FILED

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Document Code:
Zach Coughlin, Esq.
Nevada Bar No: 9473
1422 E. 9th St. #2
Reno, NV 89512
Tele: 775-338-8118
ZachCoughlin@hotmail.com
Attorney for Appellant

IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

IN AND FOR THE COUNTY OF WASHOE

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ZACHARY COUGHLIN;
Appellant,

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vs.

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Electronically
01-14-2012:12:07:28 AM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2700423

MATTHEW MERLISS
Respondent.

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) CASE NO: CV11-03628
) DEPT: D7
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) Opposition to Motion for Attorney's Fees
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)

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Opposition to Motion for Attorney's Fees

PLEASE NOTE: ALL I DID HERE IS ADD A DECLARATION BECAUSE I AIM TO LISTEN
AND LEARN WHEN JUDGE FLANAGAN POINTS OUT SOMETHING THAT MY MOTIONS
LACK AND I AM TRYING TO GET BETTER AS AN ATTORNEY
This undersigned hereby files this Opposition to Motion for Attorney's Fees, as Attorney of Record

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for Appellant, Zach Coughlin. The undersigned has been a victim of domestic violence, beginning

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with his move, on or about December 27th, 2011 until the present, with the Reno Police needed to

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visit the 1422 E. 9th St. #2 address the undersigned is currently stationed at on at least 6 occasions.

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Further, for NRCP 59 and NRCP 60 basis, this Court's recent Order is clearly inaccurate to the extent

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Opposition to Motion for Attorney's Fees

is purports to find that the undersigned made any agreement to waive his security deposit in exchange

for additional access to the property. Hill and Baker have an established practice, in this case

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especially of moving for attorney's fees where no basis in fact or law exists, See RJC 2011-001708
Memorandum of Fees for some $20,000 based upon a controlled substance manufacture statute that
clearly was completely inapplicable to this matter, then a similar motion they filed under NRS 69.030

despite "summary eviction proceedings" not being "civil actions" under N JCRCP 3, which identifies

four types of cases in justice courts, an only one, "civil actions" come within the purview of NRS

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69.030. To the extent the attorneys fees issue is not made moot by this Court's recent order, it is
hereby opposed.
PLEASE NOTE THAT THE UNDERSIGNED COUNSEL APOLOGIZES FOR THE

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SOMEWHAT SLAPDASH NATURE OF THIS FILING, HOWEVER, IT MUST BE EXCUSED

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TO SOME EXTENT CONSIDERING THE UNDERSIGNED JUST SPENT 12 HOURS IN JAIL

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AFTER THE RENO POLICE DEPARTMENT (WITH THE HELP OF OPPOSING COUNSEL IN

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THE UNDERSIGNED EVICTION FROM HIS LAW OFFICE CASE, RICHARD G. HILL, ESQ)

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ARRESTED THE UNDERSIGNED FOR "JAYWALKING" OR "FAILURE TO USE A

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SIDEWALK WHERE PRESENT" OR SOME OTHER SUCH CHARGE WHILE THE

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UNDERSIGNED WAS IN THE COURSE OF FILMING THE DESTRUCTION OF ITEMS OF

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PERSONAL PROPERTY (LIKE THE LAST THING THE UNDERSIGNED'S GRANDMOTHER

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GAVE HIM BEFORE SHE DIED, LIKE THE CARICTURE DRAWING OF THE

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UNDERSIGNEDS GIRLFRIEND AND DOMESTIC PARTNER FOR FIVE YEARS WHOSE 22

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YEAR OLD COUSIN JUST DIED IN A CAR ACCIDENT DAYS AGO) PEACEABLY AND ON

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PUBLIC PROPERTY AND AFTER A RENO PD OFFICER WHO ACTUALLY HAS SOME

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CLASS INFORMED RICHARD HILL THAT THE UNDERSIGNED WAS NOT DOING

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Opposition to Motion for Attorney's Fees

ANYTHING ILLEGAL. BUT THEN IN COMES OFFICER DEL VECHIO WHO ACTUALLY

"DREW DOWN" AFTER SCREACHING TO A HALT AND VEERING ACROSS THE LANE OF

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ONCOMING TRAFFIC ON THE UNDERSIGNED THIS SUMMER IN FRONT OF THE SAME

LAW OFFICE AT NIGHT DUE TO THE UNDERSIGNED'S MOUNTAIN BIKE, ALLEGEDLY
LACKING A PROPER LIGHT, AND NOTHING ELSE. TODAY, WHILE BEING ARRESTED

FOR JAYWALKING (DESPITE THE FACT THAT RICHARD HILL'S CREW OF MOVERS

HAD THEIR TRUCK PARKED IN THE MIDDLE OF THE SIDEWALK THE UNDERSIGNED

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WAS ON) RICHARD HILL WENT BACK TO A PLACE HE REALLY, REALLY LIKES, THE
RENO JUSTICE COURT, AND APPARENTLY GOT HIMSELF A PROTECTION ORDER,
THEN DROVE OFF IN ONE OF HIS APPROXIMATELY 11 PORCHES WEARING A SHIRT

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WITH FLAMING SKULLS ON IT IN A REPEATING ED HARDY INSPIRED DESIGN. THE

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UNDERSIGNED WAS DENIED ANY PHONE CALLS AT THE WASHOE COUNTY JAIL FOR

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AT LEAST 6 HOURS, IMMEDIATELY PLACED IN A SOLITARY CONFINEMENT STYLE

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ICE LOCKER DESPITE HAVING MADE NO DEMONSTRATION OR RESISTENCE OR

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DEMONSTRATING ANY INAPPROPRIATE CONDUCT TO THE JAIL STAFF, WHEREUPON

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SEVERAL JAIL NURSE REFUSED TO PROVIDE MEDICAL CARE (EXCESSIVE FORCE

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WAS USED DURING THE ARREST, WHICH APPARENTLY, WAS CONDUCTED BY AN

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OFFICER LEEDY THAT OFFICER DEL VECHIO WAS "TRAINING", THEN MONEY WAS

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STOLEN FROM THE UNDERSIGNED BY THE JAIL STAFF, A DEPUTY ADAMS, IN FRONT

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OF DEPUTY DOCIO INFORMED THE UNDERSIGNED THAT HE "DIDN'T GIVE A SHIT IF A

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DIPSHIT LIKE YOU HAS LIFE THREATENING MEDICAL ISSUES" AND REFUSED TO

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SUMMON A NURSE. THE WASHOE COUNTY JAIL FOUND IT APPROPRIATE TO

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FINALLY RELEASE THE UNDERSIGNED FROM JAIL AFTER MAKING HIM PAY SOME OF

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Opposition to Motion for Attorney's Fees

THE LAST MONEY HE HAD FOR "BAIL", TAKING MOST OF THE REST OF THE MONEY

THE UNDERSIGNED HAD AND CLAIMING IT WAS EITHER "LOST" OR THAT "THEY

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WERE WRONG EARLIER WHEN THE SWORE THAT THAT AMOUNT WAS ALL YOU
WOULD NEED TO BAIL OUT" WHEREUPON THE JAIL STAFF DECIDED TO POCKET
CASH FROM THE UNDERSIGNED, WITHOUT HIS CONSENT, PRIOR TO RELEASE. THE

JAIL SAW FIT TO RELEASE THE UNDERSIGNED ONLY MINUTES AFTER THE LAST BUS

FOR THE NIGHT LEFT PARR BLVD, AND AT 11:00 AT NIGHT, WITH THE UNDERSIGNED

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DRESS ONLY IN A THIN SHIRT AND JEANS, THE TEMPERATURE A FREEZING 25

DEGREES, AND THE UNDERSIGNED HAVING $2 IN HIS POCKET, WHEREUPON THE
UNDERSIGNED CALLED 911 AND WAS HUNG UP ON BY SUPERVISOR "KARI" WHO

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INFORMED THE UNDERSIGNED THAT SHE KNEW EVERYTHING THE RENO PD COULD

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OR WOULD DO AND THAT THEY WOULDN'T DO ANYTHING WRONG, AND THEN KARI

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REFUSED TO DIVULGE THE IDENTITY OF THE 911 OPERATORS WHO INFORMED THE

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UNDERSIGNED THAT HYPTHERMIA OR EXPOSURE TO COLD WEATHER DID NOT

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CONSITUTE AN EMERGENCY, NEITHER WOULD A SITUATION WHERE POLICE OR

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SHERIFF PERSONNEL WERE CONSPIRING TO MURDER SOMEONE RISE TO THE LEVEL

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OF EMERGENCY. FINALLY THE UNDERSIGNED GOT TO HIS VEHICLE, NEAR THE

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SIENNA HOTEL, ONLY TO PROMPTLY BE PULLED OVER BY 5-6 ARMED RENO PD

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OFFICERS WHOM CITED THE FACT THAT THE UNDERSIGNED LICENSE PLATE WAS

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GONE (IT HAD, APPARENTLY, MYSTERIOUSLY DISAPPEARED WHILE THE

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UNDERSIGNED WAS IN JAIL FOR A CUSTODIAL ARREST FOR "JAYWALKING",

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SOMETHING RICHARD HILL, ESQ. DID IN FRONT OF THESE VERY SAME OFFICERS

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SEVERAL TIMES WHILE THE UNDERSIGNED WAS IN THE PATROL CAR), INCLUDING

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Opposition to Motion for Attorney's Fees

ONE WHOM THE UNDERSIGNED HAS SUBMITTED A COMPLAINT REGARDING TO THE

RENO PD JUST DAYS BEFORE, OFFICER NICHOLAS DURALDE, WHOM WAS PRESENT

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WHEN OFFICER RON ROSA ATTEMPTED TO EXTORT A CONFESSION OR CONSENT TO

SEARCH FROM THE UNDERSIGNED DURING AN INCIDENT IN AUGUST BY, IN ROSA'S
WORDS "CALLING THE STATE BAR" AND DEFAMING THE UNDERSIGNED,

WHEREUPON OFFICER DURALDE COMMITTED EGREGIOUS POLICE MISCONDUCT. IT

IS IMPORTANT TO NOTE THAT RENO PD OFFICER CARTER PREVIOUSLY INFORMED

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THE UNDERSIGNED THAT "RICHARD HILL PAYS HIM A LOT OF MONEY AND
THEREFORE HE WILL ARREST WHO RICHARD HILL SAYS TO AND HE WILL DO WHAT
RICHARD HILLS SAYS". PREVIOUSLY, RENO PD SARGENT TARTER HAS TICKETED

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THE UNDERSIGNED FOR FAILURE TO STOP COMPLETELY BEFORE THE WHITE LINE

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AT A STOP SIGN, IN A RETALIATORY FASHION, AFTER THE UNDERSIGNED LEFT

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RICHARD HILL, ESQ.S OFFICE, WHERE RICHARD HILL HAD BEEN REFUSING TO TURN

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OVER THE UNDERSIGNED STATE OF NEVADA DRIVER'S LICENSE FOR OVER ONE

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WEEK. FURTHER, RICHARD HILL'S LICENSED CONTRACTOR (WHOM HAD

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PREVIOUSLY SUBMITTED WHAT APPEARS TO BE A FRAUDULENT BILL FOR $1060 TO

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BOARD UP AND "FIX A LEAK IN THE BASEMENT" (THE LEAK, HE INFORMED THE

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UNDERSIGNED, HE ACTUALLY JUST FIXED OUT OF THE "GOODNESS OF HIS HEART")

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AS, SOMEHOW, QUALIFYING AS "REASONABLE STORAGE, MOVING, AND

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INVENTORYING EXPENSES" LANDLORD LIEN UNDER NRS 118A.490, DESPITE THE

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FACT THAT THE CONTRACTOR USED THE UNDERSIGNED'S OWN WOOD AND

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PLYWOOD TO BOARD UP THE PROPERTY DESPITE CHARGING $1060 FOR DOING SO

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AND WHOM TODAY WAS THROWING AWAY THE CALIFORNIA NUEROSURGEON,

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Opposition to Motion for Attorney's Fees

MATTHEW JOEL MERLISS, MD.'S CARPET, WHILE RICHARD HILL WAS APPARENTLY

READYING HIMSELF TO SUE THE UNDERSIGNED BOTH FOR THE COST OF DISPOSING

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IT AND FOR COST OF IT AS PROPERTY, AND BOTH OF THESE DISCOVERIES SEEMED

TO VEX THE CONTRACTOR SO COMPLETELY THAT HE FELT IS NECESSARY TO CALL
UP RICHARD HILL RIGHT AWAY AND HAVE RICHARD DO HIS THING WITH THE RENO

PD (LIKE WHEN OFFICER CARTER AND OFFICER LOPEZ ARRESTED THE

UNDERSIGNED FOR TRESPASSING DESPITE NOT ONCE IDENTYING THEMSELVES

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PRIOR TO ARREST AS OFFICER AND NO ONE HAVING ASKED THE UNDERSIGNED TO

LEAVE THE PREMISES, AND WHERE THESE OFFICERS, AGAIN, STRANGELY, FOUND
THE UNDERSIGNED NOT "CANDIDATE FOR A CITATION". THE ARREST TODAY WAS

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PARTICULARLY CONVENIENT FOR RICHARD HILL CONSIDERING IT PREVENTED ANY

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FILMING OF THE DESTRUCTION OF PROPERTY HE WAS ENGAGING IN. RICHARD HILL

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PREVIOUSLY GAVE THE UNDERSIGNED A BAG OF TRASH IN RESPONSE TO THE

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UNDERSIGNED'S DEMAND THAT HILL CEASE APPLYING AN UNLAWFUL RENT

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DISTRAINT TO THE UNDERSIGNED'S CLIENT'S FILES. FURTHER, WHEN THE

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UNDERSIGNED REFERENCE THE DAMAGE RICHARD HILL WAS DOING TO CLIENT'S

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INTERESTS IN CASES JUST LIKE THE CARPENTIER'S, RICHARD HILL, IN JUDGE

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SFERRAZZAS COURT ROOM WATCHING THE PROCEEDINGS AND PERIODICALLY

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CROSSING THE BAR TO PASS POST IT NOTES TO CASEY BAKER (DESPITE JUDGE

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SFERRAZZA DIRECTING HILL AND OTHER WITNESSES TO LEAVE THE COURTROOM

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UNTIL CALLED TO TESTIFY) MADE A MASTURBATORY JESTURE AND EXTREMELY

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DISMISSIVE AND CRUDE FACIAL EXPRESSION AS IF TO SIGNAL HOW LITTLE HE

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Opposition to Motion for Attorney's Fees

CARED ABOUT THE FORECLOSURE DEFENSE OF MIDDLE CLASS AMERICANS AND

CITIZENS OF WASHOE COUNTY LIKE the undersigned's foreclosure defense clients.

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Dated this January 13th, 2012

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/s/ Zach Coughlin_________________

Zach Coughlin, Esq.
NV Bar No. 9473
1422 E. 9th St. #2
Reno, NV 89512
Tele: 775-338-8118
Fax: 949-667-7402
ZachCoughlin@hotmail.com
Attorney for Appellant

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Opposition to Motion for Attorney's Fees

DECLARATION OF ZACH COUGHLIN, ESQ. IN SUPPORT OF

OPPOSITION TO ATTORNEY'S FEE MOTION
1. This Declaration is made pursuant to the provisions of NRS 53.045, we are presently
in the State of Nevada and I declare under penalty of perjury that the foregoing is true
and correct.
2. Declarant is a party in this case.
3. Declarant avers that the factual statements set for above in the foregoing document
are accurate to the best of his knowledge.
4. I, Zach Coughlin, am available to testify, if necessary, as to these matters. I declare
under penalty of perjury that the foregoing is true and correct.
Executed on January 13, 2011
/S/ ZACH COUGHLIN_
ZACH COUGHLIN, ESQ.
COUNSEL OF RECORD FOR SELF

AFFIRMATION Pursuant to NRS 239B.030

Also, this document does not contain any social security number or other
inappropriate material pursuant to NRS 239B.030.
DATED this January 13th, 2012

_/s/ Zach Coughlin

Zach Coughlin
Appellant

PROOF OF SERVICE
I, Zach Coughlin, declare:
On January 13th, 2012, I, Mr. Zach Coughlin served the foregoing Opposition to
Motion for Attorney's Fees by faxing and serving upon registered efilers and depositing a
true and correct copy in the US Mail addressed to:
Richard G. Hill, Esq. and
Casey Baker, Esq.
652 Forest St.
Reno, NV 89503
Attorneys for Respondent Matt Merliss, MD

----------------------------Zach Coughlin
AGENT OF APPELLANT