossing, which subjects those forced to have evaluations done there to impermissible
searches in violation of the Fourth Amendment and which filed with the RJC lie riddled note attempting to describe my first trip down to Lake's Crossing. I
wish to have other evaluators perform these evaluations and want to be reimbursed for the cost of doing so. Please let me know, in writing, how much your
office pays Lake's Crossing (Judge Sferrazza sent the bill back to you after the last evaluation, or at least made statements in court that he would do so,
given how weak Goodnight and Hylin's rationale was for seeking such an evaluation in the first place, in pathetic combination with Goodnight immediate
request to be allowed out of the case at the status conference hearing following the evaluation. Judge Sferrazza pointed out to Goodnight how very
intellectually dishonest it was for he and the WCPD to alternately force me to have such and evaluation conducted, only to immediately seek to withdraw, then
to divulge client confidences in open court over the remonstrances of the client.
Lorrain Pelosi, from Lake's Crossing indicates that "we have a contract with the Public Defender" and, therefore, I am only able to utilize a non-Lake's
Crossing evaluator if I have a "private attorney". Further, she indicates that I will not be provided reimbursement for using a non-Lake's Crossing evaluator if
I utilize the services of the WCPD.
Further, there are reports that Mr. Dogan and someone else from the WCPD called Department 3 of the RMC and made impermissible communications in
violation of the duty of confidentiality attendant to the attorney-client relationship. This is not the first report of such a violation, Mr. Bosler, and the practice
of having WCPD's drag their clients to Bailiff's to have blood alcohol level breath tests forced upon them based upon "hunches" and the DPD's "duty to the
court" is rather suspect.
Lastly, RJC Bailiff John Reyes, whom has previously menacingly indicated to Coughlin that he would "put my foot up your ass" (at a time during which Bailiff
Reyes was attempting to prevent Coughlin from standing near the second floor filing counter in the RJC to hear what Coughlin's Deputy Public Defender
Goodnight and Goodnight's supervisor were purporting to the RJC counter staff). Bailiff Reyes now obsessively positions himself all over the RMC And RJC
Courthouse to insure he will encounter Coughlin as each and every court appearance Coughlin has, whereupon Reyes will offer a menancing glare that he
alternates with a shingle eating smile and cutesy commentary. Bailiff Reyes will then follow Coughlin around from the RJC's civil filing office to its criminal
filing office, hounding Coughlin and insisting that Coughlin leave. While Richard G. Hill, Esq. was extremely successful in getting a protection order from
Judge Schroeder of the RJC, in a scant 40 minutes from the time he filed it no less (and that application contained perjury by Hill that was subsequently
unveiled at the hearing on Hill's Motion for Order to Show Cause before Judge Flanagan on 3/23/12), Coughlin was not so successful in getting a Protection
Order against Bailiff Reyes. While Hill's protection order application contained only unsupported hearsay, and some nonsense about climbing on a truck
(which was thoroughly discredited at the 3/23/12 Hearing in D7), Coughlin's TPO application against Bailiff Reyes actually set forth a threat of sexual assault,
yet Coughlin did not even get a hearing on the matter and now Bailiff Reyes has amped up his misbehavior. This, in combination with RJC civil office counter
clerk Christine Erickson brazen refusal to file various exigent Motion's and Notices of Appeal and other landlord tenant based filings submitted by Coughlin,
despite Coughlin providing the RJC with support for his contention that such refusals are clearly in violation of established Nevada law and contribute to
substantial losses to Coughlin personally and professionaly. Most ironic of all, Bailiff Reyes, recently, explained to RJC Court Administrator Tuttle in
Coughlin's presence at the RJC civil division filing office that Reyes "does not think it is appropriate" for Coughlin to have any communications with RJC civil
division filing office staff of anything other than the most brief and sterile nature. Apparently Bailiff Reyes finds telling Coughlin, under color of law, and for
no legitimate reason, that he will "put my foot up your ass", while, curiously Bailiff Reyes somehow finds Coughlin's sayign "hello" and "how was your
weekend" to filing office staff to be "inappropriate".
Further, Richard G. HIll, Esq. threatened Coughlin at the 12/20/11 Hearing on Coughlin's Motion to Release Personal Property (where Coughlin as charged
the outrageous sum of $30 per day "storage" and forced to pay a lien for the contents of his former law office after Richard G. Hill, Esq.'s negligence cause
it to be burglarized on December 12, 2011, something for which Hill now seeks to have Coughlin pay for in his ridiculous Memorandum of Costs on appeal
in D7 in CV11-03628) when Hill exclaimed to Coughlin, in front of Bailiff Reyes and Chief Bailiff Sexton (whom has also made threatening commentary to
Coughlin on multiple occasions seeking to prevent Coughlin from filing documents with the RJC incident to exigent eviction matters) that Hill, too, "would like
to stick something up Coughlin's ass". Hill said this in a loud voice approximately 20 feet from Coughlin, with Bailiff Reyes and Chief Bailiff Sexton standing
near Hill, all three gentlemen sharing a good laugh, during a recess, but while in the courtroom, in RJC Rev201-001708's 12/20/11 Hearing. Judge Sferrazza
was informed of this on the record. Please place a copy of this formal complaint in both Deputy Reyes and Chief Deputy Sexton's employment and
Biray Dogan's Malpractice
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 4/11/12 9:51 AM
To:
jbosler@washoecounty.us; bdogan@washoecounty.us; jgoodnight@washoecounty.us; jleslie@washoecounty.us; william.rempel@latimes.com;
stermitz@sbcglobal.net; sfarmer@lakes.nv.gov; billdavis@lakes.nv.gov; stuttle@washoecounty.us; zyoung@da.washoecounty.us; mkandaras@da.washoecounty.us;
kstancil@washoecounty.us; rbaker@washoecounty.us
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Dear Mr. Bosler,
Mr. Dogan's malpractice and violations of the RPD are bad enough. Your compounding them with your mincing, nonsensical interpretation of Dogan's tacky
commentary on my suit and tie ("so, are you workin' construction these days?") is something much worse. As was supervisor Jim Leslie's painful attempts at
humor prior to a hearing wherein he attempted to mitigate risk from behind the bar, from gallery, after admittedly muzzling Joe Goodnight, who I respected
at one time. Mr. Goodnight, please do not speak with Biray Dogan about my case ever, at all. I am formally requesting under FOIA and the Nevada Open
Records law copies of all emails and other correspondence between anyone with the WCPD and anyone with the WCDA. Mr. Dogan, your commentary
regarding Ms. Halstead was especially troubling. I am formally forbidding anyone with the WCPD from speaking with anyone with the Reno Municipal Court
or otherwise sharing any documentation, any copies of micro sd card data that was seized from an attorney in open court under a search incident to arrest
following a pretexutal summary contempt arrest (which came just moments after the Judge began a sua sponte interrogation of the attorney in an apparent
attempt to protect Reno City Attorney Ormaas and RMC Marshal Harley from their own misconduct and intentional failure to document admissions of
bribery by the RPD's Officer Chris Carter involving Richard G. Hill, Esq. incident to a pathetic criminal trespass arrest in the context of a civil eviction
proceeding, especially where Hill admits on film and in writing that he was seeking to charge the same $900 "fair rental value" of the tenant, that was
attendant to full use and occupancy, in violation of the prohibition of such unlawful rent distraints under NRS 118A.520 and in a perverted interpretation of
NRS 118A.460.
RJC Court Administrator Steve Tuttle assures me that he will get to the bottom of these retaliatory competency evaluation requests and the complete and
utter lack of documentation in these files setting forth any reasonable basis for so seeking such and evaluation, and the apparent dishonesty attendant to
filings which indicate that a hearing and motion exist in that regard where no such hearing or motion was ever conducted. Further, Mr. Goodnight, the file int
he RJC for the matter you are attached to indicates that I need to be arraigned on the second charged. That has not been done. Please have the Trial date
vacated, and file a Motion to Dismiss based upon the right to a speedy trial found in the Sixth Amendment. Further, Mr. Dogan and Mr. Goodnight
constantly quote me the "basis in fact and law" language in NRCP Rule 11 when explaining their complete failure and refusal to do anything I ask be done in
my case (subpoena officer's personnel file, file a motion in limine, etc., etc.) then turn right around and indicate that NRCP Rule 11 is inapplicable in a criminal
setting when explaining their refusal to move for sanctions or file any sort of motion or grievance against DDA Zach Young, Esq., and the WCDA's office for
continuing to prosecute this pathetic gross misdemeanor "misuse of 911" charge against a victim of domestic violence (according to Master Edmondson in
FV12-00188 and FV12-00187 and NRS 33.018) even where the DA has been provided a video of the arresting RPD Sargent Sifre admitting he was engaging
in classic "blame the victim" police work wherein Sifre admits, on film, that he is making the arrest because the victim keeps putting their self into situations
where they are victimized. Further troubling is that RPD Sargent Zach Thew had directed the victim to make such a call, though Sifre curtly and dismissively
rebuked such involvement by Sargent Thew. About six weeks later, Sargent Sifre then subsequently went on to detain Coughlin for over an hour (after Sifre
had, in his own word, screwed up and let out Coughlin's dog during a subsequent and legitimate "misuse of 911" violation by someone other than Coughlin,
who could articulate no basis whatsoever for their apparent "fear" sufficient to support at least two 911 calls within a couple hours.
The wrongful arrest for which a gross misdemeanor charge is still being Nifonged by DDA Zach Young and for which DPD Biray Dogan has sought a
retaliatory competency evaluation after Coughlin reported and criticized Dogan's failure to appear for a court date:
http://www.youtube.com/watch?v=oU3t_kRR0RA
The jaywalking arrest of Coughlin for which Hill was awarded a Protection Order by the RJC:
http://www.youtube.com/watch?v=gBu9zflGALE
Further, DPD Goodnight. You have failed to provide me with the recent motion work in RJC RCR 2012-063341, including the disclosure of witnesses.
Amazingly, you have disclosed a "Colton Templeton" while refusing to disclose Nicole Watson or Lucy Byington, two individuals who were there when the
unidentified man threatened to "throw this phone in the river if somebody doesn't claim it right now". This "Lawyer Kevorkian" approach needs to cease,
Mr. Goodnight.
The Arrest:
http://www.youtube.com/watch?v=5PR7q4OI5b0
Nicole Watson admitting that she heard the man saying he would throw this phone in the river if somebody doesn't claim it right now:
http://www.youtube.com/watch?v=to_UOFIccLw
Biray Dogan is not very fond of individuals recording events and conversations, however, without the above recordings, it is a very different landscape here.
Further, your WCPD office has repeatedly refused to indicate, in writing, why an SB89 form and or "motion" for Order for Competency Evaluation was
sought, after a "hearing" for BOTH of the competency evaluations I have been ordered to undergo. Mr. Hylin admitted to me that no "hearing" was held,
however, the record at the RJC filing office indicates "upon motion of Defendants counsel and after a hearing on the matter an Order for Competency
Evaluation....". There was no hearing. There was no motion. There was a retaliatory motive. There is an impermissible quid pro quo between Lake's
Crossing and the WCPD, and an illegal tying arrangement with Lake's Crossing, which subjects those forced to have evaluations done there to impermissible
searches in violation of the Fourth Amendment and which filed with the RJC lie riddled note attempting to describe my first trip down to Lake's Crossing. I
wish to have other evaluators perform these evaluations and want to be reimbursed for the cost of doing so. Please let me know, in writing, how much your
office pays Lake's Crossing (Judge Sferrazza sent the bill back to you after the last evaluation, or at least made statements in court that he would do so,
given how weak Goodnight and Hylin's rationale was for seeking such an evaluation in the first place, in pathetic combination with Goodnight immediate
request to be allowed out of the case at the status conference hearing following the evaluation. Judge Sferrazza pointed out to Goodnight how very
intellectually dishonest it was for he and the WCPD to alternately force me to have such and evaluation conducted, only to immediately seek to withdraw, then
to divulge client confidences in open court over the remonstrances of the client.
Lorrain Pelosi, from Lake's Crossing indicates that "we have a contract with the Public Defender" and, therefore, I am only able to utilize a non-Lake's
Crossing evaluator if I have a "private attorney". Further, she indicates that I will not be provided reimbursement for using a non-Lake's Crossing evaluator if
I utilize the services of the WCPD.
Further, there are reports that Mr. Dogan and someone else from the WCPD called Department 3 of the RMC and made impermissible communications in
violation of the duty of confidentiality attendant to the attorney-client relationship. This is not the first report of such a violation, Mr. Bosler, and the practice
of having WCPD's drag their clients to Bailiff's to have blood alcohol level breath tests forced upon them based upon "hunches" and the DPD's "duty to the
court" is rather suspect.
Lastly, RJC Bailiff John Reyes, whom has previously menacingly indicated to Coughlin that he would "put my foot up your ass" (at a time during which Bailiff
Reyes was attempting to prevent Coughlin from standing near the second floor filing counter in the RJC to hear what Coughlin's Deputy Public Defender
Goodnight and Goodnight's supervisor were purporting to the RJC counter staff). Bailiff Reyes now obsessively positions himself all over the RMC And RJC
Courthouse to insure he will encounter Coughlin as each and every court appearance Coughlin has, whereupon Reyes will offer a menancing glare that he
alternates with a shingle eating smile and cutesy commentary. Bailiff Reyes will then follow Coughlin around from the RJC's civil filing office to its criminal
filing office, hounding Coughlin and insisting that Coughlin leave. While Richard G. Hill, Esq. was extremely successful in getting a protection order from
Judge Schroeder of the RJC, in a scant 40 minutes from the time he filed it no less (and that application contained perjury by Hill that was subsequently
unveiled at the hearing on Hill's Motion for Order to Show Cause before Judge Flanagan on 3/23/12), Coughlin was not so successful in getting a Protection
Order against Bailiff Reyes. While Hill's protection order application contained only unsupported hearsay, and some nonsense about climbing on a truck

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