7 24 13 Stamped 0204 63324 Motion To Amend Petition For Extraordinary Writ

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Electronically Filed
Jul 24 2013 08:42 a.m.
SUPREME COURT OF THE STATE OF NEVADA
Tracie K. Lindeman
Clerk of Supreme Court
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ZACHARY BARKER COUGHLIN, ESQ. )

)
Petitioner,
)
) CASE NO:63342
vs.
)
RENO JUSTICE COURT; J. THOMAS
) CHIEF JUDGE ISSUE
SUSICH, NORTHERN NEVADA
)
DISCIPLINARY BOARD, SECOND
)
JUDICIAL DISTRICT COURT, HON.
) ----JUDGE PATRICK FLANAGAN, HON. )
JUDGE STEVEN ELLIOTT, 2JDC
CLERK OF COURT JOEY ORDUNA
HASTINGS, RJC COURT
ADMINISTRATOR STEVE TUTTLE,
KAREN STANCIL, STATE BAR OF
NEVADA, ET AL, HON . JUDGE
ELLIOTT SATTLER, WASHOE
COUNTY JAIL, RENO JUSTICE COURT,
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Defendant. RJC RCR2011063341

RCR2012-071437, rcr2012-065630,
rcr2012-067980, RCR2013-072675,
Adminstrative Order 2012-01 In Re
Zachary Coughlin, etc.
---------------------------------------richard g. hill, esq. v. zach coughlin rcp
2012-000018
------------------------------------------Milan Krebs v. Zach Coughlin RJC
Rcp2012-000287
-------------------------------------------City of Reno v. Zachary Coughlin
Motion to Amend Petition for Extraordinary Writ or to Consolidate with Other Such Petitions
Involving Substantially Similar Law and Factual Circumstances 1/11 Docket 63342 Document 2013-21712
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RMC 11 CR 26405, 11 tr 26800, 12 cr

12420, 12 cr 00696, 13 cr 3913, 13 cr 3914
-----------------------------------------.
Matthew Merliss
v.
Zachary Coughlin rev2011-001708,
rev2011-001492
----------------------------ZACH COUGHLIN
V.
MATT MERLISS, ET AL. (CV11-03051,
CV11-03126, CV11-03051)
----------------------------------ZACH COUGHLIN
V.
CITY OF RENO CR11-2064, CR13-0011,
CR12-1262-----------------Zach Coughlin v.
State of Nevada CR12-2025, CR12-1262
CR13-0614, (2JDC)
-------------------------------Zach Couglin v.
Reno Justice Court CR13-0552
---------------------------------------Park Terrace Townhomes
v.
Zachary Coughlin rev2012-000374
rev2012-074408
----------------------------------------Northwinds Apartments
v.
Zachary Coughlin
rev2012-001048,
1167, 1168, 1082, 1083, Rev2012-076746
(all Rev2012-)etc.
------------------------------------------Washoe County, applicants
v.
Zach Coughlin rcp2012-000599
---------------------------------------State Bar of Nevada, applicants
v.
Zach Coughlin, respondent RCP2012000607
Involving Substantially Similar Law and Factual Circumstances 2/11 -
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-----------jeff nichols Rev2012-075658

---------------superior mini storage v. tahoe quarterly and
or zach coughlin
and or zach coughlin v
superior mini storage Rev2011-078432
-----------------------------Motion to Amend Petition for Extraordinary Writ or to Consolidate with Other Such
Petitions Involving Substantially Similar Law and Factual Circumstances
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COMES NOW, ZACH COUGHLIN, and files the above titled document on his own
behalf and it is based on the argument and authorities herein. Coughlin respectfully submits
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this under enormous duress and submits that a good deal of the writing in the attached
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Declaration is fairly over the top and not necessarily literal but more done for effect to
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illustrate the gravity of these matters. Coughlin needs some breathing room, but with
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looming trials (two of them) in the RMC connected to the SBN's spurious TPO/EPO for
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workplace harassment, the exigencies associated with the SBN's fraudulent approach to the
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ROA in 62337, and the everpresent threat of some RJC Bailiff or RMC Marshals etc
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attacking Coughlin and fraudulently stacking up bail amounts makes these circumstances
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such that Coughlin must file these hanzel and gretl bread crumb trails and asks for a full time
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security detail to protect him from the City of Reno Washoe County Industrial Complex and
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its phalanx of crooked attorneys and associated functionaries and the the August trials in 13
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CR 3913, 3914, and RCR2013-072675 and RCR2011-063341 to be ordered vacated
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(especially considering RJC Judge Pearson's 2/5/13 Order for Competency Evaluation has
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still yet to be properly addressed and resolved (ie, a Judge cannot set aside his own order for
competency evaluation any more than he could legally write himself a script for narcotics,
NRS 178.405). Coughln also requestes unfettered access to all of his files in the RMC and
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RJC, at no cost, includign audio transcripts, dockets, etc., without the glowering presence of
those courts strike forces. Coughlin further requests a Nevada universal Order granting him
IFP status for the next 6 months in any and all cases wherein he is a party in Nevada's courts.
Coughlin further seeks an immediate stay of any and all probations he is currently subjected
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to and and extension of time as to any and all deadlines past, present or future in any of these
matters given the uniqueness inherent to a solo attorney having his former home law offices
and rentals burglarized by the Washoe County sheriff and Reno Police Department on a
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multitude of occasions since August 2011, and and Order suspending any and all protection
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orders Coughlin is currently subject to and and order requiring the copying of every single
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thing the state bar of nevada has received from Coughlin to Coughlin and the originals to this
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Court, including any and all attachments and faxes, and a full report of any instances wherein
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the SBN or any of these other courts have failed to maintain copies or the originals of the
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documents Coughlin has submitted for filing and an order requiring that the RMC and RJC
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immediately provide Coughlin with a digital copy of every file in its entirety wherein he has
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appeared as a party, including all audio transcripts that have not already been provided to
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Coughlin (especailly those in the Milan Krebs matter, etc., etc. Such would be money well
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spent as it would raise to level of landlord tenant pracitce and filing office clerk compliance
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with traditional standards of practice (ie, no more throwing away documents, no more
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refusing to accept supersedeas bonds, no more throwin attorneys over benches, etc., etc.),
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Lastly please grant an Order requiring RMC Dilworth and RJC Clifton and all other judges
whom have had NRS 1.235 disqualification motions filed by Coughlin (the serving a copy on
the Judges chambers requirement shoudl be suspended where Coughlin has been ragdolled
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around by the RMC and RJC's storm troopers, and where Coughlin has made every
legitimate attemtp to so comply with such requirement.
FACTS/POINTS AND AUTHORITIES
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As to 61383, perhaps the relief sought herein relates more to the WCSO, RPD, RMC,
RCA, WCSO etal...The Nevada Supreme Court has established precedent in support of
. Coughlin submitted multiple Notices of Appeal in the RMC (one on 6/28/12 in 11 CR
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26405 that the RMC just flat refuses to countenance (Judge Elliott's dismissal of Coughlin's
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appeal (beyond being premised upon a fraudulent Request to Submit by RCA Hazlett, whom
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violated SCR 123 in citing ot an unpublished TN case, State v. Lovins relied on heavy in the
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trial, Elliott's Order Dismissing Coughlin's appeal was premised upon his contention that
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NRS 189.010 was not complied with where the NOtice of Appeal is notated as being filed
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7/27/12, which not only discounts the original 6/28/12 Notice, but also, given the tolling
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Motion of 6/26/12, the jails failure to timely transmit indigent Coughlins' 7/10/12 Notice of
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Appeal should dictate reinstating that Appeal or Ordering a new trial, better yet as it was
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Hill's Office and his associate Baker and the Washoe Co Sheriff and RPD would burglarized
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Coughlins' former home law office under Russell v. Kalian, and which resulted in 61901 and
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is being used as a basis for attempting to disbar Coughlin in 62337, in addition to. As formal
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hearing exhits 4 and 5 in 62337, Judge Nash Holmes just flat refuses to allow Coughlin to
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appeal her contempt ORder of 2/28/12 and her second bite at the appele of 3/12/12 wherein
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she attempted to transmogrify a simple traffic citation trial to a summary disciplinary
proceeding, and where despite impounded Coughlin's smart phoen and micro sd card into
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"evidence" for 37 days, then returning it wiped of all data, Jduge Nash HOlmes testified that
she wasn't sure if Coughlin had "lied" by found that he had as to her vague questions
regarding "recording" or "recording devicces" and conduct she admits allegedly occurred
outside the immediate presence of the court where she failed to follow NRS 22.030(2)'s
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affidavit requirement. Coughlin should be permitte dto appeal both of those RMC 11 TR
26800 "contempt" Orders and that of 11/30/11 by Judge Howard (Judge Elliot's 3/15/12
Order Affirming "the Ruling" of the RMC is cryptic at best and fails to address Coughlin's
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appeal fo the "contempt conviction", which is just as suspect as the conviction in 60838 given
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the denial of the Sixth Amendment to a per se indigent udner the 2009 Indigent Defense
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Order (Canon 2 Rule 2.15 basis for "appropriate action" towards RMC Judge Howard,
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period), in addition to doubling up and denying Coughlin his right to Counsel upon, ten
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minutes into the 11/30/11 petty larceny trial in RMC 11 CR 26405 Judge Howard found
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Coughlin in contempt then refused Coughlin counsel for that circumstances, w hich
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ultimately did included 3 days of summary incarcearatino fo a practicing attorney. Lastly,
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Coughlin requests permission to issue his own subpoenas, especially where Coughlin is self
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representing in these various matters and therefore, given that Coughlin is "an attorney" (a
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patent attorney whom is tempoarily suspended in Nevada is still an attorney), Couglin is
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arguably therefore, per NRCP "authorized to practice" in such courts and should not be
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subject to the vagaries of the third hand retellings by RJC/RMC filign office clerks as to how
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this or that judge refused to allow some subpoena to be issued to Coughlin. If it is so tedious
and burdensome the city of Reno on the Washoe County District Attorney's Office and/or
local law enforcement responded Coughlin subpoenas and perhaps the answer isn't to deprive
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Coughlin of his constitutional rights but rather to try to get those entities to quit actin' a fool
so very often. Lastly, Coughlin request an Order removing all of his cases from the RJC and
RMC and requiring the RPD, WCSO, WCDA, WCPD, and RCA to propound every
recording, report, police report, incident report, video audio or other recording to Coughlin in
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any way connected to Coughlin immediately and and Order addressing NDNB Chairman
Susich's apparent complete and utter fail to fulfill his SCR 110(3)-(4) duties vis a vis the
rampant contempt of court exhibited by those Coughli's subpoena (city of reno marshals,
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keith loomis, Judges Flanagan and Elliott, RMC Judges (Panel Chair has no jurisdiction to
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quash such subpoenas), sBN, etc., etc. and for the IFP to include all services fees and to
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require the 2JDC waive Coughlin's electronic filing fees or subscriptions. and and order
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requiring the RJC to immediately release the $500 worth of supersedeas bonds Coughlin
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deposited that sit there still, no stay having been forthcoming, Coughlin's motions for the
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release of such gone unresponded to, and requiring the RJC transmit Coughlin's notices of
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appeal, all of them, under the threat of criminal prosecution of its clerks should they continue
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doing as they please or as they are being intimidated into doing.

CONCLUSION
Please provide the JAVS audio recordings sought herein and access to or copies of
(digital copies are great) of ALL of Zach Coughlin's files, ever, in the RJC.
The undersigned hereby request this Court consider these materials presented herein in
deciding upon this matter.
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AFFIRMATION AND DECLARATION

I declare, pursuant to NRS 53.045, under penalty of perjury under the laws of the State
of Nevada that the foregoing and all factual claims herein is and are true and correct and that
this document does not contain any social security numbers, pursuant to NRS 239B.030, an
affirmation to that effect this hereby is.
DATED this 7/22/13
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_/s/ Zach Coughlin

Zach Coughlin, Esq.
PETITIONER
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PROOF OF SERVICE
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On this date, I caused a copy of the foregoing document to be served upon the
following by placing a true and correct copy of the foregoing document in the U.S. mail
addressed to and personally delivering the same to the WCDA's Office at 1 South Sierra St.:
Amos R. Stege, astege@da.washoecounty.us
Zachary N. Young, Esq. zyoung@da.washoecounty.us
Washoe County DA
1 South Sierra P.O. Box 30083
Reno , NV 89520
Phone Number: 775-328-3200 Fax number: 775-325-6703
Email: zyoung@da.washoecounty.us
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Richard G. Hill, Chartered

652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858
Email: rhill@richardhillaw.com
11791 Ridge Rim Road, Chico, CA 95928, copy to Matthew Joel Merliss to the extent Hill
refuses to file a notice of appearance in CV11-03051.
Ken and Matt, Managers
Superior Storage LLC
7750 W. Fourth St. (At Mayberry) Reno, NV 89523
7795 White Fir St. Reno, NV 89523
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Phone: 775-746-4322 Fax: 775-746-9741, might be represented by Rick Elmore, Esq.:

RICHARD L. ELMORE Company: Holland Hart, LLP Address: 5441 Kietzke Lane, 2nd Flr. ~ Reno , NV 89511
Phone Number: 775-327-3000 Fax number: 775-786-6179 Email: relmore@hollandhart.com Website:
http://www.hollandhart.com Admit Date: 9/19/77
Jeff Nichols, Owner Cobblestone Masonry

PO BOX 10605
Reno, NV 89510
Tel: 775 323 3626
Fax: 775 345 7529
Sue King, Western Nevada Management, Park Terrace TownhomesHOA

804 Mill Street Reno, NV 89502
(775) 284-4434 and faxed to
kern ad PTTHOA 7753246173
and King and WNM at 7752844465
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Gayle A. Kern. Ltd. Address: 5421 Kietzke Lane Suite 200 Reno , NV 89511 Phone
Number: 775-324-5930 Fax number: 775-324-6173 Email: gaylekern@kernltd.com attoreny
for Park Terrace THOA
NORTHWIND APARTMENT ASSOC LLC
1031 XPRESS NORTHWIND LLC
110 110TH AVE NE STE 550
BELLEVUE, WA 98004
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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
Nevada Court Services
Lew Taitel, Esq., Staff Attorney
Jeff Chandler, Owner and CEO
Robert Wray/Joel Durden, Licensed Process Server
475 S. Arlington Avenue, Suite 1A
Reno, NV 89501
(775) 348-7560
Lewis S. Taitel, Esq.
Attorney at Law
475 S. Arlington Suite 1A
Reno, Nevada 89501
(775) 322-2272
Fax: (775) 348-7977
Nevada State Bar No. 4397
Not sure who Mr. Taitel represents in this matter, if anyone...
Apparently representing Northwinds Apartments Associates, LLC and or Northwinds
Apartments, though Chandler's "landlord's affidavit" swears that he, Chandler is the
"landlord", so...
Northwind Apartments and Milan Krebs 1680 Sky Mountain Drive, Reno, NV 89523-8147
DATED this 7/22/13
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/s/ Zach Coughlin

Zach Coughlin, Esq.
Defendant Attorney temporarily suspended in Nevada but not before USPTO
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INDEX TO EXHIBITS:
1. VARIOUS RELEVANT MATERIALS, INCLUDING THE FILINGS BAILIFF
RAMSEY ADMITS TO THROWING AWAY, ETC., ETC.
https://skydrive.live.com/redir?resid=43084638F32F5F28!8413
https://skydrive.live.com/redir?resid=43084638F32F5F28!8413
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7 24 13 Stamped 0204 63324 Motion To Amend Petition For Extraordinary Writ

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7 24 13 Stamped 0204 63324 Motion To Amend Petition For Extraordinary Writ

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ZACHARY BARKER COUGHLIN, ESQ. )

Defendant. RJC RCR2011063341

RMC 11 CR 26405, 11 tr 26800, 12 cr

-----------jeff nichols Rev2012-075658

CR 3913, 3914, and RCR2013-072675 and RCR2011-063341 to be ordered vacated

she attempted to transmogrify a simple traffic citation trial to a summary disciplinary

ultimately did included 3 days of summary incarcearatino fo a practicing attorney. Lastly,

patent attorney whom is tempoarily suspended in Nevada is still an attorney), Couglin is

doing as they please or as they are being intimidated into doing.

AFFIRMATION AND DECLARATION

_/s/ Zach Coughlin

Richard G. Hill, Chartered

Phone: 775-746-4322 Fax: 775-746-9741, might be represented by Rick Elmore, Esq.:

Jeff Nichols, Owner Cobblestone Masonry

Sue King, Western Nevada Management, Park Terrace TownhomesHOA

Fictitious Firm Name - Counter

/s/ Zach Coughlin

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