3 25 13 Motion For Extension of Time To File Opening Brief 0204 62337 13-08766

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Electronically Filed
Mar 25 2013 11:57 a.m.
Tracie K. Lindeman
Clerk of Supreme Court
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IN THE SUPREME COURT OF THE STATE OF NEVADA
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IN RE DISCIPLINE OF
ZACHARY BARKER COUGHLIN
BAR NO 9473
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) 62337
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MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF

Zach Coughlin, (Coughlin), self representing appellant respectfully
moves this Court for an extension of time to file his opening brief.
Submitted this March 21st, 2013.
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________________________
Zachary Barker Coughlin
Nevada Bar No 9473
1471 E. 9th St.
Reno, NV 80512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
self representing Appellant
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- 1/154 MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF; EXCUSABLE NEGLECT FOR THIS
NOT BEING FILED PRIOR TO 11:59 PM
Docket 62337 Document 2013-08766
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POINTS AND AUTHORITIES

Motions to extend the time for filing briefs are carefully scrutinized [U.S. v.
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Raimondi, 760 F.2d 460 (2d Cir. 1985] and typically will be granted by the court only
upon a showing of good cause.[SCR 105(3)(b);Fed. R. App. P. 26(b)] Good cause
requires that the movant aver something more than the normal, or even the reasonably
anticipated but abnormal, vicissitudes inherent in the practice of law. Norvelle v. City
of Hobart, 1993 OK CIV APP 135, 862 P.2d 82 (Ct. App. Div. 1 1993).The consent of
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opposing counsel to extend the time for filing briefs does not play a decisive role in the
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court's treatment of such a motion.U.S. v. Raimondi, 760 F.2d 460 (2d Cir. 1985);
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Barber v. American Sec. Bank, 841 F.2d 1159 (D.C. Cir. 1988). 5 Am. Jur. 2d
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Appellate Review 533. FilingExtensions for filing. As to the consequences of an
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appellant's or an appellee's failure to file a timely brief, see 536 to 538.
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SCR 105(3).Review by supreme court.

(a)Time and manner of appeal.A decision of a hearing panel shall be served on
the attorney, and service shall be deemed Notice of Entry of Decision for appeal
purposes. Except as provided in Rule 105(3)(b), a decision is final and effective 30
days from service, unless an appeal is taken within that time. To the extent not
inconsistent with these rules, an appeal from a decision of a hearing panel shall be
treated as would an appeal from a civil judgment of a district court and is
governed by the Nevada Rules of Appellate Procedure.
(b)De novo review of public discipline.... Extensions of time to file briefs are
disfavored and will only be granted upon a showing of good cause. The parties shall
not be required to prepare an appendix, but rather shall cite to the record of the
disciplinary proceedings. If no opening brief is filed, the matter will be submitted for
decision on the record without briefing or oral argument.
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The 12/14/12 FOFCOL by the Panel is just that, a Findings of Fact;

Conclusions of Law...not a decision sufficient to invoked SCR 105(3), just yet.
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However, to whatever extent the 12/14/12 FOFCOL is deemed a decision, Coughlin

filed numerous tolling motions and supplementals and amendments thereto (NRCP 15,
NRCP 52, 59, etc.) and as such where SCR 105(3) provides that an appeal from a
decision of a hearing panel shall be treated as would an appeal from a civil judgment of
a district court and is governed by NRAP, then a tolling motion tolls the deadlines
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associated with this appeal, and therefore, the transmittal of the Record on Appeal was
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premature, and the SBN's failure to file in and provide to the Panel Coughlin's tolling
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and other post-judment motions, is misconduct.

Atty. Griev. Commn v. Blum, 373 Md. 275, 29394, 818 A.2d 219, 23031 (2003)
(addressing Respondents motion for new hearing that was included in Respondents
exceptions)...[T]he issue of recusal in attorney discipline matters is within the
province of the Court of Appeals, not within the province of the hearing judge. Atty.
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Griev. Commn v. Shaw, 363 Md. 1, 1011, 766 A.2d 1028, 1033 (2001) (citing Atty.
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Griev. Commn v. Hollis, 347 Md. 547, 559, 702 A.2d 223, 229 (1997))" Page 15..."21
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Even if this Court were to accept Respondents motion to dismiss as exceptions, we
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would overrule the claims. Respondent argues that Rule 16-757, which states that the
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disciplinary hearing before Judge Cavanaugh was governed by the procedure
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applicable to a court trial in a civil action tried in a circuit court, entitles him to a seek
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a new trial, pursuant to Rule 2-535. This argument fails because Rule 16-758 governs
specifically posthearing procedure in attorney disciplinary cases, overriding the general
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provision in Rule 16- 757. See, e.g., A. S. Abell Pub. Co. v. Mezzanote, 297 Md. 26,
40, 464 A.2d 1068, 1075 (1983) (Ordinarily, a specific enactment prevails over an
incompatible general enactment in the same or another statute.). " Id. at 16. In Nevada
SCR 105(3) is such a specific enactment and it specifically calls for just the approach
Coughlin advocates for here, ie, application NRCP and NRAP in allowing tolling
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motions, etc. There is nothing in SCR that excludes such, and there is much within the
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SCR's that permits it.
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Further, NRAP The use of the term record in SCR 105(3)(b), along with SCR
119(3), arguably makes applicable NRAP 10 and 11. Coughlin filed several tolling
motions a ala NRCP 59(a)-(e) sufficinet to auguer towards striking the 12/24/12 filings
and Briefing schedule in 62337. Post-Judgment Tolling Motions NRAP 4(a)(4)
identifies the four recognized types of tolling motions: 1. A motion for judgment under
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Rule 50(b); 2. A motion under Rule 52(b) to amend or make additional findings of fact
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3. A motion under Rule 59 to alter or amend the judgment; and 4. A motion for a new
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trial under Rule 59. According to NRCP 50(b), 52(b) and 59, these tolling motions
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must be filed within 10 days after service of the written notice of entry of the judgment
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or order.
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Just what is included within the purview of those two terms (record and
decision) is not clear (arguably, the record should extend beyond the transcript and
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Hearing Exhibits to all pleadings on file, and all correspondence (including faxes and
emails between the Respondent, Bar Counsel, NNDB, Panel, and SBN Clerk of Court),
and all documents submitted for filing, even where such were not actually filed in by
the SBN's Clerk of Court (or, like with Coughlin's 10/31/12 Pre-Hearing MTD, MSJ,
Memorandum of Law, those that were filed in by the Clerk, but which, mysteriously,
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are absent from the ROA), and certainly all exhibits attached to any filings or
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documents submitted for filings.
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Also, arguably, the 12/14/12 FOFCOL is not a
decision, and any Recommendation contained therein is not announced thereas in
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the title of that filing, and was it not Judge Nash Holme's criticims that Coughlin's
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filing contained little in their body that related to the actual title of the filing itself (Hill
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made the same claim) that the Panel found supportive of its Findings of Fact;
Conclusions of Law?
Chief Justice Pickering's 2/7/13 Order (Our preliminary review of the record
in this case reveals that the record is not submitted in the proper format. The threevolume record contains double-sided pages, each volume exceeds 250 pages, and not
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all pages are consecutively numbered. The rules of appellate procedure require that
only one side of the paper may be used; moreover, each volume of the appendix is not
to contain more than 250 pages, and each page is to be numbered consecutively in
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the lower right corner. NRAP 30(c)(1), 30(c)(2), 32(a)(1)(A), 32(b). (So, NRAP 30
applies) Accordingly, we direct the clerk of this court to strike the three-volume
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record filed December 24, 2012, and we order the State Bar of Nevada to re-submit the
record in the proper format.) The use of the noun State Bar of Nevada, rather than
Clerk of Court etc., brings up some confusion with respect to a joint appendix and
the duties on the parties under NRAP Rule 30. The main point is, where the SBN
has chosen to try to take away Coughlin's law license forever (it has already devoured
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a year of Coughlin's life and much of his professional reputation and personal
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relationships, and of course, whatever respect for the State Bar of Nevada Coughlin
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ever had (not much after the 2002-2005 debacles), especially by casting such a
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ridiculously wide net in the complaint, violating SCR 105(2)(c)'s every single
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requirement, and jamming the opportunity to be heard of it all into six, or so hours of
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a formal hearing (wherein King was allowed to call Coughlin as a witness, accorded
his 15 minutes for direct, but Coughlin was not allowed to cross-examine
himself...And, upon Coughlin calling himself on direct (and, of course, the Panel
managed to eat up practially all of the 15 minutes Coughlin was allowed to testify on
his own behalf (which, was a completely ridiculous rule to put into effect, giving the
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Respondent only as much time to testify in his own defense as some ancillary witness
was accorded?) King was then accorded another fifteen minutes to question Coughlin,
then, through cross-examination.
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All of this establishes good cause for an extension of time for Coughlin to file
his Opening Brief. While Coughlin's earlier filings (especially the Motion to Strike the
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Record on Appeal and Declaration thereto filed on 3/19/12) could arguably be

construed as a Motion for Extension of Time, and therefore, this filing an supplemental
thereto, and, as such, making it unnecessary to demonstrate good cause, or excusable
neglect for any failure to timely move for such an extension found here (Coughlin's
internet connection, the eFlex system, or Coughlin's computer system experience
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technical difficulties between 11:00 pm and 11:59 pm on 3/20/12, preventing this filing
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being stamped on that date, but submitted very soon thereafter...with all of that added
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to a grueling 8 hours of trial in RCR2012-065630 on 3/19/12, in an extremely specious
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prosecution of Coughlin for resisting a public officer stemming from an original
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misuse of 911 emergency systemgross misdemeanor charge of 1/14/12
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(interestingly, Coughlin's public defener (Notice of Dogan's assignment as attorney of

record sent out, per office policy, within 10 days of the filing of the Complaint in
065630 on 1/24/12, Dogan's supervisor emailing Coughlin on 2/6/12 about Dogan's
appearing, and Coughlin and Dogan conferring about the case at length in person on
2/8/12, wherein Coughlin understood that Dogan would appear on his behalf and in his
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stead at the 2/14/12 arraignment and enter a not-guilty plea...instead, Dogan failed to
appear (despite Nevada law requiring Coughlin, where charged with a gross
misdemeanor, be provided represenation at all stages of the proceedings...) at that
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arraignment, and then refused to ameliorate his no show, and retaliated against
Coughlin's 2/21/12 filing in RJC RCR12-065630 by moving for an Order for
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Competency Evaluation on 2/27/12, along with the Washoe County Public Defender's
Officer calling RMC Judge Holmes (as admitted in Holmes 3/14/12 grievance against
Coughlin.
CURRY v. CLAYTON, 715 S.W.2d 77 (1986): In the
present case, Curry's motion to extend time stated that his delay
in filing his response to Clayton's requests for admissions was not
intentional but was merely the result of his attorney's "busy
schedule." A statement that the delay was due to the attorney's
"busy schedule," without more, is not sufficient to show good
cause for permitting the late filing of a response to requests for
admissions. Cf. Texas Employers' Ins. Assoc. v. Bragg,670
S.W.2d 712, 715 (Tex.App.-Corpus Christi 1984, writ ref'd n.r.e.)
(trial court did not abuse its discretion in denying motion for
leave to file late response to requests for admissions upon
allegations that respondent's attorney had numerous conflicting
trial settings and personal matters requiring his attention);Trevino
v. Central Freight Lines, Inc.,613 S.W.2d 356, 359
(Tex.Civ.App.-Waco 1981, no writ) (no abuse of discretion was
shown where the uncontradicted testimony established that the
failure to file responses to requests for admissions was solely due
to attorney's neglect)
CONCLUSION
Please grant this Motion for Extension of time to file Opening Brief.
Dated this 3/21/13
__/s/ Zach Coughlin_____
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CERTIFICATE OF SERVICE:
The undersigned hereby certifies that a true and correct copy of the
foregoingMOTION TO STRIKE 2/13/13 RECORD ON APPEAL was placed in a
sealed envelope and sent by U.S. Regular mail and certified mail, postage fully prepaid
thereon, to:
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Patrick O. King, Esq.

Nevada Bar No 5035
9456 Double R BLVD
Reno, NV 89421
Tel: 775 329 4100
patrickk@nvbar.org
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and was electronically served through the Nevada Supreme Court's eflex system on:
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David Clark, Esq., Bar Counsel, State Bar of Nevada, registered on this Court's eFlex
system
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Dated March 21, 2013

____________
Zach Coughlin
Appellant
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Index to Exhibits:
1. Exhibit 1: Declaration of Zachary Barker Coughlin
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2. Exhibit 2: various other relevant materials
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DECLARATION OF ZACHARY BARKER COUGHLIN:

I, Zachary Barker Coughlin, swear under penalty of perjury, NRS 53.045 that the
following is true and correct to the best of my knowledge:
1. I tried to file my Motion for Extension just prior to 11:59 pm on 3/20/12 but some
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technical malfunction resulted in my computer, the internet, eflex, or something

freezing up...Flagship West, LLC v. Excel Realty Partners, L.P., No. CV-F-02-5200
OWW/DLB, 2007 WL 1574967, at *79 (E.D. Cal. May 30, 2007) and Pace v. AIG,
No. 8 C 945, 2010 WL 4530357 (N.D. Ill. Nov. 1, 2010). In Flagship West, defense
counsel timely filed a posttrial motion but did not meet the courts deadline to file a
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memorandum in support of that motion. When filing the memorandum, the attorney
failed to complete the technical steps required for electronically filing of documents
by not clicking next on the last screen necessary to commit the transaction. Id. at
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*7. He correctly filed the following day, after the deadline. Id. The court was
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persuaded that excusable neglect existed because the filing attorney attempted to
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comply with the order of the court. Id. In Pace, the court found excusable neglect after
an electronic notice was diverted into a blocked e-mail folder at appellants counsels
law firm because the firms e-mail system classified the notice as spam. 2010 WL
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4530357, at *1. Although the court called the question close and questioned why the
notice evaded all six attorneys of record for the appellants, it found no reason to doubt
the veracity of counsels explanation here, [that was] supported by an affidavit and
evidence from his firms information...
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Additionally, the matter resulting in Couglin's now nine month long temporary
suspension, the 11/30/11 Trial in RMC 11 CR 22176 (and the 10/10/11 arraignment)
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ought be transcribed (involving an allegation of Coughlin consuming $14.00 worth of

a candy bar and cough drops while shopping for an paying for $83.82 worth of
groceries at and Indian Colony owned Wal-Mart, where an arrest was made by tribal
police that violated NRS 171.1255, and Coughlin was denied his Sixth Amendment
Right to Counsel, and the RMC failed to adhere to this Court's 2008 Indigent Defense
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Order and order the preparation of the transcript at public expense pursuant to NRS
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189.030, denied Coughlin a single continuance despite a multitude of factors weighing
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in favor of such, likely violate NRS 1.235 in finding Couglin in direct contempt
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following his making a motion to disqualify the Judge therein, and where Couglhin
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was summarily incarcerated, prejudice to his client's be what it may, for three days,
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despite being denied counsel for both the underyling petty larceny charge (Aigersinger
requires such) and the civil contempt charge that the Judge indicated would issue ten
minutes into the Trial (indicating such would issue at the Trial's conclusion,
whereupon Coughlin requested to be appointed counsel in that context as well,
Feiock).
Additionally, incident to the criminal trespass matter in 61901, there is a
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transcript of the 6/18/12 Trial in 11 CR 26405, however, this matter would benefit
greatly by the transcription of the hearings therein on 2/2/12, 4/10/12, and 5/8/12,
especially where the matters addressed on the record therein are so pertinent to the
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allegation of numerous violations of the mandatory stay in NRS 178.405, recusal and
disqualification motions, right to counsel, and RPC 1.2 issues related to court
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appointed defenders, and more).

SCR 105(3)(b): The parties shall not be required to prepare an appendix, but
rather shall cite to the record of the disciplinary proceedings. If no opening brief is
filed, the matter will be submitted for decision on the record without briefing or oral
argument.
Couglin requests leave to submit such an appendix, and an extension of time to
do so, especially given the lack of communication or cooperation in creating a joint
appendix on Bar Counsel and the SBN's part. NRAP 30
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NRAP RULE30.APPENDIX TO THE BRIEFS

(a)Joint Appendix; Duty of the Parties.Counsel have a duty to confer and
attempt to reach an agreement concerning a possible joint appendix. In the absence of
an agreement, the parties may file separate appendices to their briefs.
(b)Contents of the Appendix...(1)Transcripts.Copies of all transcripts that
are necessary to the Supreme Courts review of the issues presented on appeal shall be
included in the appendix.
(2)Documents Required for Inclusion in Joint Appendix.In addition to the
transcripts required by Rule 30(b)(1), the joint appendix shall contain:...
(E)Verdict or findings of fact and conclusions of law with direction for entry
of judgment thereon...
(J)Proof of service, if any, of:
(i)the summons and complaint;
(ii)written notice of entry of the judgment or order appealed from;
(iii)post-judgment motions enumerated in Rule 4(a); and
(iv)written notice of entry of an order resolving any post-judgment motions
enumerated in Rule 4(a).
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(1)Order and Numbering of Documents.All documents included in the

appendix shall be placed in chronological order by the dates of filing beginning
with the first document filed, and shall bear the file-stamp of the district court
clerk, clearly showing the date the document was filed in the proceedings below.
Transcripts that are included in the appendix shall be placed in chronological order by
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date of the hearing or trial. Each page of the appendix shall be numbered consecutively
in the lower right corner of the document. Page 216 of the ROA in 62337 is
particularly trouble hearing, as its positioning (and therefore, the dates of filing for
the 10/9/12 Affidavit of Laura Peters (which shouldn't even be filed as it lacks a
caption and case number, and is not attached to
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(d)Exhibits.Copies of relevant and necessary exhibits shall be clearly

identified, and shall be included in the appendix as far as practicable. If the
exhibits are too large or otherwise incapable of being reproduced in the appendix,
the parties may file a motion requesting the Supreme Court to direct the district
court clerk to transmit the original exhibits. The Supreme Court will not permit
the transmittal of original exhibits except upon a showing that the exhibits are
relevant to the issues raised on appeal, and that the Supreme Courts review of
the original exhibits is necessary to the determination of the issues.
(e)Time for Service and Filing of Appendix.A joint appendix shall be filed
and served no later than the filing of appellants opening brief. An appellants
appendix shall be served and filed with appellants opening brief. A respondents
appendix shall be served and filed with respondents answering brief. If a reply brief is
filed, any reply appendix shall be served and filed with the reply brief.
(g)Filing as Certification; Sanctions for Nonconforming Copies or for
Substantial Underinclusion.
(1)Filing an appendix constitutes a representation by counsel that the appendix
consists of true and correct copies of the papers in the district court file. Willful or
grossly negligent filing of an appendix containing nonconforming copies is an
unlawful interference with the proceedings of the Supreme Court, and subjects
counsel, and the party represented, to monetary and any other appropriate
sanctions.
(2)If an appellants appendix is so inadequate that justice cannot be done without
requiring inclusion of documents in the respondents appendix which should have been
in the appellants appendix, or without the courts independent examination of portions
of the original record which should have been in the appellants appendix, the court
may impose monetary sanctions...
The ROA filed by the SBN is materially deficient given the applicability of
NRAP 32 (see 2/7/13 Order in this matter): NRAP RULE32.FORM OF BRIEFS,
THE APPENDIX AND OTHER PAPERS
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(a)Form of a Brief....
(1)Reproduction.
(A)A brief shall be reproduced by any process that yields a clear black
image of letter quality. The paper must be opaque and unglazed. Only one side of
the paper may be used.
(B)Text must be reproduced with a clarity that equals or exceeds the
output of a laser printer...
(4)Paper Size, Line Spacing, Margins, and Page Numbers... Margins must be
at least 1 inch on all four sides.
Coughlin requests permission to file an additional few pages to supplement this
Motion beyond the 10 page limit.
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SCR 105(4). Rules of procedure. The chairs, after consulting with their
respective disciplinary boards, may adopt rules of procedure, subject to approval by the
board of governors.
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Coughlin diligently attempted to obtain express indications from the Clerk of
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Court/sbn/nndb/and paenl respective the applicable rules of procedure in this matter
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incident to the dicdtates of scr 105(4), but was given the runaround or had the rug
pulled out from under him by all involved:
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Coughlin has been met with silence in his attempts to have the
NNDB/Panel/OBC provide him something in writing or directions as to how I may
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obtain a copy of any rules adopted pursuant to SCR 105(4) pr any other procedural
polices, rules, or procedures? Does the NNDB have a position respecting the
misrepresentations made by King and Clerk of Court Peters vis a vis the SBN asserting
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the 8/23/12 mailing as a basis for a finding of SCR 109 compliance? Is it the position
of the SBN and NNDB that Asst. Bar Counsel King may communicate with the Panel
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outside of Coughlin's presence as to substantive and procedural matters?
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From: tsusich@nvdetr.org To: zachcoughlin@hotmail.com CC:

PatrickK@nvbar.org Date: Fri, 27 Jul 2012 08:58:01 -0700 Subject: RE:
referral to Northern Nevada Disciplinary Board Dear M. Coughlin: I am
in receipt of your request for a hearing before the Northern Nevada
Disciplinary Board. I have forwarded your request to the Nevada State
Bar's Northern Office for processing. Please communicate directly with
the State Bar concerning your case. They are the ones who will process
your request and set up any appropriate hearings. If you have questions
you can contact Pat King, the Northern Nevada Bar Counsel. Sincerely,
J. Thomas Susich, Esq. From: Zach Coughlin
[mailto:zachcoughlin@hotmail.com] Sent: Thursday, July 26, 2012
10:30 AM To: Tom Susich Subject: referral to Northen Nevada
Disciplinary Board Dear Mr. Susich, I am writing to request a hearing
before the Northen Nevada Disciplinary Board and to make sure the
Board has the correct contact information for me. I am representing
myself. Sincerely, Zach Coughlin PO BOX 3961.
Then there is Clerk of Court Peters and King repeated written admissions that
fax filing was permissible. And even though Coughlin definitely made very, very clear
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to Peters that he was not indicating one way or the other whether he had received the
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complaint during the 9/11/12 conversation, she, for some reason, decided to swear that
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he had, but regardless, that doesn't matter. Clerk's must file in what is submitted for
filing, not make arbitary decisions such as that Peters only claimed to make after the
fact, and where she failed to at all promptly inform Coughlin thereof (only upon
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Coughlin pointing out his motion to dismiss went unresponded to by the SBN) did
Peters bring her emailed why would I filed in your motion to dismiss when you said
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you didn't get the complaint?. Well, there is the whole part about Whitman, Sullivan,
NRCP 5(e), here duty to, etc., etc. Also, the failure to file in numerous of Coughlin's
filing s rest on entirely arbitary decision by King and Peters that this or that was later,
couldn't be characterized as something else, may have involved a defense that was
waived (not if the supplemental came before King's Opposition, and a late Reply
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could be characterized as a Motion for Reconsideration, etc., regardless, it should be in
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the record. Additionally, Coughlin has filed or submitted appropriately the the SBN
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Clerk of Court a timely Motion for New trial or alternatel Motion to Alter, Amend or
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otherwise seek Reconsderation of the 12/14/12 FOFCOL by Chair Echverrria and has
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received no response or indication from either the SNB/Panel/or Board as to whether it
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was filed in or being reviewed.

knowledge of relevance that the judge had percipient recollections of. There are a
multitude of difficult and thorny issues respective contact with represented parties
that and discovery, subpoena power, and evidence rules and rules related to contact
with represented parties, amibuity with respect to judges as grievants, refusals by the
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SBN to properly and or timely identify whom the grievants are (thereby presenting
Coughlin with a minefiled of RPC 4.2 (and Comment thereto) issues resulting in no
reasonable opportunity for Coughlin to take advantage of the due process required
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prior to a Fourteenth Amendment protected property right like a law license being
taken away.
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NRAP RULE10.THE RECORD
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(a)The Trial Court Record.The trial court record consists of the papers
and exhibits filed in the district court, the transcript of the proceedings, if any, the
district court minutes, and the docket entries made by the district court clerk...
Despite the FOFCOL citing to the Pleading Docket Coughlin had never seen one
from the trial court, despite requesting such from the SBN, OBC, Clerk of Court
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Peters, and the Panel.
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(1)Retention of Record.The district court clerk shall retain the trial court
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record. When the Supreme Court deems it necessary to review the trial court
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record, the district court clerk shall assemble and transmit the portions of the
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record designated by the Supreme Court to the clerk of the Supreme Court in
accordance with the provisions of Rule 11. Any costs associated with the preparation
and transmission of the record shall be paid initially by the appellant, unless otherwise
ordered. Obviously, the LITIGATION HOLD NOTICE Coughlin placed King,
Peters, the SBN, and the Panel on respecting the insufficient postage the SBN placed
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on the 10/9/12 Notice of Intent to Take Default ought prove useful in requiring the
SBN explain any asserted losing or do not retain such things excuses the SBN may
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offer should this Court grant the request Coughlin herein makes to require the SBN to
turn over the envelope returned to sender (the SBN) upon the USPS refusing to release
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that 10/9/12 NOITTD mailing to Coughlin in light of the insufficient postage placed
thereon by the SBN. Coughlin made the preparation of the appendix or record on
appeal exceedingly easy and economical for the SBN, providing his lengthier exhibits
on cd, making for easy electronic filing and transmittal to the N. S. Ct., and making
this Court's Clerk of Court's tasks in assembling the ROA for each Justices review far
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easier and economical. Additionally, it is not Coughlin's fault that King crafted a
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shotgun type of complaint, completely devoid of any sense of proportion or specifics
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(12 RPC's alleged violated an unenumerated number of times..crammed ridiculously
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into a barely 5 page long Complaint, that failed to attach or incorporate or adopt most
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of the Exhibits King sought admission of at the Hearing).
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(b)The Appellate Court Record.

(1)The Appendix.For the purposes of appeal, the parties shall submit to the
Supreme Court copies of the portions of the trial court record to be used on
appeal, including all transcripts necessary to the Supreme Courts review, as
appendices to their briefs. Under Rule 30(a), a joint appendix is preferred. Where
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Coughlin went to the trouble to have the transcript of the 6/18/12 criminal trespass trial
prepared and provided it in both digital and hard copy form (in addition to an unofficial
transcript of most of the 10/13/11 and 10/25/11 summary eviction proceeding/unlawful
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detainer Trial, the SBN saw fit to include those in the ROA only in a four page per
page form, made entirely illegible upon some extremely specious fiddling with the
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scanner and copier settings by the SBN. There are dpi requirements. Coughlin used a
1200 dpi laser printer at all times. Even if the SBN is able to excise from the record
the pdf's indigent Coughlin included in the discs attached to his filings (Coughlin is no
longer surprised by anything the SBN does, and, in fact, began anticipating much of
the ultra questionable tactics the Clerk of Court and OBC engage in fairly early
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on...leading to attaching Exhibits, at times, in both disc and hard copy form, though
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Coughlin's indigency at times resulted in his printing out four pages per page (as
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Coughlin could not use his duplex printer the with the reckless abandon the SBN so
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often did, given the risk that the SBN would claim Coughlin's filing must be stricken
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were they to have been printed on both sides of the page like the SBN's were, often).
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(2)Exhibits.If exhibits cannot be copied to be included in the appendix, the

parties may request transmittal of the original exhibits to the Supreme Court
under Rule 30(d). Coughlin hereby so requests (though he has already discussed this
concern at length with Deputy Clerk Castillo, and Clerk Lindemann and pointed out in
various previous filings (or documents submitted for filing, which the N.S.Ct. Clerk's
Office chose not to file (including those of 1/24/13 and 1/29/13 or thereabouts;
meaning, Coughlin has arguably already made such a request under Rule 30(d) for the
transmittal of the original exhibits, including the discs attached to his filings as
exhibits.
(c)Correction or Modification of the Record.If any difference arises about
whether the trial court record truly discloses what occurred in the district court,
the difference shall be submitted to and settled by that court and the record
conformed accordingly. Questions as to the form and content of the appellate
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court record shall be presented to the Supreme Court. The problem with that is
the SBN keeps threatening to abuse process anytime Couglin brings up such matters,
then the SBN has the RPD come down to Coughlin's residence and point a loaded gun
at his head from four feet away to send a message. King's TPO application is
completely ridiculous and shameful, as has been Clerk of Court Laura Peters behavior
throughout this matter.
NRAP RULE11.PREPARING AND FORWARDING THE RECORD
(a)Preparation of the Record.Upon written direction from the Supreme
Court, the district court clerk shall provide the Supreme Court with the papers or
exhibits comprising the trial court record. The record shall be assembled, paginated,
and indexed in the same manner as an appendix to the briefs under Rule 30. If the
Supreme Court determines that its review of original papers or exhibits is
necessary, the district court clerk shall forward the original trial court record in
lieu of copies. It is definitely necessary her, but Coughlin is preparing and has
been an Appendix or Record of his own, though good cause for this extension
extends into the extent to
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(1)Exhibits.If the Supreme Court directs transmittal of exhibits, the exhibits

shall not be included with the documents comprising the record. The district court
clerk shall place exhibits in an envelope or other appropriate container, so far as
practicable. The title of the case, the Supreme Court docket number, and the number
and description of all exhibits shall be listed on the envelope, or if no envelope is used,
then on a separate list.
(2)Record in Proper Person Cases.When the Supreme Court directs
transmission of the complete record in cases in which the appellant is proceeding in
proper person, the record shall contain each and every paper, pleading and other
document filed, or submitted for filing, in the district court. The record shall also
include any previously prepared transcripts of the proceedings in the district court. If
the Supreme Court should determine that additional transcripts are necessary to
its review, the court may order the reporter or recorder who recorded the
proceedings to prepare and file the transcripts....
Under Waters the SBN is an arm of the Court, the Nevada Supreme Court, and
it is not clear that the SBN is a district court a la NRAP 10...However, Coughlin has
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attempted to seek correction or modification of the record in line with NRAP 10(2)(c),
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but given the SBN's propensity for baseless histrionics (stay away letters, calling the
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police upon a Respondent complying with an SBN Order to call ahead 15 minutes if
they are headed to the SBN to file something with Clerk of Court Peters, filing for
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workplace harassment protection orders, though failing to put up the statutorily

required bond and failing to withdrawal upon King becoming a witness where
previously he was, allegedly, only counsel, having indigent Coughlin arrest upon some
specious allegation of his violating a TPO and the subsequent EPO (both of which are
subject to attack on numerous grounds and where obtained on a questionable default
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basis where service of the TPO and notice of the extension hearing may have been
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deficient, violative of both the courthouse sanctuary rule, and the immunity often
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accorded to attorney's and litigants when accessing justice in court and filing offices.
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Coughlin has been declared indigent as recently as in a 1/9/13 Order by a Second
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Judicial District Court Judge, and such arrest required some $750 cash to bail Coughlin
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out, and seemed to be little more than an attempt to obstruct Coughlin's ability to
pursue this appeal and or intimidate him out of pointing out that which has necessarily
prejudiced Coughlin's ability to do so, and were such was a mitigating factor attendant
to all the various allegations against Coughlin, none of which actually have merit.
Coughlin is temporarily suspended (as WCDA DDA Watts-Vial pointed out in his last
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minute 11/13/12 faxed objection to Coughlin's subpoenas upon 2JDC Judges and
personnel; SCR 110(4) applies not NRCP 45, further, even if NRCP 45 did apply,
Coughlin, even while suspended (not suspended by the U), and, as such, should be
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accord pro per status hearing, as he was in 60302 (which, along with 60317 (a matter
presided over by a Judge who was on the Executive Board of the entity Coughlin had
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joined as a defendant in the wrongful termination suit against WLS and Paul Elcano,
whom the Bar called as a witness at Coughlin's formal disciplinary hearing, despite
constructive notice thereof only being provided to Coughlin the day prior to the
hearing, and where the Bar sought to have Hill provide expert testimony thereto.
Coughlin hereby request this Court Order the preparation of additional transcripts, at
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public expense, that are necessary to its review (which is a de novo review)
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(including the transcript of both hearings in 11 TR 26800, that resulted in NG12-0434
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and arguably were required to have already been prepared upon indigent Coughlin
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filing (since stricken where that contempt order is a final appealable order, thus, RMC
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in violation of NRS 189.030) multiple Notices of Appeal of such final appealable
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Orders as those of 2/28/12 and 3/12/12 in that matter, RMC 11 CR 26405 (which
became 61901, and is at issue in 60331 and 61383). Further, the summary eviction
proceeding involving Richard G. Hill, Esq., (the grievant in NG12-0204, outside of
whose office the traffic citations the subject of the trial in 11 TR 26800 that begat
NG12-0434 (and therefore NG12-0435 considering the fact that Bar Counsel obtained
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the Formal Hearing Exhibit 3 via it being passed from the judge to her brother, whom
was the judge on the criminal trespass trial in 11 CR 26405, where Hill signed the
criminal complaint therein, upon his lying to the police resulting in the wrongful arrest
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of Coughlin (and there is a multitude of videos of these various arrests of an

exculpatory nature that Bar Counsel King and the Panel have curiously avoided like
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the plague, sufficient to justify this Court requiring the SBN to transmit copies of all
the Exhibits in this matter, including those attached to documents Coughlin submitted
for filing, but, for whatever reason, the SBN chose not to file, curiously, including all
the audio transcripts of the various hearings at issue in King's 8/23/12 Complaint and
the multitude of insufficiently notice subject matter not included therein that found its
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way into the 12/14/12 FOFCOL). That summary eviction from Coughlin's former
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home law office in RJC Rev2011-001708, and the appeal thereof (Hearing Exhibit 1
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emanates from that appeal in CV11-03628, though not plead in the Complaint in any
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way...whereas the jaywalking arrest that Hill succeeded in subjecting Coughlin to on
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1/12/12 was pled in the Complaint, though the Panel refused to admit a video
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thereof....including footage of Hill's prevarications to the police). The dates of the

summary court eviction that are necessary and should be transcribed are 10/13/11,
10/25/11, 11/7/11, 12/20/11, and the Show Cause hearing in the appeal thereof on
3/23/12 and 3/26/12. Further, given the primacy accorded to a bankruptcy Judges
testimony, especially where such was only constructively noticed to Coughlin the day
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before the hearing, the scant appearances before that Judge ought be transcribed, or at
least the audio transcripts furnished and transmitted at public expense (NVB 10-05104,
11-05077 and 11-05078), or, such testimony stricken, given the enormously prejudicial
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nature thereof, the violations of SCR 105.5 and gratituitous Coe Swobe name dropping
therein, and the utter paucity of specifics provided or opportunity to cross-examine
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given the enormously overreaching nature of the testimony, and curious peripheral
coincidences attendant thereto. Additionally, the Trial from which NG12-0435 springs,
in DV08-01168 is necessary and should be transcribed as well. Coughlin provided the
audio transcripts of all of these matters as Exhibits to his various documents submitted
for filing.
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1. I had a telephone, fax, and email communciations with Bruce Lindsay, Esq., and his
staff Of the Law Office of Bruce Lindsay, Esq., wherein I was told the following:
Ms. Sims indicated to me on 3/5/13 that she had spoken with the RJC on 3/4/13
to confirm the time of the Show Cause Hearing involving Zach Coughlin on 3/5/13 and
the case number of the same and that such was still on calendar. Ms. Sims indicated to
me that she was told the Show Cause Hearing was still on calendar, to be held before
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Judge Clifton, in case number RCR2012-067980, the case wherein Bruce Lindsay,
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Esq., suddenly appeared the morning of the 1/7/13 hearing in RCR2012-067980
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following WCPD Jim Leslie, Esq's questionable withdrawal and failure to oppose or
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even address (by Leslie or DDA Young), Coughlin's 12/3/12 Motion therein (see
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attached).
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I was taken in to custody on 2/12/12 RCR2012-065630 upon appearing late to

court by one hour. I appeared and conducted a cross-examination of ECOMM's
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Carthen, then was remanded into custody, despite being out on an OR release and not
having ever failed to appear previously. I did not fail to appear on 12/11/12 in 065630
at 8:30 am, but rather, was set to appear at the 1:00 pm start time as had been changed
as communicated to me expressly by RJC Criminal Division Clerk Robbin Baker the
week before. Judge Clifton dismissed my assertion that Clerk Baker had
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communicated the start time had been pushed back, then refused to indicate how he
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could be sure she did not so communicat such to me. As such, my position is that any
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such warning issued in regard to my allegedly being late to court on 12/11/13. My
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position is that I have never been late nor failed to appeared to any hearing or trial date
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in 12-065630. I was taking off my medication against my will by the Washoe County
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Jail staff upon being taken into custody at noon on 12/11/13, then brought to a 9:00 am
Contempt or Show Cause hearing the next morning, whereupon I was brought into
custody, in jail reds.
Coughlin has learned that Mr. Lindsay's Office has yet to file one Notice of
Appearance in any of the various matters to which the RJC Bailiffs and Filing Office
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have been purporting Mr. Lindsay to be Coughlin's Attorney of Record (see WDCR
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Rule 3) (whether it be in RCR2011-063341, RCR2012-065630, RCR2012-067980, the
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new RCR2013-071439 (which is now, curiously featuring a new, altered version of the
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original 12/20/12 Administrative Order 2012-01 baring a caption of only In the

Administrative Matter of Zachary Coughlin and no case number of opposing party
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(there is no corollary to SCR 99 for the Justice Court and the inherent authority or
power of such does not extend to usurping the executive branch's function in sua
sponte entering Orders such as that of 12/20/12, and 2/25/13 in AO2012-01 In the
Administrative Matter of Zachary Coughlin, please incorporate by reference all of the
arguments in Coughlin's 2/28/13 and 3/1/13 filings in AO12-01 and RCR11-063341)
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was faxed to Linday's Office on 2/28/13 at which point Lindsay was in no way
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Coughlin's attorney or record in AO12-01 or RCR2011-063341, though some fallout
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may be gleaned from the failure of the 2/25/13 combination hearing in RCR2012-
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067980 and RCR2011-063341 (presumably a Gagnon I style hearing as Coughlin has
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yet to be provided any written notice of the allegations and facts in support of the
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summary arrest for an alleged DAS probation violation made by Officer Ramos on
2/1/13 in RCR11-063341, and such is a due process requirement prior to any such
Show Cause hearing or Probation Revocation Hearing being held. Coughlin paid the
$500 cash bond on that arrest.
. Further, While the RJC Filing Office has been indicating to Mr. Lindsay's Office's
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Sims that the 3/5/12 Show Cause hearing was in RCR2012-067980, upon Coughlin
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arriving at that hearing, and making clear that he was not giving up in any way his self-
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representing status (ie, no sole attorney of record designation for Lindsay allowing the
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recent deprivation of Coughlin's right to file documents in these various matters),

Judge Pearson indicated on the record that the RJC then sought to orally amend the
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2/25/13 Order to Show Cause (which, again, lacks any case number, and has a caption
with only the In the Administrative Matter of Zach Coughlin an referecing the
12/20/12 Administrative Order 2012-01 by then Chief Judge Sferrazza) in some
manner to thereby accord it an actual case number from one of Coughlin's then existing
criminal prosecutions. Such is not permissible and Coughlin preserved his objections
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thereto at both the 3/5/13 Show Cause Hearing and any continuance connected thereto
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to be gleaned from the record and any notice thereof with respect to the 3/11/13
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Hearing at which Coughlin appeared on his own behalf, and wherein Coughlin in no
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way gave up his designation as his own attorney or record in any matter wherein
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Coughlin is being prosecuted or subject to an Administrative Order. Further, the RJC's
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practice throughout this year of failing to recognize then licensed attorney Coughlin's
Notices of Appearance, Substitution of Counsel, and Authorizations to Represent on
file in these various matters appears to be impermissible. Coughlin has been denied
standby counsel in RCR2012-065630, though such may be required under the law, and
Coughlin hereby requests a stipend of some sort to offset that, and to seek his own
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private, and self chosen stanby counsel and or co-counsel.

At the 3/5/13 Show Cause Hearing for the Administrative Order 2012-01
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stemming from an impermissibly short notice period where the 2/25/13 Order to Show
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Cause was insufficiently served by RJC Bailiff Ramsey, in the courthouse, while
Coughlin was heading to a DAS check in and perhaps to file documents or conduct
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other business related to his various cases, Judge Pearson mentioned, on the record,
some alleged failure of Coughlin to have a mental health evaluation done in
connection with RCR2011-063341. The 3/5/13 Show Cause Hearing in no way related
to that matter, and may not now be shoehorned into it retroactively, nor may the
12/20/12 Administrative Order 2012-01 be affixed, retroactively, with some RCR2013-
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071437 case number, and no new file stamp, nor may the subject matter set out in the
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2/25/13 Order to Show Cause in AO12-01 be reference as a justification for any
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reinstatement to CCP now being shoehorned into RCR2011-063341, where Mr.
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Lindsay was not Coughlin's attorney of record, and where, it has been learned, Mr.
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Lindsay had yet to even be provided the file, much less the Complaint in that matter,
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much less any written notice of the alleged probation violations, prior to arriving to
court on 3/11/13, twenty minutes late, being informed by his client (who had been
crying due to a delay in getting his medication from NNAHMS that resulted in his not
having his medication for 2 days leading up to that hearing, which Coughlin pointed
out on the record (that and Lindsay's fax of 3/5/13 to Judge Clifton arguably required
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an Order for Competency Evaluation or staying proceedings, not jamming through 3

years of probation where only 2 years is permissible, on a set of facts not in any ways
connected to the case number 11-063341, that such reinstatement into DAS and CCP
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was later apparently rendered or entered into (Coughlin has yet to be provided any
Judgment or Order in any matter of case stemming from that 3/11/13 hearing, and
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Lindsay informed Coughlin that nothing would and nothing was ruled on or entered
beyond a two week continuance of all matters allowing for more pursuit of global
resolution with the WCDA's Office, which has gone against Judge Clifton's Order of
11/27/12 in RCR2012-065630 in failing to take calls from Coughlin, or allow voice
mails, and, in fact, threatening Coughlin with prosecutions and protection orders where
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Coughlin is simply seeking a stipulation to a continuance from opposing counsel prior
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to filign such a motion and conducting other regular business in connection with the
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defense of a prosecution.
What has become apparent, given the multitude of stipulations to continuances
that Mr. Lindsay has granted the WCDA's DDA Young in RCR2012-067980, and the
dismissal of that charge in the plea bargain Coughlin agreed to voluntarily, on the
record on 8/27/12 in a combination hearing that sought to dispose of all three then
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pending criminal prosecutions (and no Order or minutes reveals any justifiable basis
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for depriving Coughlin of his inviolable right to decide whether or not to take such a
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plea bargain or go to Trial and Coughlin hereby seeks to have that deal enforced as to
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all three such cases)) is that the WCDA's Office recongizes how very flawed the arrest
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of 6/28/12 in 12-067980 was, especially in connection with the suspect summary
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eviction in RJC Rev2012-001708, the fraudulent 6/14/12 Declaration of Service of the

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5 day UD Notice therein, the unauthorized practice of law by Nevada Court Services
therein, especially at the 7/31/12 Hearing, the extent to which the Order following such
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Hearing exceeded the bounds of the Notice of Such Hearing, the sua sponte
questioning by the Court therein respecting whether Coughlin prepared food or other
similar questioning...The 6/26/12 written communication by Coughlin to the RJC and
the Sparks Justice Court, Coughlin's submitting for filing his Tenant's Answer to the
forum listed for doing so on the deficient 5 day notice by NCS, which listed,
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incorrectly, Sparks Justice Court as the court in which Coughlin must file a Tenant's
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Answer (Coughlin should not be made to pay, both civilly and criminally, the price for
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Northwind's Apartments failing to hire an actual attorney...and further, the RPD
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trumped up a disturbing the peace charge and custodial arrest against Coughlin on
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7/3/12 in RMC 12 CR 12420 that resulted in Coughlin spending 18 days in jail, during
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which time his ability to file a NRCP 59 or 52 to challenge the $42K atty fee awarded
to Hill in the appeal of RJC Rev2011-001708 was compromised (and the opposition to
such 4/19/12 impermissible post-judgment sanctions motions (especially where no 21
day safe harbor procedural requisite under NRCP 11 was served on Coughlin) was
compromised by both WCPD Goodnight and WCDA DDA Young breaking NRS
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178.405's mandatory stay where jurisdiction was not returned to the RJC from CR120376, as to any department, until 5/19/12, by Order of D10's Judge Elliott. The
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Opposition was due the day Young and Goodnight tried to hold a Trial in RCR11063341.
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Further, while Judge Pearson indicated at the 2/2/13 hearing in rcr11-063341

(which was incorrectly noticed on Coughlin's jail release paperwork at to occur on
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2/5/13...which is one of the dates listed as involving an impermissible contact with
RJC staff by
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The 2/25/13 Order to Show Cause lists an alleged contact (though no Affidavit
or name of accuser as required for such conduct outside the court's presence, under
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NRS 22.030, or NRS 22.010, or even NRS 22.100, and if its criminal contempt a la
NRS 199.340, there are much stricter procedural due process requisites to be met that
have not herein) with the RJC on 1/7/13, a day where, as far as Coughlin knew, the
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pre-trial hearing in rcr12-067980 was still on calendar despite WCPD Leslie's dubious
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exit on 12/18/12...and while the Case Summary in 12-067980 indicates that Lindsay
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was appointed on 12/20/12, though neither he nor his office made any attempt to
communicate with Coughlin as required by RPC 1.4 until just prior to the start time of
the 1/7/13 hearing. Regardless, the 2/25/13 OSC itself appears to recognize some
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statement by an RJC Bailiff that day as amounting to a clarification of the 12/20/12

AO12-01, and, as such, not a basis for an alleged violation of such. The text of the
12/20/12 Ao12-01 would not seem to even allow calling the Bailiff station on the
phone, so, arguably such Order was not clear or has been interpreted to allow
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reasonable modification or de minimis violations thereof where circumstances and the

efficient adminstration of justice (which includes Coughlin's participation therein) so
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requires.
The 2/25/12 OSC goes on to reference some alleged contact on 1/23/13, though
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absolutely no specifics are provided. Where such contact involves any form of contact
with a DAS officer, whether by phone, fax, or email, such an allegation is not
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supportable to the extent it purpots to represent a violation of the AO12-01. Judge

Pearson, at the 2/1/13 hearing in 11-063341 verbally, not in writing, on the record,
indicated that DAS was under the umbrella of the RJC, which may have apparently
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been some attempt to bring the DAS Office (not an area under the exclusive control
of the RJC, some might say) within the purview of the 12/20/12 AO12-01).
Subsequently, and only after some alleged Consent Order was purportedly agreed to by
Lindsay and or Coughlin resulting in Coughlin being place, for 36 months, or
reinstated in to DAS and the CCP program (where no DAS violations or allegations
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where mentioned at all at such 3/11/13 hearing, no DAS witnesses present, DDA
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Young barely made it to the hearing, and he was late as well...) did Judge Pearson
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indicate, on the record, that DAS is, in fact, separate from the RJC, and, apparently, not
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within the purview of the 12/20/12 AO12-01, and without more, the allegation in the
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2/25/13 OSC as they relate to 1/23/13 would seem to be retracted. Any allegation of
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talkign to a Family Court Judges Deputy would similarly be outside the purview of
AO12-01.
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Coughlin has learned that there are apparently other instances where Coughlin is
alleged to have contacted other RJC employees whom are not Bailiff's, yet such were
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not included in the 2/25/13 OSC, apparently, given the de minimis or good faith nature
of such contacts, and arguably, and of those such alleged contacts left in the 2/25/13
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OSC are of a similar nature (if the RJC had intended for the 2/5/13 hearing reference in
Coughlin's jail release papers to be a Gagnon II style hearing, such was not indicated at
the 2/2/13 Hearing, as Coughlin was instructed on the record, and perhaps via a paper
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slip, that such matter was continued until 2/25/13...Nonetheless, Coughlin means no
disrepect to anyone and resolves to redouble his efforts to stricly comply with such
AO12-01 or the various iterations thereof (and different case numbers accorded
thereto) without waiving any objections he has as to the voideness of illegitimacy of
such Order, simply out of respect for the RJC and its Judges and personnel and in an
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effort to resolve matters.

Ms. Sims went on to indicate, and indicated she was sending a fax to Judge
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Clifton at 775-325-6591, 3 pages in length including the fax cover page, Subject:
Zachary Barker Coughlin, and copying DDA Young via fax thereon at 775-325-6703
that day containing consisting of the following text:
Dear Judge Clifton,
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This letter is in regards to the above referenced Defendant and

the three oustanding criminal matters before this Court. My offfice has
spoken with Bob Bell's office with regards to app on these cases and it
was suggested by him that you appt me to these cases and that I will
then bill Bob Bell with the conflicts attorneys group. I just had that
discussion with him this morning. My office has also spoken with bob
bell with regards to the mental health assistance that is also available
through the state on his behalf. I am aware that Mr. Coughlin had an
Order To Show Cause Hearing in RCR2012-067980 in your
Department 5 before Your Honor this afternoon at 2:00 pm.
Unfortunately, I am in Trial before Judge Steinheimer on March 4th
through March 6th 2013, as such I am unable to make it to that
hearing.
Your Honor, Mr. Coughlin has been working diligently with our
office to try and resolve his legal issues as well as his mental issues.
He has been to several appointments at NNAHMS and has been taking
his medication, but at their request, more appointments and counseling
are scheduled and needed before he will be stable with his medication
and his counseling.
Simply put, we plead with you to not arrest Mr. Coughlin, which
will only hinder the progress that has been made to date. Instead, we
would request that the Order to Show Cause be reschedule to another
date. This would also allow Mr. Coughlin to continue without the
interuption of an arrest, which would reverse his progress with his
medication, NNAHMS counseling, and appointments, all of which he
desperately needs. It would also allow Mr. Young and I to get together
and discuss these matters and with any luck come up with a global
resolution that will put an end to these matters.
Sincerely, Bruce Lindsay, Esq.
Lindsay's and his Office continually have implored Coughlin to simply trust
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them, and not ask questions, and not overthink things, but rather blindly follow
their instructions, insisting this is not about the money to them, then alternately
indicating that Lindsay showed upon at the 2/13/13 Contempt Hearing (Coughlin has
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been denied the Case Summary and Minutes therefrom and has never received
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anything in writing indicating whether any judgment or ruling rendered therein was a
misdemeanor, criminal or civil in nature.
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Lindsay and his office continually stressed the desire to keep Coughlin out of
jail, with absolutely no analysis as to the legitimacy of the underlying charges or the
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reasonableness of sentencing Coughlin to any jail time, either with respect to the vague
accusations made within the 2/25/13 Order To Show Cause personally handed to
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Coughlin by a party opponent, RJC Bailiff Ramsey, in violation of the courthouse

sanctuary rule and the immunity from service of process as to litigants and attorneys
(Coughlin is an attorney, the SBN continues to refer to him as such in writing,
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including in the 11/14/12 Transcript of the formal disciplinary hearing and the 8/23/12
Complaint in NG12-0204, NG12-0434, NG12-0435, and in the NNDB's 12/14/12
FOFCOL, which recommends to permanently disbar Coughlin in Nevada from the
practice of law, something the SBN's King, in filing a TPO application wherein he now
must withdraw as bar counsel of record in the appeal and underlying disciplinary
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matter in 62337, by his filing for a TPO, which was subsequently granted on 12/20/12
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and extended to a EPO in RJC RCP2012-000607, which resulted in Coughlin having a
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loaded gun pointed at his head from four feet away by RPD Officer Waddle upon the
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RPD, just days after Coughlin sent an email to the WCDA's Office detailing various
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issue, arriving at Coughlin's residence, going through a closed side gate into the
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backyard, failing to announce their presence in any way prior to drawing their
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weapons, and coming upon Coughlin in the back yard, pointing their loaded firearms at
his head at close range and placing him under arrest incident to an allegation of
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violating the TPO and subsequent EPO, with Coughlin booked on a gross
misdemeanor TPO violation on 2/8/13 incident to an allegation that Coughlin had a
courier deliver his Motion for New Trial, and to Alter or Amend Any Findings of Fact,
Conclusions of Law, or Recommendations in the NNDB's 12/14/12 FOFCOL on the
last day or next to last (depending on whether a federal holiday such as Christmas Day
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or New Years is included in the 3 days for mailing under NRCP 6(e) and DeBoer) to so
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file such an exigent Motion made under and extremely circumscribed time frame with
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two intervening major holidays in between (Christmas and New Years Day).
Further, Coughlin was also booked on 2/8/13 on a felony EPO violation charge
(another $2,500 in bail, making it $750 cash that was required to bail Coughlin out at
2:00 am on 2/9/13, and therefore making it another two days that Coughlin was forced
to abruptly go off his pyschoactive, pyschotropic medication by the jail staff in one
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instance, and in another, the jail continued to insist Coughlin take a medication known
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for causing sleeplessness at approximately 10:00 pm, making it inordinately difficult to
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get to sleep, and throwing off Coughlin's circadian rhythmns even further than the
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2/1/13 arrest on 11-063341 (incident to an extremely specious allegation of there
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existing sufficient probable cause for DAS Officer Ramos to make a summary arrest of
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Coughlin for an alleged parole violation consisting of Coughlin's alleged failure to

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check in with DAS on 1/2/3 and 1/23/13, in the DAS cubicle where the RJC Bailiff's
and RMC Marshal's have undertaken to affecdt personal service on Coughlin of the
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following: 1/16/13 Administrative Order 2013-01 by RMC Administrative Judge W.

Garnder in In the Administrative Matter of Zachary Coughlin, which lacks a case
number or opposing party in addition to failing to provide any notice or opportunity to
be heard to Coughlin prior to purporting to deprive him off his constitutionally
protected right of access to the court's particularly in prosecutions of Coughlin the in
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the RMC where Coughlin's liberty interest is at issued (including possible
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incarceration) but also where such implicates Coughlin's protected Fourteenth
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Amendment Property Right, in his license to practice law, which has now been
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suspended over nine months incident to the temporary suspension in 60838 stemming
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from Bar Counsel King's SCR 111(6) serious offense Petition following from RMC
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Judge Kenneth Gardner's convicting Coughlin of petty larceny on 11/30/11 in RMC 11

CR 22176, following Judge Gardner's refusal to follow the Sixth Amendment in
denying Coughlin his right to counsel (especially where the possibility of jail time
existed and where Judge Gardner in no manner excluded the possibility thereof prior to
rendering his 11/30/11 Judgment of Conviction and Court Order at 8:30 pm, upon his
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keeping upwards of six RMC employees working late, on overtime wages, in an

apparent desire to avoid affording Coughlin any opportunity to access the exculpatory
materials that the opposing counsel in the wrongful eviction from Coughlin's former
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home law office, Richard G. Hill, Esq., was applying an unlawful rent distraint to in
violation of NRS 118A.520
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POINTS AND AUTHORITIES
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At the outset, please allow Couglin herein to state his profound regret for how
matters have gone since his intial 8/20/11 arrest in 11-063341 and the summary
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eviction notice served on 8/22/11 in RJC Rev2011-00-1708. (please see Coughlin's

5/21/12 email to the SBN including proof of his prescription history and the fact that
Coughlin went off two pyschoactive, psychotropic medications in the first week of
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August 2011, pretty much overnight with no titration, that would seem to establish a
per se basis for finding a causal connection between such and the ensuing events.
Coughlin had attempted to mitigate such occurence prior thereto by reaching out for
help paying for his medications to his family and NNAHMS, but NNAHMS refused to
pay for Adderall (Couglhin called inquiring confidentially on several occassions prior
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thereto) and refused to pay for Wellbutrin if Coughlin continued taking Adderall.
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From then on out it was just trying to stay afloat for Couglin, and that include the
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denial of his Sixth Amendment rights incident to a 9/9/11 arrest for petty larceny of a
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candy bar and some cough melts (with an allegation that Coughlin consumed while
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shopping for and paying for some $83.82 in other grocers, a dosage of Duract Cough
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Melts (which contain a powerful dissaociative, Dextromethorphan, (DXM) to

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incapacitate or even result in death by overdoes). See 60838. Couglin was denied
counsel and any continuance in the trial of that wal-mart arrest on 11/30/11, and
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sentenced to 3 days in jail incident to a summary contempt ruling that the RMC Judge
made 10 minutes into the Trial. The arriagment in that case, on 10/11/11, occurred
during the pendency of the 9/8/11 Order for Competency Evaluation in 11-063341,
arguably violative of NRS 178.405's stay under NRS 5.073. There have been a great
deal of stay violations incident to questions involving Coughlin's competency, some
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that would seemingly play a large role in Coughlin currently facing disbarment,
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including the holding of a trial in 11-063341 on 5/7/11, the day Coughlin's opposition
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was due to an impermissible post judgment motion for atty fee sanctions on 4/19/12
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(the day coughlin was incarcerated in cR12-0376 incident to an inaccurate 4/17/12
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letter by Lake's Crossing) by the opposing counsel in the evictio in 11-001708.
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However, Judge Flanagan's 8/28/12 order in 06328 will, hopefully, make clear that his
6/25/12 award of $42K in attorney's fees was in light of an alleged failure by Coughlin
to file any opposition to the 4/19/12 Motion for Fees, under DCR 13(3), rather than any
finding that such fees were awarded as a sanction pursuant to NRS 7.085 (and, like the
sanction that resulte in Coughlin's firing from WLS in 2009, also a basis for Coughlin
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currently facing disbarment, neither opposing counsel ever served a filign ready
sanctions motion as required by the incorporation of NRCP 11 within NRS 7.085,
thereby committing there own RPC 3.1 violations...). Additionally, the attach Venetian
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v. Two Roads transcripts provides support to rebut any contention of vexatiousness by

Coughlin incident ot his various motions for stay and depositing of supersedeas bond
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(or the RJC retaining ten times that amount incident to a rent escrow deposit Order that
was violative of Nevada law in that the RJC's JCRRT do not apply to landlord tenant
matters (and therefore JudgeSferrazza's assertion that only one motion to set aside or
stay could be filed motions one made may not properly be made again and that
JCRRT allowed for escrow deposits is misplaced given the statutory restrictions an
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inapplicability of JCRRT (that is why JCRLV 44 and a rule allowing only one motion
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to stay or set aside eviciton orders was promulgated and approved by the N. S. Ct,
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incidnet to JCRCP 83 for the Justice Court of Las Vegas Township)...Judge Clifton's
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10/17/11 Order denying Coughlin's Motion for stay in 11-001708 is arguably violative
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of a mandatory stay upon the despoting of $250 under NRS 40.385 (see Two Roads
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transcript and fact that Coughlin had deposited ten times that amount that morning, as
Judge Clifton's Order notes). Further, the RJC was arguably divested of jurisdiction to
even hold the 10/25/11 Trial/continuation of a summary eviction proceeding incident
to Coughlin filing a Notice of Appeal on 10/18/11. Another basis for Coughlin facing
disbarment is NVB Judge Beesley's testimony as to Coughlin's appearance in his court
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on 3/15/12 just minutes after being evicted earlier that day in cident to a lockout Order
in 12-375 by Judge Schroeder, where Gayle Kern, Esq., arguably violated RPC 3.5A in
taking a default where Coughlin filed a Pre-Hearing brief on 3/8/12, and where Kern
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had failed to file a Landlord's Affidavit prior to that hearing, a jurisdictional bar to
holdign the hearing under NRS 40.253(6).
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Regardless, Coughlin just wants to move on, offers sincere apologies for
everything, and ask for some help in getting there and saving his law license.
Recently, due to a 2/8/13 arrest alleging felony and gross violations of the SBN EPO
and TPO, coughlin has been forced to pay $800 in bail, further makign difficult his
saving his law license.
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plea deal that I voluntarily accepted on 8/27/12 put back on the record and accepted by
the RJC, even disposing of the appeal of the convictions in 11-063341 (now on appeal
in CR12-2025):
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From: Leslie, Jim

Sent: Friday, August 24, 2012 11:17 AM
To: 'Zach Coughlin'
Subject: Coughlin: Settlement of RCR11-063341, RCR12-065630 and
RCR12-067980
Mr. Coughlin:
As I had noted earlier, I had relayed the offer you had sent for a
settlement. You had sent it to Zach Young directly, as well as me and
other recipients. I then forwarded your email offer to Mr. Young and
asked him to reply.
Mr. Young took the position that any prior State offers had been rejected
by you or had expired by their terms or by virtue of lapse of reasonable
time. Nevertheless, he has replied indicating willingness to settle as
follows:
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The entry of plea pursuant to this settlement must occur in Reno Justice
Court no later than Monday August 27, 2012.
The plea would be to two misdemeanor disturbing the peace charges, one
such charge in RCR11-063341 (the iPhone case) and once such charge in
RCR12-065630 (the 911 case);
Sentence would be 90 days jail on each charge, suspended and concurrent
to each other, with the following conditions: (1) obey all laws (except that
the parties agree that traffic violations do not constitute violation of this
condition), (2) mental health counseling as recommended by your
psychiatrist or mental health treatment provider, with regular reports
every 60 days for a period of one year, (3) take medications and engage in
counseling as recommended by said psychiatrist or mental health
treatment provider.
In exchange for this plea settlement, the State will dismiss RCR12067980 (resisting case).
Please note that Mr. Young was emphatic that this plea settlement must
be entered by the August 27, 2012, expiration date or it is rescinded. The
August 29 trial in RCR11-063341 will not be vacated until the settlement
plea is entered on monday.
Time is of the essense, since any settlement must be entered at RJC by
monday, so please reply via email with your acceptance and I will set up
a hearing for monday.
Thank you,
James B. Leslie, Esq.
Chief Deputy Public Defender
Washoe County Public Defender's Office
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I would absolutely voluntarily agree to that plea deal right now, especially
if it could dispose of the appearl in CR12-2025 in a manner that would
allow for a SCR 111(10) application like that in the setting aside of the
conviction of former Pahrump DA Beckett in In Re Beckett.
Right to Counsel
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here is no absolute due process right to counsel in probation revocation proceedings.

(Gagnon, supra, 411 U.S. at 790.) On the other hand, there are "cases in which
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fundamental fairness - the touchstone of due process - will require that the State
provide at its expense counsel for indigent probationers or parolees." (Ibid.)
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Although there are no rigid guidelines, the United States Supreme Court has suggested
that counsel should be provided anytime the defendant makes a timely and colorable
claim (i) that he has not committed the alleged violation of the conditions upon which
he is at liberty; or (ii) that, even if the violation is a matter of public record or is
uncontested, there are substantial reasons which justified or mitigated the violation and
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make revocation inappropriate, and that the reasons are complex or otherwise difficult
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to develop or present.(Ibid.) In California, however, the Supreme Court has proclaimed
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a right to counsel in probation revocation proceedings as a judicially declared rule of

procedure. (Vickers, supra, 8 Cal.3d at 461-462.)
The totality of the circumstances, including the DAS materials Coughlin was
provided, extreme health problems (including a reaction preventing Couglin from
appearing at a 1/3/13 EPO hearing in 12-599 and 12-607, even to contest service,
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process, or juridiction, includign to assert an attorney's (even a suspended attorney
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appearing pro se) immunity from service of process at the courthouse, (RJC Bailiff's
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apparently attempte to serve Coughlin 607 and 599 while in the RJC filign office/DAS
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Office...As to an attorney's exemption from service of process, see Am. Jur. 2d,
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Process 35.
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[FN2] Kelly v. Clark, 192 Wis. 2d 633, 531 N.W.2d 455 (Ct. App. 1995).
2012 ).including under courthouse sanctuary doctrine, situational stress incident to
Coughlin's formal disciplinary hearing regarding the irrevocable revocation of his law
license, misleading sworn statements by both SBN Bar Counsel Pat King and WCPD
Jim Leslie, and verbal statements and writings to Coughlin by DAS staff, including
Officer Celeste Brown, support this colorable claim by Coughlin that he has not
violated the terms of his probation , much less in a manner sufficient to support a
summary arrest. Coughlin has received indications from DAS staff including Officer
Brown that, in exigent circumstances calling or writing, especially ahead of time, may
provide a basis for not finding a probation violatin, and Coughlin submits that both
alleged probation violation (incident to DAS Officer Ramos's PC sheet of 2/1/13,
which indicate such violation occured on 1/3/13 and 1/24/13...which just happend to be
days where Coughlin had deadlines in 62337 and where Couglin now faces felony and
gross charges upon allegations of TPO and EPO violations occuring on those dates)
auguers towards either dismissing the charge of an alleged probation violation or
affording Coughlin representation at publice expense, especially where, apparently B.
Lindsay, Esq. Showed up to the 12-067980 contempt hearing on 2/13/13 as a freebie,
upbenownst to Coughlin and counter to at least the implicit representation made to him
by the Court and Lindsay upon being led into court in restraints that morning, absent
any consultations with Lindsay beforehand whatsoever..
Such a basis to preclude a probable cause finding includes:
RE: Update Brown, Celeste (CBrown@washoecounty.us)Add to
contacts 1/24/13 To: 'Zach Coughlin' From: Brown,
Celeste
(CBrown@washoecounty.us) This sender is in your safe list. Sent:
Thu 1/24/13 3:10 PM To:'Zach
Coughlin'
(zachcoughlin@hotmail.com) Per the video, you showed up at
2:56 p.m From here on out Zach, you need to check in between
9:45 and 2:00 p.m. Lets see if we can fix the problem ok? Sgt.
CJ Brown WC Dept. Of Alternative Sentencing 1 South Sierra St.
Reno, Nv 89501 desk 775)327-8384 fax 775)327-8383 From:
Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent:
Thursday, January 24, 2013 2:42 PM To: Brown, Celeste Subject:
Update Dear Officer Brown, I appreciate your recent note. Thank
you. It meant a lot. I came in yesterday well more than 5 minutes
prior to 3 pm, but was detained too long at the security station for
Bailiff Medina to escort me to the DAS Office (then Chief Judge
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Sferrazza's Administrative Order 12-01 of December 20th, 2012

requires as much). I saw Judge Linda Gardner's bailiff, Deputy
Kirkham milling about with four or five other deputies near the
courthouse exit performing a pbc test on a man, and requested
permission to wait my turn and take one as well. I memorialized
this in a note that I gave to Bailiff Medina for which he agreed to
provide to DAS. Deputy Kirkham made some sneering
commentary about alcoholism and dependency issues in general (I
cannot recall specifically whether or not she then "high-fived" one
of her fellow deputies) as they relate to me, and perhaps the Irish
race and my ancestry in general, then refused to allow me to take a
pbc test and document it on the note I left with Bailiff Medina for
DAS. Deputy Kirkham decided against assisting in a pbc test.
Deputy Kirkham, the SBN arranged, was present for my 11/14/12
formal disciplinary hearing at the State Bar of Nevada, despite the
involvement of 2JDC Family Court Judge Linda Gardner (the SBN
has been purposefully vague and obstructionist as to whether ng120435 is a grievance with a grievant of Linda Gardner given some
of the ethical problems associated with Judges writing letters
whether of recommendation or condemnation (or Orders After
Trial) and submitting them voluntarily (or having their brother
RMC Judge William Gardner do so by way of taking the 4/13/09
Order After Trial by his sister and passing it to RMC Judge Nash
Holmes, then having her include that in the 3/14/09 grievance she
herself filed on behalf of RMC Judge William Gardner and all
other RMC Judges....especially where RMC Judge W. Gardner
refused to recuse himself from the criminal trespass prosecution of
Coughlin from his former home law office incident to the summary
eviction from it presided over by RJC Judge Sferrazza (where a
$2,275 rent escrow deposit was ordered by the RJC in violation of
Nevada law and still not returned to Coughlin by the time of the
trespassing arrest or during any period in which Coughlin was
expected to hire movers and rent a uhaul and arrange for an
alternate location to place such personalty). Further RMC Judge
Garder failed to disclose that his sister is 2JDC Family Court Judge
Linda Gardner during the audio record of the 2/2/12 hearing in 11
CR 26405 wherein Coughlin prompted Judge Gardner to disclose
any such matters that would tend to create an appearance of
impropriety or a basis for a conflict or bias, whether or not such
did, in fact exist, and whether the judge himself thought such did in
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fact exist.... (NOTE: Coughlin email goes on and on and is

truncated here).
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Further, the proximity of Coughlin's arrest on 2/1/13 after 7 pm considering

Coughlin email to WCDA Criminal Division early morning 2/1/13 is troubling.
Additionally, WCDA DDA Watts-Vial's refusal to respond to Coughlin's properly
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issued subpoenas in his formal disciplinary hearing (see Watts last minute 11/13/12 fax
to Coughlin refusing to have 2JDC Judges and Administrators appear or to produced
materials requred by Coughlin's subpoena duces tecum, all properly issued under SCR
110, and where no fees were required give SCR 105(4) and SCR 119(3), and where the
Panel Chair's 11/7/12 Order Quashing subpoenas on RMC Judges is void anyways
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given jurisdiction to so rule, under SCR 111(4) resides with NNDB Board Chair
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Susich, not Panel Chair Echeverria, and where such does not apply to supboenas issued
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to 2JDC Judges and personnel. Coughlin sought to have 2JDC and or Watts-Vial
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compelled to so produced such at the peril of contempt at the 11/14/12 formal hearing.
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Further, even if NRCP 45 was applicable, as DDA Watts-Vial's 11/13/12 fax indicates,
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Coughlin has been characterized as an attorney and Coughlin was authorized to

practice and appear pro se in that matter in State Bar Court of the SBN, including by
express assertion made to Couglin on 10/15/12 by Asst. Bar Counsel King, relaying
Chief Bar Counsel's David Clark's decision vis a vis Coughlin's right to issue his own
subpoenas (versus goign to the SBN and have Clerk Peters do so), and further in
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consideration of the 7/27/12 writing to Coughlin by NNDB Chair Susich directing

Coughlin to confer with and obtain any such indications from Bar Counsel, versus the
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NNDB.
(a) This Courts precedents provide no definitive answer to the question
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whether counsel must be provided. The Sixth Amendment grants an indigent criminal
defendant the right to counsel, see, e.g., United States v. Dixon, 509 U. S. 688, 696, but
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does not govern civil cases. Civil and criminal contempt differ. A court may not
impose punishment in a civil contempt proceeding when it is clearly established that
the alleged contemnor is unable to comply with the terms of the order. Hicks v.
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Feiock, 485 U. S. 624, 638, n. 9. And once a civil contemnor complies with the
underlying order, he is purged of the contempt and is free. Id., at 633. The Due Process
Clause allows a State to provide fewer procedural protections in civil contempt
proceedings than in a criminal case. Id., at 637641. Cases directly concerning a right
to counsel in civil cases have found a presumption of such a right only in cases
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involving incarceration, but have not held that a right to counsel exists in all such
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cases. See In re Gault, 387 U. S. 1; Vitek v. Jones, 445 U. S. 480; and Lassiter v.
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Department of Social Servs. of Durham Cty., 452 U. S. 18. Pp. 710 Gagnon v.
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Scarpelli, 411 U. S. 778 (1973); Impact of the Gagnon decision All probationers in the
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United States who incur a violation or multiple violations are guaranteed certain
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hearings before any permanent, punitive action is taken. A Gagnon I hearing occurs
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when a probationer is taken into custody for an alleged violation hearing; this first
hearing determines if the probation should remain in custody or be released back into
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the community. A Gagnon II hearing is the final revocation procedure. A

determination on the status of the probation is made, and if the probationer is found in
violation, a sentence for the violation is handed down by the Judge. Even if Couglhin
may not have a right to representation paid by the state at either the 2/13/13 Contempt
Hearing in 12-065630 (that's not clear) or in the upcoming 3/11/13 Probation Violation
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Hearing (though, arguably, a Gagnon I hearing is still required to determine if the $500
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cash bail is still properly held by the Court in 11-063341), Coughlin hereby requests
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this Court take judicial notice of D10 Judge Elliot's 1/9/13 Order granting Coughlin in
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forma pauperis status, in addition to Judge Clifton granting Coughlin such status as
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well in 12-065630 on 11/27/12.
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Further, Coughlin's suspended sentence in 11-063341 was unconsitutional in

that Coughlin actually was deprived of his right to counsel (including to be his own
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counsel where Coughlin filed a Notice of Appearance and Authorization to Represent
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on 2/15/12 in 11-063341, while he was still a licensed attorney no less, but was still
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refused to right to proceed as his own counsel until finally, on 10/22/12, upon Jim
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Leslie purposefully sabotaging Coughlin's case as much as he possibly could, Judge
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Sferrazza finally recognized Coughlin's argument that he was being forced to proceed
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without any assistance from the State incident to the Sixth Amendment (Coughlin was
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continuously faced with a double edge sword...be his own counsel (except for the fact
that Judge Sferrazza ruled Coughlin not competent to be his own counsel on 8/29/12,
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though competent to stand trial, curiously, also curiosu is how Coughlin could be
convicted in 11-063341 and then order to get a mental health evaluation....):
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B. Misdemeanors Sentence of Actual or Suspended Imprisonment. An

indigent person has a Sixth Amendment right to counsel in all
misdemeanor cases in which actual imprisonment or a suspended
sentence of imprisonment is imposed. See Argersinger v. Hamlin, 407
U.S. 25 (1972); Scott v. Illinois, 440 U.S. 367, 37374 (1979) (in
misdemeanor cases, the Sixth and Fourteenth Amendments to the
United States Constitution require only that no indigent criminal
defendant be sentenced to a term of imprisonment unless the state has
afforded him the right to the assistance of appointed counsel); Alabama
v. Shelton, 535 U.S. 654 (2002) (indigent defendant has right to
appointed counsel in misdemeanor case if court imposes suspended
sentence of imprisonment); see also North v. Russell, 427 U.S. 328
(1975) (recognizing that in two-tiered court system, such as North
Carolinas district and superior court system, judge at each level must
inform indigent defendant of right to counsel if sentence of confinement
is to be imposed). This rule has three effects. First, if the court has not
appointed counsel for an indigent defendant and the indigent defendant
has not waived counsel, the court is prohibited from imposing an active
or suspended sentence of imprisonment. For example, suppose a district
court judge refuses to appoint counsel in a misdemeanor case and
continues the case to another date, when it will be heard by a second
district court judge. If the second judge does not revisit the earlier refusal
to appoint counsel and the defendant does not waive counsel, the second
judge may not sentence the defendant to an active or suspended term of
imprisonment regardless of the evidence presented at trial or sentencing.
Second, if the court imposes a suspended sentence of imprisonment in
violation of the defendants right to counsel, the court in a later
proceeding may not revoke the defendants probation and activate the
sentence. This prohibition applies even if the defendant is represented by
counsel at the probation revocation hearing. See Shelton, supra; State v.
Neeley, 307 N.C. 247, 297 S.E.2d 389 (1982) (trial judge may not
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activate suspended sentence if, in original proceeding in which

suspended sentence was imposed, defendant did not have counsel and
had not waived counsel); accord State v. Barnes, 65 N.C. App. 426, 310
S.E.2d 30 (1983) (applying Neeley to district court case); State v. Black,
51 N.C. App. 687, 277 S.E.2d 584 (1981) (to same effect as Neeley).
Third, if the court imposed an active or suspended term of imprisonment
for a misdemeanor despite the failure to appoint counsel, the conviction
should not be available in a subsequent proceeding to impeach, enhance
a sentence, or increase the level of an offense. The reason is that when a
sentence of imprisonmentactual or suspendedis imposed for a
misdemeanor, the case is considered serious enough to require the
protection of counsel. As in a felony case, if a conviction is obtained
without counsel having been afforded to the defendant, the conviction
should be subject to suppression. In this respect, the U.S. Supreme
Courts decision in Shelton, supra, which held that an indigent defendant
has a right to counsel if a suspended sentence of imprisonment is
imposed, appears to modify or at least clarify Nichols v. United States,
511 U.S. 738 (1994). Nichols held that a prior uncounseled conviction
could be used to enhance a defendants sentence in a subsequent
proceeding if the defendant did not have a right to counsel at the prior
proceeding. After Shelton, a prior conviction should not be useable in a
subsequent proceeding if the prior conviction resulted in an active or
suspended sentence of imprisonment
Please find in Exhibit 1 various relevant materials showing good cause why
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judicial economy woudl be best served to continue the 3/11/13 Show Cause Hearing.
Coughlin has recently completed an intake with NNAHMS and did in fact appear for a
DAS check on the date he is alleged to have failed to do so, 1/23/13, at approximately
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2:54 pm, though in complying with the 12/5/12 Administrative Order 12-01 of Judge
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Sferrazza requiring Coughlin check in and wait for an RJC Bailiff to escort him (even
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to DAS, as Coughlin reads it) Coughlin was, unfortunately, unable to make it to the
DAS window to complete a PBC test by 3:00 pm. Coughlin attempted to take a PBC
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with a WCSO Deputy Kirkam in a good faith effort to demonstrate compliance with
the sobriety requirement, but was unable to have such a test administered. Coughlin
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timely checked in with DAS yesterday and is taking active steps to participate in a
meaningful and successful probation experience, though complications related to going
to jail, being forced of one medication, forced to take the other (Wellbutrin) at bedtime
in jail, despite it being known to cause sleeplessness, then a 5 day contempt
incarceration beginning on 2/12/13 incidnet to Coughlin's sleeping through two alarm
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clocks and being late to court (though not given any opportunity at Contempt hearing
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the next day to question RJC's Robbin Baker as to whether Coughlin's alleged reason
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for previously being late to a hearing in that matter negated any finding or import of
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Coughlin's being warned against being late again. Again implies the the warning
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relates to a previous occurrence. Coughlin was told by Baker that the 12/11/12 Trial
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date start time had been moved to 1:30 pm. Apparently, only the witness subpoenas
were intended to be moved. Coughlin swears it was his understanding the trial time
had been moved and maintains that he should not be held to a warning and the
consquences of violating such given those circumstances.
Further basis for
continuance related to the primacy to Coughlin's life and career of completing the
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Appellant's Brief in 62337 challenging Recommendation to disbar him. Scattershot

SBN Complaint alleging 12 different RPC's violated and SCR 105(2)(c) rampant
violations makes Brief's Preparation inordinately difficult, on top of three arrests
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between 2/2/13 and 2/13/13.
Also, WCPD Dogan failed to appear at Couglin's
arraignment on the gross misdemeanor charge on 2/14/12 in 12-065630, and Coughlin
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had a right to counsel at all stages for such a gross misdemeanor charge, instead, the
RJC's Judicial Secretary Townsend send Coughlin's 2/21/12 filing in that case to the
SBN as evidence of Coughlin's lack of competency, in addition to voluntarily offering
to send Coughlin's 2/15/12 Pre-Trial Motion in 11-063341 to the SBN as well.
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Stages of Criminal Case in which Right to Counsel Applies The right to

counsel in a criminal case encompasses various proceedings. The Sixth
Amendment right to counsel attaches once adversarial judicial
proceedings have commenced and applies to any critical stage thereafter.
Other constitutional provisions and state statutes afford the defendant the
right to counsel at additional proceedings, both before and after the
initiation of judicial proceedings. A. When Right to Counsel Attaches
Sixth Amendment Right to Counsel after Commencement of Judicial
Proceedings. The Sixth Amendment right to counsel attaches upon
commencement of adversarial judicial proceedings against the defendant,
whether by way of formal charge, preliminary hearing, indictment,
information, or arraignment. Kirby v. Illinois, 406 U.S. 682, 689 (1972);
accord State v. Tucker, 331 N.C. 12, 33, 414 S.E.2d 548, 560 (1992). The
question of when judicial proceedings commence is generally a matter of
concern in assessing the lawfulness of police proceduresfor example,
whether the defendant had a Sixth Amendment right to counsel during
interrogation or at a lineup. Generally, when a defendant is arrested for a
felony (with or without a warrant) before being indicted, the Sixth
Amendment right to counsel attaches at first appearance. See State v.
Tucker, supra (taking of statement by police after first appearance
violated Sixth Amendment right to counsel; statement suppressed); State
v. Franklin, 308 N.C. 682, 304 S.E.2d 579 (1983) (taking of statement
after arrest and before first appearance did not violate Sixth Amendment);
State v. Detter, 298 N.C. 604, 260 S.E.2d 567 (1979) (first appearance
itself not critical stage). If the defendant is indicted before being arrested,
the Sixth Amendment right to counsel attaches on return of the
indictment. See Kirby, supra. In misdemeanor cases, judicial proceedings
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probably commence upon the defendants first appearance in district

court. See 3 LAFAVE 11.2(b), at 498; ROBERT L.FARB,
ARREST,SEARCH &INVESTIGATION 207 (Institute of Government,
3d ed. 2003).
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A defendant has a right to counsel in misdemeanor prosecutions if the

court imposes an active or suspended sentence of imprisonment. See
Alabama v. Shelton, 535 U.S. 654 (2002). Accordingly, if the defendant
is improperly denied counsel, the court is precluded from imposing either
an active or suspended sentence of imprisonment. Further, if the court
imposes a suspended sentence of imprisonment in violation of the
defendants right to counsel, the court may not activate the defendants
sentence at a probation revocation proceeding regardless of whether the
defendant is represented at the revocation proceeding. See infra 12.3B.
Civil Contempt. In McBride v. McBride, 334 N.C. 124, 431 S.E.2d 14
(1993), the state supreme court held that an indigent defendant charged
with civil contempt for failing to pay child support may not be
incarcerated unless he or she has been appointed counsel or has waived
counsel. The court rejected the argument that the right to counsel depends
on whether the case is considered civil or criminal, stating that jail is
just as bleak no matter which label is used. 334 N.C. at 130, 431 S.E.2d
at 19. Although McBride concerned a child support contempt case, its
reasoning applies equally to any contempt proceeding in which the
defendant is incarcerated. See John L. Saxon, McBride v. McBride:
Implementing the Supreme Courts Decision Requiring Appointment of
Counsel in Civil Contempt Proceedings, ADMINISTRATION OF
JUSTICE MEMORANDUM No. 94/05 at 1 n.3 (Institute of
Government, May 1994)
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From: Kandaras, Mary Sent: Thursday, December 13, 2012 10:20

AM To: Leslie, Jim Subject: RE: 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 Importance:
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High
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Jim:
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I believe that you should send this. Supreme Court Rule 104(a)
authorizes State bar counsel to investigate all matters involving
possible attorney misconduct or incapacity called to bar counsel's
attention, whether by grievance or both. This potentially involves
misconduct (violation of law) and incapacity.
Mary Kandaras Deputy District Attorney Civil Division Washoe
County
775 -337 -5723 direct phone
-----Original Message----From: Leslie, Jim Sent: Wednesday,
December 12, 2012 5:11 PM To: Kandaras, Mary Subject: RE:
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
Thanks, please do. He came to our office after my email to you
and caused a disturbance. We called the police, but he fled
before they arrived. jim
-----Original Message----From: Kandaras, Mary Sent:
Wednesday, December 12, 2012 3:17 PM To: Leslie, Jim
Subject: RE: 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
17
I will have to review this tomorrow and get back to you.
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Mary Kandaras Deputy District Attorney Civil Division

Washoe County
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-----Original Message----From: Leslie, Jim
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The below email from Mr. Coughlin contains a reference

at the end of the first paragraph to a website containing a video
clip from the movie Cape Fear. Please advise whether any
action is required of our office or yours regarding this possible
veiled or indirect threat of violence against attorneys in this
office by Mr. Coughlin.
Sent: Wednesday, December 12, 2012 2:59 PM To: Kandaras,
Mary Subject: FW: 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
Mary:
Please review my transmittal to Patrick King at the bar,

below, and let me know if I should do anything else from a
civil perspective.
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Thanks,
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December 12, 2012 2:49 PM To: 'patrickk@nvbar.org'
Subject: FW: The Three E's; wcpd failure to provide essential
rcr2012 -065630
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Mr. King:
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Thank you,
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James B. Leslie, Esq. Chief Deputy Public Defender Washoe

County Public Defender's Office
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RJC Judges on 2/13/13 in (an Order for Competency Evaluation signed and entered
by Judge Pearson at an 8:30 am hearing in 11-063341 was provided, in writing, to
Judge Clifton in 12-065630, with shall language, and DDA Young's willingness to
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go along with Judge Clifton in refusing to follow NRS 178.405's mandatory stay is
arguably impermissible. To have RJC Bailliff's then Order Coughlin to remain at the
RJC, then go into a hearing brought on an Emergency Basis upon DDA Young making
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an Ex Parte Request for Judge Clifton to resconsider his Order for Competency
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Evaluation is, perhaps, subject to arguments of a deprivation of due process or failure
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to apply procedural rules to the State with the same rigid, overly forumulaic approach
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in which they have been applied to pro se Coughlin (except when NRS 178.405
requires a stay, then such has been relaxed considerably, to Coughlin's detriment).
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As specifically mentioned by Judge Pearson at a 2/2/13 Show Cause hearing on

the morning of 2/2/13 (I was bailed out at 1:45 am (after the last bus had left 911 Parr
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Blvd, requiring I walk 3.5 miles to my 1471 E. 9th St. location, at which I rent a fifth
wheel trailer for $75 a month, a rent I can barely make each month) and Coughlin was
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only around to attend that 11-063341 unnoticed (or improperly noticed Gagnon 1
hearing considering his WC Inmate Release information indicated such hearing would
be on 2/5/13, and now Coughlin apparently is facing a Show Cause Hearing on 3/5/13
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over some allegation that Coughlin called the RJC, allegedly in violation of Judge
Sferrazza's 12/20/12 Administrative Order 12-01 (no case number indicated in the
caption thereinm and arguably, the service of process of that Administrative Order was
insufficient, and such Order extinguished upon the calendaring year changing to 2013,
and the seating of a new Chief Judge to replace then Chief Judge Sferrazza), to see if
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that Hearing in 11-063341 indicated as set for 2/5/13 was, in fact, still on calendar, or
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whether the Hearing held at 8:30 am on 2/2/13 replaced such Hearing) 12-065630...that
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DAS hearing in 063341 was incorrectly noticed on my Jail Release papers for 2/5/13
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or something...At that 2/3/13 Hearing I got an Order for Competency Evaluation from
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Pearson, then went and provided that to Judge Clifton at the resumption of the 065630
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trial immediately thereafter, which, under NRS 178.405, required Clifton to suspend
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the trial in 11-065630. Of course, he did not. He has demonstrated a willingness to fail
to apply the law as written in certain instances, invariably to the benefit of the State,
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often with the encouragement of DDA Young (though, to be fair, at the 2/13/13 Trial,
DDA Young did point out to Judge Clifton the shall language in NRS 178.405, to
which Judge Clifton made, admittedly, an inventive, argument that some failure to
make specific findings of fact or something along those lines in Judge Pearsons just
minted Order For Competency Evaluation in 11-063341 of 2/13/13 made inapplicable
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the mandatory stay under NRS 178.405. Even if one were to overlook in possible
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impropriety of Judge Clifton suspending that Trial, starting at 9 am in 12-065630 long
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enough for DDA Young to go to the RJC counter and make and ex parte request for an
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emergency reconsideration hearing before Judge Pearson, including the evident
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partiality revelaed by failing to apply procedural rules to the State in the same rigid and
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overly formulaic manner to which the RJC has applied them to Coughlin (including the
10 days Coughlin should have to respond to such a Motion for Reconsideration of the
Order for Competency Evaluation of 2/13/13 in 11-063341), there still exists the fact
that Judge Clifton failed to follow NRS 178.405 and immediately Stay all proceedings
in all departments, but rather, allowed DDA Young a recess to go and make his ex
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parte communications to the RJC Bailiff counter seeking an Emergency Hearing before
Judge Pearson to reconsider his 2/13/13 Order for Competency Evaluation. DDA
Young's making such Motion violated the mandatory automatic stay required by NRS
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178.405 leaving the RJC to rely upon some dubious assertion that Jduge Pearson just
happened to continue mulling his decision to enter the Order For Competency
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Evaluation he entered in 11-063441 at approximately 8:45 am, sua sponte, without any
prompting or extra judicial communications with Judge Clifton, DDA Young, or
anyone else...something Judge Pearson refused to refute the allegation of upon
Coughlin putting it before him during the brief Emergency Reconsideration Hearing
Judge Clifton left the bench long enough in 12-065630 on 2/13/13 to allow Judge
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Pearson to take it an vacate or otherwise amend his Order for Competency Evaluation,
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at which point Judge Pearson did render a rulign that he would enter an Order having
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the State pay for a mental health evaluation for the indigent Coughlin, that, to this
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date, still has not been entered and Coughlin has been unable to have such done due to
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the failure to issue a check to him made out to his pyschiatrist, Dr. Suat Yasar, MD
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(the State, DDA Young, and Richard G. Hill, Esq., have all been able to get
Emergency Ex Parte Motions granted against Coughlin, whereas, DDA Young's failure
to oppose Coughlin's 2/21/12 Motion to Dismiss in 12-065630 (which, arguably under
Polk v. State and DCR 13(3) may required such Motion to Dismiss be granted) resulted
in Judge Clifton, almost reflexively by instinct, sua sponte, making an argument on the
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State's behalf that DDA Young had implicilty opposed such Motion to Dismiss,
thereby revealing further the evident partiality against Coughlin by the RJC judiciary
pervading all of the various prosecutions and evictions/landlord tenant matters therein).
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Further, upon Judge Clifton having Coughlin taken into custody on 2/13/13 in
12-065630, Chief Bailiff Sexton reminded Coughlin that he still have hanging over
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your head five different extremely de minimis alleged violations of Judge Sferrazza's
12/20/12 Administrative Order 12-01, which threat apparently was put into play by the
2/25/13 Order To Show Cause AO 12-01, file stamped 3:45pm, upon Coughlin filing a
Notice of Appeal to the 2/13/13 Order by Judge Clifton in 12-065630 sentencing
Coughlin, summarily, and denying any stay thereto despite good cause show,
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especially relating to 62337 and the jail depriving Coughlin of his medications during
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two of the three questionable incarcerations the RJC had subjected Coughlin to
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between 2/1/13 and 2/12/13, and Coughlin's established suffering from clinical Major
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Depressive Disorder , Treatment Resistant Depression, and ADD/ADHD. The causal
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connection between Coughlin's early mornign email of 2/1/13 to WCDA Inspector
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Covington (the only person ADA Helzer is allowing Coughlin to communicate with in
reference to CR12-2025 and RJC 11-0633341) and the NRS 171.136 violating
summary arrest for an alleged probation violation disproven by DAS Officer Ramos'
own Coworker, DAS Officer Brown's 1/24/13 email to Coughlin, where such arrest is
notated at occurring AFTER 7 pm (7:02 pm) on the PC Sheet and Inmate Booking
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papers from 2/1/13, is obvious, and troubling. A similar casual connection seems
apparent between a 2/6/13 email to WCDA DDA-Civil Division Watts-Vial objecting
to his 11/13/12 faxed objections ot Coughlin's SCR 110 subpoenas on Washoe County
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and 2JDC personnel and the 2/8/13 point a gun at Coughlin's head from five feet away
for no good reason by RPD Waddle arrest and charge of a gross misdemeanor violation
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of the SBN TPO over some alleged violation on 1/3/13 and a felony charge for some
alleged violation of the SBN EPO in 12-607 over some alleged conduct on 1/23/13 or
thereabouts (the purported service of the TPO in 12-599 by Bailiff Reyes on 12/19/12
involved Reyes following Coughlin into the tiny DAS check in closet and shoving his
forearm into Coughlin's midsection in insisting Coughlin was being detained
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sufficiently long enough to serve Coughlin the TPO Order in 12-599...similarly
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shoving of a forearm into Coughlin's midsection occurred during an attempted service
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of an EPO in either both 12-599 and 12-6087 by WCSO Deputy Courteney, on 1/4/13.
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Such apparent misconduct further vitiates the viability of such attempts at service,
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especially where Deputy Courteney utilized force in attempting to prevent Coughlin
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from walking on his drive way towards his fifth wheel. Next in the apparent retaliatory
causal connection parade is Coughlin's inquiring with WCDA DDA Watts-Vial on
2/25/13 about those SCR 110 Supboenas again, at approximately 2pm, just before
former WCDA Office-Criminal Division prosecutor turne RJC Judge Pearson entered
his 2/25/13 Show Cause Order setting for hearing such matter on 3/5/13, based upon
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some unsworn, unattributed, allegations that Coughlin had made various contacts
with non-RJC Bailiff personnel, though the complete lack of specificity, the violation
of the requirement for such out of the presence of the court alleged conduct
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constituting contempt under NRS 22.030(3), and the general lack of notice as to the
charges against him (what did such contacts entail? Who exactly would the witnesses
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of such contacts be? How can Coughlin subpoena them without sufficiently detailed
notice thereof? Why is Couglhin not afforded at least the 10 judicial days seemingly
required to prepare for any such Show Cause Hearing. Is not the purported service of
such Show Cause Order incident to Coughlin checkign in with DAS insufficient
service of process for the same reasons other such service attempts in 12-607, 12-599,
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RJC AO 12-01, etc., should fail? Do not the TPO's and EPO's in 12-607 and 12-599
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exceed the jurisdiction to make such orders where they impinge upon Coughlin's first
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Amendment Rights and rights as a litigatin in his formal disciplinary hearing and the
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appeal thereof, and where such orders are in now way reasonably or narrowly tailore to
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achieve the purported safety goals to which they address?
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It has also become even further apparent that the RJC Bailiff are or may be
engaging in a coordinated effort (further suggested by the apparent dictate in Judge
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Sferrazza's Administrative Order 12-01 that Coughlin : insert language where on
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2/21/13 Couglin appeared at the RJC to take the PBC test and check in with DAS as
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required by his probation in 11-063341 (in part based upon a conviction for
possessing or receiving stolen property that is clearly violative of Nevada law:
((A) Count 3 charged Shepp with having received property stolen by
him during the commission of the burglary charged in Count 2. Since
a thief cannot receive from himself the fruits of his larceny, the
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jury must be instructed that it could convict of either burglary or

receiving, [ 484 P.2d 565 ] but not of both. People v. Taylor, 4
Cal.App.2d 214, 40 P.2d 870 (Cal. 1935); People v. Morales, 263
Cal.App.2d 211, 69 Cal.Rptr. 553 (1968); Milanovich v. United
States, 365 U.S. 551, 81 S.Ct. 728, 5 L.Ed.2d 773 (1961); Thomas v.
United States, 418 F.2d 567 (5 Cir.1969); Baker v. United States, 357
F.2d 11 (5 Cir.1966). Such an instruction was requested but the court
declined to give it. This was error, and later acknowledged by the
court to be such when it set aside the receiving conviction and ordered
a new trial on that charge. The appellate issue is whether that manner
of handling the error effectively cured it. The error was not cured by
the setting aside of the receiving conviction since there is no way of
knowing whether a properly instructed jury would have found the
defendant guilty of burglary, Count 2, or receiving, Count 3.
Milanovich v. United States, supra. Both convictions should have been
set aside and a new trial ordered. SHEPP v. STATE 484 P.2d 563
(1971))
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Coughlin overhead RJC Bailiff Medina (whom was the same Bailiff who did not
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appear soon enough to escort Coughlin to the DAS office on 1/23/13 prior to it closing
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at 3 pm, despite Coughlin presenting to the security check in no later than 2:54 pm, and
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Couglin arguably not even required to do so under AO12-01 (Coughlin got arrested
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and is out $500 for at least the time being upon the 2/1/13 summary arrest by DAS
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Officer Ramos).
At a subsequent check in Officer Ramos attempted to glean some
violation where Couglhin allegedly appeared for a check in after 2 pm, despite DAS
closing at 3pm.
To apply a narrower window of time to one with MDD and
ADHD/ADD is extremely suspect. Additionally, the same RJC Bailiff Medina was
overhead at a subsequent check in, proposing a plan to only afford Couglin a similarly
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extremely narrow time frame within with to urinate (lets wait until 5 minutes before
close to let him try to pee again, then if he can't do it, its back to jail for Coughlin!
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Bailiff Medina was overhead saying, approximately, to DAS Officer Brown on

approximately 2/20/13.
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Coughlin disputes the legitimacy of whether Bruce Lindsay, Esq. was appointed
as counsel of record in 2012-065630 for the 2/13/13 Contempt Hearing, at which I
received 5 days in jail for being late, wherein Judge Clifton alleged I had already had
the benefit of a warning, yet I maintain that Robbin Baker told me the start time of the
trial in that matter on 12/11/11 had been moved from 9 am to 1:30 pm. Judge Clifton
maintained that he did not change the start time, then insisted Robbin Baker did not tell
me that, then refused to indicate just how he could possibly know what Robbin Baker
had told me. Subsequently it was learned that Robbin Baker was not even at work that
day, and that no one had called her that day to inquire as to whether I was correct in
my assertion as to her having communicated the start time of the trial as having
changed. I believe it is situations like that that resulted in the current Administrative
Order 12-01 (which may not even still be binding considering it was from 2012 and by
former Chief Judge Sferrazza) wherein I seemingly am prevented from
communicating with any court personnel besides the Bailiff's, based upon some
unnoticed finding that I had caused distruptions in the filing office, an accusation to
which I was never provided an opportunity to be heard on.
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Previously, Judge Sferrazza refused to allow me to appear on my own behalf, despite

my having been a licensed attorney in Nevada at the time in 11-063341, and despite
my having filed a Notice of Appearance therein, and an Authorization to represent.
Then Judge Sferrazza, at trial on 8/27/12 and 8/29/12 refused to allow me to self
represent still. Then he refused to accept the plea agreement that would have disposed
of all three matters to which I am a defendant in the RJC (11-063341, which is now on
appeal in CR12-2025, with the Appeal Brief, per the attached Briefing Schedule, on
March 9th, 2013, and where Judge Elliott entered an Order granting my IFP on 1/9/13
providing for the preparation of the transcript at public expense; 11-065630, which
stemmed form a 1/14/12 "misuse of emergency communications" gross misdemeanor
arrest, that had the trial start on 12/11/12, where the WCPD was releived on 11/27/12
(the day pre-trial motions were due, I maintain I was forced to proceed pro se due to
Biray Dogan's complete lack of representation, including failing to appear where
required at the 2/14/12 arraignment on a gross misdemeanor (indigent defendnans
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entitled to representation on gross misdo and felonies "at all stages"...); and the matter
wherein Bruce is counsel of record, 12-067980, where Bruce has stipulated to several
continuances...and now today apparently DDA Young tried to pull something where he
failed to stip to the continuance in 11-063341, refuses to take my calls or respond to
any written communications. Further WCDA Legal Assistant Tina Galli informed me
today that I am not to call their office on 11-063341 and that "Diana from Bruce
Lindsay's Office is handling it". That is not true. I am self representing in 11-063341
at this point.
Further, I never expressly consented to Lindsay appearing in 11-065630 at the
2/13/13 Contempt Hearing, wherein I was brought in upon being summarily taken into
custody the day before, and without consulting with Lindsay at all or ever consenting
to his appearing on my behalf, Lindsay was seated at the defendants desk.
Lindsay then proceeded to disparage my ability to represent clients currently on the
record, stating "Your Honor, can you imagine him trying to represent clients in his
current state?" as though I was so incompetent that doing so would surely produce poor
results. Judge Clifton quickly pointed out my competency to be an attorney was not
the relevant inquiry. Lindsay refused to seek to examined Robbin Baker or call her as
a witness in line with my argument that I had not actually ever been given a "warning"
against my being late to court "happening again" (as Judge Clifton indicated I had).
Further, Lindsay ask me, in open court, in front of Judge Clifton, "so what happened,
why were you late". duty of confidentiality.
A member of Washoe County law enforcement stated to me at some point while
in custody on 2/12/13 that he expected I would be released the following day with
credit for time served. Instead, I received 5 days incarceration. Another member of
washoe county law enforcement subsequently expressed to me that he was surprised by
such an long sentence.
I have been told that Lindsay's appeared on 2/13/13 in 12-065630 "free of
charge" despite my indigent status and the fact that the State is required to provide me
an attorney at any hearing, even a civil contempt hearing, wherein there is even a
possibility of any jail time, much less 5 days of jail time...Lindsay still has not filed an
SB89 form or Proposed Order (though he seemed to orally make such motion on
2/13/13) requiring that I be evaluated for competency or fitness to stand trial, despite
his repeatedly indicating he believes my competency is seriously in question. I believe
he is obligated to file such a Propose Order and or Motion for an Order for
Competency Evaluation Immediately, pursuant to NRS 178.405. Further, even at the
Contempt Hearing on 2/13/13, in 12-067980, the State was required to provide me
counsel, and given the conflict present with the WCPD and APD, private counsel was
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required. Additionally, I believe it is extremely bad faith for the State and RJC to
refused to provide me private counsel for the 12/11/12 Trial in 12-065630 (and,
depending upon whom one talks to, also at the continuation thereof on 3/19/13 in
RCR12-065630, though RJC Bailiff's have refused filings Coughlin has submitted
therein and access to materials in such file (including requests for audio of the 2/2/13,
and 2/12/13 Hearings in that case and the 12/18/12 hearing in rcr12-067980), only to
then allow WCPD Leslie to abuse process with his 12/18/12 TPO Application, therein
bringing about the current arrangement with court appointed private counsel. Please
indicate in writing whether Lindsay was paid to appear on my behalf on 2/13/13 in 12065630 at the Contempt Hearing.
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The DAS arrest on 2/2/13 was after 7pm in violation of NRS 171.136. Further, the
attached emails below support a finding that there did not exist probable cause to make
such an arrest. Additionally, please find below the Plea Deal that I voluntarily
accepted, on the record in 11-063341, 12-065630, and 12-067980 that should dispose
of all three of these matters.
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Further, please indicate in writing whether Mr. Lindsay has been assigned to represent
me in the matter stemming from the 2/8/13 arrest for a gross misdemeanor TPO
violation alleged to have occurred on 1/3/13, and a felony EPO violation alleged to
have occurred on or about 1/23/13. Please provide any documentation your office has
received with respect to that case and an written indication of whether your office will
be appearing at the arraignment on 3/6/13.
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I would prefer that all three matters be resolved (and hopefully the appeal of 11063341 in CR12-2025 before Judge Elliott can be included in such a global resolution)
in accordance with the terms I agreed to on the record on 8/27/13 in 11-063341 (a
hearing which arguably was combined with the other two matters).
Matters? From: Dogan, Biray (BDogan@washoecounty.us) This sender is in your
safe list. Sent:
Wed 6/27/12 9:04 AM To:
zachcoughlin@hotmail.com Cc:
Goodnight, Joseph W (JGoodnight@washoecounty.us) Zach, On June 13th, I
sent to you via email (see below) an offer negotiated w/ the State. I have not heard
back from you regarding the offer. The DA is requesting an answer to whether you are
going to accept / reject the resolution by July 10. You are currently scheduled for trial
in Joe Goodnight's case on July 16, and an MSC on the same day for my case. Please
let us know before July 10 whether you want to go forward with trial or otherwise. In
the case you have w/ me. Plead Guilty to an amended count of Disturbing the Peace.
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Serve 90 days jail (concurrent to the case you have w/ Goodnight) "suspended," on
condition you continue to see your psychologist or psychiatrist, provide monthly
reports of this to the Justice Court, maintain any Rx regimen prescribed by your doctor,
and obey all laws. In the case you have Joe Goodnight. Plead Guilty to an amended
count of Disturbing the Peace. Serve 90 days jail (concurrent to the case you have w/
me) "suspended," on the same conditions stated above.
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There terms of my probation under RCR2011-063341 require me to check in
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with "DAS"...The security personnel whom I checked in with (Judge Sferrazza entered
and Administrative Order requiring me to be escorted by a RJC Bailiff anytime I go to
areas under the control of the RJC, due to, basically, from what I understanding, past
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"disruptions"...so I check in with the front door security staff whenever I go to 1 S.
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Sierra St for anything related to DAS (Department of Alternative Sentencing) or the
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RJC, and then wait for an RJC Bailiff to appear to escort me to, say, the DAS check in
area in the RJC filing office.
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The day of one of the allege EPO violation 1/23/13 was also the day my
Appellant's Brief was due in the N. S. Ct. case involving the State Bar of Nevada's
attempt to have me disbarred irrevocably. I was able to obtain a telephonic 5 day
extension, ultimately, making my brief due on 1/30/13 (ultimately the Record on
Appeal in that matter was struck from the record due to some things like the State Bar
putting more than 250 pages per bound volume, printing on both sides of the paper,
failing to bates stamp certain things, etc., so my Brief is now due further out, but at the
time, I did not know whether or not the Court would grant my Motion to Extend the
Deadline to file my Brief, etc...so, basically, is was a stressful situation..
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Also, the Northern Nevada Disciplinary Board issues its Findings on 12/14/12
recommending to the Court that I be forever disbarred. I attempted to file a postFindings Motion for New Trial or to Alter or Amend the Findings...under NRCP 52
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and or 59, and maybe DCR13(7), that was due 10 judicial days from that 12/14/12
mailing of the Findings...which would have been 1/3/13...I don't wish to violate the
EPO or file a Brief that disparages anyone. Rather, I hope to be able to pull together
the enormous amount of material involved in defending against the SBN's Complaint,
which alleged I violated some 12 Rules of Professional Conduct and untold number of
times, in a professional and fair manner, with a focus on mitigating factors involved in
what has occurred in my life since August 2011, should an outright agreement related
to some SCR 117 Disability arrangement not be available with the SBN.
I have recently complete an intake with Northern Nevada Adult Mental Health
Services and start counseling and hopefully that will result in an arrangement where,
even if I cannot afford them myself, I will be able to get my Wellbutrin antidepressant
and avoid some of the things that may, in part happen when I run out of it and can't
afford a refill. I have sent the WCDA's Office some ill advised emails and or writings
in the last month or so (and probably beyond that), and believe that was at least in part
a result of not being able to afford my medication.
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However, the TPO/EPOs may be void given the purported service of the TPO
and Notice of the EPO Hearing appears to violate Courthouse sanctuary doctrine, on
top of the dictate against serving attorney's process while they access the courts.
Additionally, neither WC nor SBN put up the bond statutorily required for
a workplace TPO, and exhibits on their face demonstrate that the link in the
email Coughlin alleged to have sent on or about 12/12/12 was to a hark.com audio
clip only not a movie. NRCP 56(g), bad faith affidavits, untenable, particulary
where WCPD Jim Leslies admits to failing to provide coughlin 911 audio files on
two dics propounded by the WCDA on 8/13 and 8/17/12. Further, audio clip speaks to
learning, reading, and philosophy, which would not seem to support a finding of the
sort of conduct required to support such an Order. Additionally, free speach and
access to SBN filing office procedures, including those under SCR 105(4), including
those expressed by the SBN and its Clerk of Court and fax filing (some authority
equates email with fax as well) may present claim of right defense to any alleged EPO
violation.
As Such, the difficulties associated with being arrested on 2/8/13 and charged with a
felony and gross misdemeanor incident to alleged EPO and TPO violations occuring
on day of deadlines to file NRCP 52 and or 59 motions as to 12/14/12 NNDB Panel
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Findings and Motion for Extension fo Time for Appeal Brief in 62337, have made it
inordinately difficult to prepare for 2/25/13 Show Cause Hearing. Additionally, it may
have been improper to apply rigid and formulaic In Re Erickson application of
procedural rules to pro se defendant in various RJC matters, where DDA Young has
obtained several Emergency Ex Parte Orders and or Motions Settings (11/27/12 no
faxing in 065630...the approach to the Order For Competency Evaluation in 063341 as
it relates to the Stay required on 2/12/13 in 065630 (shall...NRS 178.405). May be
impermissible for RJC Bailiffs and or Judge Clifton to required Coughlin, essentially
to waive any notice or service requirement for improptu reconsideration Hearing
presided over by Chief Judge Pearson setting aside the Order For Competency Eval
made just an hour previous, and such may have been the result of extrajudicial
communications which may not be a permissible basis for such action (adjudicatory
boundaries limited to what parties appropriately put forth to the Court...Ex parte
communications by DDA Young at RJC Counter and or anythign communicated to
Judge Pearson on 2/12/13 may not be appropriate basis for setting aside Order for
Competency Evaluation). Lastly, DAS Officer Celeste Brown email to Coughlin of
1/24/13 indicates the video showed Coughlin presented to the security Check in
arguably a timely manner on 1/23/13 sufficient to rebut a finding of a violation, or at
least demonstrate a good faith attempt to comply. Further, arrest report/booking sheet
for 2/2/13 arrest by DAS indicates time of arrest 7:02 pm, which may violate NRS
171.136 dicate against misdemeanor arrest between 7pm and 7am without a warrant.
Coughlin ordered to exit his residence after 7pm by DAS Officer.
Further, as to WCPD Jim Leslies's TPO application it is telling he mistates the
12/12/12 email as continaing a link to a violent video clip when in fact the link is to
nothing more than an audio clip that relates to learning, reading, and philosophy (the
verbatim transcript of the entirety of the audio only clip linked to in the 12/12/12 email
is as follows:
I ain't no white trash piece of shit. I'm better than you all. I can out learn
you. I can out read you. I can outthink you, and I can out philosophize you.
And I'm going to outlast you. You think a couple of whacks to my good old
boy gut's gonna get me down? It's going to take a hell of a lot more than
that, Counselor, to prove you're better than me! (Max looks around in an
attempt to find where Sam is hiding)
The link to this in the 12/12/12 email does not contain a single violent statement
or image. If the link had been to a clip of Max Cady's Your going to learn about
loss... speach, fine, that may amount to an implied threat. But it wasn't. It was to a
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short audio clip of Cady making the above statement. Leslie is adding his own
remembrances of Cape Fear where he alleges that such quotations occurs after Cady
has beaten two men. Actually, if one went and view that whole scene from the movie,
it shows Cady being attacked by about six men that his public defender, played by
Nick Nolte, had hired to go and attack and beat Cady with baseball bats and bicycle
chains. Cady fought them off, then delivered a speach to a trash dumpster that he
figured his former counselor Nolte was hiding behind when he heard a rustling
emanate from behind it following his successfully warding off the attack by the six
hired thugs. Leslie demonstrates a complete lack of candor to the tribunal in his
application (as does WCDA DDA Watts-Vial, whose 11/13/12 last minuted faxed
objections to Coughlin's SCR 110 Subpoenas upon 2JDC Judges Flanagan and Elliot,
Clerk of Court Hastings and the 2JDC Custodian of Records, where Watts-Vial admits
to extended discussions with the very Bar Counsel whom confirmed to Coughlin that
he, as a respondent suspended attorney appearing pro se in his formal disciplinary
matter, may, in fact, issue his own subpoenas (and, given NNDB Susich's 7/27/12
email to Coughlin, Coughlin was entitled to rely upon such express indications by Bar
Counsel King, provided as a message confirming such King was relaying to Coughlin
upon confirming such with his supervisor, Chief Bar Counsel David Clark. nstead,
leslie chooses to focus on a tertiary aspect of some description of the film incident to a
link to buy the film where he writes (NOTE: ONE RATHER IMPORTANT THING
LESLIE GETS WRONG IS THE DATE SENT FOR THE EMAIL LESLIE
ALLEGES COUGHLIN SENT HIM WITH A LINK TO THE AUDIO ONLY CLIP
OF A SPEECH FROM THE MOVIE CAPE FEAR THE DATING ON THAT
EMAIL, AS EVINCED BY THE ATTACHMENT'S TO DDA WATTS-VIAL AND
LESLIE TPO APPLICATION, INDICATES THAT EMAIL WAS SENT ON
12/13/12, RATHER THAN, AS LESLIE INDICATES BELOW, ON 12/12/12) Also,
a lot of Leslie's allegation (most of them are actually inaccurate anyways, but..) need to
be taken in the context or with the knowledge that Coughlin grew up in Reno,
attending Swope and Reno High with both of his WCPD on these cases (Joe
Goodnight in 11-063341 was a classmate for 6 years and part of similar circles of
friends as Coughlin throughout those years) and Biray Dogan in 12-065630 (Dogan
and Coughlin went through school together from 7th through 12th grade, both
graduating with the Reno High School class of 1995) and Coughlin and those two have
much more of an easy ready faimilarity with each other and their respectivie senses of
humor. Then, all the sudden, Jim Leslie, Esq., who moved to Washoe County in the
early nineties from Missouri, barges in and takes over all the cases in a belligerent
arrogant manner, and ultimately winds up getting a TPO against Coughlin and
encourageing the SBN to do so as well, which now has Coughlin facing felony
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charges, disbarment, etc., etc.. Further Coughlin coached Judge Hascheff's son in
Basketball when he was a 9th grader at Reno HS in 2008, went to school sandwiched
between the graduating class containing both of WLS's Paul Elcano's sons (PM in 1994
and John in 1996) and Judge Albright's children (Erin in '94 and Ross in '96). The
point being that Couglin has lived in this commuity for a long time and has an
established track record of being non-violent (as is often the case with individuals of
Coughlin's size (6 foot 4, 250 pounds) Coughlin has been socialized to be docile and
gentile to whatever extent he was not already. Leslie and the SBN (again, via Pat
King, someone whom did not grow up here, has little history her, moved here from San
Diego in the mid 90's) would have the RJC view Coughlin as some unknown violent
drifter type not to be trusted, but rather feared, with little to no track record of civilized
behavior, which is hardly the case. Coughlin was twice a team captain for the Reno
High School basektball team in the mid 1990's, a National Merit Finalist in 1995, has
volunteered for local non-profits like Very Special Arts Nevada, and has been a
participating member of the SBN's Lawyers Concerned for Lawyers since 2003, and
formerly worked for legal aid provider Washoe Legal Services as a domestic violence
attorney, and before that local law firm Hale Lane. He went to Swope, Reno High,
then UNR, then UNLV's Boyd School of Law with WCDA DDA Chris Hicks and Jen
Christie, and worked at Hale Lane with DDA Patricia Halstead.
Any alleged linking to a short audio clip from a mainstream movie like Cape Fear,
especially where the clip speaks only to learning, and does not contain any of the
violent imagery or other contextual references that Leslie cites to (Leslie's TPO
application Statement in Exhibit assumes a great deal of information and context about
the audio clip in question that one would only be aware of from watching the entire
move, and in no way would be aware of from simply listening to a paragraph worht of
an audio clip such as that allegedly linked to, found at a mainstream website like
www.Hark.com...and Leslie fails to actually get into what the audio clip actually says,
rather, he focuses on matters in no way depicted in the audio clip (allegations that the
former client just beat several men, that he utilized a weapon or blunt instrument to do
so, that he had theirs and his blood on his (therre is a still image depicted in the clip,
but Coughlin has an add-on in his browser that blocks such image, so even if it is
proven that Couglin sent such an email, he would not have been aware of the still
image depicted upon clickin on such link, and regardless, that image is of a mainstream
actor, Robert Deniro, and it is not clear what he is holding or what he has been doing
or why, or whether or not it is in fact blood on his shirt...further in that still image,
Deniro has his hand in a placid, resting position as though balancing his weight on a
golf putter or something, hardly a menacing stance. The audio clip is 28 seconds long.
Regardless, to whatever exten Leslie, the WCPD, King or the SBN felt threatened or
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actually fearful (which is highly unlikely given all their associated bluster and
purposeful aggravation and taunting of Coughlin for a sustained period of time and
groupthink, belligerent, pack-like, institutionalized bullying behavior in some, but not
all, instances (David Clark menacingly commented to Coughlin about being sad that
he didn't get a chance to prosecute that one attorney before the schmuck committed
suicied...Pat King faux expressing sadness in an ultra condescending tone when
mentioning the high likelihood of Coughlin being disbarred, Jim Leslie's histrionics
and Scrappy-Do-like behavior (Scrappy-Do (Jim Leslie is a Scrappy Dude
reference sounds like something a taller person might make up on the spot in an
attempt to obfuscate a reference that might come across as hurtful to a shorter person
whom had finally aggravated the taller person enough to make an arguably hurtful
comment based upon one's short statute. Couglin has been tall most all of his life. Its
not all its cracked up to be...however, Coughlin has felt empathy towards shorter men,
has always attempted to and managed to make personal invective based upon other's
physical appearances, etc., and if Coughlin did make a reference to Jim Leslie being
like the character Scrappy-Do from the children's cartoon series Scooby-Do it was
only after being aggravated endlessly by a mean spirited, at times, but not always, Jim
Leslie, whom is likely stressed out at times from handling a large case-load, and
having people's freedom in his hands day after day (somethign for which Coughlin had
a great deal of respect for the fact that such is the case incident to Leslie's job and
position...For background, the cartoon character Scrappy-Do is a diminutive canine
friend of Scooby-Do whom oftens picks fights with much large opponents, only to then
have his large friends, like Shaggy and Scooby come in and either do the fighting for
him, or, more typically, dispell the situation created by Scrappy-Do's antagonizing
bluster...fairly similar to what occurred on October 9th, 2011 when RJC Bailiff Reyes
was called in (as Leslie has done with RJC Bailiff's time and again) to crack down on
or intimidate Coughlin or other Leslie client's whom have finally started to broach at
Leslie's treatement of them and refusal to advocate on their behalf. And while Leslie
alleges Coughlin to have seemingly mostly complaints against other attorney's in our
office, by far, Coughlin's frustration has related to Leslie the overwhelming majority
of the time, though at times Coughlin and Leslie have had a rapport and Coughlin
wishes Leslie no ill will, hopes to look back at all this as friends someday, etc..)..:
Exhibit 1 to Application for Temporary Order for Protection

Against Harassment in the Workplace
Zachary Coughlin is a client of the Washoe County Public
Defender, and I have been assigned to one or more of his criminal
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cases, It is anticipated that by Tuesday, December 18, 2012, our

office will be relieved as counsel on Mr, Coughlin's single remaining
case with this office. Mr. Coughlin is an attorney on suspended status
with the Nevada State Bar arising from a conviction for
misdemeanor shoplifting which has been publicized in the press.
Mr. Coughlin represented himself in that criminal proceeding.
On December 12, 2012, I received an email from Zachary
Coughlin, a copy of which is attached hereto as Exhibit" IA" . The
email pertains to a misdemeanor petit larceny case of Mr. Coughlin's
involving theft or unlawful retention of an iPhone, on which I and
other attorneys in our office previously represented him, During the
course of the bench trial, our office was relieved as counsel upon Mr.
Coughlin's request to represent himself. Throughout the email. Mr.
Coughlin makes various derogatory complaints about and references
to me and other attorneys in our office.
At the end of the first paragraph of the email. Mr. Coughlin
complains that his various attorneys and others in the local criminal
justice system have ruined his life and he writes 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 ?" The email then
references the website http://tinyurl.com/bgmlfdr When that address
is cut and pasted into a web browser, it directs the reader to a website
containing a video segment from the movie "Cape Fear", which the
website summarizes as a film that "tells the story of a convicted
rapist who seeks vengeance against a former public defender
whom he blames for his 14-year imprisonment .... " In the movie,
the client, played by Robert Di Nero, carries out that vengeance
by stalking and trying to kill his former public defender, played
by Nick Nolte. A copy of the print out of the website is attached
hereto as Exhibit IB", The video segment on the website is a
scene in the movie where the client of the public defender has just
beaten two men. The client is wearing a shirt bloodied with his
blood and the blood of the men he just beat, and he is holding a
bluntinstrumcnt weapon or a chain in his hand. He vows to
continue his harassment of his former public defender, who is
hiding nearby behind a garbage dumpster.
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The email from Mr. Coughlin is addressed to several attorneys in

the office of the Washoe County Public Defender, including attorneys
Jim Leslie, Jeremy Bosler, Biray Dogan, Joseph Goodnight, and
Chris Fortier. Mr, Coughlin has previously and repeatedly expressed
significant dissatisfaction with his various attorneys in our office and
has almost continuosly, as he does throughout the email attachted
hereto, blamed them for his current legal problems, his recent
criminal convictions, and his suspension from active attorney
licensure with the Nevada State Bar. The email is also addressed to
several other persons outside our office, including but not limited
to Steve Tuttle of the Reno Justice Court, John Kadlic, and Daniel
Wong of the Reno City Attorney's Office, Mary Kandaras of the
Washoe County District Attorney's Office-Divil Division, and David
Clark and Patrick King of the Office of Bar Counsel of the Nevada
State Bar.
Based on Mr. Coughlin having included the various recipients
to the email who are not his attomeys, Mr. Coughlin has waived
attomey-c1ient confidentiality. Additionally, based upon the nature
of the references made in the first paragraph of the email to Mr.
Coughlin's legal problems and reference to the "Cape Fear"
regarding violence and harassment against former puhlic
defender, Mr, Coughlin has waived attorney-client confidentiality
as per Nevada Rule of Professional Conduct 1.6(c).
Later the same day as the emailn December 12, 2012. Mr.
Coughlin showed up at the offices of the Washoe County Public
Defender without an appointment, I and an investigator went to the
lobby to see him, since we had decided based on previous encounters
with Mr. Coughlin that it is best not to meet with him alone, With
the investigator present in the lobby, I asked Mr. Coughlin what he
needed. He said he wanted his discovery documents. Since we
have had prior incidents where Mr. Coughlin received documents
from us and later claimed we did not provide them, I asked him
to email me with his request and that I would respond to the
email. During our discussion I informed him that I would be asking
that our oflicc be relieved from his pending misdemeanor Obstructing
and Resisting criminal case. He became agitated and upset and I
asked him to leave and to schedule an appointment if he thought
he needed one and to send me his email request. He refused to
leave, stating he was writing a note. I asked what the note was and he
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became loud and verbally aggressive and said "None of your

goddamncd business..." His demeanor was visibly belligerent I asked
him again several times to leave and he rose to his feet (he is
approximately 6'3" and I am 5'4") and went on a verbal rant against
me. I continued to tell him to leave while I turned to the front desk
staff and asked them to call the police, He tried handing me the
note, and in response I held out my hand to receive it from him,
but then he pulled the note back from me several times in a
taunting manner while smiling. As we waited for the elevator, he
kept saying he was "chipping" at me. As he left in the elevator, he
kept saying "chip, chip, chip .... , in a taunting manner.
I asked my investigator to summarize the encounter in writing.
A copy of that written summary is hereto attached as Exhibit "]-C".
Given Mr. Coughlin's demeanor and behavior, and given the
"Cape Fear" reference in the email earlier that day, I felt it
appropriate to call the police as result of Mr. Coughlin's refusal to
leave, aggressive and hostile demeanor and statements, and the
concern that he might get physically violent. He left the building
before the police arrived.
As a result of the email and the encounter with Mr. Coughlin
in our lobby we have notified him via email that he is not to come to
our offices without prior confirmation of an appointment with his
assigned attorney. See Exhibit" I-D" attached hereto. We also advised
the front desk for the building, located on the first floor, of that
limitation on his access to our office. See Exhibit "1-E" attached
hereto.
Based on what appears to be Mr. Coughlin's escalating
animosity toward out office and staff as reflected in the email
reference to "Cape Fear", Mr. Coughlin's expressions in the email of
hostility toward several of the attorneys in our office and his
apparently bleaming of them for his legal problems and criminal
convictions, and his demonstrated aggressiveness toward our staff,
we are applying for the restraining order to which this Exhibit "1" is
attached.
Noticeably, WCPD Leslie's own Investigator, Evo Novak's statement that
DDA Watts-Vial attached to the very same TPO Application in 12-599 itself
contradicts Leslie's accounts (and Leslie contradicts himself and reveals his own
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professional misconduct upon a review of the emails between Coughlin's then

WCPD Leslie and WCDA DDA Kandaras of 12/12/12 and 12/13/12...and upon a
thorough review of those emails and Coughlin's sent messages folder it is
revealed that Couglin did not send Leslie any email on 12/12/12 (which makes it
apparent that the 12/12/12 email Coughlin sent to the SBN and others was
forwarded to Leslie by one of it's recipients, at which point Leslie forwarded the
same to WCDA DDA Kandaras, makingly particularly suspect the dubious
mistatements of the dates involved in Leslie's Ex.1 statement attached to the
Workplace Harrassment TPO filed on Leslie's behalf by DDA Watts-Vial (he of the
dubious 11/13/12 faxed objections to Coughlin's SCR 110 subpoenas in this matter)
and reveals the extent to which Leslie engages in violations of RPC 3.1, 3.3, 1.6,
and, possibly, 3.4, NRS 178.405, and RPC 1.14. Novak wrote:
Leslie, Jim From: Sent: To: Subject: Novak, Eva Wednesday,
December 12, 2012 4:51 PM leslie, Jim Coughlin office visit
121212 11:58:11 am, 12-21-2012 23/32 Knowing Mr Coughlin's
volatile past behavior I was asked to accompany Jim leslie to the
lobby to assist Coughlin, He was seated in a chair writing a note,
Jim leslie asked Coughlin what he needed, Coughlin mentioned he
needed some discovery from a case . Jim Leslie advised him make
any communications by way of email, he would handle that way,
Coughlin asked if I was present as witness, Jim Leslie confirmed
that, Jim stated that he was going to ask to be relieved from the
current Coughlin case, Coughlin's demeanor became belligerent.
Jim Leslie asked Coughlin to leave the office, Coughlin refused
claiming he was writing a note, Jim Leslie asked what the note
was. Coughlin said " it's none of your goddamn business and
walked past Jim and left the note at the reception desk,
Coughlin was advised several times by Jim Leslie to leave the
office. Jim Leslie advised him that the police were going to be
called. At that point the elevator arrived, Prior to the elevator
door closing he continued his rant toward Jim Leslie until the
door closed, Evo Novak
Additionally, WCPD and WCDA DDA-Civil Division DDA Mary
Kandaras may have violated NRS 178.405, Coughlin's rights
incident to Leslie's representation in RJC RCR2012-067980, and
11-063341, 12-065630 in light of RPC 1.16(c) in, but not limited to,
the following (an in consideration of WCDA DDA Watts-Vial's and
Leslie's subsequent TPO Application in RJC RCP2012-000699,
both appear to have violated RPC 1.1, 1.3, 3.1, 3.2, 3.2, 3.4, 3.4,
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3.5A, 3.7, 4.3, 5.1, 5.2, 5.3, 5.5, 8.1, 8.3, and 8.4 (especially
considering Leslie's continuing to maintain that he knows that his
office sent Coughlin written notice of the 8/6/12 combination
hearing in 12-067980 and 12-065630 when his legal assistant,
Linda Gray, admitted to Coughlin on 8/8/12 that she failed to mail
out the written notice to Coughlin in light of her belief that
Coughlin's then PO Box 3961, Reno, NV 89505 mailing address
was no longer good (where Gray was presumably unaware that
Coughlin bailed out of jail on 7/21/12, upon the ridiculous Order
following the unnoticed 7/5/12 bail increase hearing incident to the
fraudulent testimony by RPD Officers Weaver and or Dye, and the
advocacy by RMC court appointed counsel Keith Loomis (which
was anything but) resulting in RMC Judge W. Gardner raising
Coughlin's then bondable $1,415 bail to a cash only $3,000 (based
upon three charges that were completely phoney, drummed up, and
spurious to begin with.
TITLE 14PROCEDURE IN CRIMINAL
CASES; Chapter 178 General Provisions:
INQUIRY INTO COMPETENCE OF
DEFENDANT AND PROCEDURE
FOLLOWING FINDING OF
INCOMPETENCE...
NRS178.405Suspension of trial or
pronouncement of judgment when doubt
arises as to competence of defendant; notice
of suspension to be provided to other
departments.
1.Any time after the arrest of a
defendant, including, without limitation,
proceedings before trial, during trial, when
upon conviction the defendant is brought up
for judgment or when a defendant who has
been placed on probation or whose sentence
has been suspended is brought before the
court, if doubt arises as to the competence
of the defendant, the court shall suspend the
proceedings, the trial or the pronouncing of
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the judgment, as the case may be, until the

question of competence is determined.
2.If the proceedings, the trial or the
pronouncing of the judgment are suspended,
the court must notify any other departments
of the court of the suspension in writing.
Upon receiving such notice, the other
departments of the court shall suspend any
other proceedings relating to the defendant
until the defendant is determined to be
competent.
Further, the OBC's King backing out on his express agreement to provide
Coughlin the names of the attorney's on the Screening Panel assigned to each of
the grievances resulting in the formal disciplinary hearing held on 11/14/12 is
telling, as is the includion of WCDA DDA Bruce C. Hahn, Esq. and DDA Mary
Kandaras in the OBC's 8/23/12 First Designation of Hearing Panel Members and
Mr. Hahn's inclusion amongst the Washoe Legal Services Board of Directors at
the time in March 2009 when Coughlin quickly returned to Elcano an emergency
assignment due, two days before the start of the Joshi Trial in DV08-01168 (from
which the 4/13/09 Order After Trial by 2JDC Judge L. Gardner became NG120435, the third grievance in listed in the caption of the OBC's 8/23/12 Complaint,
which Judge Nash Holmes admits (contrary to the misleading, evasive, and
arguably duplicitous statements in that regard by the OBC's King as to the actual
genesis of that greivance and the identify of the greivant (relevant to any RPC 4.2
compliance required of Coughlin). Couglin performed ghostwriting for Elcano in
preparing the exact, verbatim version of the Taxpayer Petition for Appeal from
the Decision of the County Board of Equalization that Coughlin had filed for
Washoe Legal Services (the cover form therein contains Coughlin's handwriting,
with a markedly different handwriting for Elcano's signature, as Elcano changed
not a single character in the four page Petition Coughlin finished in time to timely
submit for filing on the statutory deadline to do so on 3/10/09.
Coughlin was assigned that project by Elcano less than 5 calendar days
before the deadline was to run, with the Joshi Trial in DV08-01168 set for
3/12/09. The project involved an attempt by WLS to get out of being stuck with
the property taxes for the real estate upon which it operates and leases from a
private, for profit landlord. Coughlin returned an excellent Petition to Elcano in
an exceedingly short time frame. For Elcano to then appear at Coughlin's
11/14/12 formal hearing and question Coughlin's competency is ridiculous and
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pathetic, especially considering the inordinate effort Elcano expends in trying to

pass himself off as some Atticus Finch type. In March 2009 Coughlin actually
met with Elcano and a WLS Board Member that may have been Hahn (its not
clear, and WLS and then it's counsel has refused to identify those who were
board members at the time of Coughlin's summary suspension and subsequent
firing) (now a member of the SBN's Board of Govenors, and WLS's then Board
President, Kathleen Breckenridge, Esq., is also amongst those identified in the
OBC's 8/23 Initial Designation, and the RJC's newest Justice of the Peace, Hon.
Pierre Hascheff was also on WLS's Board at the time of Coughlin's summary
suspension on 4/20/09 and subsequent firing during the time period to file a
Motion for Reconsideration or otherwise challenge the 4/13/09 OAT (FHE 3);
and Elliott Sattler, Esq., Washoe County District Attorney's Office Deputy
District Attorney, Criminal Division Term began: November 2009, expires:
November 2013 is listed as a WLS Board Member during the period of the
wrongful termination litigation involving Coughlin and WLS, as is Suzanne
Ramos, Reno City Attorney's Office Tern began: February 2013, Expires,
February 2015, as is grievant 2JDC Judge Linda Gardner's fellow 2JDC Judge,
Hon. Bridget Robb Peck, Second Judicial District Court Judicial Board Position
Term Began: December 2008, expires: December 2013, and NNDB Member
Kathleen T. Breckenridge, Esq., Kathleen T. Breckenridge, Ltd. Board Term
Began: September 2007, expires September 2013, here:
http://washoelegalservices.org/index.php/board-members ) to review that Petition
Coughlin prepared for WLS by the 3/10/09 deadline. That Coughlin prepared
Petition includes the following analysis (somehow, the ability to find a needle in
a haystack of legal authority in a very scant amount of time had not translated to
an ability to make much of a living in Washoe County, where, it seems, some
other qualifications are rather necessary):
...This Appeal is meant to demonstrate
that a leasehold with an option to buy for the
building and land at issue in this Appeal (and
for which the lease involved specifies that
WLS shall be responsible for the taxes
associated with), should be included in the
property to which the language of NRS
361.140(2) applies. The building and land at
issue in this Appeal should thus receive an
exemption from taxation. There exists a
wealth of support for the contention that the
language in NRS 361.140(2) allows an
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exemption to WLS where it holds a leasehold

with an option to buy in the property at issue.
Cases interpreting statutory sections with
language very similar to, or in some cases,
nearly verbatim to NRS 361.140(2) have held
that "belonging to" does, in fact, include
situations where a party has a leasehold in the
building and land at issue.
One case is particularly instructive. "The
Board concedes that the property is actually
and exclusively occupied and used by the
Hospital Corporation for a hospital conducted
not for profit, but exclusively as a charity, but
it contends that since the property is owned by
the Foundation it is not real estate "belonging
to" a hospital and is not exempt from taxation.
Thus we must first decide whether the hospital
property belongs to the Hospital Corporation
within the meaning of 183( e) of the
Constitution and its legislative construction,
Code 58-12(5), so as to exempt it from
taxation, even though the bare legal title is in
the Foundation. Board of Supervisors v.
Medical Group Foundation, Inc., 134 S.E.2d
258,261 (Va. 1964). It is instructive to note
that ""belonging to" may mean less than an
absolute and unqualified title, such as the
absolute right of use. Sisters of Charity v. City
of Detroit, 9 Mich. 94,98; City of Jackson v.
Preston, 93 Miss. 366,47 So. 547, 549, 21
L.R.A. N.S. 164; Shewell v. Board of Ed. of
Goshen Union Local School Dist. 88 Ohio
App. 1,96 N.E.2d 323, 324; Black's Law
Dictionary, 3d ed., Belong, p. 205." Id.
"From the context of 183( e) and its
statutory interpretation, when construed in the
light of other subsections and the policy of the
State as to exempted property, we hold that
"belonging to" includes, but is not limited to,
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an absolute and unqualified title. Cf.

Annotation, 157 A.L.R. 860, 862, 863." Id. "In
(e), the property is exempt if it is "real estate
belonging to, actually and exclusively
occupied and used by" a hospital "conducted
not for profit, but exclusively as" a charity ...
we must conclude from this that they intended
that the words "belonging to" require only that
the hospital have some interest or estate in the
land it occupies and uses, not necessarily
absolute ownership, as the words "owned by"
would import. In this sense the real estate here
in question "belongs to" the Hospital
Corporation, so long as it has the exclusive
right to its possession under the lease." Board
of v. Medical Inc., 134 S.E.2d 258, 262 (Va.
1964).
Several other cases argue for a similar
interpretation. "Under Art XIII 1, property
rented or leased to a school district and used
by the district exclusively for public school
purposes is exempt from taxation,
notwithstanding the fact that such property is
owned by a private individual and not by the
district." Ross v. 24 Cal 2d 258, 148 P2d 649
(1944).
"To hold, however, with the appellant
and follow the authorities cited by it and amici
curiae, it would be necessary for us to construe
the constitutional section of our state as
requiring property used by a school district for
public school purposes not only to be solely
used by the district but also to be owned by the
district before it would be exempt from
taxation. As previously stated in this opinion,
we are not able to so construe the applicable
section of our Constitution. On the other hand,
we are in accord with the decisions of those
courts in other jurisdictions, as well as in our
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own, which hold that it is the use and not the

ownership of the property in the possession of
a school district and used by it for public
school purposes that determines its status as
property exempt from taxation." 24 Cal. 2d
258, 265 (Cal. 1944).
"In Ross the property leased to a school
district by a private owner was used
exclusively for public school purposes and
was held tax exempt on that ground. In
explaining why a sheer usage of property
without a concomittant ownership should
entitle the school district to a tax exemption,
the Supreme Court pointed out that the
exemption of property used for public school
purposes is not for the benefit of the private
owner who may rent them his property for said
purpose, but for the advantage of the school
district which may be compelled to rent
property rather than to buy land and erect
buildings thereon to be used for the
maintenance of its school. With this advantage
the school district is able to rent property for a
lower rental than the owner of the same
property wouid be willing to accept from a
private individual, for the reason that if rented
to a school district the owner is relieved from
the payment of taxes thereon." Honeywell
Information Inc. v. County of Sonoma, 44
Cal. App. 3d 23,30 (Cal. App. 1st Dist. 1974).
See also, Regents of University of California
v. State Bd. of Equalization, 73 Cal.App.3d
660, 666, 140 Cal.Rptr. 857 (1977)["The
purpose of the exemption here is to obtain
lower rentals for the educational
institutions."].
One California case is instructive in
considering the curious paucity of appearances
of the phrase "belonging to" in NRS 361 when
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compared to the many instances of the use of

the word "owner", or some derivation thereof.
""Since other governmentally owned property
was also exempt, the inclusion in the 1879
Constitution of an express exemption of
"property used exclusively for public schools"
necessarily had another purpose. That purpose
was to create a new exemption, one for
property "used for," but not "owned by" a
public school." v. of 824 P.2d 663, 675 (Cal.
1992).
NRS 361 is similar to the portion of the
California Constitution at issue in in that the
phrase "belonging to" only makes one
appearance in the entirety of NRS 361 for
exemption purposes at NRS 361.140(2) (the
"belonging to" language also occurs at NRS
361.075(2) and NRS 361.745(2), though both
other instances do not seem to be relevant to
the way the phrase is used in NRS
361.140(2)). In contrast, many, many times in
the text of NRS 361 does the word "owned" or
some derivation thereof appear, strongly
suggesting that ownership in a fee simple or
title sense was not meant to be a requirement
to be read into NRS 361.140(2).
It is solely the use of the property which
determines whether the property is exempt or
not." Washburn v. Comm'rs of Shawnee Co., 8
Kan. 344 (Kan. 1871). "It makes no difference
who owns the property, nor who uses it.
Property used exclusively for educational
purposes is exempt, whoever may own it, or
whoever may use it." Anniston Land Co. v.
160 Ala. 253, 260 (Ala. 1909). The "court, in
both, brought pointedly into view the principle
that "exclusive use," irrespective of ownership,
was the test of the right of exemption. We do
not stand alone in this construction of these

decisions." Id.
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Similarly, "under the act "all buildings

belonging to institutions of purely public
charity, and all buildings belonging to public
hospitals, shall be exempt." ... Under this
construction no regard need be had to the
manner in which the title is held. v. Grand
Forks 10 N.D. 54 (N.D. 1900).
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For the reasons set forth above we

respectfully request that the State Board of
Equalization grant a property tax exemption to
the building and land that currently houses
WLS's efforts to bring legal services to needy
and deserving individuals.
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From: Kandaras, Mary Sent: Thursday, December 13, 2012 10:20

AM To: Leslie, Jim Subject: RE: 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 Importance:
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High
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Jim:
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I believe that you should send this. Supreme Court Rule 104(a)
authorizes State bar counsel to investigate all matters involving
possible attorney misconduct or incapacity called to bar counsel's
attention, whether by grievance or both. This potentially involves
misconduct (violation of law) and incapacity.
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Mary Kandaras Deputy District Attorney Civil Division Washoe

County
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December 12, 2012 5:11 PM To: Kandaras, Mary Subject: RE:
discovery of 8/13 and 8/17, 2012 to Coughlin in rcr2012
-065630
Thanks, please do. He came to our office after my email to you
and caused a disturbance. We called the police, but he fled
before they arrived. jim
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-----Original Message----From: Kandaras, Mary Sent:

Wednesday, December 12, 2012 3:17 PM To: Leslie, Jim
Subject: RE: The Three E's; wcpd failure to provide essential
rcr2012-065630
11
I will have to review this tomorrow and get back to you.
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Mary Kandaras Deputy District Attorney Civil Division

Washoe County
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-----Original Message----From: Leslie, Jim
The below email from Mr. Coughlin contains a reference
at the end of the first paragraph to a website containing a video
clip from the movie Cape Fear. Please advise whether any
action is required of our office or yours regarding this
possible veiled or indirect threat of violence against
attorneys in this office by Mr. Coughlin.
22
Sent: Wednesday, December 12, 2012 2:59 PM To: Kandaras,

Mary Subject: FW: 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
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Mary:
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Please review my transmittal to Patrick King at the bar,

below, and let me know if I should do anything else from a
civil perspective.
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Thanks,
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-----Original Message----
From: Leslie, Jim Sent: Wednesday, December 12, 2012 2:49

PM To: 'patrickk@nvbar.org' Subject: FW: 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
Mr. King:
Thank you,
James B. Leslie, Esq. Chief Deputy Public Defender Washoe

County Public Defender's Office
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-----Original Message---From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]

Sent: Wednesday, December 12, 2012 2:35 PM To: Leslie,
Jim; Bosler, Jeremy; Dogan, Biray; Goodnight, Joseph W;
Fortier, Chris; Tuttle, Steve; Kandaras, Mary; Young, Zach;
skauc@reno.gov;
wongd@reno.gov;
kadlicj@reno.gov;
complaints@nvbar.org; cvellis@bhfs.com; je@eloreno.com;
patrickk@nvbar.org; davidc@nvbar.org; rosec@nvbar.org;
laurap@nvbar.org;
skent@skentlaw.com;
mike@tahoelawyer.com;
eifert.nta@att.net;
nevtelassn@sbcglobal.net;
fflaherty@dlpfd.com;
fflaherty@dyerlawrence.com
18
Subject: The Three E's; wcpd failure to provide essential 911

call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
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rcr2012 -065630
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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
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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....
The link that Leslie refers to as containing a video clip from
the movie Cape Fear actually contains only an audio clip of a
short quote from Cape Fear (the 1991 Scorsese version).
THERE ARE A NUMBER OF MATERIAL INCONSISTIENCIES AND
CONTRADICTIONS BETWEEN THE EVEN JUST LESLIE AND EVO NOVAK'S
ACCOUNTS, MUST LESS LESLIES MISTATING THE DATE OF THE THREE
E'S EMAIL TO ADD EFFECT, INCLUDING LESLIE MISLEADING
STATEMENTS (SHOWN BY THE LACK THEREOF IN NOVAK'S ACCOUNTS)
OF WHETHER COUGHLIN ATTEMPTED TO HAND LESLIE THE NOTE
(COUGHLIN DID, THEN LESLIE PUT HIS HAND FAR OUT TO EACH SIDE AS
IF TO SAY HE WOULDN'T TAKE IT, AT WHICH POINT COUGHLIN,
DISTRUSTING LESLIE TO TAKE THE NOTE ANYWAYS, PLACED IT AT THE
RECEPTIONISTS TABLE IN FRONT OF HER WINDOW...NOVAKS FAILURE
TO COORBORATE LESLIE'S ALLEGATION THAT HE BEGAN THREATENING
TO CALL THE POLICE RIGHT AWAY, THE INABILITY OF COUGHLIN TO
LEAVE UNTIL THE ELEVATOR ARRIVED REGARDLESS, AND THE FACT
THAT COUGHLIN WAS SAYING SCRAP, SCRAP, SCRAP, NOT CHIP, CHIP,
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CHIP LIKELY IN AN ATTEMPT TO DISGUISE ANY ILL-ADVISED

STATEMENT'S REFERENCING SCRAPPY-DO, WHERE COUGHLIN ALSO
SAID AT THAT TIME JIM, YOU ARE A SCRAPPY DUDE.
Exhibit 1 to Application for Temporary Order for Protection
Against Harassment in the Workplace
...
On December 12, 2012, I received an email from Zachary
Coughlin, a copy of which is attached hereto as Exhibit" IA" . The
email pertains to a misdemeanor petit larceny case of Mr. Coughlin's
involving theft or unlawful retention of an iPhone, on which I and
other attorneys in our office previously represented him, During the
course of the bench trial, our office was relieved as counsel upon Mr.
Coughlin's request to represent himself. Throughout the email. Mr.
Coughlin makes various derogatory complaints about and references
to me and other attorneys in our office.
At the end of the first paragraph of the email. Mr. Coughlin
complains that his various attorneys and others in the local criminal
justice system have ruined his life and he writes 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 ?" The email then
references the website http://tinyurl.com/bgmlfdr When that address
is cut and pasted into a web browser, it directs the reader to a website
containing a video segment from the movie "Cape Fear", which the
website summarizes as a film that "tells the story of a convicted
rapist who seeks vengeance against a former public defender
whom he blames for his 14-year imprisonment .... " In the movie,
the client, played by Robert Di Nero, carries out that vengeance
by stalking and trying to kill his former public defender, played
by Nick Nolte. A copy of the print out of the website is attached
hereto as Exhibit IB", The video segment on the website is a
scene in the movie where the client of the public defender has just
beaten two men. The client is wearing a shirt bloodied with his
blood and the blood of the men he just beat, and he is holding a
bluntinstrumcnt weapon or a chain in his hand. He vows to
continue his harassment of his former public defender, who is
hiding nearby behind a garbage dumpster.
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The email from Mr. Coughlin is addressed to several attorneys in

the office of the Washoe County Public Defender, including attorneys
Jim Leslie, Jeremy Bosler, Biray Dogan, Joseph Goodnight, and
Chris Fortier. Mr, Coughlin has previously and repeatedly expressed
significant dissatisfaction with his various attorneys in our office and
has almost continuosly, as he does throughout the email attachted
hereto, blamed them for his current legal problems, his recent
criminal convictions, and his suspension from active attorney
licensure with the Nevada State Bar. The email is also addressed to
several other persons outside our office, including but not limited
to Steve Tuttle of the Reno Justice Court, John Kadlic, and Daniel
Wong of the Reno City Attorney's Office, Mary Kandaras of the
Washoe County District Attorney's Office-Divil Division, and David
Clark and Patrick King of the Office of Bar Counsel of the Nevada
State Bar.
Based on Mr. Coughlin having included the various recipients
to the email who are not his attomeys, Mr. Coughlin has waived
attomey-c1ient confidentiality. Additionally, based upon the nature
of the references made in the first paragraph of the email to Mr.
Coughlin's legal problems and reference to the "Cape Fear"
regarding violence and harassment against former puhlic
defender, Mr, Coughlin has waived attorney-client confidentiality
as per Nevada Rule of Professional Conduct 1.6(c).
Later the same day as the emailn December 12, 2012. Mr.
Coughlin showed up at the offices of the Washoe County Public
Defender without an appointment, I and an investigator went to the
lobby to see him, since we had decided based on previous encounters
with Mr. Coughlin that it is best not to meet with him alone, With
the investigator present in the lobby, I asked Mr. Coughlin what he
needed. He said he wanted his discovery documents. Since we
have had prior incidents where Mr. Coughlin received documents
from us and later claimed we did not provide them, I asked him
to email me with his request and that I would respond to the
email. During our discussion I informed him that I would be asking
that our oflicc be relieved from his pending misdemeanor Obstructing
and Resisting criminal case. He became agitated and upset and I
asked him to leave and to schedule an appointment if he thought
he needed one and to send me his email request. He refused to
leave, stating he was writing a note. I asked what the note was and he
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became loud and verbally aggressive and said "None of your

goddamncd business..." His demeanor was visibly belligerent I asked
him again several times to leave and he rose to his feet (he is
approximately 6'3" and I am 5'4") and went on a verbal rant against
me. I continued to tell him to leave while I turned to the front desk
staff and asked them to call the police, He tried handing me the
note, and in response I held out my hand to receive it from him,
but then he pulled the note back from me several times in a
taunting manner while smiling. As we waited for the elevator, he
kept saying he was "chipping" at me. As he left in the elevator, he
kept saying "chip, chip, chip .... , in a taunting manner.
I asked my investigator to summarize the encounter in writing.
A copy of that written summary is hereto attached as Exhibit "]-C".
Given Mr. Coughlin's demeanor and behavior, and given the
"Cape Fear" reference in the email earlier that day, I felt it
appropriate to call the police as result of Mr. Coughlin's refusal to
leave, aggressive and hostile demeanor and statements, and the
concern that he might get physically violent. He left the building
before the police arrived.
As a result of the email and the encounter with Mr. Coughlin
in our lobby we have notified him via email that he is not to come to
our offices without prior confirmation of an appointment with his
assigned attorney. See Exhibit" I-D" attached hereto. We also advised
the front desk for the building, located on the first floor, of that
limitation on his access to our office. See Exhibit "1-E" attached
hereto.
Based on what appears to be Mr. Coughlin's escalating
animosity toward out office and staff as reflected in the email
reference to "Cape Fear", Mr. Coughlin's expressions in the email of
hostility toward several of the attorneys in our office and his
apparently bleaming of them for his legal problems and criminal
convictions, and his demonstrated aggressiveness toward our staff,
we are applying for the restraining order to which this Exhibit "1" is
attached.
Noticeably, WCPD Leslie's own Investigator, Evo Novak's statement that
DDA Watts-Vial attached to the very same TPO Application in 12-599 itself
contradicts Leslie's accounts and reveals the extent to which Leslie engages in
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violations of RPC 3.1, 3.3, 1.6, and, possibly, 3.4, NRS 178.405, and RPC 1.14.
Novak wrote:
Leslie, Jim From: Sent: To: Subject: Novak, Eva Wednesday,
December 12, 2012 4:51 PM leslie, Jim Coughlin office visit
121212 11:58:11 am, 12-21-2012 23/32 Knowing Mr Coughlin's
volatile past behavior I was asked to accompany Jim leslie to the
lobby to assist Coughlin, He was seated in a chair writing a note,
Jim leslie asked Coughlin what he needed, Coughlin mentioned he
needed some discovery from a case . Jim Leslie advised him make
any communications by way of email, he would handle that way,
Coughlin asked if I was present as witness, Jim Leslie confirmed
that, Jim stated that he was going to ask to be relieved from the
current Coughlin case, Coughlin's demeanor became belligerent.
Jim Leslie asked Coughlin to leave the office, Coughlin refused
claiming he was writing a note, Jim Leslie asked what the note
was. Coughlin said " it's none of your goddamn business and
walked past Jim and left the note at the reception desk,
Coughlin was advised several times by Jim Leslie to leave the
office. Jim Leslie advised him that the police were going to be
called. At that point the elevator arrived, Prior to the elevator
door closing he continued his rant toward Jim Leslie until the
door closed, Evo Novak
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Leslie's TPO Application in 12-599 seems to clearly be in

retaliation for Coughlin filing a grievance (SEE RICHARD G.
HILL, ESQ., 1/14/12 GRIEVANCE TO THE SBN AGAINST
COUGHLIN AND RMC JUDGE NASH HOLMES 3/14/12
GRIEVANCE TO THE SBN AGAINST COUGHLIN, WHICH
ATTACHED A 3 YEAR OLD SANCTION ORDER THAT
BECAME A GRIEVANCE BY HOLME'S FELLOW RMC
JUDGE W. GARDNER THAT HE RECIEVED FROM HIS
SISTER, 2JDC FAMILY COURT JUDGE L. GARDNER
WHEREIN SHE SANCTIONED COUGHLIN RESULTING IN
HIS FIRING FROM WLS IN 2009, AND 53833 AND 54844 AND
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60303 AND 60317...) against Leslie with the SBN, including the
following:
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formal written grievance against Skau, Young, Leslie, Dogan, etc.

FW: 911 calls missing from what was produced by City Attorney
Skau? 12/04/12
To: ... zyoung@da.washoecounty.us, complaints@nvbar.org,
patrickk@nvbar.org, davidc@nvbar.org,
...bdogan@washoecounty.us, jleslie@washoecounty.us
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 12/04/12 2:07 PM
Outlook Active View 12 attachments (total 16.1 MB) CR11-20642676094 (Opposition to Motion to Dismiss CR11-20642676094.pdf).pdfDownload 11 7 12 subpoenas 063341 gricela
alvarez and hassett proof of service or waivers.pdfDownload CR112064 MOTION FOR EXTENSION OF TIME (Mtn for Extension
of Time).pdfDownload CR11-2064-2655401 (Mtn to
Dismiss ...).pdfDownload CR11-2064-2676094 (Exhibit
2).pdfDownload Download all as zip
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Dear Office of Bar Counsel, This is a formal grievance against City

Attorney Skau, Public Defender Jim Leslie and Biray Dogan, and
DDA Zach Young.
A portion of a recent email from City Attorney Skau reads:
"Fwd: FW: Case No. RCR2011-063341? From: Creighton C.
Skau (skauc@reno.gov) Sent: Fri 11/09/12 11:45 AM To:
zachcoughlin@hotmail.com Cc:
Jeannie Homer
(HomerJ@reno.gov) 1 attachment photo[1].JPG (181.2 KB) Dear
Mr. Coughlin, Please be advised that Judge Sferaza authorized
service upon you by email in an Order. Accordingly, authorized
service has already been effected... Set forth below is the language
of Judge Sferaza's Order and the language of the City's Motion. ...
But, a listen to around the 9:25 am mark on the audio transcript
form the RJC Javs recording of the 11/8/12 hearing in rcr2011- 92/154 MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF; EXCUSABLE NEGLECT FOR THIS
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063341 reveals Mr. Skau fraudulently procurred Couglin's

attendance at the 11/13/12 Hearing (and considering 11/12/12 was a
holiday, Skau would have been prevented from effecting
contstructive service prior to the 11/13/12 hearing date set...This
prejudiced not only Coughlin's formal disciplinary hearing but also
the petty larceny trial of 11/19 and 11/20 and is a straight scum bag
move by Creig Skau. Judge Sferrazza granted Coughlin a waiver of
witness fees for subpoenas and subpoena duces tecums at the 48
minute mark of the second wmv file from the JAVS audio
transwcript of the 10/22/12 Hearing in RCR2012-063341.
Regardless, City Attorney Skau not only doesn't know who Jeremy
Bosler, Esq. is, but he cites to a JCRCP 45 to challenge a subpoena
in a criminal misdemeanor case and he fails to inform the court of
the waiver of service signed by an individual who indicated she had
authority to do so, Gricela Alvarez (whom, somehow, Judge
Sferrazza was apparently aware of and had opinions
on....curiously). Speaking of scum bag moves, there's is Jim Leslie
jumping in at the 9:06 am mark on the 11/20/12 javs recording
112012coughlin1 for rcr2011-063341 (really, everything Jim
Leslie did in this case or any other in "representing" Coughlin
is hall of fame sleazy) "I can jump in as stand by counsel if you
feels he is dragging his feet, your honor...He's wasting county
assets."...Really, Jim, this is a grievance against you for seeking
to coerce a waiver of Coughlin's fifth amendment rights
incident to your refusal to utilize any of the exculpatory media
Coughlin provided you at either the Supression Hearing or the
Trial..and a greivance against DDA Young for similarly coercing
a waiver of Coughlin's Fifth Amendment rights (you really need to
listent to the last file for 11/19 and the first for 11/20 to get an idea
of the hysterics DDA Young engages in, getting Coughlin taken
into custody, wherein the RJC Bailiffs asked if they could keep
Coughlin's laptops over night...but there is some really bad audio on
there ... DDA Young getting completely coercive with respect to
a waiver of Coughlin's Fifth Amendment rights and "you can't
put on anything else or any evidence, YOU NEED TO
TESTIFY!" and Young "you Honor, it was my understanding
that you let mr. Coughlin out of custody on the condition that
he testify! If he won't do it TAKE HIM BACK INTO
CUSTODY!" add to the grievance against young the fraudulent
testimony and argument he put on where he knows or should
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have know that the rpd duralde did not receive any reports from
dispatch of "a possible fight" where Duralde had left his vehicle
and the text screen therein prior to the 11:27:11 pm text from
dispatch, and therefore, such allegations of a report from dispatch of
"a possible fight" did not bare on Duralde's probable
cause/reasonable suspicion analysis. further young put on perured
testimony by Zarate about how Zarate "personally eye witnessed
Coughlin receiving the phone" when Young was provide a video
wherein Zarate admits he only inferred that. Oh, and Coughlin
hereby swears he never received any such 11/7/12 motion, faxed or
otherwise from Dogan or his assitant Tibbals or anyone with the
WCPD. And then there is Jim Leslie failing to make a hearsay
objection when DDA Young asks Officer Duralde what some
unnamed bystanders told him upon arriving...yet, every bit of video
evidence and or testimony that Coughlin sought to have Leslie
introduce regarding Nicole Watson admitting to hearing "the man
with the six pack" threaten to throw the iPhone "in the river if
someone doesn't claim it right now" was continually excluded as
"hearsay"...Between the following two timestamped recordings
finally provided by City Attorney Skau (WCPD Jim Leslie is too
busy whistling during trail at Coughlin's pointing out how he
cautioned the youths prior to the arrival of the peace to stay
peaceful in Coughlin's references the then recent murder of Stephen
Gale just blocks away approximately two months prior to the
8/20/11 arrest, incident to the theft of a purse, and Lelise prefers
to spend his time chiming in, unprompted, on the regard,
arrogantly enough, that he can assist the court if it feels
Coughlin is "draggin' his feet" incident to the inappropriat
placement by Judge Sferrazza of Leslie as "stanby counsel" which
really amounted to no more than yet another coercive practice...In
RCR2011-063341, Coughlin's then WCPD Joe Goodnight, Esq
(who was removed from representing Coughlin by Jim Leslie and
Jeremy Bosler the Washoe County public defender applying
good nicely peers deciding that the night was doing too much to
assist Coughlin in defending himself and or otherwise zealously
advocating on call Pat good night in Coughlin had a trial prep
strategy session while Coughlin was in custody on July Friday,
July 13 at approximately 430 man and you good night reiterating
the extent to which he would be appearing on Coughlin's to have to
try the case at trial on July 16, 2012 Monday morning at 9 AM and
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it was only upon Coughlin arriving and being brought to the court
in custody seeded Jeremy Bosler was suddenly filling in for
Goodnight with and indication Goodnight's December 19, 2011
file stamp discovery requests served upon the stay and district
attorney Zach young reads at page 1 therein: "REQUEST FOR
DISCOVERY COMES NOW, the Defendant, ZACHARY
BARKER COUGHLIN, by and through his attorney of record,
Joseph W. Goodnight, Deputy Public Defender, and hereby
requests the following discovery pursuant to NRS 174.235 to
NRS 174.295, inclusive. 1. Inspect and receive copies or
photograph any written or recorded statements or confessions made
by the Defendant or any witness, or copies thereof, within the
possession, custody or control of the State, the existence of which is
known or by the exercise of due diligence may become known to
the prosecutor. NRS 174.235(1)(a). This request includes any video
and audio recordings, including those preserved on pocket
recording devices, 9-1-1 emergency calls, and any dispatch logs,
written or recorded, generated in connection with this case." It is
telling the extent to which on the record at that July 16 trial date
Washoe County public defender Jeremy Bosler indicated that Jim
Leslie would immediately be rounding you a replacement role
pretty suddenly disappearing Goodnight. And that Leslie would be
prepared to try the case by Friday and that the court could step
matter for trial on Friday it is witness. Perhaps what Mr. Bosler
meant was that Jim Leslie would, by that Friday, have completed all
the trial prep Jim Leslie would be doing on this case by Friday, and
that that would be the case whether or not that evinced any sort of
concern for his client, ability to zealously advocate on his client
behalf or willingness to do so, or indication that Jim Leslie felt that
the judges of the Reno Justice Court would hold him to a standard
of care at all tending to indicate that Mr. Leslie has any skin in this
game whatsoever. Clearly there is a bases for mistrial here were Jim
Leslie's entire contribution to the representation of Mr. Coughlin is
dripping in every way with misconduct and malpractice and
apparently willing disregard for the rules of professional conduct an
intentional manifestation of Leslie's desire to secure a conviction
the Washoe County District Attorney's Office and therein secure
added boys from local law enforcement District Attorney's Office
and perhaps the Reno justice court itself. Further Reno Municipal
Court judge Nash Holmes's admonition as to communications with
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the Washoe County public defenders office in connection with

February 27, 2012 clandestine status conference between Biray
Dogan and Zach Young which neither Dogan nor Young has ever
refuted whether they they have been sworn prior thereto or not an
especially where Dogan's coworker down the hall civil division
deputy Dist. Atty. Mary has been involved throughout the
confiscation without a search warrant or court order of any kind (or
at least one ever served on Coughlin in any manner) of Coughlin
smart phone and micro SD card incident Judy impermissible
summary contempt finding by judge Nash Holmes just two hours
after the clandestine status conference between Dogan young on
February 27, 2012 in RMC case 11 TR 26800 for which Dogan and
Young stipulated to a continu...n compliance with Judge Sferrazza
Order of 9/5/12 FW: Zach Coughlin has shared a folder with you?
From:
Zach Coughlin (zachcoughlin@hotmail.com) Sent:Tue
11/27/12 8:26 AM To: psferrazza@washoecounty.us
(psferrazza@washoecounty.us); zyoung@da.washoecounty.us
(zyoung@da.washoecounty.us) re:rcr2011-063341 Dear Judge
Sferrazza and DDA Young, I am sending this in compliance with
Judge Sferrazza's indication that I should send him materials after
the trial the bare on the ineffective assistance of counsel claim and
or the coerced waiver of my Fifth Amendment rights, especially
incident to the representation by WCPD Jim Leslie. Please note the
email of 11/5/2012 from Court Administrator Mr. Tuttle and the
inadvertent faxing of numerous filings to the wrong fax number by
myself. https://skydrive.live.com/redir?resid=43084638F32F5F28!
5141&authkey=!APibWiVXTMSWkw0 .(NOTE, THAT
EMAILED GRIEVANCE TO THE SBN CONTINUES ON FOR
QUITE SOME TIME, AND THIS IS A TRUNCATED,
EXCERPTED VERSION HERE...).
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911 Case? Leslie, Jim (Jleslie@washoecounty.us)Add to

contacts12/07/12 To: 'zachcoughlin@hotmail.com' Cc: Dogan,
Biray Outlook Active View 1 attachment (2.2 MB) Coughlin
Discovery 911 Case.pdfDownload Download as zip 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
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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. Leslie, Esq.
From: Jleslie@washoecounty.us To: zachcoughlin@hotmail.com
Subject: Coughlin Date: Thu, 13 Dec 2012 00:22:01 +0000 Mr.
Coughlin: Based on your behavior at our offices on several past
occasions, including today where we had to call the police due to
you engaging in behavior constituting disturbing the peace, you are
hereby directed NOT to come to our offices without first having
confirmed in writing an appointment with your assigned attorney. If
you violate this email notification, we will contact law enforcement.
James B. Leslie, Esq. Chief Deputy Public Defender
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discovery of 8/13 and 8/17, 2012 to Coughlin in rcr2012-065630?
Zach Coughlin (zachcoughlin@hotmail.com)12/13/12 To:
jleslie@washoecounty.us...28 attachments (total 20.0 MB)
Download all as zip THIS REPRESENTS A VERY
TRUNCATED VERSION OF THE 12/13/12 EMAIL LESLIE
ATTACHED TO HIS TPO APPLICATION, WHICH LESLIE
MISLEADINGLY AND INCORRECTLY INDICATES WAS
SENT AND RECEIVED ON 12/12/12, INSTEAD OF 12/13/12.
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Coughlin? Leslie, Jim (Jleslie@washoecounty.us)Add to contacts

12/12/12 To: 'zachcoughlin@hotmail.com' From: Leslie, Jim
(Jleslie@washoecounty.us) This sender is in your safe list. Sent:
Wed 12/12/12 4:22 PM To:
'zachcoughlin@hotmail.com'
(zachcoughlin@hotmail.com) Mr. Coughlin: Based on your
behavior at our offices on several past occasions, including today
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where we had to call the police due to you engaging in behavior

constituting disturbing the peace, you are hereby directed NOT to
come to our offices without first having confirmed in writing an
appointment with your assigned attorney. If you violate this email
notification, we will contact law enforcement. James B. Leslie, Esq.
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Jim Leslie is a scrappy dude RE: Coughlin? From: Zach Coughlin

(zachcoughlin@hotmail.com) Sent: Fri 12/14/12 1:24 AM To:
Leslie, Jim (jleslie@washoecounty.us);
jbosler@washoecounty.us (jbosler@washoecounty.us);
fflaherty@dlpfd.com (fflaherty@dlpfd.com);
fflaherty@dyerlawrence.com (fflaherty@dyerlawrence.com);
davidc@nvbar.org (davidc@nvbar.org); mpickesq@msn.com
(mpickesq@msn.com) Dear Jim Leslie, Esq., Jim, I need to get my
discovery for the resumption of the trial in rjc rcr2012065630...Despite your cries of "wasting county assets" at 9:05am on
11/20/12 when, in your standby counsel role, you attempted to
assist DDA Young and Judge Sferrazza in further coercing from me
my Fifth Amendment rights...you seem intent on wasting county
assets, as your failure to turn over the discovery (the cd recordings
of 911 calls DDA Young alleges he produced to my WCPD on
8/13/12 and 8/17/12 has not materially prejudiced my defense in
rcr2012-065630, in much the same way your failure to timely
transmit my file in rcr2011-063341 did, including your failure to
produce the results and response and production in connection with
the subpoena of 10/3/12, and given you were note removed as
counsel of record until at the earliest 10/22/12...Kelley Dodma,
ECOMM, and you have some 'splainin' to do. Now you allege that
you filed a false police report. Jim, please keep a copy of any
communications you have made to the RPD, and of course the call
you reference will be subpoenaed, and if there exists any recordings
(video/audio, whatever) of the "incidents" you describe (not sure
dropping of a written request for one's file/discovery to your
receptionist given the fact that time is of the essence here is
"distrubing the peace", but, to each his one, I guess...however, its
curious you never seem to place any restrictions on your continuing
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to cash your sweet paychecks week after week, Jim...now you seem
to be seeking some sort of protection against being served written
notices or having them delivered, or making my ability to do some
contingent upon your scheduling a meeting (any such meeting
would likely terminate after five minutes, as they have in the past,
with you pulling your Diana Ross-diva act....DDA Young got a
good knowing laugh out of that one on 12/11/12.....). Jim, please do
me a favor and reply to this email, copying the SBN and President
of the State Bar and describe just exactly what occurred during
these recent "past several occasions"...and put it in an
affidavit...also, will you finally put in an affidavit your contentions
that you "know" your office sent me notice in writing of the 8/6/12
combo-hearing date in 065630 and 067980 (please also put in
writing your refusal to send out subpoenas (easy under nrs 174.345)
to ECOMM for any calls to 911 or dispatch related to me in any
way since 8/20/12) and any dispatch to law enforcements
recordings, and recordings made by law enforcement or submitted
to law enforcement by private parties, since that date as well. Please
further indicate in writing why you are refusing to send the WCSO
a subpoena duces tecum for any materials related to me in any way
from their civil division (that served process of the items detailed in
the variosu affidavits of services by Machen et al that have become
of issue in 11 tr 26800, 067980, etc., etc., subpoena Northwinds
Lou Cadia and Duane Jakob...)....See, Jim, you are still getting paid,
you need to do some work here, guy... So cute how Biray Dogan, in
the 8/21/12 Hearing in 065630 mentioned how he "left a voice
mail" for Linda Gray, but just couldn't, gosh darn it, get an answer
from her about whether she did send out written notice of the 8/6/12
combo hearing...(you know, the one you testified about during our
closed Mardsen-lite conflict hearing in 063341...where you alleged
you "knew" for sure that notice was sent, but then refused to
provide any specifics as to how you 'knew" or what you did to make
sure of that..." Gray admitted to Coughlin on the phone that she did
not mail out any written notice of the 8/6/12 hearing to Coughlin
because your office had marked his "PO BOX 3961" address as "no
longer good" at that time (and the audio of the 7/16/12 aborted Trial
date clearlye establishes Coughlin was not provided the 8/6/12 date
at that time, because the temporary replacement for the suddenly
disappeared WCPD Goodnight, and DDA Young were directed to
meet in the hall/counter after the conclusion of the proceeding on
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7/16/12 and pick a date and time, by which time Coughlin was
taken back into custody (where he was serving 18 days in jail due to
the fraudulent bail increase in rmc 12 cr1240 (another bogus
"disturbing the peace charge" by the RPD...that even the City of
Reno prosecutors had to drop (and we all know how adverse they
are to dropping any charges, ever). Jim, why don't you just go wash
the RPD's cars or something if you want to suck up to them so bad?
Please then explain to those listed above why your cross
examination of Cory Goble on 8/29/12 in 063341 seemed to consist
solely of an attempt on your part to defeat the NRS 171.136
problem the State faced, including the exclusionary rule application,
where the testimony as to the value of the phone by the "victim"
Goble was "about $80" valuation...well under the $250 needed at
the time to support a "oooh, thats a felony" grand larceny charge (to
quote Officer Duralde), and therein vitiate the legitimacy of any
such arrest or search incident thereto (unless a citizen's arrest could
be established....which is what you spent your entire cross of Goble
trying to establish, for the State's benefit...because you are a sleazy,
spiteful, lazy, mean spirited, petty, hateful individual whom the DA
wants on the case anytime it really, really needs a win. Just because
you have ascended to Chief Deputy status doesn't mean you are any
good at what you do, Jim, nor does it, in my opinion, provide some
sheen of integrity to your act). NRS 171.136 When arrest may be
made. 1. If the offense charged is a felony or gross misdemeanor,
the arrest may be made on any day, and at any time of day or night.
2. If it is a misdemeanor, the arrest cannot be made between the
hours of 7 p.m. and 7 a.m., except: (a) Upon the direction of a
magistrate, endorsed upon the warrant; (b) When the offense is
committed in the presence of the arresting officer; (c) When the
person is found and the arrest is made in a public place or a place
that is open to the public and: (1) There is a warrant of arrest
against the person; and (2) The misdemeanor is discovered because
there was probable cause for the arresting officer to stop, detain or
arrest the person for another alleged violation or offense; (d) When
the offense is committed in the presence of a private person and the
person makes an arrest immediately after the offense is committed;
(e) When the offense charged is battery that constitutes domestic
violence pursuant to NRS 33.018 and the arrest is made in the
manner provided in NRS 171.137; (f) When the offense charged is
a violation of a temporary or extended order for protection against
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domestic violence issued pursuant to NRS 33.017 to 33.100,

inclusive; (g) When the person is already in custody as a result of
another lawful arrest; or (h) When the person voluntarily surrenders
himself or herself in response to an outstanding warrant of arrest.
Sincerely, Zach Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and
Fax: 949 667 7402 ZachCoughlin@hotmail.com
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RE: Jim Leslie is a scrappy dude RE: Coughlin? Leslie, Jim

(Jleslie@washoecounty.us)Add to contacts 12/14/12 To: Zach
Coughlin From: Leslie, Jim (Jleslie@washoecounty.us) This
sender is in your safe list. Sent: Fri 12/14/12 9:45 AM To:
Zach Coughlin (zachcoughlin@hotmail.com) Mr. Coughlin:
A hearing has been set for Tuesday December 18, 2013, at 8:30 am
in Reno Justice Court, at which we will ask to be relieved as
counsel in the remaining case you have with this office, RCR12067980, based on, among other things, (1) your prior expressed
desire to represent yourself and (2) your email to myself and several
other recipients, including state bar attorneys, which contains an
express or implied threat of violence. If you fail to appear at the
hearing, the relief will be requested in your absence upon the
grounds stated above. If you choose to agree to self-representation
without argument, the second above-noted reason may or may not
rise to the point of discussion, although I would note that the email
you sent with the express or implied threat was disseminated by you
to several recipients including representatives of the Nevada State
Bar, thereby breaching confidentiality by your own action. Pending
the hearing, there is no reason for us to meet in person or
communicate by any means. Any communications from you
pending the hearing will be deemed to be made in waiver of
attorney-client privilege and are subject to forwarding to the
Nevada State Bar and/or law enforcement as appropriate pursuant to
Nevada Rule of Professional Conduct 1.6(c). James B. Leslie, Esq.
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Leslie's RPC vioaltions extend to continuing to maintain the

WCPD sent Coughlin written notice of the 8/6/12 combination
hearing in the RJC in 12-067980 and 12-065630 when his legal
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assistant, Linda Gray, admitted to Coughlin on 8/8/12 that she

failed to mail out the written notice to Coughlin in light of her belief
that Coughlin's then PO Box 3961, Reno, NV 89505 mailing
address was no longer good (where Gray was presumably
unaware that Coughlin bailed out of jail on 7/21/12, upon the
ridiculous Order following the unnoticed 7/5/12 bail increase
hearing incident to the fraudulent testimony by RPD Officers
Weaver and or Dye, and the advocacy by RMC court appointed
counsel Keith Loomis (which was anything but) resulting in RMC
Judge W. Gardner raising Coughlin's then bondable $1,415 bail to a
cash only $3,000 (based upon three charges that were completely
phoney, drummed up, and spurious to begin with, so much so that
the RCA dropped the charge underlying the custodial arrest
(disturbing the peace), dismissed the failure to provide proof of
insurance charge (Coughlin provided such on the scene just prior
to arrest, but the fraud of Officer Weaver ignored that), leaving only
a failure to secure a load on one's truck charge, the Amended
Complaint of 10/11/12 Coughlin did not receive, but for which he
subsequently learned contained in incorrect case number therein.
Further, RCA Sooudi actually went against the RPD's own decision
making in, on 8/16/12, filing an Amended Complaint charging
Coughlin with trespassing (which was, of course, subsequently
dropped in light of the fact that, one, Coughlin did not cave to
Sooudi's attempt to gain leverage by impermissibly overcharging,
and two, the fact that Coughlin, at the time of arrest, still had at
least one, if not three, valid leases at the address to which such
trespassing charge was directed, providing a claim of right defense
to any criminal trespass charge, especially where no protection
order was in effect at such time Instead, the RCA and RPD
conspired with Bellevue, Washington's Northwinds Apartments
Associates, LLC to violat Soldal v. Cook Co, and deprive Coughlin
of his 42 USC Sec. 1983 rights and his rights under the three
different lease agreements he had with Northwinds (to which the
RJC subsquently, sua sponte, essentially filed and granted Motions
to Consolidate such three (or more) different case on behalf of the
unauthorized practitioner of law (Nevada Court Services CEO, Jeff
Chandler) representing Northwinds in RJC Rev2012-001048
(which resulted in Coughlin's custodial arrest on 6/8/12 in
RCR2012-067980, and being charged with a SCR 111(6) serious
crime under NRS 199.280 where DDA Young continues to violate
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RPC 3.8 in maintaining such charge where he has been provided

proof that the WCSO's Deputies there refused to identify
themselves prior to Northwind's Apartments maintenance man
Milan Krebs (whom was apparently so afraid of Coughlin that he
filed a TPO on 7/5/12 (whether he received a raise for doing so has
yet to be determined) in RJC RCP2012-000287), yet not so afraid
as the fail to present to the WCSO Deputies on 6/28/12 offering to
utilize a Saw-z-All to cut open the metal overhead door to
Coughlin's Unit 29 at 1680 Sky Mountain Dr., Northwind's
Apartments (later that day, following the arrest, Nevada Court
Services' Jeff Chandler posted on that Unit 29 an Amended 5 Day
Notice of Unlawful Detainer correcting the jurisdictional bar error
Coughlin pointed out under NRS 40.253(6) where the initial 5 day
Unlawful Detainer Notice listed the wrong court to file a Tenant's
Answer in (it listed Sparks Justice Court, where Coughlin did
timely submit for filing such a Tenant's Answer) where the 6/14/12
Declaration of Personal Service by NCS's Ryan Wray (one cannot
personally served a closed, locked door where entreaties made by a
process service are not met with so much as a single human voice
responding...(see NRCP 4, applicable via NRS 40.400) :
Additionaly basis for Disqualification based upon the mere APPEARANCE
OF IMPROPERITY OR BIAS OR POSSIBILITIY THEREOF (THAT IS TO
SAY, COUGHLIN IS NOT NECESSARILY ACCUSING ANY OF THE FINE
JUDGES OF THE RJC OF DOING ANYTHING WRONG, AND IN FACT,
COUGHLIN IS FOND OF AND HAS GREAT RESPECT FOR EACH OF
THOSE JUDGES, AND WISHES HE COULD HAVE HAD MORE
INTERACTION WITH JUDGE SCHROEDER AND JUDGE LYNCH. FULL
DISCLOSURE, COUGHLIN WAS A 9TH GRADE BASKETBALL COACH
FOR RENO HIGH SCHOOL IN 2007-08, COACHING NOW RJC JUSTIC
OF THE PEACE HASCHEFF'S VERY TALENTED AND ENGAGING SON
ANTHONY HASCHEFF. ADDITIONALLY COUGHLIN HAS SUED HIS
FORMER EMPLOYER, WASHOE LEGAL SERVICES IN CV11-01955,
AND CV11-01896, AND ITS BOARD OF DIRECTORS, WHICH AT THEY
TIME APPARENTLY INCLUDED NOW RJC JUDGE HASCHEFF, AND
WASHOE LEGAL SERVICES IS NOW PARTNERED WITH THE WCDA'S
OFFICE AND CO-DEFENDANTS IN A CASE INVOLVING THE
PARTNERSHIP IN THE ECR PROGRAM, WHEREIN WLS
APPARENTLY EMPLOYEES RMC DEFENDER LEW TAITEL, WHOM
WAS BRIEFLY COUGHLIN'S ATTORNEY IN THE CRIMINAL
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TRESPASS CASES STEMMING FROM COUGHLIN'S ARREST AT HIS

FORMER HOMW LAW OFFICE IN RJC 11-1708 EVICTION MATTER.).
TERMINOLOGY
Appropriate authority means the authority having responsibility for initiation of
disciplinary process in connection with the violation to be reported. See Rules 2.14 and
2.15.
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I am not longer and efiler, but was between 1/4/12 until deactivation in mid November
of 2012. All during that time the only pdf available for the 1/4/12 Supplemental in
CV11-03628 was the attached 3 page version, which fails to include the actual
documents or filings listed in the "Appeal Receipt". Such a failure to include those
filed, especially one that is characterized as "Emergency Letter to Court from Zach
Coughlin, Esq" (which is not a "letter" but rather my submission for filing of a "Notice
of Appeal" of the 12/21/11 Order Resolving Motion to Contest Personal Property Lien
by RJC Judge Sferrazza. The failure to include such items in what was provided to
Judge Flanagan for review in the ROA became very deleterious to my case in a number
of ways, including as mentioned in Judge Flanagan's 3/30/12 Order denying my
appeal, and now, arguably in the 12/14/12 Findings and Conclusions and
Recommendation to disbar me permanently from the practice of law in Nevada
incident to opposing counsel Hill's allegation that my pursuing a stay, on or around
December 22nd 2011, under NRS 40.385 was vexatious or otherwise violative of RPC
3.1 (Meritorious Claims and Contentions) (which I believe the attached transcript from
Venetian v. Two Roads disproves).
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I am writing to request the 2JDC email me or provide an electronic copy (or, a hard
copy) of the entirety of what it received, at any point, from the RJC in connection with
the 1/4/12 Supplemental filing in CV11-03628.
I believe it would appropriate not to charge me for this given anything beyond the
intial 3 page version of that 1/4/12 filing was never available during an 11 month
period wherein I did have an eFlex subscription.
A footnote on page 5 of Judge Flanagan's 3/30/12 Order in CV11-03628 indicates:
"... In addition, because Coughlin failed to timely file his notice of appeal
regarding the personal property lien, see NRS 40.253(8), and because Coughlin's
notice of appeal fails to identify an error regarding the court's procedure in
setting a hearing on this issue, this Court will no consider this issue."
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The testimony at Coughlin's formal disciplinary hearing on 11/14/12 included the

following:
"FORMAL HEARING - Vol. I, (Pages 51:10 to 54:17)
51
...
12
Was Mr. Coughlin, in his dealings with you as
13 an attorney, was he truthful or did he show candor in his
14 dealings with you as a lawyer?
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MR. COUGHLIN: I'm sorry, your Honor. If I
16 can interject. It's been well over 15 minutes.
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MR. ECHEVERRIA: That's true. Do you want to
18 wrap it up, Mr. King?
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MR. KING: Yes.
20 BY MR. KING:
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Q With that said, did he show candor to you?
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A In our dealings with Mr. Coughlin, you could
23 not trust him at all. No agreement ever made with
24 Mr. Coughlin was honored by him.
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For example, when Judge Sferrazza ordered that
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52
Mr. Coughlin could have two days -- he was originally
given a week to move his stuff out before the eviction
order was served. Thereafter there was a hearing. The
judge gave Mr. Coughlin two days to go in and remove his
possessions.
Mr. Coughlin -- we went over there, opened the
doors about 8:00 o'clock. He wasn't there. About 11:00
o'clock we get an e-mail from Mr. Coughlin saying I have
appealed Judge Sferrazza's ruling. That means his ruling
is stayed. That means I can go back into the house. I'm
staying in the house, and there's nothing you can do about
it.
MR. COUGHLIN: Objection, hearsay.
MR. ECHEVERRIA: Overruled.
THE WITNESS: Sometime later that day we got
an order from Judge Sferrazza saying that the request for
a stay had been denied. Mr. Coughlin had burned basically
a whole day doing nothing trying to get his stuff out.
That was typical....
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top of what was going on.

Finally, when we got in the district court, we
were able to use the e-flex system, and we were able to
keep track of what was going on.
BY MR. KING:
Q Let me restate the question. The question is:
As an attorney, having a responsibility to be truthful and
to have candor with opposing counsel, was Mr. Coughlin
truthful, and did he use candor with you?
A No.
MR. ECHEVERRIA: Mr. King, wrap it up, please.
You're limited to 15 minutes.
BY MR. KING:
Q Specifically relating to Mr. Coughlin's candor
to the court, did he show candor to the courts?
A No.
Q In his demeanor -MR. COUGHLIN: Objection. Lack of foundation.
MR. KING: My last question.
MR. COUGHLIN: Pretty damming statement to
have no foundation.
MR. ECHEVERRIA: Please don't interrupt. We
haven't heard the question yet to which you've objected.
MR. COUGHLIN: The last one, whether I showed
candor to the court, and he said no.
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MR. ECHEVERRIA: You object to that one? It's
2 overruled. Go ahead.
With respect to the NRS 40.385 Motion for Stay issues, I believe it may also be
relevant the extent to which my attempted filings were refused by the 2JDC from that
time, especially given NRAP 8. Please see attached emails and CV11-03051.
Also, I am requesting an electronic copy of the entire file in DV08-01168 given I
believe I was wrongfully withheld access thereto during times of exigent circumstances
in 2009 (please see attached emails and note the 5/20/09 filing by myself could not
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have been consider in Judge Gardner's 5/21/09 Order given such 5/20/09 filing was not
entered until at least 5/24/09, despite what the file stamping thereon may indicated.
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Please note WLS then Board President Breckenridge requesting and picking up the
audio cd of the Uribe TPO hearing from 3/12/09 at which the 2JDC CAAW run TPO
Office Advocate, Roxanne express aghast horror at Coughlin's representation of a male
domestic violence victim in FV09-00886. Further Elcano's representations vis a vis
Coughlin's competency are not exactly bourne out by Coughlin's filing in the
Davenport TPO and divorce case upon his taking over for then WLS Board President
Breckenridge, whom missed the I-864 Affidavit of Support issue. Note, Coughlin,
Judge Flanagan, and WCDA DDA Halstead all worked together at Hale Lane.
Lastly, please consider that, as currently carried out by the WCSO Civil Division,
Washoe County takes the absolutely most brutal approach to conducting eviction lockouts, essentially reading NRS 40.253 to allow the WCSO Civil Division race over to a
tenant's rental minutes after the summary eviction proceeding, and gain access with the
help of a locksmith, and immediately begin going through such a tenant's personalty,
then locking them out (even without their medications or eyeglasses or state issued
identifcation) whereupon the tenant is then subjected to the fraudulent approach taken
by some attorney's, such as Richard G. Hill, Esq. (see his 12/2/11 coercive letter to
Coughlin) in applying NRS 118A.460 in the most specious manner imaginable.
There is a great deal of confusion as to the law in Nevada vis a vis 24 hour lock-out
notices and how soon after posting one the constable or Sheriff may effectuate the
lock-out: http://www.lpsnv.com/EvictionFAQ.pdf: "7. DOES MY TENANT HAVE
RIGHTS? Yes they do. When the notice is served, your tenants rights state that they
can contest the notice with the justice court from the moment that they receive the
notice. Their reasons can vary, but they must get their Tenants Response filed with the
court of jurisdiction. It will then be approved or denied by the judge. If it is approved,
then a hearing will be scheduled. Your tenant can also contest the 24 Hour Lock-out
Notice, which is posted by the Constable. This notice is posted 24 hours before the
Constable returns to the property to do the lock change."
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Gayle Kern, Esq., ought to have been made to follow RPC 3.5A, but regardless, she
should not have been granted any Writ of Restitution or Lockout Order on 3/15/12
merely upon a default basis Coughlin filed a detailed Tenant's Affidavit that could
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speak for him at the hearing, and the initial burden is on the landlord (ie, the party
moving for summary judgment under Anvui), and Kern failed to even file a Landlord's
Affidavit. Kern obtained a default summary eviction against Coughlin on 3/15/12
(despite Coughlin's detailed 3/8/12 filing of a Tenant's Answer and Pre-Hearing Brief),
resulting in Couglhin being summarily evicted at gunpoint hours later (despite Kern
having failed to first file a Landlord's Affidavit as required by NRS 40.253(6) (so if
Coughlin was two minutes late to that 3/15/12 hearing, why no overly rigid and
formulaic application of procedural rules against Kern?). Consequently, at Coughlin's
11/14/12 formal disciplinary hearing, NVB Judge Beesley testified as to Coughlin's
appearance before him minutes after being evicted at gunpoint by the WCSO (whom
were violating NRS 40.253(6) in failing to post a lockout order, then wait 24 hours
before barging in with guns drawn). Somehow, Judge Beesley never considered that
Sheriff misconduct might have an effect on Coughlin's law practice, nor, curiously, did
Judge Beesley manage to mention that Coughlin's 3/30/12 filing before him in NVB
10-05104 Cadle Co. v. Keller detailed Judge Beesley's 1977 McGeorge School of Law
classmate now RMC Judge Nash Holmes confiscating Coughlin's smartphone and
micro sd card after summarily incarcerating him for 5 days on 2/27/12, though such
confiscation occurred after Coughlin's personatly had been book in at the Washoe
County Jail, and therefore was not done incident to a search incident to arrest, and
therefore required a warrant or Order to so take out of where it was booked into
Coughlin's personal property at the jail and release to the City of Reno Marshals a day
later, as WCSO Deputy Hodge admitted to Coughlin, with local attorney Pam
Willmore standing by, on March 19th, 2012. Following the 3/30/12 filing by Coughlin
detailing this before Judge Beesley, Judge Nash Holmes entered an Order releasing
Coughlin's property entered 3/30/12. WCDA DDA Kandaras finally signed off on that
Order and Coughlin's was only then permitted to retrieve his property on 4/7/12,
though all the data thereon was wiped prior to it being returned to Coughlin. Coughlin
did not lie to Judge Nash Holmes in court on 2/27/12 in 11 TR 26800, and Judge Nash
Holmes has offered nothing in the way of factual support for her initial contention that
Coughlin had lied to her that day, which, during Coughlin's cross examination of her at
his formal disciplinary hearing on 11/14/12, resulted in the basis proffered by Judge
Nash Holmes for her suspicion that Coughlin had lied to her being thoroughly and
easily disproven given the patent inaccuracies inherent to Judge Nash Holmes
contention that she had interrogated Coughlin about recording and recording
devices prior to his requesting to be permitted to use the restroom, when, in fact, such
interrogation only occurred after the one and only restroom break in that "simple traffic
citation".
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Further, Judge Nash Holmes consistently alternates between finding something

occurred by "clear and convincing evidence" only to alternately characterize her
findings as indicated such was "probable" or that she believes something "probably
occurred":
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HEARING - Vol. I, (Pages 139:11 to 157:2)

139
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11 ut a bathroom break?
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A I'm sorry. What marshals when?
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Q Well, the ones you reference on the audio from
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A Well, again, which -- my marshals. Could you
16 be more specific, please, in your question?

17
Q How much have they told you about the
18 hearing -19
MR. ECHEVERRIA: Mr. Coughlin, you interrupted
20 the judge. She asked you a question. Do you want to be

21 specific as to a particular conversation?
22 BY MR. COUGHLIN:
23
Q Yeah. There was one bathroom break in the
19
24 hearing. What were you told during the bathroom break by
20
25 either a marshal or the city attorney?
21
22
140
23
24
2 particular issue, Mr. Coughlin?
25
3 BY MR. COUGHLIN:
26
Q No. Just anything. Anything connected to me?
27
MR. ECHEVERRIA: That's what I'm asking. Is
28
6 it involving you, sir?
MR. ECHEVERRIA: With respect to any
MR. COUGHLIN: Yes.
MR. ECHEVERRIA: All right.
THE WITNESS: Mr. Coughlin asked for a
10 bathroom break. I originally said I would not give the
11 break. And then I said that I would, but he had to leave
12 all his materials in the courtroom. And I said that
13 because I suspected that he was tape-recording the court
8
9
10
11
12
13
14
15
14 proceedings without my permission, and without asking

15 permission first. Because he's apparently been known to
16 do that.
17
MR. COUGHLIN: Objection, hearsay. Lack of
18 foundation.
19
20
THE WITNESS: So I required one of my marshals
21 to accompany him to the restroom.

22
MR. COUGHLIN: She just gets to say a bunch of
16
23 hearsay?
17
24
18
25 responding to your question.
MR. ECHEVERRIA: Mr. Coughlin, she is
19
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20
21
Go ahead, Judge.
22
THE WITNESS: When the marshals came back from
23
3 the restroom, they told me that Mr. Coughlin had, in fact,
24
4 been recording the proceedings because he had disassembled
25
5 a device and left parts of it in the bathroom. Or left --
26
6 disassembled parts of it, and then they discovered parts
27
7 of it.
28
In any case, when he was taken into custody

9 and held in contempt of court at the jail, he had
10 physically two recording devices on him, a cell phone --
11 either two cell phones or a cell phone and some other
12 recording device. I assumed that was pieces of which he
13 was messing with in the bathroom.
14 BY MR. COUGHLIN:
15
Q Which marshal told you that?
16
A I'm sorry? I can't hear that.
17
Q Which marshal --
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18
MR. ECHEVERRIA: Mr. Coughlin, you don't need
19 to yell.
20
THE WITNESS: It was Marshal Harley that told
21 me that, Joel Harley, H-a-r-l-e-y. He said when they went

22 in and checked the bathroom after Mr. Coughlin left, and
23 he had found evidence that he had disassembled some object
24 or something in there.
25 BY MR. COUGHLIN:
17
18
142
19
Q What evidence, and what object?
20
A I just described it as some sort of a
21
3 recording device. Whether it was a cell phone and he took
22
4 the SIM card out or whatever it was, I wasn't sure. But I
23
5 had asked you, Mr. Coughlin, point blank in court if you
24
6 were recording, and you told me no. And then you asked
25
7 immediately to go to the bathroom, and I said no. And
26
8 then you begged and squirmed and said you had to relieve
27
9 yourself, and I had to let you go to the bathroom. And
28
10 then when you did that, you went into the bathroom -- 111/154 MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF; EXCUSABLE NEGLECT FOR THIS
11 BY MR. COUGHLIN:
12
Q Really?
13
A Took apart and disassembled a recording
14 device.
15
16
17 repeatedly to please not interrupt people.
8
9
10
11
12
13
14
Q Really? Would audio show that, Judge?

MR. ECHEVERRIA: Mr. Coughlin. I've asked you
18
MR. COUGHLIN: I thought she was done.
19
MR. ECHEVERRIA: It was clear she wasn't when
20 you were interrupting her.

21
MR. COUGHLIN: All right.
22
MR. ECHEVERRIA: You will cease that conduct.
23
MR. COUGHLIN: Okay.
24
MR. ECHEVERRIA: You've asked a question of
25 the judge. She answered it. Do you have a question?
15
16
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17
1 BY MR. COUGHLIN:
18
19
3 trial?
20
21
5 let me move across the hallway, because I can't hear
22
6 anything right now, there's a big crowd.
23
24
8 biggie.
25
Was there one bathroom break?
26
10
MR. ECHEVERRIA: Mr. Coughlin, I for one do
27
11 not appreciate your side comments. I think you should
28
12 focus seriously on the issues to be addressed here. The
Q Judge, was there one bathroom break during the

A I'm sorry. The crowd has recessed here, and
Q Don't worry. Just my law license, Judge. No
13 judge simply asked for accommodation so she could hear.
14
15 Honor.
16
17 BY MR. COUGHLIN:
18
Q Was there one bathroom break during the trial?
19
A There was one bathroom break.
20
Q Have you reviewed the audio of that trial?
21
A I'm sorry, I can't hear you again. Say it
8
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MR. COUGHLIN: I only have so much time, your

MR. ECHEVERRIA: I know. Quit wasting it.
22 again.
23
MR. ECHEVERRIA: Did you review the audio of
24 the trial?
25
THE WITNESS: I have not reviewed them
14
15
144
1 recently, no. I did at the time. I did when I entered my
16
2 contempt order and sent my package to the discipline
17
3 board.
18
4 BY MR. COUGHLIN:
19
20
6 you did not ask any questions about recording until after
21
7 the one bathroom break?
22
A I'm not sure that's the case. I don't know.
23
Q That is the case.
24
10
25
11 BY MR. COUGHLIN:
26
12
27
13 asked to use the bathroom right after I asked him about
28
14 recording. How do you explain that?
Q Why does the audio of the trial indicate that
MR. ECHEVERRIA: Mr. Coughlin -Q Yet you testified today that Mr. Coughlin
15
16 recall --
17
Q You just said you --
18
A I listened to the audio at the time when
19 things happened. And when you came back from the
20 bathroom, either way I determined from -- I concluded that
21 you were most likely recording without my permission.
8
9
10
11
22
A I don't know the sequence of events. I don't
Q Earlier your testimony was that you asked
23 Mr. Coughlin if he was recording, and he got real squirmy

24 and asked to use the bathroom. Is that correct?
25
A Yes.
12
13
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15
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1
Q Now are you remixing that testimony?
A No.
Q You just said, I don't know the sequence of
16
4 events.
17
18
6 I know that I asked you if you were recording. You denied
19
7 you were. I asked you a couple times if you were
20
8 recording, if you had gotten permission to record, what
21
9 you were doing. And at some point it was determined that
A Well, I don't recall the sequence of events.
22
10 you most likely were.
23
11
24
12 you're testifying to, right, that we can like compare to
25
13 what you're saying; right, Judge?
26
14
27
15 a civilized tone.
28
16 BY MR. COUGHLIN:
Q You know there is an audio of these things
MR. ECHEVERRIA: Mr. Coughlin, please exhibit
17
Q You're aware there's an audio?
18
A Yes, there's an audio. I have not --
19
Q That we can compare --
20
A -- I'm giving you my best recollection at this
21 time.
22
23 my patience with your continuing interruptions. That's
8
9
MR. ECHEVERRIA: Mr. Coughlin, you're trying
24 not evincing the conduct of a competent lawyer. You

25 should wait until the witness finishes before interrupting
10
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15
146
1 her.
2
MR. COUGHLIN: Yes, sir.
MR. ECHEVERRIA: Go ahead. Ask your next
4 question.
5 BY MR. COUGHLIN:
16
17
7 disassembled part of a recording device in the bathroom,
18
8 and they retrieved it from there; is that correct?
19
Q So the marshals said Mr. Coughlin left some
A I don't recall the exact words. The
20
10 impression I got from what the marshal said is that you
21
11 had gone into the bathroom, disassembled some sort of
22
12 recording device, and they went in the bathroom after you
23
13 and checked that and determined that. That's my
24
14 recollection of the events.
25
15
26
16 reason why the law requires, in a contempt not occurring
27
17 in the immediate presence of a judge, that somebody
28
18 actually put their name on an affidavit and sign it?
Q Is that murky recollection of yours maybe the
19
MR. KING: Mr. Chairman, as Bar counsel, a
20 member for Bar Counsel office, I find --
21
22 in contempt on that reason alone. You were found in
23 contempt for engaging in behavior of the same kind it
24 appears that you're doing now, and much more than that.
25 And you were found in contempt for your entire conduct
THE WITNESS: Mr. Coughlin, you were not found
147
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12
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15
1 throughout the course of the proceedings, including

2 repeatedly asking questions I ordered you not to ask,
3 delving into areas I had ruled were inadmissible, being
4 disrespectful, making faces, pretending like you were a
5 mime, sitting down, slumping down, standing up, walking
6 around, and doing a number of other things that were
7 completely improper in the manner of conducting a trial.
16
8 BY MR. COUGHLIN:
17
Q Is it proper procedure for you to --
18
10
A -- among one of the many reason why I found
19
11 you in contempt of court, sir.
20
12
21
13 criminal contempt when you cite to a civil contempt
22
14 statute?
23
15
24
16 Mr. Coughlin. I know that the behavior that I saw, I know
25
17 that I held you in contempt, I held a precise -- you
26
18 committed direct contempt in front of me in my court --
27
19
Q Criminal contempt or civil contempt?
28
20
A -- I held you in contempt on the spot, and
Q Is it proper for you to call something summary
A I don't know what is proper in your book,
21 then I went and wrote the order.
22
23 interrupt. I'm getting very tired of it. That's improper
24 behavior. As you said, your law license is at stake here.
25 You should exhibit behavior that would justify you keeping
MR. ECHEVERRIA: Mr. Coughlin, you continue to
148
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1 it. Have I made myself clear?

2
MR. COUGHLIN: Yes.
MR. ECHEVERRIA: Thank you.
Go ahead, Judge. Had you finished?
THE WITNESS: I finished with that answer,
6 yes.
7
MR. ECHEVERRIA: Go ahead, Mr. Coughlin.
8 BY MR. COUGHLIN:
9
Q Judge, did your order characterize it as
16
10 misdemeanor criminal contempt?
17
11
18
12 can consult my order. I believe it was misdemeanor
19
13 contempt. I believe it was criminal, direct criminal
20
14 contempt.
21
15
22
16 it says, Misdemeanor of criminal contempt, a violation of
23
17 NRS 22.010.
24
18
25
19 to, Mr. Coughlin?
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21 line 14.
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A I do not have my order in front of me, so you
MR. COUGHLIN: I'll note on Page 3 at line 14
MR. ECHEVERRIA: Which order are you referring

MR. COUGHLIN: February 28th order. Page 3,
MR. KING: I think it's Exhibit No. 4.
23
MR. ECHEVERRIA: Okay.
24 BY MR. COUGHLIN:
25
Q Judge, is NRS 22.010 a civil contempt statute?
149
5
6
MR. KING: Objection.
THE WITNESS: Mr. Coughlin, you can consult
8
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12
13
14
15
3 the statutes. I don't have my books right in front of me.

4 NRS identifies in Chapter 22 contempt. And the Reno
5 Municipal Code has sections relating that or incorporating
6 those sections into the Reno Municipal Code.
7
Either way, what you did in front of me was
8 direct contempt, and I held you in direct contempt, and

9 you went to jail for five days because of it.
10 BY MR. COUGHLIN:
11
Q Is it permissible for a judge to call a civil
16
12 contempt statute a criminal contempt statute, vis-a-vis --
17
13 this is 22.010, a civil contempt statute. And the law in
18
14 Nevada does have NRS 199 -- I believe it's 240 -- which is
19
15 the criminal contempt statute. Is it permissible for you
20
16 to cite to a -- easier to meet civil contempt statute, and
21
17 then recharacterize it as criminal contempt?
22
18
23
19
THE WITNESS: Mr. Coughlin, I'm not going to
24
20 argue the law with you. You have the statutes there. You
25
21 can consult them yourself.
26
22 BY MR. COUGHLIN:
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23
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24
Q On Page 3 at line 4, sub .9 -MR. ECHEVERRIA: Which exhibit, sir?
25
MR. COUGHLIN: Exhibit 4, your Honor.
150
3
4
1 BY MR. COUGHLIN:
3 response to direct questions posed by the court.
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Q You wrote, defendant lying to the court in

What were the lies in your vague order that
5 lacks any specificity to support a summary contempt

6 finding, what were those lies that you failed to elucidate
7 in your order?
8
MR. ECHEVERRIA: Mr. Coughlin, that question
9 is argumentative. Do you want to rephrase it?

10
MR. COUGHLIN: Sure.
11 BY MR. COUGHLIN:
12
Q What were you referring to when you wrote,
13 "Defendant lying to the court in response to direct
16
14 questions"?
17
15
18
16 there. I don't remember everything at this time because I
19
17 don't have it in front of me. But I do believe that you
20
18 lied about or misrepresented that you were not recording,
21
19 because I believe you probably were. I don't know. I
22
20 believe you probably were.
23
21
24
22 and the prosecutor were arguing about with regard to
25
23 discovery. And she disagreed with you and said you were
26
24 lying to her about that. And there were other items that
27
25 you went back and forth about that appeared to me that you
A Well, it would be explained in the order
At the same time there were things that you
28
151
1
2
1 were not totally honest about.
4 the record reflect that it's 12:18. I'll afford you two
5 more minutes.
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Q So when -MR. ECHEVERRIA: Excuse me. Mr. Coughlin, let
MR. COUGHLIN: Thank you, sir.
7 BY MR. COUGHLIN:
8
Q When you say, alternately you were probably
9 lying. And then you put in your order, "I find by clear
10 and convincing evidence that he lied," is that ambiguous
11 there? How do you reconcile that?
12
A How do I reconcile what?
13
Q The fact that your order says you find by
14 clear and convincing evidence?

15
A Because that's what I wrote. I did find by
16
16 clear and convincing evidence. I found by absolutely
17
17 convincing evidence that you were behaving improperly in
18
18 court, as you are now, apparently.
19
19
20
20 convincing evidence that a licensed attorney lied to the
21
21 court. And then you characterize that as probably, well,
22
22 I kind of think he was. I think he was, because I know
23
23 some unattributed hearsay that I'm going to base it on.
24
24 I'm going to get the order I think is wrong about the
25
25 bathroom break. I'm not going to have a marshal sign an
Q You're saying you found by clear and
26
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28
152
1 affidavit. Then I'm going to remix a criminal contempt
2 statute with a summary contempt statute and pick and
3 choose and make it as retaliatory as I possibly can.
4 Isn't that a fair characterization of your approach as a
5 judge?
7 answer that question. That was way out of line, and
8 extremely argumentative.
8
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MR. ECHEVERRIA: Judge, you don't need to
THE WITNESS: Thank you.
10
MR. ECHEVERRIA: Do you want to ask a
11 legitimate question, Mr. Coughlin?

12 BY MR. COUGHLIN:
13
Q What basis do you have to assert in your order
14 that defendant lying to the court in response to direct

15 questions posed by the court with regard to his recording
16 the proceedings?
17
A The opinion is self-explanatory. I do not
16
18 have it in front of me, Mr. Coughlin. You have access to
17
19 the tapes and the opinion. And I stand by what I wrote,
18
20 and I stand by the proceedings that day.
19
21
20
22 in your testimony today and those materials when you
21
23 refuse to testify now, isn't it?
22
24
23
25 You are not assisting yourself here.
Q But it's kind of hard to pick inconsistencies
MR. ECHEVERRIA: Argumentative, Mr. Coughlin.
24
153
25
26
MR. COUGHLIN: I'm asking her. It's a
27
2 question.
28
MR. ECHEVERRIA: No.

5 subverting the legal process by refusing to testify
6 instead of saying, well, read the order and read -- listen
7 to the recording, and therefore she is not subjecting
8 herself to putting forth any further inconsistencies.
7
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MR. COUGHLIN: Is that not true that she is
MR. ECHEVERRIA: Mr. Coughlin, the time for
10 argument is later, not now.

11
MR. COUGHLIN: Okay. So I'm objecting. It's
12 nonresponsive.
13 BY MR. COUGHLIN:
14
15
Q What was your basis -MR. ECHEVERRIA: That objection is overruled.
16 Now it's 12:20. If you have anything further of

17 significance that's relevant to the issues in this case,
18 please ask that question, I'll allow you one more.
19 BY MR. COUGHLIN:
16
20
17
21 bathroom break, and by whom?
18
22
MR. KING: Asked and answered.
19
23
MR. ECHEVERRIA: I think you've asked that.
20
24
MR. COUGHLIN: I don't think she answered it.
21
25
MR. ECHEVERRIA: She did. Do you have another
Q What was communicated to you during the
22
154
23
24
1 question, Mr. Coughlin?
25
26
3 BY MR. COUGHLIN:
27
28
5 Court transmit or otherwise deliver Judge Linda Gardner's
MR. COUGHLIN: Sure.

Q Did you or anyone with the Reno Municipal
6 order for sanctions to the State Bar of Nevada?
8 what? You'll have to repeat the question.
A I'm sorry. I didn't hear all that. Did I

Q Did you or anybody with your court, the Reno
10 Municipal Court, transmit or otherwise deliver Judge Linda
11 Gardner's April 2009 order sanctioning me to the State Bar
12 of Nevada?
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A I'm sorry. Deliver to whom?
14
MR. ECHEVERRIA: The State Bar, Judge.
15
THE WITNESS: Oh. After -- let me explain
16 quickly. My trial was my first experience in exposure to

17 Mr. Coughlin. After everything happened, and I held him
18 in contempt, then Judge Gardner told me that his sister,
19 Judge Gardner, has a life experience with Mr. Coughlin,
20 and he provided me a copy of her opinion from a couple
21 years earlier. And that may have been in the package I
16
22 forwarded to the court. I forwarded everything I could
17
23 possibly include that would show Mr. Coughlin's ability to
18
24 practice law. Including Mr. Coughlin's 200-page motion
19
25 that he faxed to the court.
20
155
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22
MR. ECHEVERRIA: Thank you, Judge. It's now
23
2 12:22, and we'll excuse you. And we appreciate you taking
24
3 the time --
25
26
5 about the pending --
27
MR. ECHEVERRIA: Mr. Coughlin --
28
MR. COUGHLIN: -- competency evaluation or --
MR. COUGHLIN: Can I ask one more question
MR. ECHEVERRIA: Mr. Coughlin.
MR. COUGHLIN: -- with the trial? It's a good
10 question.
11
12 question, and it's improper conduct.
13
14 answer that, huh? You are not going to make her answer
8
9
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MR. ECHEVERRIA: It's an interruptive

MR. COUGHLIN: You're not going to let her
15 that?
16
MR. ECHEVERRIA: I'm sorry. I continue to
17 talk while you're trying to interrupt.

18
Judge, thank you for your testimony.
19
MR. COUGHLIN: She held a trial with a pending
20 competency evaluation in violation of law.

21
MR. ECHEVERRIA: Quit interrupting,
22 Mr. Coughlin.
23
MR. COUGHLIN: I just got it on the record.
16
24
MR. ECHEVERRIA: Thank you, Judge. We
17
25 appreciate you taking your time into the lunch hour.
18
19
156
20
THE WITNESS: Thank you. I'll hang up now.
21
MR. KING: Thank you, Judge.
22
MR. ECHEVERRIA: It's now 12:23. Mr. King, do
23
4 you have additional witnesses?
24
25
6 have two additional witnesses. I'm not certain that I
26
7 will be able to reach them, but Judge Howard and Judge
27
8 Elliott.
28
MR. KING: I have -- my understanding is I'll
MR. COUGHLIN: I'd like to call Judge Nash

10 Holmes in my case in chief and ask her why she persists in
11 holding trial if she was aware of a pending competency
12 order.
13
14 ask her those questions.
15
16 it to me.
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MR. ECHEVERRIA: You had the opportunity to

MR. COUGHLIN: No, I didn't. You just refused
17
MR. ECHEVERRIA: No, I gave you --
18
MR. COUGHLIN: You did another basis for an
19 impartiality finding.
20
MR. ECHEVERRIA: I'm sorry. I have this
21 terrible habit of continually talking while you're trying

22 to -23
MR. COUGHLIN: You're not letting me ask any
24 question that would tend to implicate impropriety on the

25 part of a judge.
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157
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2 rulings as you wish. I have made the rulings."
MR. ECHEVERRIA: You can characterize the
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Regardless, in both 1708 and 374, NRS 40.253 does not allow for the Washoe County
Sheriff to conduct evictions in the manner in which is currently does. Hill's filings
claim that the WCSO's procedures, by being the usual and customary practices of the
WCSO, somehow become black letter law in Nevada, even where a statutory remedy is
in place, one that the legislature worked hard on (despite RJC Judge Pearson, in 1048,
ignoring AB226's minor tenant's rights victory where it required the landlord to, under
NRS 40.253(3)(a) identify the court that has jurisdiction over the matter... and 3(b)
(1)'s dctate that such notice advise the tenant: (1)Of the tenants right to contest the
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matter by filing,... an affidavit with the court that has jurisdiction over the
matter..., in the face of the unauthorized practice of law on behalf of out of state
corporation no less, Northwinds Apartments Assoc., LLC of Washington state.
NRS 40.253(6) provides...6.Upon the filing by the tenant of the affidavit permitted
in subsection 3, regardless of the information contained in the affidavit, and the filing
by the landlord of the affidavit permitted by subsection 5 (note, both in 1708 and
374, neither landlord filed such a Landlord's Affidavit in a timely manner, and Merliss
in 1708 never filed one at all. If Baker and Hill want big boy attorney's fees, they
should be required to get those sorts of things right to justify such exorbinant fees, or
even begin to), the justice court or the district court shall hold a hearing, after service
of notice of the hearing upon the parties, todetermine the truthfulness and sufficiency
of any affidavit or notice (Baker continually maintained that it was only Coughlin's
Affidavit which was up for inspection, in violation of RPC 3.1) provided for in this
section. If the court determines that there is no legal defense as to the alleged
unlawful detainer and the tenant is guilty of an unlawful detainer, the court may
issue a summary order for removal of the tenant or an order providing for the
nonadmittance of the tenant.
So, really, especially in 1708, all the debate about the import and application of
the within 24 hours language is inapplicable anyways, as that phrase is only
applicable to a situation where the tenant does not file a Tenant's Answer in
respose to a 5 day UD Notice being posted.
NRS 40.253(5):.Upon noncompliance with the notice:
(a)The landlord or the landlords agent may apply by affidavit of complaint (note,
there is nothing in Ch. 40 that allows for a landlord's agent to draft pleadings
or appear on behalf of an out of state corporation, cross the bar, and practice law
on its behalf, as WNM's Sue Kign did in 074408 and 374, and as NCS's Jeff
Chandler did in 1048) for eviction to the justice court of the township in which the
dwelling, apartment, mobile home or commercial premises are located or to the
district court of the county in which the dwelling, apartment, mobile home or
commercial premises are located, whichever has jurisdiction over the matter (in
374, RJC Judge Schroeder issued such an Order prior to Kern even filing a
Landlord's Answer). The court may thereupon issue an order directing the sheriff
or constable of the county to remove the tenant within 24 hours after receipt of
the order.
But, again, where Coughlin did comply with the 5 day notice, in both 1048, 374, and
1708, NRS 40.253(5) language is inapplicable (The court may thereupon issue an
order directing the sheriff or constable of the county to remove the tenant within
24 hours after receipt of the order.) Rather, it is NRS 40.253(6)'s language that
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controls: If the court determines that there is no legal defense as to the alleged
unlawful detainer and the tenant is guilty of an unlawful detainer, the court may
issue a summary order for removal of the tenant or an order providing for the
nonadmittance of the tenant.
There being nothing thereing speaking to some within 24 hours dicate, the
default application in civil law requires that such an an Order be served under
NRCP 6(e) where personal service is not accorded, thus requiring 3 days for
mailing. Further, NRAP 8 and some 5 day stay suggested in Anvui, is arguably
applicable. There is little indication in Ch. 40 or elsehwhere to provide some
explanation of just how and in what manner such a summary order would be
carried out and whether it would allow for the approach taken by the WCSO in
such situations. While NRS 40.253(3)(b)(2) does contain the term summary
order, the appearance therein of the within 24 hours language, combined with
the non-appearance of such within 24 hours language in NRS 40.253(6), under
traditional principles of statutory construction, actually augers for an
interpretation of subsection 6 that would require more time for a tenant than is
provided for under NRS 40.253(3)(b)(2):That if the court determines that the
tenant is guilty of an unlawful detainer, the court may issue a summary order for
removal of the tenant or an order providing for the nonadmittance of the tenant,
directing the sheriff or constable of the county to remove the tenant within 24 hours
after receipt of the order...
It seems rather implausible to suggest that the within 24 hours language is some
dictate to the Sheriff or constable requiring such lockouts be effectuated in some
narrow window of time. Rather, particularly given the primacy to individual's
and businesses inherent to their uses as residences of places of business (or, in
1708, as both) it would seem entirely more likely, and reasonable, to conclude that
the legislature intended for the within 24 hours language to afford tenant's at
least 24 hours from the posting (if not the constructive receipt in the mail under
NRCP 6(e) if no personal service was to be had) of such a lock-out Order to
remove those items they find absolutely essential (see Coughlin's difficulties in
1048 where deprived of his medications, eyeglasses, contacts, some important
legal files, etc, not to mention the RPC 3.5A violation attendant to the default on
7/5/12, especially where the RJC and NCS's Chandler knew Coughlin was in jail
incident to a 7/3/12 arrest stemming from Northwind's handyman Kreb's
falacious accusation of Coughlin disturbing the peace.
the court may issue a summary order for removal of the tenant
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Also, the RJC may need to explain why it failed to file in fax filings by Coughlin
where it either did file in some by Hill and Baker in 1708 (or consider any failure
to file any 10/13/11 Affidavit of Unlawful Detainer by landlord Merliss).
The SBN is likely resting upon some theory that the TPO and EPO granted it by RJC
Judge Pearson, which indicates that Coughlin may . First, the 1/4/13 EPO granted the
SBN indicates that Patrick Owen King, Esq., appeared at the Extension Hearing to
represent the SBN. As such, King, knowing he was extremely likely to be a witness in
such an action, had a duty to withdraw from representation, and therefore himself
violated a RPC 1.16 requir he so withdraw where his being a witness was a virtual
certainty. Further, King's TPO application rests almost entirely on unsworn hearsay,
for which King makes no indication with regard to from whom or how he became
aware of such hearsay detailing such purported facts. For instance, the magic of
hearsay may allow a comment like its not fair that Bar Counsel King gets all this ex
parte face time with Panel Chair Echeverria that may have been said to Dena
Echeverria on the telephone to become, according to King, a statement by Coughlin to
Echeverria's staff that he was coming down to the Panel Chair's Office, threatening to
get some face time. Coughlin's 1996 Honda Accord's electrical problems (an
electrical short caused problems with Coughlin's headlights requiring a primitive
workaround requiring Coughlin to braids five elecrical wires together to turn his
vehicle's headlights on...something King alleges, through unattributed hearsay, was a
case of Coughlin malingering around the SBN's Northern Office after 5 pm flashing
his headlights at the one or two women whom were working late (because, one can be
absolutely sure, Asst. Bar Counsel King has never worked late a day in his life, and
certainly not while employed by the SBN, thanks to SCR 106, natch), in an attempt to
frighten and harass them. Then there is the curiosu allegation by King in his TPO
application that Coughlin called the SBN ahead to announce he would be there in
fifteen minutes to file something. King somehow alleges that is threatening behavior
even where he subsequently indicates that he had sent Coughlin a letter demanding that
Coughlin do just that prior to appearing at the SBN for any reason, including to file
documents.
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VIOLATIONS OF NRS 178.405 AND NRS 5.010 BY RENO CITY ATTORNEY

AND WASHOE COUNTY PROSECUTORS AND RMC AND WCPD COURT
APPOINTED DEFENDERS
September 8th, 2011 Order for Competency Evaluation by Judge Schroeder in
RCR2011-063341
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September 9th, 2011: Coughlin arrested at Wal-Mart in RMC 11 CR 22176 for petty
larceny October 10th, 2011: Coughlin arraigned in RMC 11 CR 22176 for petty
larceny charge
October 26th, 2011 (or a short time after depending upon entry of order) Judge
Sferrazza declares Coughlin competent in RCR2011-063341
February 27th, 2012: file stamped at 1:31pm in RCR2012-065630 Judge Clifton signs
an Order for Competency evaluation of Coughlin
-February 27th, 2012: despite being present at the "clandestine status conference"
(Dogan's client Coughlin was noticed, in writing, that it had been reset to March 29th,
2012) DDA Young filed an Opposition to Motion to Continue Trial Date and Motion
to Appoint Co-Counsel on 2/27/12 at 2:55 pm in a companion case that he was also
prosecuting, RCR2011-063341 in violation of NRS 178.405. In her March 13th, 2012
grievance against Coughlin, Judge Nash Holmes admits to communications in this
regard between her and the Washoe County Public Defender's Office. -February 27th,
2012: At 3:00 pm, despite the communications she admits to with the WCPD, Judge
Nash Holmes holds a trial where Coughlin is forced to appear as an indigent criminal
defendant proceeding with self representation in 11 TR 26800, which is suspened upon
Judge Nash Holmes finding Coughlin in "summary criminal contempt" seconds after
he testifies that RPD Sargetn Tarter lied in connection with a retaliatory traffic
citations incident to Tarter telling Coughlin to leave the law office of Richard G. Hill,
Esq. on November 15th, 2012 after Coughlin was released from 3 days in jail incident
to a criminal trespass custodial arrest upon Hill lying to officers and signing a criminal
complaint in 11 CR 26405 for criminal trespass on November 13th, 2012. Tarter
ordered Coughlin to leave after Hill refused to give Coughlin his state issued drivers
license or identification, his hard drives/client's files, his keys, or his wallet. -Judge
Nash Holmes proceeds to file numerous Orders -March 5th, 2012: in RMC 11 CR
26405, the criminal trespass case from Coughlin's former home law office the Certified
Copy of Docket done by the Judicial Assistant, D2's Lisa Wagner, who couldn't quite
seem to find or remember the fact that Coughlin faxed in a Notice of Appeal on June
28th, 2012, and her failure to docket that led to the dismissal of Coughlin's appeal in
CR12-1262, despite Coughlin having electronic confirmation of receipt of that fax
delivering his Notice of Appeal to the RMC and to City Attorney Hazlett-Stevens
(whom coyly tries to assert he didn't get it or the paper copy Coughlin personally
delivered to the offices of the City Attorney within the 10 days set forth in NRS
189.010) Trial date set for April 10, 2012 by Court. -05 March 2012: Notice Of
Appearace As Co-Counsel And Motion To Dismiss filed defendant. 20 March 2012:
Order #1 denying defendant's motion filed 13,February 2012 signed Judge William
Gardner. RMC 11 CR 26405 -21 March 2012: Order #2 denying defendant's motion
filed 5, March 2012 signed by Judge William Gardner. RMC 11 CR 26405 -21 March
2012: Motion To Strike Defendant's Motion To Dismiss Complaint filed by Deputy
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City Attorney Christopher Hazlett-Stevens. RMC 11 CR 26405 -10 April 2012:

Defendant appeared for trial with counsel Keith Loomis, Judge William Gardner
1/5
presiding. Present on behalf of the City was Christopher Hazlett-Stevens. Several pretrial motions were heard. An Order Suspending Proceedings was signed. All
proceedings suspended until the question of competence is determined. Case Status
Hearing scheduled for 8, May 2012. RMC 11 CR 26405. See attached emails
demonstrating the knowledge of and complicity between the Washoe County Public
Defenders, the court appointed Reno Municipal Court defenders, the City of Reno
Prosecutors, Washoe County District Attorney's Office, RMC, RJC, and both court's
filing office's staff and administrators respecting the existence of these Orders for
Competency Evaluation and the brazen violation of NRS 178.405 and NRs 5.010 by
these individuals. Further, on
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-April 19th, 2012, DDA Young again violated NRS 178.405 where he moved to have
Coughlin remanded to custody (whereupon Coughlin could again have his medication
suddenly withheld from him, all while RMC Judge Nash Holmes seeks to leverage jail
staff to get Coughlin to sign some waiver of his medical records privacy rights and
where WCPD Biray Dogan announces confidential HIPAA protected medical
information relating to his client Coughlin into the public record, in front of 40
members of the public gathered in D10, a transgression which WCPD Jeremy Bosler
later refused to seek to ameliorate or strike from the record in any manner whatsoever).
-May 7th, 2012 (the day Coughlin's Opposition to Hill and Baker's 4/19/12
impermissible Post-Judgment Attorney Fee Sanctions Motion in CV11-03628 (no
21 day filing ready safe harbor motion served either, much like the approach by
Springgate approved of by Judge L. Gardner incident to here 4/13/09 Order After
Trial in DV08-01168, which became the third grievance against Coughlin
underpinning the appeal in 62337 of the Recommendation to permanently disbar
him...so, just who is it who is asserting non-meritorious contentions?). Further,
Judge Flanagan's 8/28/12 Order in CV11-03628 makes clear that his 6/25/12
Order awarding landlord Merliss (incident to Hill and Baker's attorney fee
sanction motion) was only entered in view of Judge Flanagan's opinion that
Coughlin failed to oppose their 4/19/12 Motion for Attorney Fee's Sanctions in
light of DCR 13(3). Apparently the Washoe County jail ripping Coughlin of
psychotropic medications and refusing him any ability to file court documents,
paper, envelopes, or even make phone calls did not provide "good cause" for
reconsidering that monumental fee award. Coughlin, or those attorney's seeking
sanctions under NRS 7.085 without complying with the dictates of NRCP 11? in
RCR2011-063341 WCPD Goodnight and DDA Young violate NRS 178.405 by
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attempting TO HOLD A TRIAL in that matter during the pendency of an Order for
Competency directored towards Goodnight's client, Coughlin. Goodnight manages to
jam Coughlin into an ill-advised Mental Health Court sign-up in MH12-0032, which
ends badly when the MHC's Reno Biondo commits fraud in asserting that Coughlin
was removed from the MHC for "failing to following MHC policies" similar to the
arguments put forth by Sharon Dollarhide, despite the MHC, and perhaps Goodnight
too, having given Coughlin a list of medications it prohibits, and a contract for entry
into the MCH, after having informed Coughlin he was accepted into the MCH upon
entering the contract. The MCH subsequently threatened Coughlin with incarceration
for taking a medication is only after the fact objected to, then, upon having the
bargained for consieration, offer and acceptance pointed out to it, the MCH lied and
disparaged Coughlin to the RJC and others, causing Coughlin reputational damage, and
Coughlin's case was remanded to the RJC at a later date. During this period of time,
D10 Judge Elliot forced Coughlin back into custody at the WCDC, where Coughlin
has been denied his medication every single one of his 10 trips to jail this year, with no
titration down of dosing whatsoever, even where Coughlin was willing and able to
arrange for delivery of the medication at his own expense, etc.
-08 May 2012: Case Status hearing held before Judge William Gardner. Present on
behalf of the City was Deputy City Attorney Christopher Hazlett-Stevens, for the
defense Keith Loomis and defendant Zachary Coughlin. Defendant was found to be
competent. Defendant's motion to remove Keith Loomis as counsel granted. Trial date
set by the court for June 18,2012. RMC 11 CR 26405. Strangely, despite Coughlin still
being subject to an as yet to be ruled upon Order For Competency evaluation and
despite Coughlin having just the previous day been accepted into Mental Health Court
and the RJC case RCR2011-063341 transferred there, RMC Judge William Gardner
jammed Coughlin both into proceeding without the Sixth Amendment Right To
Counsel and into some trial setting, even though NRS 178.405 and NRS 5.010 forbids
it, and even though Judge Gardner admitted to being aware of Judge Nash Holmes, his
fellow RMC Judge, seeking to have Coughlin's law license taken away based upon a
SCR 117 Disability Petition (Judge Nash Holmes, in her March 14th, 2012
letter/grievance to the State Bar of Nevada, wherein she purports to speak for Judge
William Gardner and managed to pass on to the SBN the April 2009 Order For
Sanctions by Judge William Gardner's sister Family Court Judge Linda Gardner, that
Judge William Gardner passed to Judge Nash Holmes after receiving from his sister
sometime in
2/5
the first quarter of 2012). Incidentally, Coughlin was previously a domestic violence
attorney at Washoe Legal Services until Family Court Judge Linda Gardner's April
2009 Order sanctioning Coughlin $1,000 personally for the arguments he made in
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representing a domestic violence victim in a divorce trial were cited by WLS Executive
Director Paul Elcano as the "sole reason" for Coughlin being fired. Coughlin filed a
Petition for Writ of Mandamus in respone to that Order with the Nevada Supreme
Court in 54844. Coughlin filed a Notice of Appeal of the dismissal for insufficient
service of process of his wrongful termination case against Washoe Legal Services on
February 27th, 2012, and that matter is currently on appeal with the Nevada Supreme
Court in 60302. Oh, and Reno City Attorney John Kadlic is a patient of Zach
Coughlin's father, Dr. Timothy Coughlin, and the City of Reno and or the RPD have
sought to pressure Coughlin's parents into having him "committed", despite the fact
that the numerous (about 8-10 ish) wrongful arrests Coughlin has been subjected to this
year (most of which violate Soldal v. Cook County and have been captured on video
tape, amazingly) all kind of give Mr. Kadlic a bit motivation to quiet and or discredit
Coughlin (and and arrest on June 28th, 2012 by the WCSO and various instances this
year where fraudulent Affidavits of Service by the WCSO have been involved in
arrests of Coughlin give the WCDA Office its own motivations).
Given that this trial setting and denial of Coughlin's Sixth Amendment Right to
Counsel occurred during the pendency of an Order for Competency Evaluation of
Coughlin that the RMC, Judge William Gardner, court appointed defender Keith
Loomis, Esq. and City Attorney's Christopher Hazlett-Stevens, Esq. were well aware
of, the following are void: O5 June 2012: Notice Of Appearance As Counsel ; Motion
To Dismiss; Motion To Suppress; Motion For A Continuance Of Trial And Transfer
To Mental Health Court filed by defendant. 18 June 2012: Defendant appeared for trial
pro-per, Judge William Gardner presiding. Present on behalf of the City was
Christopher Hazlett-Stevens. Several pre-trial motions were heard. Motion to Continue
filed by defendant denied. Motion to Dismiss filed by defendant denied. Motion to
Suppress denied. Motion to Recuse denied. Motion to Transfer to Mental Health Court
denied. Case tried on its merits and the Defendant was found guilty of the charge of
Trespass, a violation of R.M.C 08.10.010. .."'Y25'2012 The Defendant was sentenced
as follows: Trespass, a violation of R.M.C 08.10.0 10. : Time Served (3 days at usual
$100 a day, and a $310.00 fine for a total of $610 raked in by the RMC on a first
offense trespass charge where typically the fine is $305. Also, Richard G. Hill, Esq.
lied under oath at that June 18th, 2012 criminal trespass Trial where he testified that
the RPD identified themselves as law enforcement and issued a lawful order or
warning for Coughlin to leave the premises prior to the landlord kicking down a door
to a quasi "basement" under the former law office. The videos of the arrest filmed by
Hill demonstrate that Coughlin was never given an opportunity to heed any warning to
leave given that day prior to a custodial arrest being effectuated, contrary to the
Supplemental Declaration by RPD Officer Chris Carter, Jr. RPD Sargent Marcia Lopez
subsequently admitted that the RPD neither identified themselves as law enforcement
nor issued a lawful order to emerge from the basement prior to landlord Merliss
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kicking down the basement door on November 13th, 2012. WCSO Civil Supervisor
Liz Stuchell has admitted in an email to Coughlin that Deputy Machen's November
7th, 2011 Affidavit of Service swearing to have "personally served" the RJC
REV2011-001708 Summary Eviction Order on November 1st, 2011 was "incorrect" in
that to Machen "personally served" means "posting it to the door when no one is home.
However, given NRS 40.400 makes applicable NRCP 5(b)(2) and 6(e) to summary
evictions (even those that are noticed by the RJC, in writing, as a "Trial" and even
where, at the October 13th, 2011 "summary eviction proceeding" the RJC ruled that
Coughlin "had met his burden of establishing there is a genuine issue of material fact
concerning his retaliatory eviction defense" and the matter was then "set for trial on
October 25th, 2011 provided Coughlin deposits $2,275 into the court's rent escrow
account", all of which violates JCRCP Rule 109 and NRS
3/5
40.253(6)) the lockout Deputy Machen oversaw on November 1st, 2011 was based
upon a void Eviction Order and Decision of October 25th, 2011 and an October 27th,
2011 Findings of Fact...that Hill's associate Baker testified as to having apparently
provided receipt thereof to the WCSO on October 28th, 2011, and which RJC Chief
Civil Clerk Karen Stancil indicates were transmitted to the WCSO via fax according to
the usual custom and practice of the RJC...meaning, the WCSO failed to effectuate a
lockout "within 24 hours" of "receipt" of either of those Orders...meaning Hill and
Merliss were trespassing on November 13th, 2011, not Coughlin, and they brought the
RPD along for the ride, whereupon the RPD effected a wrongful arrest (based upon lies
by neurologist Merliss and his attorney Hill to the effect that they warned Coughlin to
leave that day prior to the RPD showing up, which is clearly show to be false by the
videos filmed by Hill and Merliss themselves and Hill's subsequent testimony at the
June 18th, 2012 criminal trespass trial in 11 CR 26405).
May 9th, 2012: Order finding Coughlin competent in CR12-0376, by Judge Elliot of
Department 10 resolving the February 27th, 2012 Order for Competency Evaluation
signed by RJC Judge Clifton and file stamped at 1:31 pm on that date.
September 5th, 2012: Order for Competency Evaluation of Coughlin by Judge
Sferrazza in RCR2011-063341
October 2, 2012: WCPD Leslie and Dogan and DDA Young violate NRS 178.405 by
swapping the October 15th, 2012 Trial continuation/Competency Hearing Date in
RCR2011-063341 with RCR2012065630, and setting/stipulating to a new hearing on
October 22nd, 2012, and resetting the Trial date to November 19th, 2012, but not
before attempting to cram RCR2012-067980 onto the calendar with RCR2012-063341
for October 22nd, 2012 (and Leslie and Dogan lied to Coughlin about whether
"mandatory status conference" was held on August 6th, 2012 in RCR2012-065630, and
RCR2012067980, the latter at which Leslie set a Trial date of September 18th, 2012
despite his legal assistant Linda Gray admitting to Coughlin that Coughlin was
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provided no notice whatsoever of the August 6th, 2012 hearing date in those cases.
Also, Dogan and Leslie again violated NRS 178.405 on October 2nd, 2012 where tehy
reset for October 30th, 2012 a Motion Hearing on DDA Young's impermissible Motion
to Amend the Complaint in RCR2012-065630 (six months after the arrest, no specific
facts pled in either to support either charge, really). Further, Dogan failed to alert
Coughlin in any way to the fact that, in his July 31st, 2012 Motion to Amend Criminal
Complaint, DDA Young attempted to, in violation of RPC 3.8, amend the "misue of
emergency services" charge (where Coughlin is accused of using 911 to report police
misconduct) to a charge that would provide the District Attorney more leverage against
Coughlin, a retaliatory prosecution, for a crime that would damage Coughlin's law
license given the import of SCR 111(6), despite DDA Young lacking probable cause to
so amend his charge. Dogan and Young previously conspired to retaliate against
Coughlin incident to their "clandestine status conference" of February 27th, 2012,
which just so happened to be the date that Coughlin filed a Notice of Appeal in his case
against Washoe Legal Services 60302 and the date that Judge William Gardner
transferred jurisdiction from RMC D1 Judge Dilworth to RMC D3 Judge Nash Holmes
in 12 CR 000696, a case where Coughlin was subject to a custodial arrest for
jaywalkign on January 12th, 2012 incident to Coughli's peacefully filming Richard G.
Hill, Esq.'s contractor's crew from a public sidewalk, disposing of property left at
Coughlin's former home law office due to Hill locking a gate thereto during the time
Coughlin was afforded to remove such property and where Hill had boarded up on of
the entrances to the property as well, in addition to remove the only ladder to the
4/5
upstairs attic/storage space at the property. On February 27th, 2012 in 11 TR 26800
Judge Nash Holmes told Coughlin she would have him thrown in jail if he mentioned
Richard G. Hill's name one more time. On January 31st, 2012, at an extension hearing
on the TPO Richard Hill received against Coughlinf or Coughlin's alleged jaywalking
on January 12th, 2012, RJC Judge Schroeder roared at Coughlin "do you want to go to
jail!" when Coughlin broached the subject of Hill's abuse of process. Judge Schroeder
is listed in the RJC docket as presiding over the February 27th, 2012 "clandestine
status conference" that ultimately resulted in Judge Clifton signing the Order for
Competency Evaluation. It is unclear if any actual hearing before a judge even took
place that day, however.
5/5
Local judges seem to dutifully report some far flung applications alleged violations of
SCR's related to the media and reporters vis a vis hunches they have about whether an
attorney is recording the proceeding (which is in the public record) or has "recording
devices" in his pocket, yet violations of NRS 178.405 seem to receive scant application
of Canon 2.15.
Zach has 76 files to share with you on SkyDrive. To view them, click the links below.
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1 4 12 0204 1708 03628 Appeal Receipt tiff and Supplemental Justice

Court Proceedings.pdf
12 21 11 1708 03628 Order Resolving Contest Property Lien NO
NUMBERS.pdf
3 30 12 0204 03628 Order Denying Coughlin's Appeal of Summary
Eviction Order.pdf
10 13 10 transcript of Motion to Stay execution of summary eviction order
Venetian v Two Roads compare to 60331 0204.pdf
8 23 12 0204 Complaint SBN v Coughlin stamped bf.pdf
11 14 12 0204 Transcript of Hearing with Index 170008ch-Full.pdf
12 14 12 stamped 0204 Order by Chair Echeverria Findings of Fact
Conclusion of Law seeking to disbar Coughlin bz no line numbers.pdf
10 17 11 emergency motion to stay summary eviction 1708 etc. 60331
AND 61383 COUGHLIN V MERLISS 26406 1708 26800 0204.pdf
10 17 12 Coughlin's Emergenc Motion commercial tenant no cause
forbidden 0204 1708 60331 61383 0204-3.pdf
10 18 11 0204 1708 marked received by RJC Dreme Smith Coughlin's
NOtice of Appeal of 10 13 11 Sferrazza Order after summary eviction
hearing 03628 divests RJC jurisdiction.pdf
10 18 11 Notice of Appeal divesting RJC of jurisdiction CV11-03628
ENTIRE EFLEX COMBINED FOR APPENDIX IN 60331 AND 61383
COUGHLIN V MERLISS 26406 1708 26800 NG12-0204 BF.pdf
10 19 11 baker letter to clifton emergency inspection with 10 20 11
sferrazza note order have p draft order will isgn it 1708 0204.pdf
10 19 11 Justice Court Civil Appeal cv11-03051 couglhin v merliss 1708
0204 .pdf
10 26 11 0204 03051 1708 03528 Purdy marked as received by M. Purdy
Mtn and Affid proceed on appeal IFP Merliss v Coughlin eviction.pdf
10 27 11 to 11 2 11 Motion to Stay CV11-03051 03126 1708 emails to
eflex purdee 26405 60331 purdee.pdf
10 27 12 emails on 03051 emergency appeal maybe a motion for stay 1708
26405 03126 conyers orduna wdc 0204 purdy.pdf
10 27 12 emails on 03051 emergency appeal maybe a motion for stay 1708
26405.pdf
10 28 11 1048 am email to Purdy mpurdy@washoecourts.us 03051 appeal
motion for stay compare 03126 0204 60331 61383.pdf
10 28 11 1054pm email to eflex and courtadmin@washoecourts.us 03051
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03126 0204 10 PAGES.pdf

10 28 11 03126 motion and affidavit for ifp attached to from 10 26 11 civil
suit merliss marked as received by M. Purdy Mtn and Affid proceed on
appeal IFP Merliss v Coughlin eviction.pdf
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all
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Also, as to the summarily denied applciations for TPO's by Coughlin (one on

2/10/12 or thereabouts against RJC Bailiff Reyes, transferred to Sparks Justice Court
(which begs the question why 12-599 Washoe County v Coughlin was not transferred
to SJC, or to a Court outside Washoe County) and the two different TPO's Coughlin
requested against Leslie (in, in Court on 8/29/12 in 11-063341 to which Judge
Sferrazza angrily rebuked Coughlin) and another, filed stamped 12/18/12 an hour
before the TPO Application for Leslie by DDA Watts of 12/18/12, in 12-598, which
Judge Schroeder summarily denied (odd that Judge Pearson rules on 12-599, while
Judge Schroeder rules on 12-598, where such applications where filed within an hour
of each other).
Leslie has often threatened Coughlin with abuse of process, in violation of his
duty to his then client Coughlin, sometimes in an attempt to dissuade Coughlin from
seeking to introduced exculpatory video evidence in 11-063341 (often in conjunction
with Leslie attempting to deprive Coughlin of his involable Fifth Amendment Right to
decide whether or not to testify, take a plea, subpoena witnesses, etc.). This
questionable practice by Leslie also included Leslie telling Coughlin Judge Sferrazza
would punish Couglhin for pointing out apparent RPD misconduct in 11-063341 on
8/29/12 during the Supression Motion Hearing, and in the following emails:
RE: Jim Leslie is a scrappy dude RE: Coughlin
From:
Leslie, Jim (Jleslie@washoecounty.us) This sender is in
your safe list.
Sent: Fri 12/14/12 9:45 AM
To: Zach Coughlin (zachcoughlin@hotmail.com)
Mr. Coughlin:
A hearing has been set for Tuesday December 18, 2013, at 8:30 am in
Reno Justice Court, at which we will ask to be relieved as counsel in
the remaining case you have with this office, RCR12-067980, based
on, among other things, (1) your prior expressed desire to represent
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yourself and (2) your email to myself and several other recipients,
including state bar attorneys, which contains an express or implied
threat of violence. If you fail to appear at the hearing, the relief will
be requested in your absence upon the grounds stated above. If you
choose to agree to self-representation without argument, the
second above-noted reason may or may not rise to the point of
discussion, although I would note that the email you sent with the
express or implied threat was disseminated by you to several
recipients including representatives of the Nevada State Bar,
thereby breaching confidentiality by your own action.
Pending the hearing, there is no reason for us to meet in person or
communicate by any means. Any communications from you
pending the hearing will be deemed to be made in waiver of
attorney-client privilege and are subject to forwarding to the
Nevada State Bar and/or law enforcement as appropriate
pursuant to Nevada Rule of Professional Conduct 1.6(c).
James B. Leslie, Esq., Chief Deputy Public Defender
Consider also, as attached in Ex 1 to the TPO application of 12/18/12
in 12-599:
From: Leslie, Jim (Jleslie@washoecounty.us) This sender is
in your safe list. Sent: Wed 12/12/12 4:22 PM To:
'zachcoughlin@hotmail.com' (zachcoughlin@hotmail.com)
Mr. Coughlin: Based on your behavior at our offices on several
past occasions, including today where we had to call the
police due to you engaging in behavior constituting
disturbing the peace, you are hereby directed NOT to come to
our offices without first having confirmed in writing an
appointment with your assigned attorney. If you violate this
email notification, we will contact law enforcement. James B.
Leslie, Esq. Chief Deputy Public Defender
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Download as zip
911 Case Leslie, Jim (Jleslie@washoecounty.us)12/07/12 To:
'zachcoughlin@hotmail.com' Cc: Dogan, Biray From: Leslie,
Jim (Jleslie@washoecounty.us) This sender is in your safe list.
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Sent:
Fri 12/07/12 9:18 AM To:
'zachcoughlin@hotmail.com' (zachcoughlin@hotmail.com)
Cc:Dogan, Biray (BDogan@washoecounty.us) Outlook Active
View 1 attachment (2.2 MB) Coughlin Discovery 911
Case.pdfDownload Download as zip
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. Leslie, Esq. Chief Deputy Public
Defender
It is quite obvious that Washoe County put a Chief Deputy Public Defender on
three of Coughlin's misdemeanor case to limit potential County liability rather than
actually defend Coughlin. Coughlin has never been provide a reason for Goodnight
being suddenly taken off his case minutes before the 7/16/12 trial in 11-063341.
Further, the hearing in 12-067980 was not properly noticed, Coughlin's showing up
to it fails to excuse that fact, Coughlin did not waive his rights as to those
insufficiencies, but rather asserted them, and therefore Leslie should not have been
granted an Order allowign his Withdrawal (which he attempted to coerce a consent
to from Coughlin, and all of this is rather supsect considering the timing....the
County gets to force Coughlin to self represent after the WCPD sabotaged his case
in 11-063341 and 12-065630 just as much as it possibly could, and only then, on
12/18/12 in an unnoticed (no 10 days to responde for Coughlin, and WCDA DDA
Young wasn't even there) hearing before, again, Judge Clifton, Leslie is permitted to
withdraw...very similar to Clifton, on 11/20/12, just before a short hearing in 12065630, while Coughlin was viewing Leslie testify in some ineffective assistance of
counsel dmage to former client's immigration status hearing also before Judge
clifton...Judge Clifton actually said that he found Leslie's initial lack of certainty
during his initial testimony as to whether he informed his client of the sentencing
enhancement consequences of her charge prior to her entering a plea agreement
stemming from United States v. Lopez-Pastrana, 244 F.3d 1025, 1027 (9th
Cir.2001), combined with Leslie's suddenly becoming more certain that he did, in
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fact so warn his former client thereof upon it becoming more obvious the
malpractice possibilities attendant to his failing to do so, as a basis for finding
Leslie's testimony to be more credible than his former client's, rather than providing
an inference that Leslie's sudden remebering that he so warned his client of the
immigration consequences to be rather suspect given the obvious self protection
utliity inherent to his doing so.
In fact, upon being removed as counsel in 11-063341, Leslie apparently
attempted to hide from Coughlin the fact that the ECOMM recordings between the
RPD and ECOMM dispatch actually revealed a failure to propound Brady material
and failure to appropriately responde to Goodngiths 12/19/11 discovery requests for
such records (RPD Harriet Truman's written response failed to address ECOMM
recordings of what dispatch told the RPD, which becamse of salient relevant in 11063341, and ultimately showed that RPD Duralde's and DDA Young argument and
testimony as to the reports from dispatch of a possible fight allegedly received by
Duralde and his two fellow officers that night (such reports were not received by the
RPD as the officer were out of their vehicels and on scened at the time the one text
Ecomm log was sent to their in car screens only) were not known to Duralde et al,
and therefore, a fraudulent assertions of knowledge thereof was made to buttress the
reasonable suspicion and probable cause analysis integral to the State's prosecution
therein. Leslie subpoened ECOMM's Kelley Wood on 10/3/12 for such recordings,
and more than the 15 days by which she was required to respond passed before
Leslie was granted his withdrawal on 10/22/12, however, Leslie persisted, as
evinced in the email below, in refusing to turn over the ECOMM dispatch to and
from RPD recordings required to be produced by such subpoena. Leslie
continuously revealed a vindictive, self interested streak a mile long in his dealings
with Coughlin.
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RE: Kelly Odom/ECOMM subpoena duces tecum, please email materials produced
and other materials? Leslie, Jim (Jleslie@washoecounty.us) 11/01/12 To: Zach
Coughlin From: Leslie, Jim (Jleslie@washoecounty.us)
Sent: Thu 11/01/12 12:00 PM To:
Zach Coughlin (zachcoughlin@hotmail.com)
Mr. Coughlin: As indicated in the transmittal I sent with the PDF attachments, I
attached the written documentation in PDF format. Thats your digital transmittal.
The other materials are disks and color photographs in tangible form. James B.
Leslie, Esq. Chief Deputy Public Defender
None of the discs Leslie ultimately turned over contained any ECOMM
recordings beyond the 911 calls (ie, none of the recordings between the RPD and
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dispatch/ECOMM that would reveal one way or another when and what the RPD
was informed of in responding to the scene on 8/20/11 incident to Coughlin's
defense in 11-063341). It was only upon the State turning over such recordings
(way too late in the game to avoid prejudicing Coughlin's defense, where such was
turned over by the WCDA's Office on 11/5/12 (RCA Skau turned over some
recording that contained material ommission on 11/13/12...and see the
impermissible, insufficieny notices, perhaps fraudulent assert of Skau's incident to
the 11/8/12 ex part hearin in 11-063341 and Judge Sferrazza'a 11/8/12 TRO (to be
fair to Skau, Judge Sferrazza's 11/8/12 Order does seem to allow for service on
Coughlin by email of a motion to contest to sufficiency of Coughlin's own service of
subpoenas....though Judge Sferrazza, on 11/19/12 rejected any assertion that he had
made such an order allowing emailed service upon Couglin...but pointed out that it
was a good thing Coughlin had shown up anyways to the 11/13/12 hearing, as Judge
Sferrazza would have ruled against Coughlin without Coughlin's having had an
opportunity to be heard had he not shown up, in an echo to Judge Clifton's but
your're here! argument upon Coughlin pointing out the insufficiency of notice as to
Leslie's Emergency Motion to Withdrawal as counsel on 12/18/12 in 12-065630
(which, by the way failed to addres the Motion Coughlin filed therein, unopposed by
either Leslie or DDA Young, on 12/3/12, which should under DCR 13(3) and or
Polk v. State result in a dismissal of 12-067980 as well.
Leslie's coercive threats of abuse of process to Coughlin is
further evinced in the following, which provides support for
Coughlin's own application for a TPO against Leslie:
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Thursday, November 01, 2012 3:14 AM
To: Leslie,
Jim; davidc@nvbar.org; patrickk@nvbar.org; fflaherty@dlpfd.c
om; complaints@nvbar.org
Subject: RE: Coughlin: Petit Larceny case -- Hand-Off
Transmittal Jim, I will give you an opportunity to retract or
fully explain your statement in your last correspondence to me,
wherein you wrote: "Given your past statements to me, I believe
I should also warn you of the possibility of applicability of
Nevada Rule of Professional Conduct 3.3. In that regard, please
recall that during a meeting between you and I in one of the
interview rooms at Reno Justice Court during trial on 9/5/12, you
suggested to me that I alter the video recording of your
interaction with the police officers in the petit larceny case. I
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told you I cannot do that. You became irate and argumentative

and asked why I could not do it, and I told you it would be
unethical. I raise this issue in this email transmittal to reiterate
what I have had to tell you more than once in this case, that is, I
cannot and will not assist you in alteration of evidence or other
commission or attempted commission of fraud upon the court.
Should I observe you attempting to do so during the resumed
trial, currently set for November 19, 2012, as noted above, I
believe I would be required under Nevada Rule of Professional
Conduct 3.3 to advise the Court." I don't know what is funnier,
Jim, the accusation that I would somehow view you as tech
savvy enough to whip up some video editing on the spot with
"the county laptop" which "takes a little while to boot up", or the
suggestion that I would be stupid and reckless enough to attempt
to encourage you to commit some vague misconduct, you whom
I cannot stand and whom clearly wants nothing but the worst for
me. Sure, Jim, sure. I get it Jim, you have had a chance to read
the Memorandum I submitted, which painstakingly dissects your
misconduct, and you are panicking, doing damage control,
reverting to your tried and true threatening of your indigent
criminal client's routine....next, you will attempt to have a bailiff
lean on your client with some intimidation tactics, probably have
him threaten to "put my foot up your ass" as you did with Bailiff
Reyes on October 8th, 2011 at the RJC. I consider your above
writing to be an inappropriate threat, and beyond inaccurate.
Jim, if there was a transcript of these conversations you refer to,
and one compared them to your above statements, would your
conduct be ethical or even legal? By "alter", what exactly do
you mean, Jim? Are you referring to the "10 minute break"
where you need to "boot up the county laptop" 10 minutes before
lunch, which Judge Sferrazza granted you so you could "do
some trial prep" (mid-way through the trial, whereupon you were
going to view, for the first time, apparently, the video of the
arrest, especially given your early foul ups on the record wherein
you failed to recognize the difference between the extortionate
threats made by Officer Rosa from those made by Officer
Duralde...then, during that "10 minute break" you proceed to do
something other than what you told Judge Sferrazza the break
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was for...instead of reviewing the exculpatory video, you talked

to the State Bar of Nevada on the phone and received
confidential information related to Keith Loomis's representation
or lack thereof of myself...I asked you whether you had any
authority for your position that the videos of the arrest, and other
investigatory videos I capture had to be submitted or presented
to the court in their entirety (some of the videos are quite
long...you wouldn't know Jim, because you have not viewed
them....). You, of course, because you never have any citation
for anything, instead proceeded to attempt to make some lame
threat accusing me of some gibberish, in that classic Jim Leslie,
CYA, faux sincere, hyperpretentious delivery of yours that is so
very grating.... Don't have time to go into all the
misrepresentations you make in your email below. Jim, why
don't you just email me the dispatch tapes, you know, as that is a
very material issue in this matter. This is especially true where
the RPD and DDA Young have seemingly come up with this
"dispatch reported to the officers a possible fight" despite the
fact that the dispatch logs mention only a "disturbance" at first,
then Further, Duralde's Supplemental Declaration (the one he
filed the day after the arrest, not the Narrative he filed 3 months
later when the RPD found out the arrest had been captured on
tape by Coughlin...its a great video, Jim, you should watch it
sometime....): "report of a larceny of a cell phone at that location.
Dispatch relayed information that the victim had set his phone
down and that he was now calling the phone and It was lighting
up In the suspecfs pocket. The suspect was described as a white
male adult, 35 years of age, 6'02",210 Iba, wearing a red
Chicago hat and a white or yellow shirt and plaid shorts.
Dispatch also relayed that the suspect was still on scene." Then,
on page two of DDA Young Opposition to the Motion to
Suppress (the one where you guys failed to preserve arguments
related to the impermissiblity of a search incident to arrest based
upon what remained of the facts should your suppression motion
be granted as it related to the pat-down alone), DDA Young
seems to come out of nowhere with this "report of a possible
fight" stuff, which, conveniently, really helps in the whole "need
for articulable facts supporting a reasonable suspicion/pat down
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or probable cause/search incident to arrest analysis...On page 5

of his Opposition, DDA Young drives the point home: "In the
instant case, the pat-down search of the Defendant was proper
under the totality of the circumstances. 3 Prior to arriving,
Officer Duralde learned that the scene involved a loud
disturbance with possible fight, thereby immediately raising the
concern of weapons and the safety of all those present . This is
just one factor for this Court to consider. Upon contacting the
Defendant, he became uncooperative and challenged Officer
Duralde that there was not enough information for a detention.
This is just one factor for this Court to consider. Upon
contacting the Defendant, he became uncooperative and
challenged Officer Duralde that there was not enough
information for a detention . Thereafter , in response to Officer
Duralde's inquiry whether the Defendant had Mr. Goble's phone,
the Defendant asked if he had the right not to answer the
question. While the Defendant arguably can choose not to
answer such a question, this response, along with his general
attitude, demeanor, and reaction, certainly can be considered by
this Court when addressing the reasonableness of Officer
Duralde 1s concern for his and others l safety . It is important to
note that there were multiple people on 2 scene, any of which
could be subjected to injury or death if the 3 Defendant had a
weapon . Upon arrival , the Defendant and a group of 4 people
(including Mr. Goble) were on scene, and with the allegation
that the Defendant had stolen a phone belonging to a person of
said 6 group, emotions were high and a physical fight could have
erupted. Again, such factors should be considered by this Court
when 8 determining the reasonableness of the pat-down search."
But where is the support for this "a possible fight" suggestion?
Its not in the discovery produced to me. So, how about those
dispatch tapes, huh, Jim. Kelly Odom? Please email them to
me, I don't want you trying to jam me up so close to trial with
some non-sense about how some blank or scratched cd you gave
me was the "only copy" your office had. I know you well, Jim.
So, seeing as how you finally served a subpoena duces tecum on
Kelly Odom/Ecomm/ 911 dispatchers, so we can finally hear the
dispatch tapes, and see if any "possible fight" was mentioned,
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why don't you go ahead and email me those audio files (and
audio files are mercifully small compared to video files, Jim, yet
I have managed to send you reams of video files via email...).
Also, I need the audio of the aborted Trial in this matter that was
held on May 7th, 2012 (despite the fact that Judge Elliot did not
sign the Order finding Coughlin Competent, and therefore
ending the period in which "all proceedings must be stayed"
required by NRS 178.405, until two days later, on May 9th,
2012. So you guys were going to jam me into a Trial while there
was a pending Order for Competency Evaluation, just days after
my getting out of jail, where my medication was wrongfully
withheld from me (and some medications should not be ceased
or started to abruptly), where I spent 8 days due to the lies of the
Lakes Crossing evaluators and the misconduct and malpratice of
your protege, Biray Dogan, whom proceeded to read my
confidential medical information into the open, public record, in
front of 40 or so members of the public....a transgression which
Mr. Bosler saw no need to attempt to have stricken or corrected.
BUT TO ME CLEAR, JIM...I know Goodnight orderd a copy
of the May 7th, 2012 aborted Trial, that occurred during the
pendency of an Order for Competency Evaluation. I do not have
a copy of that JAVS audio, nor do I have a copy of my
arraignment in rcr2011-063341. You guys don't even get billed
for these and yet you have denied them to me, until you got wind
of the fact that I went and got my own, then you come up with
you faux offers to provide me copies....Very clever. Jim, the RJC
severely limits my access to the files, so you are not entitled to
make any assumptions that alleviate your duty to provide me
copies of filings, access to my file, etc. Further, I see that Linda
Gray filed a request for the audio of the October 22nd, 2012
Hearing, and I want a copy of it, so please email it to me, and
also provide a hard copy. Its not rocket science copying a CD,
Jim, and it doesn't take ages, either. You remember the October
22nd, 2012 Hearing, right, Jim...the one where you can be heard
on the record telling me "you are going to fail" and "your're
disintegrating" and making more of your threats about how I
attempt to advocate on my own behalf the Judge will put me in
jail, etc.,etc.? Yeah, I need a copy of the copy your office got of
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that hearing. With the bits where you tell the Judge "he
(Coughlin) doesn't get to dip into our money, no one cent" in
your explaining your refusal to subpoena material witnesses or
send out subpoena duces tecums (odd, because the RPD doesn't
seem to charge you guys for those....yet you never sent one to
ECOMM until well over midway through the trial, why is that,
Jim?). See, Jim, it was professional misconduct for you to spend
your entire cross-examination of Cory Goble trying to establish a
citizen's arrest was effectuated, and therefore help the police and
the State overcome the fact that Officer Duralde cleary
overcharged the crime as a felony in an attempt to game the
system and get around the whole statutory dictate against
officer's making custodial arrest (and therefore being permitted
to conduct searches incident thereto) for misdemeanors,
allegedly committed after 7 pm and outside the officer's presence
(unless a citizen's arrest is immediately effected). Your cross
was pretty good work for a prosecutor, but you get paid to fulfill
the Sixth Amendment Jim, not throw retaliatory tizzy fits. Your
failure to in any way utilize the 911 call tapes and videos
Coughlin took of the moments prior to arrest (where the youths
admit they are trying to steal Coughlin's bike and his dog, to
teach him a lesson...not to "detain" him or effect a "citizens
arrest" (it almost seemed like DDA Young had you make the
arguments he wanted to make, but knew would be unethical for
him to make, or would expose other glaring weaknesses in his
case, and in that way, you two really make beautiful music
together, Jim). Then there is the fact that Coughlin himself
called 911, and that Coughlin is heard on the video's prior to the
police arriving encouraging the hostile gang of late teens, early
twenties skateboarders to remain peaceful, and wait for the
police to arrive, so the matter could be handled civily (and not
lead to anyone dying, as Coughlin referenced the tragic death of
a 25 year old man intervening in a purse snatching of that was in
the news just months prior to the August 20th, 2011 arrest in this
matter RCR2011-063341...really, Jim, you should join us at the
November 14th,2 011 bar hearing in NG12-0204, as the SCR
105 Complaint saw fit to make this pending criminal charge a
basis for a professional misconduct hearing. In the meantime,
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why don't you send me the digital transmissions that Judge

Sferrazza ordered, and not hide behind some "there's not enough
time to make copies" non-sense. Right, Jim, you are really going
to give me your only copies of things. Uh-huh. You? Jim, you?
Jim, you spend all day covering your ass, so please. Besides,
the Judge did not rule that I have to pick up some box of stuff,
and sign some document while being harassed by you, attesting
to the contents of long pieces of digital media (which I am sure
you will object to me watching right there in your office). That
is the beauty of the digital transmission, Jim. Maybe the WCPD
will need to get itself a Skydrive, they are free, who knows? All
I know is I have made far less money than you this year Jim, and
done the lion's share of work on this case (with lots of extra work
added by your misconduct), and I have found your work on this
matter to be amongst the most distasteful I have ever seen by an
attorney. So, now that I know that your office did subpoena
Kelly Odom (she showed up to Trial, yet you kept that secret
from me, in addition to the subpoena duces tecum you sent her,
really late in the game, on October 3, 2012. Also, you do
realize that RPD Officer Duralde's wife was on duty that night
working as a dispatcher for ECOMM, right? Jessica Duralde,
and what dispatch told the RPD that night has become a material
issue in this case. Yet, the WCPD was satisfied with was the
RPD gave them and didn't send a subpoena duces tecume out to
ECOMM until after the Trial would have been over already, had
it not been for how tenacious that Coughlin is.
Finally, Jim,
you might want to reconsider your analysis respecting your
purported failure to subpoena witnesses after reviewing the
attached, as you wrote: "I have not subpoenaed witnesses to the
November 19, 2012, resumption of trial because (1) contrary to
your assertions, no witnesses appear to have credible and
persuasive prospective testimony to help your case, in fact most
of the witnesses you have insisted on calling at trial appear to
have prospective testimony harmful, not helpful, to your defense,
(2) the witnesses you have demanded we subpoena and have
testify appear to actually have prospective testimony contra to a
finding of not-guilty, and (3) I already obtained several points
through cross examination of Zurate, Duralde, and Goble that
you requested and that are credible and potentially persuasive

points in favor of your defense (please recall your comments to
me during the first day of trial, I like where you are going with
this . . . . )."
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That coercive threat by Leslie to alleged to the SBN some phoney accusation
against Coughlin suggesting Coughlin told Leslie to alter video evidence (Leslie
indicated any such thing was evidence of Coughlin's lack of fitness to practice law in
an apparent misunderstanding of the import of the decision in Sierra Glass (Conduct
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of counsel in omitting portion of deposition when deposition is read into record, and
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giving impression that entire document is being proffered, resulting in buttressing of
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his
party's position is fraud on the court warranting the imposition of sanctions.
Sup.Ct.Rules,
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Rules 172, 172, subd. 1(a, d). Sierra Glass & Mirror v. Viking Industries, Inc., 1991,
808 P.2d
512, 107 Nev. 119, rehearing denied)) Leslie misstament and confusion of the
interaction between the excuplatory video evidence Coughlin wish to have Leslie
introduce or utlize in some way (including to impeach all of the State's witnesses in
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11-063341) prior to being forced to make his decision whether to invoke his Fifth
Amendment Rights or Not (and really, also incident to the decision of whether to
accept the plea or go to trial) is contained in the following email from Leslie to
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Coughlin (to be clear, a criminal defendant has not duty to offer any incriminating
evidence, and regardless, Coughlin ultimately sought to introduce the entirely of all
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videos, without any editing, but Judge Sferrazza largely refused to so admit such
materials based on either relevancy or hearsay grounds, but the Sierra Glass case
should have indicated to Leslie that a criminal defendant attorney does not have some
obligation to play the entire video, under RPC 3.3, if he feels some portions of it are
not useful, or even if they would be prejudicial or incriminating, where such criminal
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defendant attorney (or his counsel, as they case was there) did not give the
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impression that the entire document is being proferred):
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From: Leslie, Jim Sent: Monday, October 29, 2012 2:17 PM To:
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zachcoughlin@hotmail.com Subject: Coughlin: Petit Larceny case -Hand-Off Transmittal Importance: High Mr. Coughlin: This
transmittal is protected by Attorney-Client Confidentiality. However,
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dissemination of any kind of the contents hereof or of any of the

attachments hereto may effect a waiver of such Confidentiality, as
you have been previously advised in prior emails and as you know
from your legal training. Transmitted herewith as attachments are file
materials which are transmitted as courtesy hand-off transmittal
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from us as assigned counsel of record to you as court-permitted self-
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representing defendant, for purpose of assisting you in your

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preparation for resumption of trial in the Petit Larceny case currently

scheduled for November 19, 2012, at 8:30 a.m., and as to which date
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you have been previously advised via US Mail, email notice, verbal
notice, and as you have previously acknowledged being advised of in
prior proceedings in open Court. The attachments themselves shall
serve as inventory of the materials transmitted herewith. Additionally,
as courtesy and as memorialization of various issues, please note the
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following: Please note that there are also several computer
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discs/DVDs containing video and/or audio on them, as well as a set
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of color-printed photographs which we had prepared in response to
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your September 20, 2012, email to us, that we will produce in
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tangible form separate and apart and in addition to this email
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transmittal. You will need to pick those items up from our office and
sign a receipt. A copy of that receipt is attached hereto as a PDF
attachment, titled Receipt of Documents. Please email me whether
you are available 10/29/12 or 10/30/12 for pick-up of the additional
documents and I will arrange to be present with an executable receipt
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for your signature. Said receipt is necessary in part because the

materials listed in the Receipt of Documents cannot be reproduced on
short notice, in an effort to ensure you receive them well before the
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resumption of trial, and to avoid dispute as to what materials were

handed over to you. I note that you and the Court confirmed at the last
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hearing that you have already directly received copies of the JAVS
audio recordings of proceedings from the Court, so we are not
producing those in duplicate. Included in the attached PDF
transmittals are copies of clean, unredacted discovery materials from
the State, copies of those materials with redactions, and our
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transmittal letter to you including redacted copies of the discovery
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materials dated December 1, 2011. We have also provided you via
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email other copies of those same discovery materials on prior
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occasions. Additionally, I recall personally trying to provide you
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additional courtesy copy of those materials on at least one occasion
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when you came to the office without an appointment and made loud
verbal demands for another copy of your discovery because you had
lost your previously provided copies, however, you then left the
office when we tried to provide you that additional copy. Although
we are hereby producing various pleadings as PDF attachments to this
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email, as listed herein, my understanding from you is that you already

have copies of all filed pleadings, orders, etc., from your direct
contacts with the Reno Justice Court. Nevertheless, the pleadings
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listed herein are produced as PDF attachments as a courtesy. We are

not producing you copies of the voluminous emails and email
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attachments you have previously sent us, since by being the

transmitting party of those emails and attachments you obviously
have them yourself. Please also note that you are now operating as
your own self-representing counsel, by way of the self-representation
granted you by the Court on 10/22/12, in the petit larceny case. If you
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represent to anyone that you are operating in that case in conjunction
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with or as co-counsel with our office or any attorney therein, other
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than in our capacity as Stand-By Counsel, we will have to consider
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reporting you to the State Bar for fraudulent misrepresentation.
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Additionally, as you were warned by the Court on 10/22/12, you
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cannot use any of the materials we are transmitting or the information

contained in those materials to harass any person or otherwise put the
materials or information therein to any other improper use. These
cautionary notes include but are not limited to information contained
in the cell phone records of Mr. Goble and the addresses, phone
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numbers, and other contact information of any persons identified in

the transmitted materials, including those attached to this email
transmittal and those contained in the Receipt of Documents. Given
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your past statements to me, I believe I should also warn you of the
possibility of applicability of Nevada Rule of Professional
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Conduct 3.3. In that regard, please recall that during a meeting

between you and I in one of the interview rooms at Reno Justice
Court during trial on 9/5/12, you suggested to me that I alter the
video recording of your interaction with the police officers in the
petit larceny case. I told you I cannot do that. You became irate
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and argumentative and asked why I could not do it, and I told you
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it would be unethical. I raise this issue in this email transmittal to
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reiterate what I have had to tell you more than once in this case, that
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is, I cannot and will not assist you in alteration of evidence or other
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commission or attempted commission of fraud upon the court. Should
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I observe you attempting to do so during the resumed trial, currently

set for November 19, 2012, as noted above, I believe I would be
required under Nevada Rule of Professional Conduct 3.3 to advise the
Court. I have not subpoenaed witnesses to the November 19, 2012,
resumption of trial because (1) contrary to your assertions, no
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witnesses appear to have credible and persuasive prospective

testimony to help your case, in fact most of the witnesses you have
insisted on calling at trial appear to have prospective testimony
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harmful, not helpful, to your defense, (2) the witnesses you have
demanded we subpoena and have testify appear to actually have
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prospective testimony contra to a finding of not-guilty, and (3) I

already obtained several points through cross examination of Zurate,
Duralde, and Goble that you requested and that are credible and
potentially persuasive points in favor of your defense (please recall
your comments to me during the first day of trial, I like where you
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are going with this . . . . ). Additionally, the Court advised you on
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10/22/12 that if you believe you require subpoenas, you may contact
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the Court directly and obtain subpoenas with waiver of fees. As
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directly by the Court on 10/22/12, I will be present at the trial on
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November 19, 2012, at 8:30 a.m. as Stand-By Counsel. If during the
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resumed trial you believe you are unable, after all, to adequately
handle the trial proceedings yourself, I will be available to take over
representation, at which point I would do my best to correct any
errors or tactical mistakes you might have committed as well as
otherwise try to win the case for you. Thank you, James B. Leslie,
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Esq.
Dated this 3/21/13
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__/s/ Zach Coughlin_____

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IN
1U13 JAN \ S Pt,\ \: 31
THE MUNICIPAL COURT OF TI;! [: ,,}I;v.,R.l{

I
COUNTY OF WASHOE, STAT
f
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v'-
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,.:
....
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IN THE ADMINISTRATIVE MATTTER OF:
ZACHARY BARKER COUGHLIN,
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ADMINISTRATIVE ORDER 2013-01
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WHEREAS, ZACHARY BARKER COUGHLIN has been the subject of disciplinary

hearings before the State Bar of Nevada Northern Nevada Disciplinary Board where the Board found
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Mr. Coughlin "committed multiple violations of the Rules of Professional conduct" and that Mr.
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Coughlin "engaged in bad faith obstruction of the disciplinary process"; and
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WHEREAS, ZACHARY BARKER COUGHLIN has been a party in cases before the
Reno Municipal Court, including cases before the Honorable William L. Gardner, the Honorable
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Dorothy Nash I-lohnes, the Honorable Jay Dilworth and the Honorable Kenneth Howard, wherein Mr.
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Coughlin was h eld in contempt of court by the Honorable Kenneth Howard and the Honorable
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Dorothy Nash I-Iohnes for failing to follow the Court's orders and d i rectives ; and
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WHEREAS, ZACHARY BAKER COUGHLIN has been a party in both civil and
criminal matters before the Reno Justice Court, including cases before the Honorable Peter Sferrazza,
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the Honorable Scott Pearson, and the Honorable Dav i d Clifton, wherein Mr. Coughlin has been
admonished for failing to follow the Court's orders and directives; and
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WHEREAS, ZACHARY BARKER COUGHLIN is currently the subject of an Order
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for Protection against H a rassment in the Workplace in effect until January 4, 2014, requested by the
Washoe County Public Defender's Office, his counsel in several cases before the Reno Justice Court
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and
WHEREAS, ZACHARY BARKER COUGHLIN is cu rrently a party in cases before
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this Court and citizens, whether or not i n digent , have a constitutional right to access to the courts with
the protection of due process oflaw; and
WHEREAS, frivolo us or vexatious claims and d efenses overburden limit ed juri dical
resources, hinder the time ly resolution of meritorious claims and i nc rease the costs of engaging in
business and provi ding professional services to the public; and
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WHEREAS, ZACHARY BARKER COUGHLIN has repeatedly caused a disturbance
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in and around the Clerk's Otlice of the Reno Municipal Court, disrupted the or de rly business of the
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Court and ov erburdened the limited judicial resources of this Court thereby hindering the timely
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resolution of meritorious claims and increasing the costs of engaging in busi n ess and provi ding
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professio nal services to the public; and
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WHEREAS, pursuant to NRS 22.010(2) "[a] breach ofthe peace, boisterous conduct or
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violent dist urbance in t he presence of the court, or in its immediate vicinity, tending to interrupt the
due course of the trial or other judicial proceedings" constitutes contempt of court in the State of
Nevada; and
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WHEREAS, "[dJisabedience ar resistance to any lawful writ, order, rule or proces s

\
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issued by the court or judge at chambers," NRS 22.0 10(3), constitutes contempt of court in the state of
Nevada; and
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WHEREAS, Nevada's courts are constitutionally authorized to issue all writs "proper
and necessary to the complet e exercise of their jurisdiction." Nev. Const.
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att.
6, 6(1); and
WHEREAS, to protect the peaceful and effective operation of this Court,
IT lS HEREBY ORDERED:
1.
ZACHARY BARKER COUGHLIN shall not enter the premises of the Reno
Municipal Court at One South Sierra Street, Reno, Nevada except as follows:
A. If ZACHARY BAKER COUGHLIN wishes to file a document with the Reno
Municipal Court or attend a hearing in the Reno Municipal Court, he must notify the security
personnel at the main security screening entrance located at the east entrance of One South Sierra
Street and wait for a marshal of the Reno Municipal Court to respond to his location.
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B. If ZAC HARY BARKER COUGHLIN wis h es to make a request of the Reno
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Municipal C ourt for copies, transcripts, access to a court file or ask a question, hc shall do so in
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writing and either mail the request to Reno Municipal Court or deliver the written request to a marshal
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ofthe Reno Municipal Court by first contacting the Marshal's OHice through court security as detailed
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above. The marshal will then file the document for Mr. Coug hl in and provide a file-stamped copy to
Mr. Coughlin in return.
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C. IfZACHARY BARKER COUGHLIN wishes to attend a Court hearing in the
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Reno Municipal C ourt he shall be escorted by a marshal of this Court.

,
2. ZACHARY BARKER COUGHUN shall not be present in the exclusive premises

of the Reno Municipal Court including the Clerk's Oflice, courtrooms, ASU Office, administrative
offices on the second and third floor of the South 'rower of One South Sierra Street, Reno, Nevada,
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without escort of a marshal of this Court and without first following the notification pr ocedures as
outlined above.
3. ZACHARY BARKER COUGHLIN is prohibited from contacting any employee of
the Reno Municipal Court other than a Reno Municip al Court Marshal.
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4. IfZACHARY BARKER COUGHLIN is a party to a case, he may address the Court

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during the Courl proceedings.

5. Any violation of thi s Order may be considered a contempt of court and punished
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pursuant to NRS Chapter 22 by a fine of up to $500 and/or incarceration for up to 25 days in the
Washoe County Detention Facility.
6.
This Order is effective upon the date of persona) service upon ZACHARY
BARKER COUGHLIN.
Dated this
&urday of January, 2013.
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ADMINISTRATIVE JUDGE
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NOTE BY COUGHLIN: THE RENO JUSTICE COURT FAILED TO ACTUALLY TRANSMIT THESE SUPPLEMENTALS FILINGS
TO THE DISTRICT COURT, BUT RATHER MERELY FILED THIS INDEX OF THE FILINGS, WHICH, INCIDENTALLY
IMPLICATED THE RJC'S FAILURE TO FILE IN COUGHLIN'S 12/26/11 SUBMISSION FOR FILING OF A NOTICE OF
APPEAL DIRECTED TO JUDGE SFERRAZZA'S 12/20/11 ORDER RESOLVING COUGHLIN'S MOTION TO CONTEST
PERSONAL PROPERTY LIEN. Coughlin completely rejects any contention by Judge Sferrazza that he
"agreed" to "allow" Judge Sferrazza to enter some Order "resolving" Coughlin's Motion. The
atmosphere at that 12/20/11 Hearing on Coughlin's 11/16/11 filed Motion to Contest personal
property lien in RJC Rev2011-001708 was one of the most coercive and threating Coughlin has
encountered in a courtroom.
IT is rather curious that the RJC not only refused to file in Coughlin's 12/26/11 Notice of
Appeal (the RJC failed to inform Coughlin of this refusal in a timely manner), especially
considering Judge Flanagan's 3/30/12 Order denying Coughlin's Appeal specifically limits
Judge Flanagan's decision as to not include the 12/20/11 Order mentioned above and which
should be included in this Supplemental, as should have been Coughlin's 12/26/11 filing of
a Notice of Appeal and all the other materials so submitted and or merely mentioned in this
Supplemental.
Print
Close
RE: thanks
From: Helzer, John (jhelzer@da.washoecounty.us)
Sent: Tue 1/08/13 7:54 AM
To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
Cc: Covington, Mark H. (MCovington@da.washoecounty.us)
Mr. Coughlin:
I didnt say you were an active member of the bar. If I should have been more accurate and simply indicated you have
graduated from a law school and have been a member of the Nevada Bar in the past, I apologize. I still stand by my
previous representations with respect to what we will and will not provide.
In addition to the above, I am again concerned that you appear unable to restrict your communications to assist this
Office in addressing your requests. As previously noted, endless comment, accusations and assertions will delay the
efforts of this Office to assist you and probable result in matters being overlooked because they are buried. Anyway,
your latest e-mail will be processed as previously set forth.
John Helzer

Sent: Monday, January 07, 2013 6:45 PM
To: Helzer, John
Subject: thanks
I am not an attorney, your office (Kandaras and Watts) moved to quash my subpoenas
in two different settings by alleging that I, as someone whose law license is suspended,
may not issues subpoenas (they were clearly wrong in the SBN/NNDB setting,
although, of course bar counsel was able to cheat their way around that (bar
counsel/NNDB/Panel/Clerk of Court had affirmatively indicated I had the right and
ability to issue my own subpoenas, yet your Judges and Court Staff and WCPD Biray
Dogan failed to show up to my 11/14/12 formal disciplinary hearing, then Watts and
SBN Pat King lied about King having a "certified copy" of the April 2009 Order by
former WCDA DDA Linda Gardner (whom went to Reno High School in 1975 and
worked as a domestic violence prosecutor with RJC Judge David Clifton at one point in
the WCDA's Office. Mary Kandaras openly enthuses about Jim Leslie's willfully
depriving me of the discovery I am entitled to under the law, then you have continued to
provide me the 12/6/12 804 page filing in cr12-2025 that the RJC indicated it would
provided me, then failed to, all while DDA Young et al have been provided it via Eflex,
an therefore have obtained an impermissible advantage from both of your courts, and
DDA Young failed to appear today to a 8:30 am status conference in RJC RCR2012067980, and I have the file, and Jim Leslie failed to turn over quite a bit from it, while
also clearly disenfecting from it all of my communications and productions of videos
and documents that implicate fraud by the RJC and WCSO, some might say, incidnet to
the faulty 6/14/12 notice, the 6/26/12 email from me to Stancil, RJC Web, Stuchell,
WCSO, and the Sparks Justice Court (I can prove that email was on the left hand side of
the file, at least at one one, in REV2012-001048) and further, DDA Young has failed to
propound the Brady material recordings that were made at the time of the arrest in
rcr2012-067980, while continuing to violate rpc. 3.8 where has has been provided
exculpatory video and audio evidence. Lastly, there is no duty to come out of one's
rental in an eviction context, particularly where law enforcement repeatedly failed to
and then openly refused to identify themselves. Additional;y, the presence of Jeff
Chandler and NCS, and the extent to which the file contains pictures and pictures of my
personatly within the rental, in a clear attempt to document evidence to support an
eviction for impermissible use allegation, clearly suppots a finding of Soldal v. Cook
Co. impropriety by the Sheriff's office, and therefore the WCDA's to the extent all my
meanderings and musings have now put you on notice thereof, where you persist in
prosecuting. The fact that this has been done in the context of a scurrilous backwoods
attempts to take away my law license refelcts immeasurably poorly on you and DDA
Young, Kandaras, and Watts-Vial (David, not Laura, though she was involved in the
UIFSA case that brought forward so many troublesome constitutional law issues.
Sincerely
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
From: jhelzer@da.washoecounty.us
To: zachcoughlin@hotmail.com
Subject: RE: WCDA Conflicted out of prosecuting Coughlin, candor to the tribunal FW: attempt to file prior to
5pm denied
Date: Mon, 7 Jan 2013 23:34:39 +0000
Mr. Coughlin;
Again, your communication will be processed as previously stated.
In attempting to provide you with what you are entitled to please consider the following request. Begin your
communications with what you want. If you are entitled to it, it will be provided much more quickly than if an
investigator has to glean it from your lengthy efforts. Not only will complying with this request hasten our compliance, it
is less likely that a request will be overlooked because it is buried in a mass of assertions and comments.
I would note, that we provide what is required by law. It may be that we could more easily access something you
want, but unless we are required to do so dont ask us to do what you can do. You are an attorney representing yourself.
The requirements of what we are both called upon to do are not a mystery. I do not intend to spend a great deal of time
exchanging e-mails with you. If we cant arrive at an agreement of how to proceed in this medium, lets consider closing
down these efforts and conduct any necessary matters through the courts.
It is my hope that you are able to restrict the length and content of your communications. I am making this last effort to
keep communications open. I believe it is to your benefit for this to continue. If you truly are unable to control yourself, I
can only assume you are either lacking something else to fill your time; find your approach amusing or acting
compulsively. I am not here to fill your days, provide entertainment and I do not have the ability to address a compulsive
personality.
This communication has not been made available to anyone but you. Accordingly, any additional publication would
only result from your efforts.
John Helzer

Sent: Monday, January 07, 2013 1:26 PM
To: Helzer, John; Lipparelli, Paul A.
Subject: RE: WCDA Conflicted out of prosecuting Coughlin, candor to the tribunal FW: attempt to file prior to 5pm denied
Thanks Assistant District Attorney Helzer,
I would like to respectfully note that all three of these cases would probably be plea
bargained out by now if it weren't for the diva Diana Ross stylings of one WCPD Jim
Leslie, Esq, who seemed to go out of his way to implore Judge Sferrazza to refuse to
accept my plea resolving all three cases on 8/27/12, then Leslie argues against allowing
me to self represent, then he proceeds to refuse to subpoena witnesses (but lies to the
Court on 8/29/12 in asking for permission to tell the witnesses they are held to their
subpoenas), the he attempts to aid in coercing a waiver of my Fifth Amendment rights

or the right to decide whether or not to testify etc., etc.
I don't actually believe Leslie or anyone else is at all afraid of me, but in the event they
are, allow me to indicate, I abhor violence, I am not a violent person, I have made no
threats of violence, I will not be committing any violent acts upon anyone, etc., etc.
Is Leslie trying to make the WCDA happy? If so, it sure involves a lot of resources
being expended, and a lot of grievances and complaints being filed, some against
DDA's, some against former WCDA's turned judges (well, Mr. Sarnowski has indicated
those might not, technically be "filed" just yet, so...).. I clearly represented to all
involved that I just want to move on with my life in a positive direction, and not pursue
civil litigation, and under some authority, as long as the DA is brought in to "okay"
things, it is permissible to resolve bar matters, criminal matters, and anticipated or
pending civil matters in a global resolution...
I have a request. Would your office please email me the12/6/12 filing in the appeal of
rcr2011-063341 (the appeal is CR12-2025). The RJC did not mail me the ROA (I
think on the docket its just listed as a Notice of Appeal, but it contains 804 pages...)
here is the docket entries that I am requesting your office email me. As an efiler DDA
Young has access to these pdfs...yet, I am an not an efiler, so I do not. It would seem to
create an unfair advantage to not provide non efiler a copy of that 12/6/12 "Appeal
from Justice's Court".
Filing
Date
Description
06-DEC- Appeal from Justice's Court

2012
09:39 AM
Entry:
none.
Name
COUGHLIN, ZACHARY
Monetary
06-DEC- ** Exhibit(s) ...

2012
09:40 AM
Entry:
STATE'S EXHIBITS A AND B DEFENDANT'S EXHIBITS 1 THROUGH 21 and DISK/CD

ZACH COUGHLIN PD#144825
I believe the WCDA should be conflicted out of prosecuting me. Already there has been an impermissible
teaming up against me by DDA Kandaras and Jim Leslie, imploring each other to file charge against me (despite
Leslie lying in the TPO Application sponsored by DDA Watts where Lelise attests to a "video clip" when, in
actuality the clip is to an audio file only, and the quotation mentions reading, learning, and philosophy, and
"outlasting" one in the context of speaking to reading, learning and philosophy...yet DDA Kandaras whole
heartedly endorsed Jim Leslie's grandstanding (even where Kandaras has some messy explaining to do with
regard to her participation in the RMC Judge Nash Holme's confiscating of my cell phone, smartphone, and
micro sd card where she found I was functioning as my own attorney (in a search and seizure well outside the
temporal limitation for a search incident to arrest). So, I need to interview employess of the RJC for the
defense of my formal disciplinary hearing. The RJC never responded to my subpoena that Nicholas Hasset
served upon Karen Stancil, Steve Tuttle, and the RJC Custodian of Records on 10/30/12 in NG12-0204. Then
there is the RJC just plain refusing to file my notices of appeal of 12/26/12 in rev2011-001708 (to the 12/21/12
Order Resolving Mtn Contest Personal Property Lien) and the 3/16/12 notice of appeal in rev2012-00374
(where the fax header on the eviction order reads 8:24 am for a hearing set for 8:30 am, and where the clerk
on the transcript is heard whispering the Judge Schroeder suggesting he take the cases out of order to hurry
through a default against Coughlin because he had not shown up yet...
Then there is Judge Pearson authorizing the unauthorized practice of law in Rev2012-001048 (while also
dispensing with the requirement in NRS 40.235 that the forum to file a tenant's affidavit or answer be listed on
the 5 day notice), which resulted in the wrongful arrest in rcr2012-067980 by the same WCSO Deputy Machen
who filed false affidavits of service as to the lockotu on 11/1/11 based upon a void or stale eviction order, and
also for "personal service" (in violation of courthouse sanctuary doctrine) of the Order To Show Cause in the
appeal of that eviction cv11-03628) outside the traffic trial in RMC 11 TR 26800 (the traffic citations involved
the opposing counsel in the eviction, Richard G. Hill, Mary Kandaras's co-member of the NNDB), and Hill paid
the the WCSO to show up at the traffic trial on 2/27/12 to attempt personal service of the Order to Show Cause
(despite his knowing I was an efiler at the time, and attorney of record, thus making personal service, under
Caplowunnecessary...just more of a attempt to try to embarass me in front of court staff and harass me and
otherwise create an appearance of impropriety (like in hi 1/14/12 letter ot Bar counsel where he suggest they
call RJC clerks STancil and Baker, whom he implies will bad mouth me, or in his 11/22/11 letter to me where
he suggests that he will be able to control the RJC and prevent my getting a hearing for 6 weeks despite one
being required within 10 days under NRS 40.253(8).
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
12 17 11 Stancil sand Jonas statements Contest Lien Hearing setting 11 22 11 from a month prior 1708
063341 0204.pdf
6 26 12 email to various rjc wcso rpd on soldal (2).pdf
7 2 12 email to rpd etc.pdf
2 6 12 0204 1708 26405 email to wcso stuchell nvrenopd@coplogic.com kandaras kadlic WCSO Deputy
Machem's personally serve.pdf
2 10 12 EMAIL TO KANDARAS RE STUCHELL ADMISSION.htm
11 7 11 0203 WCSO Machen Affidavit of personal service then 2 7 12 Stuchell admits merely posted
26405 0204.pdf
12 5 11 and 2 7 11 emails to and from Stuchell lstuchell@washoecounty.us 26405 1708 26800 01896
60302.pdf
Download all
3/8/13
Outlook Print Message
proof of insurance and registration

Affidavit/Declaration and supporting
documentation
Sent: Mon 1/09/12 5:58 PM
To: renomunirecords@reno.gov; renodirect@reno.gov
1 attachment
Zach Coughlin license plate 838NER proof of insurance and
registration for citations 544281 and r47190389731.pdf (1737.4 KB)
Dear Reno Municipal Court Clerk's Office,
My name is Zachary B. Coughlin.

My vehicle and myself were appropriately insured, as verified by
the attached Proof of Insurance for my USAA automobile
insurance at the time of both Traffic Citations No's: 544281 and
R47190389731. Copies of both citations are attached as well. My
vehicle, at the time of both citations, was in compliance with
Nevada law with regard to vehicle registration. A true and correct
copy of this Affidavit and the attached copies of Traffic Citations
https://bay158.mail.live.com/mail/PrintMessages.aspx?cpids=20e40c14-2d33-49ae-9ca5-aed385e88cb2,m&isSafe=false&FolderID=66666666-6666-6666-6666-
1/4
3/8/13
No's: 544281 and R47190389731 and a true and correct copy of

the Proof of Insurance for the time of both citations from my
USAA automobile insurance (Policy Number 0098527 96C 7104 3)
and a true copy of my DMV automobile Registration Certificate for
both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this
Declaration under penalty of perjury pursuant to NRS 199.145.
Please find attached a 6 page pdf with this Affidavit/Declaration

and the accompanying copies of the two citations and the proof of
insurance at the time and date of both citations and the same for
the registration for the vehicle. I am disputing the "failure to come
to a complete stop" part of the citation in 544281 and
understanding that I have a hearing in Reno Municipal Court on 2 6
12 at 8:30 am in that regard, please correct me if that is not the
correct date and time.
2/4
3/8/13
Also, I have called several times and keeping leaving messages

about disputing the following parking tickets, and do not believe
any "additional fines" should have attached to the base fine where I
have communicated that I am disputing them and have not receive
a response with regard to the date and time of my hearing to
dispute them:
Citation Details
Citation Number: 020146724
Amount Due: $60.00
Issue Date:
12/03/2011 10:30:00
Plate Number: 838NER
State:
NV
Related Citations
We have found the following additional outstanding
citations for this license plate number. Please check the box
next to each additional citation that you would like to pay
for at this time.
Citation
Number
Issue Date
Amount
Due
11/03/2011
3/4
3/8/13
020145322
03:20:00
$55.00
Sincerely,
Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
** Notice ** T his message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 25102521, and may contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an
agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that
any review, dissemination, copying, or the taking of any action based on the contents of this information is strictly prohibited. This
message is confidential, intended only for the named recipient(s) and may contain information that is privileged,
attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are
notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on the contents
of this information is prohibited and may be unlawful. If you receive this message in error, or are not the named
recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in any form
immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work product,
or other applicable privilege.
4/4
F I LED
Electronically
01-09-2013:05:08:52 PM
Joey Orduna Hastings
Clerk of the Court
Transaction # 3453849
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IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
IN AND FOR THE COUNTY OF WASHOE
***
THE STATE OF NEVADA,
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Plaintiff,
Case No.:
Dept. No.:
vs.
CR12-2025
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ZACH COUGHLIN,
Defendant.
--------/
ORDER GRANTING IN FORMA PAUPERIS
Upon consideration of Defendant's December 19, 2012 Application to Proceed In
Forma Pauperis, this Court believes that Defendant does not have sufficient income,
property or resources with which to commence and maintain the action. Pursuant to
Nevada Supreme Court's Order ADKT No.4H, a person will be deemed indigent who is
unable, without substantial hardship to himself or his dependents, to obtain competent
qualified legal counsel on his own. The Court finds that pursuant to NRS 171.188,
defendant has insufficient assets and/or Income to proceed absent a grant of forma
pauperis status. Accordingly, this Motion is granted.
NOW, THERE FORE,
IT IS HEREBY ORDERED that pursuant to NRS 171.188
defendant is granted leave to proceed in forma pauperis.
IT IS FURTHER ORDERED that the Court allow defendant to bring such action
without costs and file or issue any necessary writ, process, pleading or paper without
-1-
charge, with the exception of jury fees.

IT IS FURTHER ORDERED that the Sheriff or any other appropriate officer within
the state make personal service of any necessary writ, process, pleading or paper without
charge for defendant.
IT IS FINALLY ORDERED that the preparation of the transcript be provided at the
public's expense.
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DATED this
L day of January 2013.
District Judge
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-2-
CERTIFICATE OF MAILING
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I hereby certify that I electronically flied the foregoing with the Clerk of the Court by
using the ECF system which served the following parties electronically:
ZACH YOUNG, ESQ. for STATE OF NEVADA

I certify that I am an employee of the Second Judicial District Court of the State of
Nevada, in and for the County of Washoe, and that on this date I deposited for mailing a
copy of the foregoing document addressed to:
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Zach cou
lin
1471 E. 9 Street
Reno, NV 89512
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DATED this
_q-+-_ day of January, 2013.
&;.o&
HEIDIHO
Judicial Assistant
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-3-
02/15/2005
17:32
MUJAHID RA5UL MD
7753224747
1699 SOuTH VIRGINIA STRE:ET SUIT!;: :201

(775) 322-<1666
PAGE
RENO, NEVADA 89502
FAX (7715) 322-<17<17
February 15,2006
RE:
Zach. Coughlin
To Whom It May Concern,
This letter is to certify that Zach Coughlin has been ulider my care since April 12,
2004. He is diagnosed as having Major Depressive Disorder and Attention
Deficit/Hyperactivity Disorder and is currently on Adderall XR 20mg and
Wellbutrin XL 300mg . He is well maintained and dOAs not abuse his
medications_ If you have any further questions, please contact the office.
Sincerely,
'
J2-
Mujahid Rasul, M.D.
02
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Document Code:
Zach Coughlin
Nevada Bar No: 9473
1422 E. 9th St. #2
Reno, NV 89512
Tele: 775-338-8118
Fax: 949-667-7402
Attorney for Pro Se Attorney Plaintiff Denied Sixth Amendment Right to Counsel
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IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

IN AND FOR THE COUNTY OF WASHOE
CITY OF RENO;
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PLAINTIFF,
vs.
ZACH COUGHLIN;
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DEFENDANT.
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) Case No: 11 CR 22176
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) Dept No: 4
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MOTION TO SET ASIDE ORDER OF JUDGMENT AND CONVICTION AND SUMMARY

CONTEMPT ORDER AND NOTICE OF INSUFFICIENCY OF SERVICE OF BOTH; AND
NOTICE OF APPEAL OF SUMMARY CONTEMPT ORDER AND ORDER OF
DECEMBER 16TH 2011; and MOTION FOR RECUSAL OF JUDGE HOWARD; NOTICE
OF INSUFFICIENTY OF RECORD ON APPEAL
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COMES NOW, Plaintiff, Zach Coughlin, by and through himself as he was denied his Sixth
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Amendment Right To Counsel (mentioned quite clearly in the 2008 Limited Jurisdiction Court's
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Bench Book for Nevada Judges, along with the 2010 Supplement thereto), and files this Motion To
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Set Aside Judge Howard December 16, 2011 Order (see attached Exhibit 1). s pled in that
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alternative as a ; or in the alternative Opposition to Motion to Dismiss, however the filing office
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routinely rejects anything Plaintiff so files as violative of WDCR 10, even where the phrase pled in
the alternative is placed in the caption or name of the filing...
- 1 MOTION TO SET ASIDE ORDER AND NOTICE OF APPEAL OF SUMMARY CONTEMPT ORDER; and MOTION FOR RECUSAL OF JUDGE HOWARD;
NOTICE OF INSUFFICIENTY OF RECORD ON APPEAL
LEGAL ARGUMENT
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Argersinger v. Hamlin (407 U.S. 25) establishes that the right to the assistance of counsel,
whether retained or court appointed, is required in all prosecutions which may result in
imprisonment, unless a complete Faretta canvas has been completed and the request for waiving
counsel is granted.
While there is a time and place, perhaps for Orders finding Summary Contempt under NRS
22.030...perhaps, the greatest strength a judge can demonstrate is the ability to show a little weakness,
to demonstrate something other than ruling with an iron hand, to do something other than crush any
voice of dissent in his court room like Mike Singletary (former linebacker for the Chicago Bears in
the 1980's) would crush a running back going through the A gap. To strangle out of litigants the
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freedom to zealously adovocate on their own or another's behalf (in the case of licensed attorneys) is
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perhaps the most heinous, sad, and ugly thing a judge could do. A judge whom demonstrates an
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ability to oversee that which makes him less than comfortable in his courtroom, that which he does
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not necessarily agree with, is a judge secure in his abilities and aware of the premium on restraint and
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patience called for in order for a judge and court to transcend from mere debt collector for the City
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Attorney to impartial arbiter of fact and law. To demonstrate otherwise may create an atmosphere
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where court employees overstep their bounds and begin to bully and harass those seeking to access
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justice, a true violation of the trust in which the public endows such public servants.
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Now, apparently, Interim Court Administrator Cassandra Jackson is seeking to impart orders
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upon litigants carrying color of law by emailing them with her interpretation of what an Order
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purports to require, even where that Order rules on matters beyond the jurisdiction of the Judge and
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or Court making the Order. That is the case here. Ms. Jackson sent the undersigned an email on or
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about January 10th, 2012 that impermissibly seeks to impose upon a litigant, and an attorney, a
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restriction that would violate the 14th Amendment's Equal Protection class and further make unduly
burdensome upon the undersigned the right to file papers with the Reno Municipal Court. The
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undersigned should not be assigned a different set of rules for filing documents than the far better
funded Reno City Attorney's Office is.
RMCR Rule 3: Authorization to Represent Attorneys representing defendants shall
promptly serve written notice of their appearance with the City Attorney and file the
same with the Court. An attorney desiring to withdraw from a case shall file a motion
with the court and serve the City Attorney with the same. The court may rule on the
motion or set a hearing. RMCR Rule 5: Motions by Facsimile A. All rules and
procedures that apply to motions filed in person at the court shall also apply to motions
filed by facsimile, except as otherwise specified in this rule. B. All persons are eligible
to use motion-by-facsimile procedures. C. All motions filed by facsimile must be
accompanied by a cover sheet which must include the persons name, address, fax
number and telephone number. D. All facsimile motions filed by an attorney must
include the attorney's name, the firms name, address, fax number and telephone
number. In addition, the attorneys state bar number must be conspicuously displayed
on the cover sheet. E. All motions filed by facsimile must be accompanied by proof of
service.
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Wheres Defendant went to great lengths to demonstrate to Judge Howard and the RMC that
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he is indigent, he, apparently, is not allowed to be so, so much so that this Court went against the
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Nevada Court of Limited Jurisdiction Bench Book of 2008 and its 2010 Supplement in denying the
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undersigned the his Sixth Amendment Right To Counsel, set forth explicitly in several locations in
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the Bench Book and mandatory authority in the United States. Argersinger v. Hamlin, (407 U.S. 25).
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Nevada NRCP 60(b)(3) allows a party to move for relief from a judgment which is void, and
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while motions made under NRCP 60(b) are generally required to "be made within a reasonable time"
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and to be adjudicated according to the district court's discretion, this is not true in the case of a void
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judgment. Necessarily a motion under this part of the rule differs markedly from motions under the
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other clauses of Rule 60(b). There is no question of discretion on the part of the court when a motion
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is made under [this portion of the Rule]. Nor is there any requirement, as there usually is when
default judgments are attacked under Rule 60(b), that the moving party show that he has a
meritorious defense. Either a judgment is void or it is valid. Determining which it is may well present
a difficult question, but when that question is resolved, the court must act accordingly. By the same
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token, there is no time limit on an attack on a judgment as void. . . . [E]ven the requirement that the
motion be made within a "reasonable time," which seems literally to apply . . . cannot be enforced
with regard to this class of motion. Understandably, the parties were not attuned to our recent Jacobs
decision during oral argument. Accordingly, it was determined at that time to allow the parties to
supplement their briefs in order to determine with certainty whether, in fact, no default had been
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entered against Garcia prior to the entry of the default judgment. Garcia's supplemental material
supplied additional evidence that no default was ever entered, including an affidavit by Clark County
Court Clerk Loretta Bowman attesting that no such filing exists in the case file. Respondents also
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acknowledged that no default was ever entered but argue in their supplemental brief that Jacobs
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should not be applied retroactively, noting that the default judgment at issue herein was entered prior
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to our Jacobs decision. This argument is without merit. The court in Jacobs determined, consistent
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with law from other jurisdictions, that the default judgment entered in Jacobs was void. We
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accordingly ordered the district court to grant relief from the void judgment, despite the fact that the
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ruling in Jacobs was, of course, preceded by entry of the default judgment against Jacobs. If this case,
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rather than Jacobs, were before us as a case of first impression, we would have reached the same
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conclusion. A void judgment is void for all purposes and may not be given life under a theory based
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upon lack of legal precedent. Garcia v. Ideal Supply Co., 110 Nev. 493, 874 P.2d 752 (Nev.
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5/19/1994). The defective service rendered the district court's personal jurisdiction over Gassett
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invalid and the judgment against her void. For a judgment to be void, there must be a defect in the
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court's authority to enter judgment through either lack of personal jurisdiction or jurisdiction over
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subject matter in the suit. Puphal v. Puphal, 669 P.2d 191 (Idaho 1983). In Price v. Dunn, 106 Nev.
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100, 787 P.2d 785 (1990). We now hold that the filing of a motion to set aside a void judgment
previously entered against the movant shall not constitute a general appearance. See, e.g., Dobson v.
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Dobson, 108 Nev. 346, 349, 830 P.2d 1336, 1338 (1992). Nonetheless, since the order was void, a
judgment based thereon would likewise be void.. Nelson v. Sierra Constr. Corp., 77 Nev. 334, 364
P.2d 402. Under NRCP 60(b) a motion to set aside a void judgment is not restricted to the six months'
period specified in the rule. NRCP 54(a) provides that the word "judgment" as used in these rules
includes any order from which an appeal lies. Therefore there is no merit to appellants' contention
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that the motion to vacate the judgment was not timely made. Foster v. Lewis, 78 Nev. 330, 372 P.2d
679 (Nev. 6/19/1962). A void judgment is subject to collateral attack; a judgment is void if the
issuing court lacked personal jurisdiction or subject matter jurisdiction; See 49 C.J.S. Judgments
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401, at 792 (1947 & supp. 1991); 46 Am.Jur.2d Judgments 621-56 (1969 & supp. 1991).
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Judge Howards December 16th, 2011 Order rules on matters outside Judge Howards
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jurisdiction and is therefore void for lack of jurisdiction. Further, it is impermissible for the RMC's
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Cassandra Jackson to attempt to rewrite RMC Rules (and it is not clear whethe she is doing this on
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her own accord or if she has been instructed to do so as Judge Gardner's Administrative Assistant or
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as the Interim Court Administrator, or in some other capacity). Further, it is inappropriate for
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Jackson to be copying Reno City Attorney (and very recent former coworker of RMC's Judge
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Gardner) and Robert Puentes (who recently asked to be granted a Motion to Withdraw from
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representing the undersigned because doing so actually required him to do some legal work, and that
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was hard for him) on her correspondence, which related to a filing in a traffic citation for which
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MR. Puentes has absolutely no connection and where Mr. Wong had not yet made an appearance.
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Mr. Wong did express a complete lack of concern to the undersigned when it was reported to him that
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a RPD Officer, Chris Carter, had admitted to the undersigned that the opposing counsel in RJC
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REV2011-001708 summary eviction from a commercial tenancy law office where non payment of
rent was not alleged (in violation of NRS 40.253's express dictate against such actions) had paid
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money to RPD Officer Carter to arrest the undersigned (a bribe). Mr. Wong indicated a complete
lack of consternation in this regard and expressed that he intended to conduct zero follow up with
respect to that troubling breach of the public trust, even though, as a Reno City Attorney, Mr. Wong
likely has a duty to do so and his failure to will augur strongly toward a finding that the Reno City
Attorney is liable for any RPD misconduct on a negligent hiring, training, and supervision claim and
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that the Reno City Attorney is aware of and, in fact, ratifies or endorses such bribe taking by the RPD
from Richard G. Hill, Esq, opposing counsel in that RJC eviction matter.
Under federal law, as well as the law of some states, the misbehavior that permits summary
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action must in addition present an imminent threat to the administration of justice; it must
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immediately imperil the judge in the performance of his or her judicial duty or constitute an actual
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obstruction of justice. U.S. v. Turner, 812 F.2d 1552 (11th Cir. 1987) (attorney's posing of single
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question to witness about race of certain individuals, though in clear violation of verbal court order,
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did not so obstruct justice as to enable court to resort to summary procedure for contempt under
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Federal Rule of Criminal Procedure 42(b)); In re Holloway, 995 F.2d 1080 (D.C. Cir. 1993) (attorney
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pursued lines of questioning ruled out by judge).Witness's refusal to answer questions the court
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orders him to answer is contumacious conduct which may subject witness to summary punishment
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for criminal contempt under Direct contempt justifying summary disposition is confined to
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exceptional circumstances involving acts threatening the judge, disrupting the hearing, or obstructing
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court proceedings. Rule 42. In re Boyden, 675 F.2d 643 (5th Cir. 1982). Because summary contempt
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procedure fills a need for the immediate penal vindication of the dignity of the court, its application is
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confined to unusual situations where the court's instant action is necessary to protect the judicial
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institution itself. In re Gustafson, 619 F.2d 1354, 58 A.L.R. Fed. 1 (9th Cir. 1980), on reh'g, 650 F.2d
1017 (9th Cir. 1981).
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NRS 22. 030. Summary punishment of contempt committed in immediate view and
presence of court; affidavit or statement to be filed when contempt committed outside
immediate view and presence of court; disqualification of judge:
1. If a contempt is committed in the immediate view and presence of the court or judge at
chambers, the contempt may be punished summarily. If the court or judge summarily punishes
a person for a contempt pursuant to this subsection, the court or judge shall enter an order
that:
(a) Recites the facts constituting the contempt in the immediate view and presence of the court
or judge;
(b) Finds the person guilty of the contempt; and
(c) Prescribes the punishment for the contempt...
154 ALR 1227, Necessity and Sufficiency of Making and Recording Subsidiary or Detailed
Findings Supporting Adjudication of Direct Contempt.
Statute providing that in all cases of contempt arising without immediate view and presence of
court, judge of court in whose contempt defendant is alleged to be, shall not preside at such
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trial over objection of defendant, is constitutional. N.C.L.1929, 8943. McCormick v. Sixth
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Judicial Dist. Court in and for Humboldt County, 1950, 218 P.2d 939, 67 Nev. 318. Contempt
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For purposes of statute governing summary contempt proceedings for direct contempt committed
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in judge's presence, which requires court to enter an order, while a trial court's oral
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contempt order is immediately enforceable, a written order including the statute's required elements
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must be promptly entered. Houston v. Eighth Judicial Dist. Court ex rel. County of
Clark, 2006, 135 P.3d 1269, 122 Nev. 544.
Appropriate remedy for attorney who had been found in direct contempt of court in divorce
proceeding in which he represented wife, where contempt order had been found to be insufficient
by Supreme Court, in that it did not contain a sufficient statement concerning what conduct
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was held to be contemptuous, was to permit trial court to enter amended order, given that
Supreme Court's opinion addressed issue of first impression and announced standard for contents
of written contempt order. Houston v. Eighth Judicial Dist. Court ex rel. County of
Clark, 2006, 135 P.3d 1269, 122 Nev. 544.
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Judge Howard Summary Contempt Order relies in part on "continuing lines of inquiry after
told by the Court not to do so..." however any such alleged instances of this are explained away by
the fact that any such questions where not posed to prove the truth of the matter asserted but rather
for other permissible purposes (and this was pointed out to the Court at trial). Further, for Judge
Howard to rule that it is not relevant whether Wal-Mart's Asset Protection team had verbally
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threatened the accused or otherwise indicated they would retaliate against him for filming a
documentary related to Wal-Mart's continual practice of lying to customers about their Return Policy
and selectively enforcing it, despite its terms being part of a contract between the retailer and
consumers, it plain error.
A written summary contempt order, issued pursuant to statute governing summary contempt
proceedings for direct contempt committed in judge's presence, must set forth specific facts
concerning the conduct found to be contemptuous. Houston v. Eighth Judicial Dist. Court ex rel.
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County of Clark, 2006, 135 P.3d 1269, 122 Nev. 544. Judge Howards Order is of the "check the box"
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variety, on a preprinted form, seemingly taken from the Bench Book, containing mere conclusory and
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circular statements about the purported contempt and in no way satisfies the above standard. Indeed,
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Judge Howard does not specify what "lines of inquiry" were continued, nor is it clear how a pro se
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defendant denied his Sixth Amendment Right To Counsel could reasonably know what is required of
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him to comply with Judge Howards vague and menacing contempt pronoucements while also
zealously advocating on the defendant's behalf.
Written summary contempt order finding attorney for wife in divorce proceeding in direct
contempt of court failed to indicate what particular comments by attorney were held to be
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contemptuous, and, thus, order was insufficient, under statute governing summary contempt
proceedings for direct contempt committed in judge's presence. Houston v. Eighth Judicial Dist.
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Court ex rel. County of Clark, 2006, 135 P.3d 1269, 122 Nev. 544.
Other than indicating the defendant said Wow, Judge Howard's Order does little to comply
with the above standard. Further, Judge Howard makes allegations of laughter, however, and this
goes to the evident impartiality/Motion for Recusal, Judge Howard seemed to go to great lengths to
strike from the record the fact that Thomas Frontino, Wal-Mart Asset Protection Associate and
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witness for the City of Reno, was continually smirking and laughing on the stand, particularly while
he was committing perjury. Judge Howard makes no specific indication as to what the undersigned
supposedly laughed about, or at what time of the proceeding (the audio of which is recorded and
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preserved by the RMC's For The Record system). Even if laughter was present, it is not per se
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contemptuous and Judge Howard does not make clear how his attempt to prohibit such allows for a
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defendant to zealously advocate on his own behalf, or whether it is ever permissible, or even a skillful
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trial tactic, for a litigant to engage in laughter. Really, what Judge Howard seems to want the most
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is for those defendants that he wishes to find guilty to lay down and die a death of sorts in his
courtroom, and to thank the RMC for its wise crypt-keeping.
Regardless, with respect to Judge Howard's, December 16, 2011 Order, it attempts to rule on
matters far beyond the jurisdiction accorded to Judge Howard. The email address
renomunirecords@reno.gov is held out to the public in a number of instances. See, Exhibit 1:
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January 10th, 2012 email from RMC Interim Court Administrator Cassandra Jackson with Attached
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December 16th, 2011 Order of Judge Howard. The Order reads: Defendant Coughlin forwarded a
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communication to Judge Howard's personal electronic mail account. Defendant Coughlin is warned
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that he must ccase and desist furthcr e-mail communication with Judge Howard, his stalTor any other
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employee of the Reno Municipal Court. However, it is not clear at all that that email address is a
personal email address. The email address gateway is that of one belonging to the City of Reno,
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not to a private citizen, and therefore it can hardly be said to be a personal email address, like
Hotmail, or Gmail address. It is an email address provided to a public servant, an elected or
appointed official, to be used in the course of official business and held out to the public as a valid
means for contacting that official. How an email is any different than a fax is something not at all
clear. Both means of correspondence convert the communication to a series of 1's and 0's for the
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purpose of transmitting date in a digital form. To hold these means of communication are
fundamentally different, is a distinction without a difference and arbitary and capricious. To required
litigants to accept such pronouncements where they are not supported by sound rationale or policy is
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to engage in tyranny, something for which the American public has never had much of a taste.
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The December 16th, 2011 Order goes on to hold that: IT IS HEREBY ORDERED that
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Defendant Coughlin shall not communicate via email with Judge Howard, his staff or any other
employee of the Reno Municipal Court. First, It is not clear whether a transcriptionist recommended
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or required by the RMC is a RMC employee. It is not clear is Marshal Roper is an RMC
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employee, or an employee of Washoe County, or the City of Reno. To be a valid Order such that a
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Contempt Order may issue from a violation of it requires that the Order be sufficiently detailed and
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clear such that one could be reasonably said to have an understanding of what is required of him to
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comply with it. The undersigned seeks clarification of the Order in this regard. Further, the Order
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does not contain any language purporting to make inapplicable to the undersigned the right enjoyed
by all other litigants before the RMC, ie, that contained in RMCR 5:
RMCR Rule 5: Motions by Facsimile A. All rules and procedures that apply to
motions filed in person at the court shall also apply to motions filed by facsimile,
except as otherwise specified in this rule. B. All persons are eligible to use motionby-facsimile procedures. C. All motions filed by facsimile must be accompanied by
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a cover sheet which must include the persons name, address, fax number and
telephone number. D. All facsimile motions filed by an attorney must include the
attorney's name, the firms name, address, fax number and telephone number. In
addition, the attorneys state bar number must be conspicuously displayed on the
cover sheet. E. All motions filed by facsimile must be accompanied by proof of
service.
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The undersigned is indigent. That might be hard for a public official making $180,000 a year
after benefits to conceptualize, but what it means it that requiring him to take an hour out of his work
day every time he wants to file something with the RMC is unduly burdensome, particularly where
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the Reno City Attorney acting as opposing counsel is not under a similar directive (and where that
Reno City Attorney making well over $100,000 after benefits are considered as well). It seems the
Court understands this, and that is why only email was expressly prohibited in the Order. Further, the
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Order would seem to be wisely curtailed to only matters relating to the case in which is was rendered.
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Yet, Ms. Jackson's email seems to capitulate and extend upon Judge Howard's Order by including the
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dicate that the undersigned cease partaking in the filing by facsimile expressly allowed by RMCR 5,
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and further, RMC Interim Court Administrator Jackson seeks to add to the Order and extend its
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already overbroad reach. In doing so, Jackson is engaging in impermissible conduct similar to that
19
exhibited earlier in this matter by Judge Howard's Judicial Assistant Veronica Lopez. Ms. Lopez
20
refused to provide a copy of the Judgement and Order of Conviction in 11 CR 22176 to Coughlin
21
(actually she lied to Coughlin saying she would fax him a copy of it (though she never did) after
22
berating Coughlin for losing him chance to get a copy at the conclusion of the 11/30/11 Trial when
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RMC Marshals demanded the undersigned sign some documents prior to having a chance to review
25
them, whereupon these Marshals angrily took away the documents, smirking about how they would
26
just put that you refused to accept the service thereof. However, upon being release from what may
27
well be the one and only time (hopefully ever, past or future) that an attorney in this state, or any
28
other, was summarily forced to spend three days in incarceration is is clear from jail property records
that Coughlin was not provided any copy of any Judgement of Conviction or Order from the
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November 30th, 2011 Trial in the RMC. Clearly, if the undersigned is in handcuffs, it is not for the
undersigned to decide whether or not a piece of paper will travel with him to jail and be there when
he is released. The RMC's conduct in subsequently refusing to provide or otherwise served a copy of
that Order is extremely troubling and reflects poorly upon the RMC. The same can be said for the
some extremely long time it took the RMC to provide the undersigned with an audio copy of the
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recording of the Trial and the indications RMC filing office staff gave the undersigned at first that he
would not be afforeded any access to such an recording, but rather, that he could pay some exorbinant
some to have one particular court reporter or transcriptionist favored by the RMC (Pam Longioni) to
13
transcribe the recordings. Ms. Longioni, while driving and talking on the phone, actually hung up on
14
the undersigned when his answers to her attempts to cross examine him with regard to when he filed
15
his Notice of Appeal and when he was served this or that were not met with her approval. Longioni
16
subsequently failed to return any phone calls or written correspondence from the udnersigned.
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During this three day incarceration was denied a single phone call or tier time by Sheriff's
19
Deputies, resulting in much prejudice to his client's cases, for which Judge Howard indicated he was
20
saddened, though he failed to allow for any measures to be taken to avoid such prejudice occurring
21
to those who vote on whether or not he will be reelected, should he run opposed next time, in contrast
22
to his last election) for saying Wow amidst saying Yes, Sir, and Your Honor about four
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hundred times throughout the course of a six hour trial, the denouement of which was apparently
25
important enough to keep upwards of six court employees working until approximately 9 pm at night,
26
receiving overtime wages in the process as a time in which the economy of Reno is markedly
27
challenged and the budget of the Reno Municipal court is such that it has taken to laying off Court
28
staff and cutting their pay (though elected officials are exempt from such measures) in addition to
curtailing the hours the Court is open to the public on Fridays to half a day.
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It is instructive to compare Jackson's interpretation of the Judge Howard's Order, and to

consider to extent to which she may be acting in a judicial capacity (unless this Court will provide
some indication of whether Jackson's email was done at the behest of any of the RMC Judges).
Whereas Judge Howards 12/16/11 Order holds: IT IS HEREBY ORDERED that Defendant
Coughlin shall not communicate via cmail with Judge Howard, his staff or any other employee of
the Reno Municipal Court, Jackson's 1/10/12 email to Coughlin extends the reach of that Order,
directing Coughlin thus: "I have been informed that you continue to contact Reno Municipal Court
staff and attempt to file documents via e-mail. This is in violation of the Order issued by Judge
13
Howard on December 16, 2011, which prohibits you from contacting Reno Municipal Court staff
14
via e-mail (see attached). Any correspondence you wish the court to consider and any documents
15
that you wish to file with the court must be filed through the Reno Municipal Court Clerk's
16
Office, via U.S. mail, messenger service or in person.
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18
First, Judge Howard's Order indicates that it applies to Defendant Coughlin, not citizen
19
Coughlin. Thus, it does not apply to actions taken by Coughlin not within the scope of his
20
appearance as Defendant Coughlin within that one particular matter 11 CR 22176. If citizen
21
Coughlin wants to file something related to a traffic citation, Judge Howard's December 16, 2011
22
Order has not application. For Jackson to rule otherwise indicates she lacks an appreciation for the
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judicial skill and temperance Judge Howard has developed since taking the bench in 1998. While
25
someone without Judge Howard's acumen and expertise may purport to rule on matters far afield
26
from the jurisdiction the law has vested them with, Judge Howard would not, I believe, as he takes
27
the trust the citizens of Nevada have bestowed upon him far to seriously to so recklessly exceed the
28
scope of that jurisdiction. The employees of the RMC (including Marshal Mentzel, Veronica Lopez,
and Cassandra Jackson) need to stop embarrassing the RMC Judges, with the abusive, overreaching
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approach they take to carrying out their duties and in relating to the public. While their behavior may
be completely acceptable in the private sector, they have a hire calling in being public servants
working in a court of law, where the equal and measured dispensation of justice must be delivered in
a manner that, at all times, comports with traditional notices of due process and substantial justice.
The undersigned was given express permission by RMC Filing Officer Supervisor Donna
Ballard to file documents by email This was requested in light of the undersigned belief that filing by
fax may unnecessarily tax the RMC's fax machine and or line. Further, Judge Howards 12/16/11
Order only purports to rule on the propriety of Coughlin's attempts to communicate via cmail with
13
Judge Howard, his staff or any other employee of the Reno Municipal Court. It does not (as
14
Jackson's email purports to interpet that Order to rule) that any documents that you wish to file with
15
the court must be filed through the Reno Municipal Court Clerk's Office, via U.S. mail,
16
messenger service or in person. An attempt to communicate is different from an attempt to file a
17
18
document with the court. Further, communicating with Judge Howard, his staff or any other
19
employee of the Reno Municipal Court is different than communicating something to or filing
20
something with a general email address, RenoMuniRecords@Reno.gov, that is not attached
21
specifically to Judge Howard, his staff, or any other employee (in the way Judge Howard mentions
22
his own email address as his personal email address), which is held out to the public in numerous
23
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settings as the way to contact the Reno Municipal Court or City of Reno (included amongst these is
25
the method for requesting records from the City of Reno, and the Reno City Attorney's Office, not
26
just the Reno Municipal Court). In so attempting to extend Judge Howard's Order, Jackson
27
impermissibly attempts to assert an unequal application of RMCR 5 upon Coughlin, a deprivation of
28
equal protection and due process under the law that could arguably get the RMC and Jackson herself
held personally liable for violations of the undersigned's civil rights. However, the City of Reno will
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be liable if there is a custom and policy in place that encourages constitutional violations and that
policy is the standard operating procedure of the Reno Municipal Court or where the RMC had
knowledge of Jackson's deprivation of Coughlin's civil rights or otherwise engaged in negligent
hiring, training, and supervision of employees such a Jackson with respect to such deprviations.
Likewise, with the Washoe County Sheriff's Office and the County. See Gillette v. Delmore, 979 F.2s
1342, 1347 (9th Cir.1992).
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Motivational inspiration for the RMC and Mentzel, Lopez, and Jackson can be found in
Lippis v. Peters, 112 Nev. 1008, 921 P.2d 1248 (1996):
The judgment awarding fees in this case imposes upon two justices' courts and seven
justices of the peace an obligation to pay to the tenants' attorneys the sum of
$18,693.50. This judgment does present a problem when we start to think about how
these public officials and two courts of law might go about allocating the obligation of
$18,693.50. It would not appear that the courts themselves are subject to execution
process; and, therefore, the fee, if it were going to be paid, would have to be paid by
the individual justices, who would have to pay, if the matter were handled fairly,
$2,670.50 each. The justices' judgment obligation to pay attorneys' fees is based (1) on
their having followed a procedural rule (JCRCP 106) enacted by this court and (2) on
their having made several erroneous judicial decisions. We hesitate to get into the
thorny problems presented by this judgment, problems relating to execution upon
public property, relating to official immunity and judicial immunity and some other
similar problems that attend the enforcement of such a judgment... Lippis v. Peters,
112 Nev. 1008, 921 P.2d 1248 (1996): In their action challenging justice courts'
practice of denying appeals to district court in summary eviction actions, tenants did
not allege that they were deprived of federal rights, and therefore they could not claim
attorney fees under federal civil rights statute. 42 U.S.C.A. 1983, 1988.
Defendant may ultimately be forced to be so alleging such a deprivation and or claim such
26
attorney's fees; See, also, Cheung v. Eighth Judicial Dist. Court ex rel. County of Clark, 124 P.3d
27
550, 552, 121 Nev. 867, 869 (2005); Schneider v. Elko County Sheriff's Dept., 17 F.Supp.2d 1162,
28
1165 (1998); G.C. Wallace, Inc. v. Eighth Judicial Dist. Court of State, ex rel. County of Clark, 262
P.3d 1135, 1140+, 127 Nev. Adv. Op. 64, 64+ (2011).
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Ms. Ballard actually agreed with this assessment and thanked the undersigned for the
consideration demonstrated. To the extent Judge Howard does not wish for the undersigned to file
(as opposed to just communicate) by email (and its not clear that the Order purports to rule on
situations outside of the case in which it was made, despite the implication's of Jackson's email), the
undersigned will, of course, respectfully comply with that dictate, especially to the extent that it is not
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expressly permitted by RMC Rules (though the distinction between facsimile and email is not always
the clearest and where facsimile seems to disadvantage those without the budget to have a separate
phone line to run a fax machine, etc.). However, the Record on Appeal in this matter is deficient in
13
several respects and the undersigned asks that it be corrected. To wit, prior to such time as the
14
express permission to so file by email could reasonably be said to have been withdrawn, the
15
undersigned file numerous documents with the RMC. However, not all of those are reflected in the
16
Record on Appeal Further, in that Record, the four pages per page attachments to the 12/13/11
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18
filing are illegible, though the undersigned file a completely legible one page per page version via
19
email with the RMC and feels that that legible version should be included in the Record on Appeal.
20
The four page per page version was filed in hard copy (on top of the same being filed the night
21
before via email) in an abundance of caution given the importance of the filing (a, perhaps,
22
jurisdictional Notice of Appeal, and should the permission to file by email not be honored, the
23
24
undersigned would have been severely prejudiced....) The undersigned filed the four page per page
25
version of the Exhibits to that 12/12/11 filing in that form because he lack the money to buy the paper
26
and ink necessary to print those voluminous attachments out in the one page per page style that would
27
have been preferable. Exhibit 5: All emails from ZachCoughlin@hotmail.com to
28
RenoMuniRecords@Reno.gov from 10/4/11 to present; citing to attached pdf filings that should be
included in the Record on Appeal, yet are not in some instances.
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Appealability of contempt adjudication or conviction. 33 A.L.R.3d 448 (Originally published in

1970); 12[a] GenerallyRule of appealability [Cumulative Supplement] Contempt proceedings
not characterized as criminal or civil have frequently been held or recognized to be appealable in the
absence of statutes other than those generally making final decisions appealable.US In re Ryan, 538
F.2d 435, 76 2 U.S. Tax Cas. (CCH) P 9518, 38 A.F.T.R.2d 5452 (D.C. Cir. 1976) Ala Uhls v Uhls
9
10
11
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(1989, Ala App) 551 So 2d 1065 Ex parte Boykin (1994, Ala Civ App) 656 So 2d 821 Alaska
Gillette v Coffer (1912) 4 Alaska 622 (recognizing rule) Cal LaBella v Kaiser Foundation Health
Plan, Inc. (1977) 72 Cal App 3d 499, 138 Cal Rptr 212 For California cases, see 16, infra Colo Hill
13
v Boatright (1994, Colo App) 890 P2d 180, reh den (Sep 15, 1994) and cert gr (Feb 20, 1995) DC 33
14
A.L.R.3d 448 Page 178 33 A.L.R.3d 448 (Originally published in 1970) For District of Columbia
15
cases, see 3[a], supra Fla State ex rel. Pearson v Johnson (Fla App) 334 So 2d 54 For Florida cases,
16
see 6[a], supra Ga Manning v MNC Consumer Discount Co. (1994) 212 Ga App 824, 442 SE2d
17
18
919, 94 Fulton County D R 1442 For Georgia cases, see 15, infra Ill People ex rel. Hinckley v
19
Pirfenbrink (1879) 96 Ill 68 (recognizing rule) Ex parte Smith (1886) 117 Ill 63, 7 NE 683
20
(recognizing rule) Lester v Berkowitz (1888) 125 Ill 307, 17 NE 706 (recognizing rule) People v
21
Gilbert (1917) 281 Ill 619, 118 NE 196 Hill v Thomas B. Jeffery Co. (1920) 292 Ill 490, 127 NE 124
22
People ex rel. Andrews v Hassakis (1955) 6 Ill 2d 463, 129 NE2d 9 But see People ex rel. General
23
24
Motors Corp. v Bua (1967) 37 Ill 2d 180, 226 NE2d 6, infra. And see Illinois cases limiting review to
25
question of abuse of discretion, 13, infra. Waste Management, Inc. v International Surplus Lines
26
Ins. Co. (1991) 144 Ill 2d 178, 161 Ill Dec 774, 579 NE2d 322 Almgren v RushPresbyterianSt.
27
Luke's Medical Ctr. (1994) 162 Ill 2d 205, 205 Ill Dec 147, 642 NE2d 1264, mod and reh den (Nov
28
15, 1994) Robinson v People (1906) 129 Ill App 527 Kelly v Chicago, B. & Q. R. Co. (1919) 213 Ill
App 296 (recognizing rule) People ex rel. Rusch v Kirgis (1936) 287 Ill App 378, 4 NE2d 894
3
4
5
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Tegtmeyer v Tegtmeyer (1937) 292 Ill App 434, 11 NE2d 657 (recognizing rule) People ex rel.
Rusch v Ferro (1942) 313 Ill App 202, 39 NE2d 707 Kemeny v Skorch (1959) 22 Ill App 2d 160, 159
NE2d 489 Maywood v Jackson (1963) 42 Ill App 2d 29, 190 NE2d 593 Koch v Mettler (1964) 49 Ill
App 2d 251, 199 NE2d 417 Re October 1985 Grand Jury (1987, 1st Dist) 154 Ill App 3d 288, 107 Ill
Dec 342, 507 33 A.L.R.3d 448 Page 179 33 A.L.R.3d 448 (Originally published in 1970) NE2d 6,
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app gr (Ill) 113 Ill Dec 304, 515 NE2d 113 and vacated on other grounds (1988) 124 Ill 2d 466, 125
Ill Dec 295, 530 NE2d 453 Re Marriage of Ryan (1989, 2d Dist) 188 Ill App 3d 679, 136 Ill Dec 1,
544 NE2d 454 Testin v Dreyer Medical Clinic (1992) 238 Ill App 3d 883, 179 Ill Dec 56, 605 NE2d
13
1070, app gr 149 Ill 2d 661, 183 Ill Dec 872, 612 NE2d 524 In re Marriage of Dieter (1995, 1st Dist)
14
271 Ill App 3d 181, 207 Ill Dec 848, 648 NE2d 304 People ex rel. Hawthorne v Hamilton, 9 Ill App
15
3d 551, 292 NE2d 563 Md Droney v Droney (1995) 102 Md App 672, 651 A2d 415 Mich People ex
16
rel. Port Huron & G. R. Co. v Jones (1876) 33 Mich 303 Haines v Haines (1876) 35 Mich 138 Re
17
18
Bissell (1879) 40 Mich 63 (recognizing rule) Ross v Ross (1881) 47 Mich 185, 10 NW 193 See
19
People v Den Uyl (1949) 323 Mich 490, 35 NW2d 467. But see Michigan cases limiting review to
20
question of abuse of discretion, 13, infra. Minn For Minnesota cases, see 8[a], supra Miss For
21
Mississippi cases, see 15, infra Mo For Missouri cases, see 3[b], supra Neb Dunning v Tallman
22
(1993) 244 Neb 1, 504 NW2d 85 NY Watrous v Kearney (1880) 79 NY 496 (recognizing rule)
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Strong v Western Gas & Fuel Co. (1904) 177 NY 400, 69 NE 721 (recognizing rule) King v Ashley
25
(1904) 179 NY 281, 72 NE 106 Re Hayward (1899) 44 App Div 265, 60 NYS 636 (recognizing rule)
26
Moore v Moore (1910) 141 App Div 532, 126 NYS 412 Re Baker (1855) 11 How Pr 418
27
(recognizing rule); Re Percy (1868) 2 Daly 530 (recognizing rule); Richie v Bedell (1885, Sup) 22
28
NY Week Dig 563; Finck v Mannering (1887) 46 Hun 323; Re Anonymous (1887) 18 Abb NC 216
(recognizing rule); 33 A.L.R.3d 448 Page 180 33 A.L.R.3d 448 (Originally published in 1970)
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People ex rel. Post v Grant (1888) 13 NY Civ Proc 305, revd on merits 50 Hun 243, 3 NYS 142
(recognizing rule); Boon v McGucken (1893) 67 Hun 251, 22 NYS 424; Re De Long (1896) 25 Civ
Proc 363, 41 NYS 201; Siegel v Solomon (1905, Sup App T) 92 NYS 238 (recognizing rule).
McCredie v Senior (1834) 4 Paige 378 But see Mitchell's Case (1861) 12 Abb Pr 249. ND State v.
Zahn, 1997 ND 65, 562 N.W.2d 737 (N.D. 1997) Ohio For Ohio cases, see 15, infra Pa Scranton v
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People's Coal Co. (1922) 274 Pa 63, 117 A 673 State Grand Lodge v Morrison (1923) 277 Pa 41, 120
A 769 (recognizing rule) Re Aungst (1963) 411 Pa 595, 192 A2d 723 (recognizing rule) Re Myers &
Brei (1924) 83 Pa Super 383 Appeal of Reap (1926) 88 Pa Super 147 (recognizing rule)
13
Commonwealth v Morrisey (1942) 150 Pa Super 202, 27 A2d 446 DeMasi v DeMasi (1991, Pa
14
Super) 597 A2d 101 Commonwealth ex rel. Ziccardi v Hendricks (1964) 33 Pa D & C2d 419
15
(recognizing rule) But see Pennsylvania cases limiting review to question of abuse of discretion, 13,
16
infra. SC For South Carolina cases, see 13, infra Utah Smith v Kimball (1930) 76 Utah 350, 289 P
17
18
588, 70 ALR 101 (recognizing rule) Vt But see Vilas v Burton (1854) 27 Vt 56. Re Consolidated
19
Rendering Co. (1907) 80 Vt 55, 66 A 790, affd 207 US 541, 52 L Ed 327, 28 S Ct 178 (apparently
20
recognizing rule) Cutting v Cutting (1928) 101 Vt 381, 143 A 676 (recognizing rule) Socony Mobile
21
Oil Co. v Massena Iron & Metal Co. (1966) 125 Vt 403, 217 A2d 56 Va Street v. Street, 24 Va. App.
22
14, 480 S.E.2d 118 (1997) 33 A.L.R.3d 448 Page 181 33 A.L.R.3d 448 (Originally published in
23
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1970) For Virginia cases, see 15, infra A judgment of contempt for publishing in a newspaper an
25
article critical of the judge in a pending case was held reviewable by writ of error, in People v Gilbert
26
(1917) 281 Ill 619, 118 NE 196. The court said that while the court against which the alleged
27
contemptuous matter is published passes on the question whether or not the published matter is
28
actually contemptuous, yet the decision of that court is not conclusive: a writ of error may be sued out
to review the judgment of the lower court. An order of commitment for contempt of court for
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refusing to give a deposition was held to be a final, appealable order, in Hill v Thomas B. Jeffery Co.
(1920) 292 Ill 490, 127 NE 124. The court said that the order of commitment by the superior court
was a final judgment in the ancillary proceeding that was brought to enforce the interlocutory order
directing the plaintiff to appear and testify. While the purpose of that proceeding was connected with
and had its foundation in the main case, reasoned the court, it was a separate case prosecuted
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independently to enforce a compliance with the order of the court. The court said that whether that
order to testify was interlocutory or final was immaterial: if it was lawfully made it was the plaintiff's
duty to obey it, and a judgment either that he was guilty of contempt or that he was not was a final
13
judgment. See, however, People ex rel. General Motors Corp. v Bua (1967) 37 Ill 2d 180, 226 NE2d
14
6, where the court said that while ordinarily a contempt adjudication is a final and appealable order,
15
this rule would not be followed where, instead of the traditional fine or imprisonment as punishment
16
for contempt, the defendant held in contempt was punished by having its answer to the amended
17
18
complaint stricken and judgment entered against it. The contempt was adjudged for failure to comply
19
with pretrial discovery orders, and while the court determined that the striking of pleadings and the
20
entry of a default judgment was permissible as a sanction for the nonproduction of documents under a
21
court rule authorized by the legislature, the court held that this could not be used to render an
22
interlocutory order final and appealable by the use of contempt language. The imposition of a fine or
23
24
imprisonment as a sanction for contempt is final and appealable because it is an original special
25
proceeding, collateral to and independent of the case in which the contempt arises, explained the
26
court, but the sanction imposed in this case did not directly affect the outcome of the principal action.
27
Therefore the court concluded that since the contempt order, in effect, determined liability without a
28
determination of damages, it was not yet final and appealable. While recognizing the right to appeal,
the court in People v Den Uyl (1949) 323 Mich 490, 35 NW2d 467, in considering an appeal from
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6
one confined for contempt in refusing to answer certain questions before an examining magistrate,
ruled that the dismissal of the principal case (because the prosecution could not proceed without the
witness' testimony) abated the contempt proceeding and required the dismissal of the appeal. The
court, however, in the order dismissing the appeal, also dismissed the warrant of commitment under
which the witness was confined. A chancery decree adjudging a corporation to be in contempt of
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12
court for disobeying a court order was held appealable in Socony Mobil Oil Co. v Massena Iron &
Metal Co. (1966) 125 Vt 403, 217 A2d 56, on the authority of an earlier case[2] that differed from the
case at bar only because it originated in the County Court rather than the Court of Chancery, and that
13
was held to be properly transferred to the Supreme Court by way of a bill of exceptions. An- 33
14
A.L.R.3d 448 Page 182 33 A.L.R.3d 448 (Originally published in 1970) other case,[3] which held
15
that an appeal would not lie from the decree of the
16
chancellor in matters of contempt, was relied upon to support a motion to dismiss the appeal, but the
17
18
court, pointing out that a 1941 statute provided that causes heard in chancery pass to the Supreme
19
Court in the same manner as appeals from County Court, said that the effect of this legislation was to
20
abolish appeals in chancery as they previously existed, and to substitute the statutes applicable to
21
obtain review of County Court proceedings. Therefore, concluded the court, the Vilas Case presented
22
no obstacle to the pending appeal. CUMULATIVE SUPPLEMENT Cases: To obtain appellate
23
24
review, subpoenaed party must defy district court's enforcement order, be held in contempt, and then
25
appeal contempt order, which is regarded as final. Dynegy Midstream Services v. Trammochem, 451
26
F.3d 89 (2d Cir. 2006). Where securities trading corporation was adjudged in contempt for failing to
27
turn over tape recording as ordered by court, court had jurisdiction to review contempt order even
28
though imposition of sanctions was stayed and no sanctions were formulated prior to entry of stay. Re
Three Grand Jury Subpoenas (1988, CA2 NY) 847 F2d 1024. A district court's ruling on an
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6
application for a contempt order is reviewed for abuse of discretion. Frontier-Kemper Constructors,
Inc. v. American Rock Salt Co., 224 F. Supp. 2d 520 (W.D. N.Y. 2002). Post-judgment orders of
contempt are within an appellate court's jurisdiction as reviewable "final orders." 28 U.S.C.A. 1291.
Berne Corp. v. Government of The Virgin Islands, 570 F.3d 130 (3d Cir. 2009). Court of Appeals
had jurisdiction of defendant's appeal of contempt order, although contempt order of itself did not
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11
12
constitute a final order that could be appealed, where portion of order that included contempt finding
was complete and final. M & C Corp. v. Erwin Behr GmbH & Co., 289 Fed. Appx. 927 (6th Cir.
2008). When the disobeyed order would be independently appealable under an exception to the final-
13
decision rule, then the contempt citation also may be appealable. S.E.C. v. McNamee, 481 F.3d 451,
14
Fed. Sec. L. Rep. (CCH) P 94172 (7th Cir. 2007). Grant or denial of contempt order is reviewed for
15
abuse of discretion, but order of contempt is reviewed more searchingly. U.S. v. Teeple, 286 F.3d
16
1047, 89 A.F.T.R.2d 2002-2102 (8th Cir. 2002). Contempt adjudication issued in postjudgment phase
17
18
of civil action was appealable whether contempt was considered to be civil or criminal, since
19
adjudication possessed attributes of operativeness and consequence necessary to appealability.
20
Consumers Gas & Oil, Inc. v. Farmland Industries, Inc., 84 F.3d 367, 34 Fed. R. Serv. 3d 1550 (10th
21
Cir. 1996). Denial of motion for order to show cause why party should not be held in contempt is
22
final, appealable order. Thomas v. Blue Cross and Blue Shield Ass'n, 594 F.3d 814 (11th Cir. 2010).
23
24
A contempt order is final and appealable when the opportunity to purge the contempt has passed and
25
the position of the parties has been affected by the contempt order. Seiko Epson Corp. v. NuKote
26
Intern., Inc., 190 F.3d 1360, 52 U.S.P.Q.2d (BNA) 1011 (Fed. Cir. 1999), reh'g denied, in banc
27
suggestion declined, (Oct. 19, 1999). 33 A.L.R.3d 448 Page 183 33 A.L.R.3d 448 (Originally
28
published in 1970) A contempt order is a final, appealable order. Thelman v. State, 375 Ark. 116, 289
S.W.3d 76 (2008). Contempt judgment is reviewable final order. C.G.S.A. 5133. State v. Brescia,
3
4
5
6
123 Conn. App. 342, 1 A.3d 1145 (2010). Appellate Court will reverse a finding of contempt only if
the Court concludes the trial court abused its discretion. Dowd v. Dowd, 96 Conn. App. 75, 899 A.2d
76 (2006). Even if adjudication of contempt was considered final judgment, court was without
jurisdiction where notice of appeal was filed more than a month before sentencing. West v United
States (Dist Col App) 346 A2d 504. Order of family court in matrimonial action determining custody
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11
12
of children demanding support payments, alloting personal property and finding party in contempt for
violation of prior order was final and appealable, notwithstanding continuing jurisdiction of family
court to modify order. Cleveland v Cleveland (1977, Hawaii) 559 P2d 744. A contempt order is
13
appealable under the same circumstances as any other order or judgment entered in a civil or criminal
14
action. Callaghan v. Callaghan, 142 Idaho 185, 125 P.3d 1061 (2005). Under rule that review of
15
already issued contempt order must be by writ of review or by appeal, writ of prohibition was not
16
proper remedy by which to contest order finding divorced wife in contempt for failure to grant
17
18
visitation rights to divorced husband. Dey v Cunningham, 93 Idaho 684, 471 P2d 71. Ordinarily,
19
adjudication in contempt proceeding is final and appealable because it is original special proceeding,
20
collateral to, and independent of, case in which contempt arises, where imposition of sanction does
21
not directly affect outcome of principal action, even though such adjudication does not dispose of all
22
issues in litigation. Earles v. Earles, 287 Ill. Dec. 400, 815 N.E.2d 1203 (App. Ct. 3d Dist. 2004). It is
23
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appropriate for a party to request that a contempt order be entered against it so that party may seek
25
immediate appeal of a trial court's discovery order. Webb v. Mount Sinai Hosp. and Medical Center
26
of Chicago, Inc., 283 Ill. Dec. 185, 807 N.E.2d 1026 (App. Ct. 1st Dist. 2004). When an individual
27
appeals from a contempt sanction imposed for violating, or threatening to violate, a discovery order,
28
the contempt finding is final and appealable and presents to the reviewing court the propriety of that
discovery order. Reda v. Advocate Health Care, 199 Ill. 2d 47, 262 Ill. Dec. 394, 765 N.E.2d 1002
3
4
5
6
(2002). Judgment of contempt against law firm for violating order to withdraw appearance after firm
was disqualified from representing defendant constituted final and appealable judgment and
presented to court for review propriety of court's order, even though suggestion that law firm refuse
to withdraw came from trial judge and underlying controversy was not certified for review. Index
Futures Group, Inc. v Street (1987, 1st Dist) 163 Ill App 3d 654, 114 Ill Dec 735, 516 NE2d 890. The
9
10
11
12
Court of Appeals will reverse a trial court's finding of contempt only where there is no evidence or
inferences from the record to support it. Deel v. Deel, 909 N.E.2d 1028 (Ind. Ct. App. 2009).
Contempt judgment for violation of an order of the court regarding child visitation was final and
13
therefore appealable. Thibodeaux v. Thibodeaux, 748 So. 2d 1180 (La. Ct. App. 5th Cir. 1999). 33
14
A.L.R.3d 448 Page 184 33 A.L.R.3d 448 (Originally published in 1970) Interlocutory judgment
15
finding exwife in contempt and ordering her to pay a fine and attorney fees threatened irreparable
16
injury, and thus, direct appeal could be taken. Ducksworth v. Ducksworth, 727 So. 2d 1254 (La. Ct.
17
18
App. 4th Cir. 1999). A party found in contempt has a right to appeal from that decision even though
19
the merits of the litigation in which the contempt order was entered have not yet been resolved.
20
Morris v. Walden, 856 So. 2d 705 (Miss. Ct. App. 2003). Appellate court will not reverse a contempt
21
citation where the chancellor's findings are supported by substantial credible evidence. Goodson v.
22
Goodson, 816 So. 2d 420 (Miss. Ct. App. 2002). Although separate issues of main petition and
23
24
contempt were addressed within same judgment, each portion of judgment was separately appealable.
25
STL Capital Management, LLC v. Brda, 207 S.W.3d 649 (Mo. Ct. App. E.D. 2006). While contempt
26
orders generally are final and not appealable, exception exists for family law cases, in which appeals
27
are permitted. Heath v Heath (1995, Mont) 901 P2d 590. Although contemptofcourt orders issued
28
by District Court are final and usually unreviewable except by way of writ of certiorari or review,
exception exists for contempt orders made in dissolutionofmarriage proceedings. In re Marriage of
3
4
5
6
Boharski (1993) 257 Mont 71, 847 P2d 709. An appellate court, reviewing a final judgment or order
in a contempt proceeding, reviews for errors appearing on the record. Douglas County ex rel.
Douglas County Assessor's Office v. Kowal, 270 Neb. 982, 708 N.W.2d 668 (2006). Appellate court,
reviewing final judgment or order in contempt proceeding, reviews for errors appearing on record.
Klinginsmith v. Wichmann, 252 Neb. 889, 567 N.W.2d 172 (1997). A contempt order imposing a
9
10
11
12
punitive sanction is a final order and is reviewable on appeal. McDermott v. McDermott, 8 Neb. App.
860, 602 N.W.2d 676 (1999). Whether the trial court adhered to the requisite procedures in a criminal
contempt proceeding is a question of law, which is reviewed de novo. Mortgage Specialists, Inc. v.
13
Davey, 904 A.2d 652 (N.H. 2006). A finding of contempt, combined with a sanction for contempt,
14
forms a final appealable order. State v. Adams, 153 Ohio App. 3d 134, 2003-Ohio-3086, 791 N.E.2d
15
1045 (7th Dist. Harrison County 2003). A contempt proceeding, even though it grows out of another
16
proceeding, is ordinarily regarded as a collateral or separate action from the underlying case and is
17
18
separately appealable, with appellate review limited to the contempt order itself. Lerma v. Wal-Mart
19
Stores, Inc., 2006 OK 84, 148 P.3d 880 (Okla. 2006). Order of contempt is final and appealable when
20
the order contains a present finding of contempt and imposes sanctions. In re C.W., 2008 PA Super
21
254, 960 A.2d 458 (2008). A contempt order is appealable where the order constitutes a final one that
22
imposes sanctions upon the offending party. Takosky v. Henning, 2006 PA Super 237, 906 A.2d
23
24
1255 (2006). Superior Court will reverse trial court's determination as to contempt conviction only
25
when there has been plain abuse of discretion. Com. v. Haigh, 2005 PA Super 139, 874 A.2d 1174
26
(2005), reargument denied, (June 17, 2005). Contempt order preventing neighbors
27
28
from using property owners' pond was immediately appealable; it imposed cost of bond on
neighbors, and this sanction could not be purged. 33 A.L.R.3d 448 Page 185 33 A.L.R.3d 448
3
4
5
6
(Originally published in 1970) Wolanin v. Hashagen, 2003 PA Super 258, 829 A.2d 331 (2003). In a
case of contempt, the trial court may find a party in contempt and that party may appeal the finding of
contempt, but the party asking for the contempt may not, as it is not aggrieved. Borough of Slatington
v. Ziegler, 890 A.2d 8 (Pa. Commw. Ct. 2005). Since a contempt order is final in nature, an order
compelling discovery may be appealed only after a trial court holds a party in contempt. Tucker v.
9
10
11
12
Honda of South Carolina Mfg., Inc., 582 S.E.2d 405 (S.C. 2003). The finding of contempt is
immediately appealable. Ex parte Cannon, 685 S.E.2d 814 (S.C. Ct. App. 2009). Circuit court's
remedy or punishment for contempt of court is reviewed under the abuse of discretion standard.
13
Sazama v. State ex rel. Muilenberg, 2007 SD 17, 729 N.W.2d 335 (S.D. 2007). A trial court's finding
14
of contempt is reviewed for abuse of discretion. State ex rel. Flowers v. Tennessee Trucking Ass'n
15
Self Ins. Group Trust, 209 S.W.3d 602 (Tenn. Ct. App. 2006), appeal denied, (Oct. 30, 2006). A trial
16
court's sentence for contempt, like the exercise of its contempt power, is reviewable for abuse of
17
18
discretion. State v. Clark, 2005 UT 75, 124 P.3d 235 (Utah 2005). Trial courts have discretion to
19
issue contempt orders, and reversal of a contempt judgment is appropriate only if the trial court's
20
discretion was either totally withheld or exercised on grounds clearly untenable or unreasonable. In re
21
Duckman, 898 A.2d 734 (Vt. 2006). An adjudication of contempt is appealable if it is a final order or
22
judgment; i.e., the contumacy, the party's willful resistance to the contempt order, is established, and
23
24
the sanction is a coercive one designed to compel compliance with the court's order. RAP 2.2(a). In re
25
Estates of Smaldino, 212 P.3d 579 (Wash. Ct. App. Div. 1 2009). Appeals from contempt orders are
26
one-judge appeals. W.S.A. 752.31(2)(h). In re Washington, 2006 WI App 99, 716 N.W.2d 176 (Wis.
27
Ct. App. 2006).
28
CONCLUSION
1
2
3
4
5
6
7
8
9
Based upon the foregoing the undersigned respectfully requests that this Court set aside its
Order of December 16th, 2011, Set Aside the Summary Contempt Order) and any other relief this
Court deems just. Appellant Declares under
penalty of perjury, pursuant to NRS 53.045, that the assertions in this document are true and correct.
AFFIRMATION PURSUANT TO NRS 239B.030
The undersigned does hereby affirm that the preceding document does not contain the social
10
security number of any person.
11
Dated: February 22, 2012
12
13
/S/ Zach Coughlin________

Zach Coughlin, Defendant
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
PROOF OF SERVICE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Pursuant to NRCP 5(b), I certify that I served a copy of the foregoing document upon the
following party by faxing, emailing, dropping Rf at their office, and placing a true and correct copy
of the foregoing document in the us mail. addressed tp:
Pamela Roberts, Esq.
John Kadlic, Esq.
Reno City Attorney's Office - Criminal Divison
P.O. Box 1900 Reno , NV 89505
Tel: 775-334-2050 Fax: 775-334-2420
robertsp@reno.gov
KadlicJ@Reno.gov
Attorney for City of Reno
Reno Municipal Courth
FILED BY FAXING TO RMC AT 775 334 3824; and deposting in

the usps mail a true and correct copy of
24th
xx
Date this February 22, 2012:
/S/ Zach Coughlin
Zach Coughlin, Plaintiff
15
16
17
18
19
20
21
22
23
24
25
26
27
28
INDEX TO EXHIBITS
2
3
4
5
1. Exhibit 1: January 10th, 2012 email from RMC Interim Court Administrator Cassandra Jackson
with Attached December 16th, 2011 Order of Judge Howard; Four (4) pages
and All emails from ZachCoughlin@hotmail.com to RenoMuniRecords@Reno.gov from 10/4/11 to
present; citing to attached pdf filings that should be included in the Record on Appeal, yt are not in
some instances; Forty Four (44) pages.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Hotmail Print Message
1 of 47
http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=4b...
records request for incident report urgent please

Sent: Tue 10/04/11 3:10 PM
To:
renomunirecords@reno.gov
1 attachment
records request to reno city attorneys office oct 4.pdf (66.5 KB)
RenoMuniRecords@reno.gov
Dear Reno City Attorney Records Department.
My name is Zach Coughlin. I wish to obtain any and all records available
incident to an arrest at the E. 2nd St. Walmart by the Reno Sparks Indian
Colony Police on or about Saturday October 10th, 2011 at between
approximately 9pm and 10:30pm. I want any and all records, video, audio,
paper documentation or otherwise that I have a right to. I am representing
myself. I have sought these records from the Reno Municipal Court's
Records Office and they kept telling me they didn't have them yet and that I
should return sometime soon. Finally, they admitted the do not keep these
records and they must be obtained from your office. The RSIC Police
refused to give me a copy of these records. This delay has unduly prejudiced
my case and I request that you provide these records to me at once, with no
delay, please. I believe this case should be dismissed.
Sincerely,
Zach Coughlin signed electronically and signed in attached PDF. I can come
pick the records up with identification if that is required or I hereby give you
permission to email them to me or mail them to the address below:
Zach Coughlin
121 River Rock St.
Reno, NV 89501
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited.
1/29/2012 8:46 PM
2 of 47
CONFIDENTIALITY NOTICE
This message is confidential, intended only for the named recipient(s) and may contain information that is
privileged, work product or exempt from disclosure under applicable law. If you are not the intended recipient(s),
you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on
the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not
the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in
any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client,
work product, or other applicable privilege.
records request
Sent: Tue 10/04/11 4:41 PM
To:
2 attachments
RMC subpoena.pdf (67.8 KB) , RECORD_REQUEST_Zach Coughlin to RMC.pdf (20.2 KB)
October 4, 2011
Dear Reno Municipal Court Records Division,
My name is Zach Coughlin. I have now been informed by both the Reno
Municipal Court and the Reno City Attorney's officer, and the Reno Sparks
Indian Colony none of these entities can provide my requested records. You
have them, I believe I have a constitutional right to them. If you feel
differently, please explain in writing why that is the case.
I wish to obtain any and all records available incident to IC110627 at the E.
2nd St. Walmart by the Reno Sparks Indian Colony Police on or about
Saturday October 10th, 2011 at between approximately 9pm and 10:30pm. I
1/29/2012 8:46 PM
3 of 47
want any and all records, video, audio, paper documentation or otherwise that
I have a right to. I am representing myself. I have sought these records from
the Reno Municipal Court's Records Office and they kept telling me they
didn't have them yet and that I should return sometime soon. Finally, they
admitted they do not keep these records and they must be obtained from your
the Reno City Attorney's Office. At the RMC records window I spoke with a
supervisor named Karen. She denied my request for these records today.
This delay has unduly prejudiced my case and I request that you provide
these records to me at once, with no delay, please. The RS Indian Colony
Police refused to give me a copy of these records today when I spoke with
Sargent Avansino, who was polite and helpful otherwise. I believe this case
should be dismissed.
Signed electronically and signed in a signed attached PDF. I can come pick
the records up with identification if that is required or I hereby give you
permission to email them to me or mail them to the address below:
Zach Coughlin
121 River Rock St.
Reno, NV 89501
Sincerely,
Zach Coughlin
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the
intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have
received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents
of this information is strictly prohibited.
CONFIDENTIALITY NOTICE
This message is confidential, intended only for the named recipient(s) and may contain information that is
1/29/2012 8:46 PM
privileged, work product or exempt from disclosure under applicable law. If you are not the intended recipient(s),
you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on
the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not
the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in
any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client,
work product, or other applicable privilege.
Reno Municipal Court appointment of counsel

Sent: Mon 11/28/11 11:42 AM
To:
ltaitel@sbcglobal.net; renomunirecords@reno.gov
Dear Mr. Taitel,

I understand you have been assigned to represent me in the Reno Municipal Court trespass Complaint against
me. Please note that my address has recently changed to:
Zach Coughlin
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
I have recently been evicted and it has caused enormous upheaval to my life, and I am indigent, as such, I believe a
continuance is necessary and ask that you seek one for the December 13th, 2011 "trial" that I only became aware of through
calling the Reno Municipal Court. Also, please provide me a copy of any motions or pleadings you have filed on my behalf
and any documentation that you have been provided by the court, opposing counsel, or anyone else. I prefer such
documentation be emailed, but I realize that may not be possible. I would like to obtain a copy of the Complaint and
Discovery, including the probable cause sheets and any witness statements as soon as possible.
Sincerely,
Zach Coughlin
4 of 47
1/29/2012 8:46 PM
5 of 47
contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure
under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited
and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the
sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone
other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
records request
Sent: Mon 11/28/11 2:30 PM
To:
1 attachment
RECORD_REQUEST_FORM_2010[1] rmc trespass 11 13 11 records request 11-22185.pdf (20.8 KB)
Zach Coughlin, 817 N. Virginia St. #2

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
FW: temporary address change and instruction to pursue a continuance

1/29/2012 8:46 PM
6 of 47

Sent: Tue 11/29/11 3:14 PM
To:
robertsp@reno.gov; renomunirecords@reno.gov
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,

I am forwarding this apology I sent to Judge Howard in response to his remonstration responding to my email to
him, in an abundance of caution to avoid ex parte communications with the court, outside your presence. Please
also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I am hereby serving on you,
invoking the 21 day safe harbor, with a reservation that any misconduct you commit in the court's presence may
be punished sua sponte or subject to contemporaneous sanctions requests, particular with regard to you blase
dismissal of the official misdoncut, malicious prosecution, 42 USC Sec 1983 deprivations of civil rights under
color of state law and all those other things your office and Hartshorn, et all have been sued for over the years.
Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
privilege.
From: zachcoughlin@hotmail.com
To: howardk@reno.gov
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800
1/29/2012 8:46 PM
7 of 47
Dear Judge Howard,

My apologies Your Honor. I have had an unlawful rent distraint applied to all
my office equipment and the files necessary to defend this case and produce
motions, incident to a summary eviction stemming from a lease that was at
least in part commercial, had a rent escrow deposit forced upon me in
violation of Nevada Law, had all my computers printers, everything subject
to the distraint. I have a netbook it won't accept a printer and on and on. I
apologize. I do note that the RMC rules allow for filing by facsimile, though
I gather not to the fax number listed for yoru chambers at www.nvbar.org.
Sincerely,
Zach Coughlin,
request of cd of trial in 11 CR 22176 2I

Sent: Thu 12/08/11 4:00 PM
To:
Hello, I am writing to request a copy of the cd of the record of trial in 11 CR 22176 2I in addition to a copy of the Contempt
Order and any other orders made in that matter, in addition to a copy of the docket.
Please email these to me if possible. I will agree to pay the copying costs or the paper documents or the audio cd/dvd. I
need these as soon as possible please.
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
1/29/2012 8:46 PM
8 of 47
privilege.
REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER

DOCUMENTATION URGENT PLEASE
Sent: Thu 12/08/11 5:45 PM
To:
1 attachment
RECORD_REQUEST_FORM_2010[1] trial cd and orders to RMC 12 8 11 final.pdf (441.5 KB)
Please let me know right away if there is any problem opening the attached
pdf containing my URGENT records request. Please find attached my urgent
request for a tape of the trial held on November 30, 2011 (exigent concerns
related to my ability to filed relief from judgment motions with 10 days of
the Order, which was apparently made on 11/30/11 dictate that I be provided
a copy of the tape or cd/dvd of the hearing very quickly, please), any order or
findings in this case, the entire docket, any Contempt Order stemming from
the 11/30/11 trial, etc. I will pay all charges required, though I believe my
indigent status should yield an IFP or fee waiver, however, time is of the
essence and I cannot wait more than half a day to have an IFP ruled on, so
please proceed as though I will pay. Please let me know immediately, via
email preferably, or by fax (but not by phone or USPS mail) when these
materials are ready, in addition to providing me a written estimation of how
long it will be before they will be ready and made available to me.
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
1/29/2012 8:46 PM
9 of 47

privilege.
signed REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER

DOCUMENTATION URGENT PLEASE
Sent: Thu 12/08/11 5:56 PM
To:
1 attachment
RECORD_REQUEST_FORM_2010[1] trial cd and orders to RMC 12 8 11 signed.pdf (446.2 KB)
I am resending the Records and REcording of Trial request form, SIGNED, just in case that is necessary.
Thank You,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
1/29/2012 8:46 PM
10 of 47
privilege.
To: renomunirecords@reno.gov
Subject: REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER DOCUMENTATION URGENT PLEASE
Date: Thu, 8 Dec 2011 17:45:27 -0800
Please let me know right away if there is any problem opening the attached
pdf containing my URGENT records request. Please find attached my urgent
request for a tape of the trial held on November 30, 2011 (exigent concerns
related to my ability to filed relief from judgment motions with 10 days of
the Order, which was apparently made on 11/30/11 dictate that I be provided
a copy of the tape or cd/dvd of the hearing very quickly, please), any order or
findings in this case, the entire docket, any Contempt Order stemming from
the 11/30/11 trial, etc. I will pay all charges required, though I believe my
indigent status should yield an IFP or fee waiver, however, time is of the
essence and I cannot wait more than half a day to have an IFP ruled on, so
please proceed as though I will pay. Please let me know immediately, via
email preferably, or by fax (but not by phone or USPS mail) when these
materials are ready, in addition to providing me a written estimation of how
long it will be before they will be ready and made available to me.
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
1/29/2012 8:46 PM
11 of 47
privilege.
RMC said I could file this by email

Sent: Mon 12/12/11 7:28 PM
To:
1 attachment
12 11 11 final motion for new trial city of reno v coughlin RMC 11 CR 22176.pdf (12.9 MB)
Dear RMC,
I called an wrote earlier and received approval to file the attached pdf and
media files by email rather than fax or other submission. This filing is large,
as such, it must be broken down into segments. this is part one, part two will
be in the next email. I will pay whatever filing fee or bond or whatever I
have to pay to access justice in this here case.
Sincerely,
Zach Coughlin, Esq.

Reno, NV 8950
fax: 949 667 7402
1/29/2012 8:46 PM
12 of 47
privilege.
Motion for New Trial Etc. in RMC 11 CR 22176

Sent: Mon 12/12/11 7:40 PM
To:
fiskm@reno.gov; renomunirecords@reno.gov
1 attachment
RMC 11 CR 2217 part two Exhibit 1 pages 1-300 of Motion for New trail from 12 12 2011.pdf (8.6 MB)
I received approval to file by email from RMC

This is the second file in the filing. Please note, the file name of the attachment should actually have the correct
case number of RMC CR 22176. It is missing the 6 on the end in the file name of the attachment
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
1/29/2012 8:46 PM
13 of 47
privilege.
Motion for New Trial Etc. in RMC 11 CR 22176

Sent: Mon 12/12/11 7:57 PM
To:
1 attachment
RMC 11 CR 22176 part three Exhibit 1 pages 301-600 of Motion for New trail from 12 12 2011.pdf (9.7
MB)
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
RMC 11 CR 22176 part four Exhibit 1 pages 601-701 of Motion for New
trail from 12 12 2011 ey
1/29/2012 8:46 PM
14 of 47

Sent: Mon 12/12/11 8:23 PM
To:
1 attachment
RMC 11 CR 22176 part four Exhibit 1 pages 601-701 of Motion for New trail from 12 12 2011 ey.pdf
(11.8 MB)
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
Sent: Mon 12/12/11 8:29 PM
To:
1 attachment
(14.4 MB)
1/29/2012 8:46 PM
15 of 47
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
To: fiskm@reno.gov; renomunirecords@reno.gov
Subject: Motion for New Trial Etc. in RMC 11 CR 22176
Date: Mon, 12 Dec 2011 19:57:50 -0800
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
1/29/2012 8:46 PM
16 of 47
privilege.
audio of the November 30th Trial in Judge Howards court

Sent: Mon 12/12/11 9:56 PM
To:
Dear Mr. Fisk and the RMC,

RMC 11 CR 22176. I really need to quickly get a copy of the audio
recording from that. I went to the filing office counter and the clerk said I
couldn't get it, but I could fork over a lot to have it transcribed, is that true. I
have IFP status, and filed a Motion for Transcription at Publice Expense, but
should I be able to pay the $30 or whatever and get a cd of the hearing? Here
is another copy of My Motion for new Trial/NOtice of Appeal/IFP thing:
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1031&parid=root
Maybe that will be easier, that is where the exculpatory video evidence is sent to you as well, a continuation of
exhibit one. I appreciate the RMC allowing me to file via email this way as sometimes my fax service is clunky.
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
1/29/2012 8:46 PM
17 of 47
privilege.
Sent: Tue 12/13/11 2:26 PM
To:
1 attachment
(11.8 MB)
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
records request
1/29/2012 8:46 PM
18 of 47

Sent: Tue 12/13/11 4:02 PM
To:
renomunirecords@reno.gov; fiskm@reno.gov
2 attachments
RECORD_REQUEST_FORM walmart RMC 11 CR 22176 IC 110627 trial cd and orders to RMC 12 8 11
signed.pdf (453.4 KB) , RECORD_REQUEST_FORM_2010[1] rmc trespass 11 13 11 records request 11 CR
22185 City of Reno v Coughlin signed.pdf (510.9 KB)
Let this writing also werve as the cover letter called for in RMCR 5(D):
attorney's name,: Zach Coughlin, Esq.
the firms name: Zach Coughlin, Esq.
address, 817 N. Virginia St. #2
fax number 949 667 7402
telephone number: 775 229 6737
the attorneys state bar number: NV Bar No: 9473
Dear Mr. Fisk,

I really need a copy of the audio of the Trial in 11 CR 22176 and a copy of
both the Contempt Order and the Guilty Verdict (Veronica said she would fax
one and that the RMC never sent or served me a paper copy beyond shoving
some papers in my fax when I was being handcuffed then taking them away
from me separately in a huff when I stated that I might like to know what it
was I was to sign or read it (or 6th Amendment, etc). However, I have
received no fax of those Orders as Veronica said she would send me
yesterday. She said it in an angry unprofessional tone and I am hereby
complaining in writing about that and Marshall Monte's angry threatening
tone and language to me at the arraingment of October 11, 2011. Please
place a copy of this in their personnel files and the record in both of my CR
RMC cases.
I was told by a RMC filing office counter clerk yesterday that I was not
allowed to get a copy of the audio of my 11 30, 2011 hearing before Judge
Howard, that I would only be able to get a transcript after using the one
transcriptionist the RMC approves of and after paying her a substantial
amount of money up front, but that ultimately, the audio would never be
made available to me.
Is this the case? Please respond in writing or email me a copy of the audio
files and the pdf's or whatever file type the Contempt Order and Guilty
Verdict etc, in 11 CR 22176 are in, in addition please provide the Motion to
Withdraw and Notice of appearance in 11 CR 22185 by Taitel and then
1/29/2012 8:46 PM
19 of 47
Puentes. I sent you the video exhibits with the same mysterious Verint codec
that the RMC provided me. Why a simple .avi file needs some mysterious
codec that is about 13mb in size is truly a mystery to me.
12 11 11 Defendants Motion for New Trial, Set Aside, Vacate Judgment/Conviction of underlying crime and
Contempt in Court's Presence finding/ IFP Petition/ Motion for Reconsideration/Notice of Appeal, Case Statment
in case: city of reno v coughlin RMC 11 CR 22176; Records Request form Defendant and Request for
Transcription at Public's Expense and Request for a copy of the audio recording of the Trial of 11 30, 2011 1:45
pm to end in RMC 11 CR 22176.
Additionally, I never received service of any Notice of Appearance nor a Motion to Withdraw by Lew Taitel, Esq.
the attorney appointed to represent me as required by RMCR Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of
their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the
court and serve the City Attorney with the same. The court may rule on
the motion or set a hearing."
Further, RMCR state: "Rule 5: Motions by Facsimile

A. All rules and procedures that apply to motions filed in person at the
court shall also apply to motions filed by facsimile, except as otherwise
specified in this rule.
B. All persons are eligible to use motion-by-facsimile procedures.
C. All motions filed by facsimile must be accompanied by a cover sheet
which must include the persons name, address, fax number and
telephone number.
D. All facsimile motions filed by an attorney must include the attorney's
name, the firms name, address, fax number and telephone number. In
addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
E. All motions filed by facsimile must be accompanied by proof of service.
Service may be accomplished by facsimile when the receiving party is a
governmental agency, an attorney, or with the consent of the receiving
party. If service of the motion is accomplished by facsimile the 3-day
allowance for mailing shall not be computed into the time for response.
F. A defense attorney filing a motion in the first instance must also file a
proper authorization to represent.
G. Any motion received by the court after 4:30 p.m. or on a non-court day
shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except
for good cause. A motion or stipulation for continuance must state the reason
therefore and whether or not any continuance has previously been sought or
granted."
Let this writing also werve as the cover letter called for in RMCR 5(D):
attorney's name,: Zach Coughlin, Esq.
the firms name: Zach Coughlin, Esq.
address, 817 N. Virginia St. #2
1/29/2012 8:46 PM
20 of 47
fax number 949 667 7402

telephone number: 775 229 6737
the attorneys state bar number: NV Bar No: 9473
And: "Rule 9: Appeals to District Court
Except as otherwise provided in NRS 177.015 a defendant in a criminal action
tried before a Municipal Court Judge may appeal from the final judgment
therein to the Second Judicial District Court, at any time within 10 days from
the date that judgment is rendered."
Judge Howard informed me during his oral pronounce of his Contempt Order and Guilty Verdict on 11 30,2011
that he would afford me an additional 3 non judicial days to file a Notice of Appeal or any other Motion, Request
for Reconsideration, or other Motion seeking relief from his 11 30 2011 rulings on account of his sua sponte, with
no possibility of Stay or prior judicial review ordering his Marshalls to slam be into handcuffs and throw me into
Jail, kind of like in Houston v. 8th Judicial District Court, escept Judge Howard didn't cool down like Judge
Pomeranz did and Houston wasn't defending a criminal charge that carred a possibility of incarceration of
substantial length after being denied his 6th Amendment Right to Counsel. I am formally complaining about
Judge Howard;s conduct in that regard, please place a copy of this in his personnel file and let me know whether
you think a Complaint to the Judicial Discipline Commission would be appropriate, in your professional opinion.
I filed my Notice of Appeal in 11 cr 22176 yesterday with the RMC via email, as previously given permission to do
by the RMC. To the extent that was ineffective, let this writing act as a Notice of Appeal and agreement to pay
all charges required for such.
PROOF OF SERVICE:
I emailed a copy of this to Pam Roberts for the Plaintiff City of Reno on this date, a true and correct copy and
further email her a copy of all the 12 11 11 MOtion for New Trial, etc. yesterday to:
Pamela G Roberts
Company: Reno City Attorney's Office - Criminal Divison
Address: P.O. Box 1900
Reno
, NV
89505
Phone Number: 775-334-2050
Fax number: 775-334-2420
Email: robertsp@reno.gov
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
1/29/2012 8:46 PM
21 of 47
privilege.
IFP/ FINANCIAL INQUIRY APPLICATION

Sent: Wed 12/14/11 12:22 AM
To:
ballardd@reno.gov; renomunirecords@reno.gov
2 attachments
Coughlin IFP and Financial Inquiry Application RMC 11222011 11 CR 26405 2I.pdf (381.9 KB) , Coughlin
IFP and Financial Inquiry Application RMC 11222011 11 CR 22176 2I.pdf (372.0 KB)
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
Ms. Ballard,
Please note, the gentleman I worked with at the filing office counter today informed me there were no
appeal fees, bonds, or other charges that I could pay (including transcription costs) as "all charges are
1/29/2012 8:46 PM
22 of 47
being taken from" my bail in the respective matters. Please email me the audio from the November
20th,2011 Trial in 11 cr 22176 2I and proof of service of any Contempt Order or Guilty Verdict/Order
in that matter. Please file this as well as a Opposition to Any Motion to Continue Trial in 11 cr 26405,
dept 2, and a Motion to Set Aside or Vacate any Order Granting Continuance in response to such an
Order Granting Continuance. Please email, fax, or mail me a copy of the Notice of Appearances by
both Taitel and Puentes and the Motion and Order Granting Withdrawal of Taitel, if it exists. I would
like a copy of the docket in both 11 CR 26405 2I and 11 CR 22176, despite your informing me today
that I would need to subpoena the docket to have any chance of seeing it and that I would not be
provided access to documents in the public record, including Orders in both of these cases.
Sincerely,
Zach Coughlin
privilege.
RE: Message left on 12/13/2011

Sent: Wed 12/14/11 6:52 PM
To:
roperj@reno.gov; fiskg@reno.gov; ballardd@reno.gov; renomunirecords@reno.gov
Dear Chief Marshal Roper, and the RMC,

Thank you for your quick reply. I actually requested a copy of some
documentation related to my complaints about both incidents with Marshal
Mentzel be placed in his employment or personnel file, not that you provide
1/29/2012 8:46 PM
23 of 47
me a copy of his file. I would like one, or a copy of any complaints against
any Marshals, but I realize a subpoena would likely be required to have any
chance at that. Negligent Training, Hiring, Supervision.
I never received a copy of the Contempt Finding and Guilty
Verdict/Judgment/ORder or whatever from the 11 30, 2011 Trial before Judge
Howard in 11 CR22176 2I, though "Veronica" (no one will tell me her last
name, but she works closely with the RMC Judges) said the only "service" of
those Orders that was ever attempted on me occured while I was handcuffed,
after which point some Marshalls (I did not catch their names and they
manhandled me roughly into handcuffs, refusing to even let me save my
notes on my laptop at the sudden conclusion of Judge Howards Order and
Contempt finding. This is truly reprehensible to not even let me save my
damn notes and act like I was some perp who just knocked of a god damn
liquor store with a firearm. Some people need to get a grip inside. Please
place a copy of this written complaint against whatever Marshals were
involved in that in their employment/personnel files as well. Please provide
me a copy of any complaints you have received against any Marshals.
I would like a copy of the 11 30, 2011 Order and the audio of the Trial. I
believe you have a duty to find out what those Marshals did with this
document that "Veronica" alleges they attempted to serve on me, though,
even 14 days after the Trial, the "docket" in the RMC filing office still
contains no Order, no mention of an Order, and certainly no Proof of Service
of anything of the sort, nor have they responded to any of my documentation
requests or a request of the audio of the Trial of 11 30, 2011, despite an
exigent need for such to prepare Relief from Judgment Motions that have
deadlines of 10-20 days from "service" of the "Order", and who knows how
that will be measure. Why it was necessary to cost the public a bunch of
overtime pay for the 5 or so Marshalls, and who knows how many court staff
to stay until nearly 9pm on 11 30, 2011 to complete this "Trial", and how it
was such a damn emergency, especially where Richard Hill was able to get a
continuance because he was going to be on vacation in the trespass case
against me 11 CR 22185 2I, despite the fact that Lew Taitel never receive my
consent to such a Motion for Continuance, and further Taitel was arguably
conflicted out of representing me considering his "association" with Nevada
Court Services and the torts the committed against me, which resulted in a
1/29/2012 8:46 PM
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lawsuit being filed against them, or at least an IPF Petition and Proposed
Complaint in District Court, prior to Taitel's appointment and representation.
If the RMC can afford all that damn overtime for everyone, why couldn't it
appoint me a defense attorney in RMC 11 CR 22176, especially where Judge
Howard ruled, not 20 minutes into Trial that he was finding me in Contempt
of Court and would decide the sentence (which obviously included a
possibility of incarceration) at the conclusion of the Trial?
Further M. Mentzel clearly bumped Donna Ballard out of the way in his zeal
to establish dominance of me, a person who was providing absolutely no
resistance at the time. Mentzel went on to start order me to leave the
premises after my conversation with Ballard and the file clerk was done.
Duh, Mentzel, it was 5:00 pm or so "closing time" what do you think I am
going to do, hang out and chill with you guys? Look at the Notice of Hearing
or Docket in RMC 11 CR22176 2I (I am also hereby requesting a copy of
the audio or video of the hearing from the RMC) and the hand written
interlineations I made on the document M. Mentzel provided me in court on
10 11, 2011, where I mention the problems associated with asking questions
about my Sixth Amendment Right to Counsel where only the possibility of
jail time exists. I asked Mentzel at that time a question about the process and
he got very angry, threatening, and insulting with me, then later, criticized my
appearance before Judge Gardner, I believe he said I was "sarcastic" and or
rude to the Judge in the same way I had been to Mentzel himself. I submit
that citizens trying to access justice should not be taken as a personal affront
to RMC employees like Mentzel, and that he needs to strongly consider how
he comes across to the public when he acts the way he does, and carries a
firearm, color of law, a badge, and apparently, the blessing of the RMC in
carrying out behavior that seems more fitting for a nightclub bouncer than a
Marshal. Further, the video played at arraignments is overly hostile and
threatening in my opinion, especially the parts where Judge Gardner makes
statements on the "extremely" poor choice it would be to represent one's self
pro se and all these tones and words used that make it sound like pro se
defendants will be punished for not either copping a plea or going with one
of the "four former prosecutors" who are now drawing a paycheck from the
RMC/Citizenry to fulfill the Sixth Amendment. I am something completely
other than impressed with the work done by Lew Taitel, Esq. for me in RMC
11 CR 22185 2I, in that regard. Why shouldn't defendants in the RMC, after
viewing the arraignment video and receiving representation like that which I
1/29/2012 8:46 PM
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received from Taitel, feel like lambs being led to slaughter? Baah,
baaaaaaaaah! Two other Marshals were there yesterday when Mentzel was
berating me, I would like their names, please.
Now, just awhile ago, "RMC Court Transcriptionist Pam Longoni" called me
on the phone ("while driving" according to Ms. Longoni) and informed me
that the RMC must permit her access to the audio files, and that, while she is
linked into "their system" (meaning the RMC's), the RMC must take some
additional step to allow Ms. Longoni to access the audio files and continue
with the process of tending ot a request for a Transcript on Appeal. I was
told by a female RMC counter clerk that I would not ever be provided a copy
of the audio recording of the 11 30, 2011 Trial, but that I may purchase from
Ms. Longoni an official transcript, and that "appeal transcripts are billed at
$4.10 per page" etc. and that a substantial deposit would be required, and that
"No Transcript is considered to be official ordered, and commencement of
transcription will not begin, until receipt of the required deposit..." I asked
Ms. Longoni to inform me of everything I must do or pay to have the
transcript deemd officialy ordered and she informed me that she could not tell
me that, despite the apparent hard and fast deadlines applied to ordering,
officially, such a transcript, with the RMC in an Appeal context, until the
RMC allowed Ms. Longoni to access the RMC "system" and view/hear the
audio of the 11 30, 2011 Trial in 11 CR22176 2I. Ms. Longoni angrily hung
up the phone on me and is now not returning my calls and has failed to
respond to my request that she inform me, in writing, as to where to send
money or a deposit or anything else required for the transcript. I have yet to
receive a fax from the RMC's "Veronica" (whose last name has repeatedly
been denied to me) despite her angry assurances on the phone on 12 12, 2011
that she would finally hae the RMC attempt to appropriately (or almost
appropriately) serve me a copy of the Contempt Finding and Guilty Order
stemming from the 11 30, 2011 Trial in RMC 11 CR 22176 2I. Please have
this request and communication reiterated to whoever it concerns at the
RMC, and have such a copy of those documents emailed, faxed, and mailed
in the US Postal Service mail immediately. Further, please do the same with
respect to the audio of the 11 30, 2011 Trial in RMC 11 CR 22176 2I, and of
course I will pay a reasonable cost for the cd to the extent my IFP is not
granted. The RJC and Washoe District Court charge about $30 per cd. The
also provide copies of the dockets in cases without demanding a subpoena
1/29/2012 8:46 PM
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force them to first. Please ask the gentleman Ms. Ballard saw me working
with yesterday what he said in that regard about providing me a copy of
anything, much less the docket in either RMC 11 CR 22176 2I or RMC 11
CR 22185 2I.
I believe I am entitled to a copy of the audio recording quickly, whether or
not a transcript has been officialy ordered, for the purposes of appeal or for
any other purposes. I believe in something called "transparency" in
goverment. Sunshine.
Let me ask you a question: If a Judge told you to jump off a bridge, would
you? It is my belief that Judge Howard ordered everyone to clear the
courtroom, including a female, shortly after my 11 20, 2011 Trial began and
it became clear that I was not going to lay down meekly for the Court, or for
Wal-Mart, or for the Reno City Attorney. 2 million of my people starved to
death during a "Great Famine" between 1848-1850 in Ireland, despite being
surrounded by water and fish, where the English were arresting Irishmen who
attempted to save their families and their own live's by fishing. I will be
fishing here, gentleman. Deal with it. I want that recording, for, among
many other reasons, to see if Judge Howard merely asked those who might
be called as witnesses to leave or whether he demanded every member of the
public leave before he sent me off to Guantanamo, er, I mean the Washoe
County Detention Facility after the Military Tribunal, er, the Trial in RMC.
Interestingly, while at the Washoe County Detention Facility, I have been
made to strip naked while being videotaped, wear a green dress for days on
end, go without a toothbrush for days, refused any opportunity to make
phone calls to protect my clients cases from prejudice, forced to spread apart
my buttocks and allow an overly long look at my anus by Sheriff's Deputies,
and further, I was forced to submit to a position on my knees in the
immediate vicinity of two Sheriff's Deputies crotches in some sadistic forced
simulation of performing oral sex upon those men. Rico/Negligent Hiring,
Training, Supervision, 42 USC Sec. 1983 Deprivation of Civil Rights Under
Color of State Law, etc., etc. Qui Tam, Whistleblower. Mr. Roper, I doubt a
Federal Court Judge would require that I have come obtained a Statement
From you to complain about any Marshal's conduct. I am pretty sure this and
my other correspondences have placed you on notice.
1/29/2012 8:46 PM
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Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Date: Wed, 14 Dec 2011 16:26:47 -0800

From: RoperJ@reno.gov
To: ZachCoughlin@hotmail.com
Subject: Message left on 12/13/2011
Mr. Coughlin,
I received your message that you left on my phone on December 13, 2011 in regards to a complaint against Marshal
Menzel. The Marshal Division takes all citizen complaints seriously and investigates all complaints received in writing or
verbally. However, I would need more information from you prior to moving forward with an investigation. I encourage
you to come to the court to obtain a statement form, or contact me directly should you wish to pursue this matter. As to
your request to obtain a copy of Marshal Menzel's personnel file, I am unable to provide that to you without a valid
subpoena or warrant.
1/29/2012 8:46 PM
28 of 47
You also stated you were attempting to obtain a copy of your Judgement of Conviction from Dept. 4, specifically Veronica
Lopez, you can reach her at 326-6673. I am aware that a copy of your Judgement of Conviction was provided to you and
booked into your property on the night you were arrested. You are entitled to another copy should you wish.
Thank you,
Justin Roper
Chief Marshal/Department of Alternative Sentencing
Reno Municipal Court
775-334-1254
RMC 11 CR 22176
Sent: Thu 12/15/11 11:59 PM
To:
howardk@reno.gov; ballardd@reno.gov; robertsp@reno.gov; fiskm@reno.gov;

renomunirecords@reno.gov; lopezv@reno.gov
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
DATE: December 15, 2011

TO: .RMC et al
FAX NO: RMC approved email ling
1/29/2012 8:46 PM
29 of 47
RE: . City of reno v Coughlin RMC 11 CR 22176 2I

Motion for New Trial,Notice of appeal and other issues
Dear RMC,
I do not mean to be disrespectful in contacting the court via email. I have been so stamped
out by the events of the last few months that its all I can do to try to protect my rights to get
information and media to the court in my attempts to access justice. Veronica Lopez told me on
the phone on Monday of this week that she would fax me a copy of the Order and Contempt finding from the 11
30, 2011 Trial, yet I have not received any such fax. I have not received any order in any form, not on my release
from the 3 days summary incarceration, not ever. The RMC confirmed there has been no Notice of Entry of any
order in their docket or anything, etc.
I believe the following should be added to record and presents a strong argument for a
conflict of interest or other 60(b) basis for setting aside the verdict and contempt Order in
RMC 11 CR 22176 2I. I did not plead guilty in that case, and any RMC record that
suggests that is completely inaccurate. Please let me know if your records indicate I plead
guilty in that matter. Further, I have never been provided a copy of the Guilty Verdict/Order
in this matter, I requested on to be emailed to me and sent in the USPS mail. Please serve
me a copy of the order, preferably by email and USPS mail. Further, the "RMC's official
court transcriptionist" informed me yesterday that she could not quote me or accept an
money from me for the transcript on appeal. Further I have been told by court staff that I
would never be provided access to the audio recording of the Trial of 11 30, 2011. I believe
I have a right to it, and need it on an exigent basis in connection with the various motions I
have, will, or intend to to file challenging the decision in this case. The RMC filing office
informed me there has been no Notice of Entry of Order in this matter at this point.
T
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
1/29/2012 8:46 PM
30 of 47
fax: 949 667 7402

Nevada Bar No: 9473
privilege.
FW: RMC 11 CR 22176

Sent: Fri 12/16/11 12:00 AM
To:
howardk@reno.gov; ballardd@reno.gov; robertsp@reno.gov; fiskm@reno.gov;

renomunirecords@reno.gov; lopezv@reno.gov
1 attachment
emergency filing rmc 11 cr 22176 12 15 11.pdf (260.9 KB)
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
1/29/2012 8:46 PM
31 of 47
Nevada Bar No: 9473
privilege.
To: howardk@reno.gov; ballardd@reno.gov; robertsp@reno.gov; fiskm@reno.gov; renomunirecords@reno.gov;
lopezv@reno.gov
Subject: RMC 11 CR 22176
Date: Thu, 15 Dec 2011 23:59:45 -0800
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
1/29/2012 8:46 PM
32 of 47
DATE: December 15, 2011

TO: .RMC et al
FAX NO: RMC approved email ling
RE: . City of reno v Coughlin RMC 11 CR 22176 2I
Motion for New Trial,Notice of appeal and other issues
Dear RMC,
I do not mean to be disrespectful in contacting the court via email. I have been so stamped
out by the events of the last few months that its all I can do to try to protect my rights to get
information and media to the court in my attempts to access justice. Veronica Lopez told me on
the phone on Monday of this week that she would fax me a copy of the Order and Contempt finding from the 11
30, 2011 Trial, yet I have not received any such fax. I have not received any order in any form, not on my release
from the 3 days summary incarceration, not ever. The RMC confirmed there has been no Notice of Entry of any
order in their docket or anything, etc.
I believe the following should be added to record and presents a strong argument for a
conflict of interest or other 60(b) basis for setting aside the verdict and contempt Order in
RMC 11 CR 22176 2I. I did not plead guilty in that case, and any RMC record that
suggests that is completely inaccurate. Please let me know if your records indicate I plead
guilty in that matter. Further, I have never been provided a copy of the Guilty Verdict/Order
in this matter, I requested on to be emailed to me and sent in the USPS mail. Please serve
me a copy of the order, preferably by email and USPS mail. Further, the "RMC's official
court transcriptionist" informed me yesterday that she could not quote me or accept an
money from me for the transcript on appeal. Further I have been told by court staff that I
would never be provided access to the audio recording of the Trial of 11 30, 2011. I believe
I have a right to it, and need it on an exigent basis in connection with the various motions I
have, will, or intend to to file challenging the decision in this case. The RMC filing office
informed me there has been no Notice of Entry of Order in this matter at this point.
T
1/29/2012 8:46 PM
33 of 47
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
emergency filings
Sent: Fri 12/16/11 7:55 AM
To:
renomunirecords@reno.gov; robertsp@reno.gov
2 attachments
12 16 11 emergency filing with fax cover sheet rmc 11 cr 22176.pdf (330.0 KB) , fax cover sheet and
notice of denial of service clarification motion.pdf (202.1 KB)
1/29/2012 8:46 PM
34 of 47
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
FW: 121 River Rock

Sent: Sat 12/17/11 12:15 AM
To:
ballardd@reno.gov; howardk@reno.gov; robertsp@reno.gov; renomunirecords@reno.gov; hazlettstevensc@reno.gov; puenteslaw@aol.com
Unbelievable. The idea that exculpating evidence is being withheld under some "lien" is transmitted into the
universe, next thing I know, my law office is broken in to and the Richard B. Hill gang is stil asserting a lien on
property that was stolen, in my opinion, as a result of their own negligence, leaving a window air conditioner unit
in a window, without even putting a window jam between the top of the sill and lower pain, facing a sidewalk a
block from the Lakemill Lodge and across from City Center Apartments, great. Great. And I still have not been
faxed or appropriately served the Order and Contempt Order I was told would be faxed to me.
Zach Coughlin, Esq.
1/29/2012 8:46 PM
35 of 47

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
To: cdbaker@richardhillaw.com; knielsen@richardhillaw.com; sgallagher@richardhillaw.com
Subject: RE: 121 River Rock
Date: Wed, 14 Dec 2011 15:43:38 -0800
Dear Mr. Baker,
I drove by the property recently and saw you had added boarding up the front door on very, very recently.
Unfortunately, your client and your firm, despite billing up some $1,060 for "securing" the property on top of
charging $900 for storage for what could fit inside a 10x20 foot storage shed, never once providing an inventory,
and contributing to a wrongful arrest and defamation causing me and my clients great damage, failed to take
even basic steps to secure the property, despite my making numerous written requests that you do so, including,
but not limited to, taking the damn window unit air conditioner out of the window facing the sidewalk on the
side of the house very close to the damn Lakemill Lodge, or even putting a strong stick in between the bottom
sliding window pain and the top of the sill to prevent someone from simply pushing in the window unit air
conditioner and pushing the window up to gain access. Further, a blanket that was on the orange circular couch
is clearly in the flower bed in front of the house. Additionally, there are reports that someone with your office
gave someone a mattress from the inventory of Coughlin Memory Foam (a Nevada licensed business located at
1/29/2012 8:46 PM
36 of 47
the property) and an expensive mattress platform has clearly been damaged and placed in the flower bed as
well, in addition to one of the wooden porch shades being removed from the front porch. You and your client
are, of course, liable for all of this.
Sincerely,
Zach Coughlin, Esq.

Reno, NV 89501
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
From: cdbaker@richardhillaw.com
CC: rhill@richardhillaw.com
Subject: 121 River Rock
Date: Wed, 14 Dec 2011 13:50:02 -0800
Mr. Coughlin:
The River Rock property has been broken into. We believe the break-in occurred sometime on Monday,
1/29/2012 8:46 PM
37 of 47
December 12, 2011. There appear to be items missing, including the TV in the living room, perhaps a computer
monitor, and perhaps some stereo equipment. I cant tell what else. The contents of the residence appear to
have been rifled through.
I am providing you with this information as a courtesy. This email does NOT constitute permission for you to go
to the River Rock property.
Casey D. Baker, Esq.

Richard G. Hill, Chartered
652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858
Email: cdbaker@richardhillaw.com
CONFIDENTIAL: ATTORNEY WORK PRODUCT; ATTORNEY-CLIENT PRIVILEGE

This e-mail may contain legally privileged or confidential information. If you are not the intended recipient, please do not read, copy, use, or disclose this
communication to anyone other than the intended recipient. If you have received this message in error, please notify the sender and delete the email message from
your system. Thank you.
Circular 230 Notice.
To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any
attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting,
marketing or recommending to another party any transaction or matter addressed herein.
emergency
Sent: Mon 12/19/11 4:32 PM
To:
supplement to motion to set aside all orders, see attached exhibit, there is no initialing on
the filestampe for the order on the 11 30th, 2011
Tom said there was no docket entry or record of anything as of 12 13 11, i wans't provided copy of discovery for
over 30 days after arrest, rmc said it didn't have pc and witness satements but rec'd date indicates otherwise,
potentially, release sheets fromjail property inventory does not show 11 30 11 order, I declare under penalty of
1/29/2012 8:46 PM
38 of 47
perjury i did not refuse any order or the chance to have a physical copy of one.
Zach Coughlin, Esq.

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
I will fax this to Ms. Roberts and the RMC as well, this is a courtesy copy
Sent: Mon 12/19/11 5:15 PM
To:
1 attachment
RMC 11 CR 22176 12 19 11 filing with 3 exhibits.pdf (9.1 MB)
I will fax this to Ms. Roberts and the RMC as well, this is a courtesy copy
Zach Coughlin, Esq.
1/29/2012 8:46 PM
39 of 47

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
no reply from Transcriptionist

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

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
1/29/2012 8:46 PM
40 of 47
Nevada Bar No: 9473
Dear RMC,
It is my understanding the Judge Howard's order regarding email does not extend to the
address to which I am sending this correspondence: renomunirecords@reno.gov which is
the email address filing office supervisor Donna Ballard indicated to me was acceptable for
sending correspondence and filings to the RMC in lieu of faxes. I am writing because the
email address I was provided for RMC "official transcriptionist" Pam Longoni yielded a
"return to sender/failed transmission" message when I wrote to the email address provided
for her: plongoni@charter.net. Further, please see the forwarded email below that I sent to
Ms. Longoni. I have not received a return call from her regarding my recent messages to
her. I was told by a RMC filing office counter employee that I must get the transcript
through Ms. Longoni, as she is the "official transcriptionist" for the RMC. Please confirm
that I am no able to have another certified court reporter or transcriptionist create the
official transcript and indicate by what date this must be done, how it must be done, etc.
I was told by RMC filing office staff, including Ms. Ballard, that the RMC would not accept
any filings fees, bonds, or any other payments from me in relation to the underlying case 11
CR22176 2I or the appeal of that matter given that the RMC was holding the bail money I
paid into the court. If this is not the case or if I must pay anything into the RMC to ensure
that my appeal goes forward, please indicate as much in writing and with particularity. If I
am able to use any other transcriptionists and or the RMC has a list of such with contact
information, please provide such in writing.
Sincerely,
/s/Zach Coughlin
Zach Coughlin, Defendant/Appellant
1/29/2012 8:46 PM
41 of 47
privilege.
To: plongoni@charter.net
Subject: where to pay and how much
Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,

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

Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
1/29/2012 8:46 PM
42 of 47
privilege.
proof of insurance and registration Affidavit/Declaration and supporting

documentation
Sent: Mon 1/09/12 5:58 PM
To:
renomunirecords@reno.gov; renodirect@reno.gov
1 attachment
Zach Coughlin license plate 838NER proof of insurance and registration for citations 544281 and
r47190389731.pdf (1737.4 KB)

My vehicle and myself were appropriately insured, as verified by the attached Proof of Insurance for
my USAA automobile insurance at the time of both Traffic Citations No's: 544281 and R47190389731.
Copies of both citations are attached as well. My vehicle, at the time of both citations, was in
compliance with Nevada law with regard to vehicle registration. A true and correct copy of this
Affidavit and the attached copies of Traffic Citations No's: 544281 and R47190389731 and a true and
correct copy of the Proof of Insurance for the time of both citations from my USAA automobile
insurance (Policy Number 0098527 96C 7104 3) and a true copy of my DMV automobile Registration
Certificate for both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this Declaration under penalty of perjury
pursuant to NRS 199.145.
1/29/2012 8:46 PM
43 of 47
Please find attached a 6 page pdf with this Affidavit/Declaration and the accompanying copies of the
two citations and the proof of insurance at the time and date of both citations and the same for the
registration for the vehicle. I am disputing the "failure to come to a complete stop" part of the citation
in 544281 and understanding that I have a hearing in Reno Municipal Court on 2 6 12 at 8:30 am in
that regard, please correct me if that is not the correct date and time.
Also, I have called several times and keeping leaving messages about disputing the following parking
tickets, and do not believe any "additional fines" should have attached to the base fine where I have
communicated that I am disputing them and have not receive a response with regard to the date and
time of my hearing to dispute them:
Citation Details
Amount Due: $60.00
Issue Date:
12/03/2011 10:30:00
State:
NV
Related Citations
We have found the following additional outstanding citations for this license plate
number. Please check the box next to each additional citation that you would like to pay
for at this time.
Citation Number
Issue Date
Amount Due
020145322
11/03/2011 03:20:00 $55.00
Sincerely,
1/29/2012 8:46 PM
44 of 47
Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118

fax: 949 667 7402
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may
contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it
to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking
of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable
law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message
in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work
product, or other applicable privilege.
debt validation documentation request and dispute letter under FDCPA

to City of Reno et al
Sent: Mon 1/09/12 6:09 PM
To:
renodirect@reno.gov; renomunirecords@reno.gov
Dear City of Reno,

This writing is written notice to you that I dispute the debt your office and the City of Reno
and or the Reno Municipal Court has recently sent me, alleging that I owe some debt for
either parking tickets and or traffic citations. Further, I request verification and
documentation in support of your contention that I owe such a debt pursuant to the Fair
Debt Collection Practices Act.
Sincerely,
1/29/2012 8:46 PM
45 of 47
Zach Coughlin1422 E. 9th St. #2

RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402

To: renomunirecords@reno.gov; renodirect@reno.gov
Subject: proof of insurance and registration Affidavit/Declaration and supporting documentation
Date: Mon, 9 Jan 2012 17:58:47 -0800

My vehicle and myself were appropriately insured, as verified by the attached Proof of Insurance for
my USAA automobile insurance at the time of both Traffic Citations No's: 544281 and R47190389731.
Copies of both citations are attached as well. My vehicle, at the time of both citations, was in
compliance with Nevada law with regard to vehicle registration. A true and correct copy of this
1/29/2012 8:46 PM
46 of 47
Affidavit and the attached copies of Traffic Citations No's: 544281 and R47190389731 and a true and
correct copy of the Proof of Insurance for the time of both citations from my USAA automobile
insurance (Policy Number 0098527 96C 7104 3) and a true copy of my DMV automobile Registration
Certificate for both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this Declaration under penalty of perjury
pursuant to NRS 199.145.
Please find attached a 6 page pdf with this Affidavit/Declaration and the accompanying copies of the
two citations and the proof of insurance at the time and date of both citations and the same for the
registration for the vehicle. I am disputing the "failure to come to a complete stop" part of the citation
in 544281 and understanding that I have a hearing in Reno Municipal Court on 2 6 12 at 8:30 am in
that regard, please correct me if that is not the correct date and time.
Also, I have called several times and keeping leaving messages about disputing the following parking
tickets, and do not believe any "additional fines" should have attached to the base fine where I have
communicated that I am disputing them and have not receive a response with regard to the date and
time of my hearing to dispute them:
Citation Details
Amount Due: $60.00
Issue Date:
12/03/2011 10:30:00
State:
NV
1/29/2012 8:46 PM
47 of 47
Related Citations
We have found the following additional outstanding citations for this license plate
number. Please check the box next to each additional citation that you would like to pay
for at this time.
Citation Number
Issue Date
Amount Due
020145322
11/03/2011 03:20:00 $55.00
Sincerely,
Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118

fax: 949 667 7402
1/29/2012 8:46 PM
2/28/13
Request for copy of 1/4/12 Supplemental in CV1103628

Sent: Tue 2/26/13 3:05 PM
To: michelle.purdy@washoecourts.us (michelle.purdy@washoecourts.us)
Cc: david.hardy@washoecourts.us (david.hardy@washoecourts.us);
judge.hardy@washoecourts.us (judge.hardy@washoecourts.us);
chuck.weller@washoecourts.us (chuck.weller@washoecourts.us)
49 attachments
1 4 13 0204 EPO SBN v Coughlin 607.pdf (1396.0 KB) , 1 4 13 0204
599 EPO Washoe County v Coughlin.pdf (1438.6 KB) , 2 1 13 0204
62337 request to inspect roa.pdf (761.1 KB) , 2 1 13 0204 063341
WC Jail Inmate Booking Information Form $500 bail DAS probation
violation.pdf (964.7 KB) , 2 1 13 0204 065630 email to WCDA with
complaints@nvbar.org listed among recipients.pdf (270.3 KB) , 2 1
13 02024 063341 WC Jail Inmate Release Information Form arrest by
DAS after 7pm for alleged late check in on 1 23 13.pdf (805.2 KB) , 2
1 13 063341 DAS probation violation arrest after 7pm PC sheet
0204.pdf (1856.3 KB) , 2 1 13 email to WCDA Covington's threats vis
a vis SBN 62337 long letter resulting in 2 arrests in next 8 days.pdf
(270.2 KB) , 2 1 13 email to WCDA duty to file sb89 competency
evaluation form 0204 065630 067980.pdf (833.6 KB) , 2 2 12 0204
RMC 26405 W Gardner Order granting Puentes Withdrawal with Cert
of Service by email to RCA and Loomis and 1422 E. 9th address for
Coughlin.pdf (267.0 KB) , 2 4 12 03628 0204 Appellant's Opening
Brief.pdf (353.6 KB) , 2 5 12 0204 Coughlin's TPO Application
against RJC Bailiff Reyes.pdf (1248.3 KB) , 2 6 12 email from Fortier
regarding Dogan 065630.pdf (30.3 KB) , 2 6 13 email to Watts
WCDA please responde to my subpoenas.pdf (137.3 KB) , 2 7 12
0204 065630 26405 email from lstuchell@washoecounty.su re deputy
machen's 11 7 11 personally served affidavit.pdf (69.2 KB) , 2 7 12
Couglin's Opening Brief in appeal 60838 and Supplement thereto
cr11-2064 record on appeal and filing in appeal itself 0204 608384.pdf (1413.5 KB) , 2 7 12 Order by Chief Justice Pickering striking
SBN's record on appeal, suspending briefing schedule 0204 62337.pdf
https://bay002.mail.live.com/mail/PrintMessages.aspx?cpids=cbdcbb06-1f5a-4ca8-8fb4-4cc7f3de239f,m&isSafe=false&FolderID=00000000-0000-0000-0000-0
1/40
2/28/13
(28.3 KB) , 2 8 12 0204 Flanagans Order to Show Cause that RMC

Marshal Harely violated courthouse sanctuary doctrine servingt 2 27
12 CV11-03628-2696056.pdf (132.3 KB) , 2 8 13 inmate booking
information form Coughlin 50336 epo violations 0204.pdf (434.4 KB)
, 2 8 13 inmate release information 0204 50336 epo.pdf (444.9 KB) ,
2 11 13 Nnahms intake mental health eval proof for now 12-067980
063341 cr12-2025.pdf (781.8 KB) , 2 12 13 065630 WC Jail Inmate
Release Information Form 5 days in jail summary contempt for being
late to court Clifton 2 12 13.pdf (822.7 KB) , 2 12 13 WC Jail Inmate
Booking Information Form 0204 62337.pdf (1040.7 KB) , 2 13 13
0204 60302 01168 Coughlin ltr to re Joshi request 2.13.13.wpd
(1).pdf (54.5 KB) , 5 7 04 judicial discipline commission opinion nv
on judges writing letters.pdf (49.4 KB) , 5 13 09 0204 Springgate's
Opposition to Coughlin's Reconsideration Motion DV08-011681070083.pdf (193.7 KB) , 5 13 09 Springgate's Motion to Strike
Coughlin's Notice of Appeal 0204 DV08-01168-1070084 01955
60302.pdf (338.1 KB) , 5 14 09 email from
mashely@washoelegalservices.org 0204 01955 01168 not providing
attorney to defend Coughlin Gardner Order.pdf (23.6 KB) , 5 14 12
and 7 31 12 0204 RX history email to @nvbar.org with attachment to
email to @nvbar.org from Zach Coughlin rx history since February
2008.pdf (1324.4 KB) , 5 15 12 0204 063341 Mental Health Court
mh-0032 contract coughlin rcr2012-065630 rcr2011-065630 5 5
2012.pdf (596.5 KB) , 5 18 12 0376 certified copy of order remanding
to justice court 0204 CR12-0376 650630 FV12-01012 rains mhc
dogan rmc 26405 00696 26800 rpd elliot-2.pdf (32.7 KB) , 5 20 09
0204 01168 54844 Coughlin's Reply to Springgate's Opposition to
Mtn Reconsideration Appdx G DV08-01168_1083206.pdf (559.7 KB)
, 5 20 09 email from 2JDC Fladager DV08-01168 regarding Eflex
copying Purdy.pdf (118.8 KB) , 5 21 09 0204 01168 Judge L.
Gardner's ORDER DENYING REQUEST FOR
RECONSIDERATION 53833 54844.pdf (249.2 KB) , 5 21 09
Springgate's Prop FOFCOLDOD 0204 01168 01955 email Springgate
w 5 21 12 Req Sub Prop Ord spare sanct compare 4 10 09 Ord.pdf
(128.0 KB) , 5 24 09 0204 01168 email to 2JDC Fladager about
curious refusal to file Couglin's 5 20 09 Reply Oppos 5 21 09 Ord
Deny Reconsid.pdf (212.8 KB) , 5 26 09 email from Springgate 0204
54844 0204 re wdcr 9 proposed final decree he says he did his
discovery in the 16.1.pdf (25.2 KB) , 5 28 09 0204 01168 01955 letter
2/40
2/28/13
from Springgate regarding personal communications.pdf (62.9 KB) , 5

28 09 email from Michelle.Purdy@washoecourts.us 0204 01168
54844.pdf (31.3 KB) , 5 29 09 0204 01168 54844 eFlex email from
Cindy.Fladager@washoecourts.us Purdy.pdf (14.6 KB) , 5 29 09 0204
01168 email from 2JDC eFlex received notice of Coughlin's
Opposition to Motion.pdf (153.6 KB) , 5 29 09 email to Springgate
54844 01168 0204 21 day safe harbor provision of NRCP 11.pdf
(19.1 KB) , 12 0 04 Letter of Recommendation Hale Lane's Kelly
Testolin 0204.pdf (1379.8 KB) , 12 2 11 1708 contest lien LT
Coughlin (disp of pers ppty - with encl).pdf (86.4 KB) , 12 8 06 CBX
filing citing Hale Lane employment 13577 printed.pdf (37.0 KB) , 12
8 09 0204 letter from Springgate 01955 01168 Coughlin letter.pdf
(41.8 KB) , 12 8 11 letter to Richard G. Hill re contest personal
property lien.pdf (110.8 KB) , 12 9 04 0204 Lawyer's Concerned for
Lawyers Coe Swobe Letter of Recommendation.pdf (1181.0 KB) , 12
27 11 stamped cover page of 15 page fax arguably applies to 37 page
fax that followed it with fax header NOA RJC may have failed to file
stamp for 12 21 11 Sferrazza Order Resolv Pers Prop Lien 0204 1708
03628 3 30 12 Order not included.pdf (2039.7 KB)
Dear Supervising Clerk Purdy,

TERMINOLOGY
Appropriate authority means the authority having responsibility for initiation of disciplinary process in connection
with the violation to be reported. See Rules 2.14 and 2.15.
I am not longer and efiler, but was between 1/4/12 until deactivation in mid
November of 2012. All during that time the only pdf available for the 1/4/12
Supplemental in CV11-03628 was the attached 3 page version, which fails to
include the actual documents or filings listed in the "Appeal Receipt". Such a
failure to include those filed, especially one that is characterized as
"Emergency Letter to Court from Zach Coughlin, Esq" (which is not a "letter"
but rather my submission for filing of a "Notice of Appeal" of the 12/21/11
Order Resolving Motion to Contest Personal Property Lien by RJC Judge
Sferrazza. The failure to include such items in what was provided to Judge
Flanagan for review in the ROA became very deleterious to my case in a
number of ways, including as mentioned in Judge Flanagan's 3/30/12 Order
denying my appeal, and now, arguably in the 12/14/12 Findings and
3/40
2/28/13
Conclusions and Recommendation to disbar me permanently from the

practice of law in Nevada incident to opposing counsel Hill's allegation that
my pursuing a stay, on or around December 22nd 2011, under NRS 40.385
was vexatious or otherwise violative of RPC 3.1 (Meritorious Claims and
Contentions) (which I believe the attached transcript from Venetian v. Two
Roads disproves).
I am writing to request the 2JDC email me or provide an electronic copy (or,
a hard copy) of the entirety of what it received, at any point, from the RJC in
connection with the 1/4/12 Supplemental filing in CV11-03628.
I believe it would appropriate not to charge me for this given anything beyond
the intial 3 page version of that 1/4/12 filing was never available during an 11
month period wherein I did have an eFlex subscription.
A footnote on page 5 of Judge Flanagan's 3/30/12 Order in CV11-03628
indicates: "... In addition, because Coughlin failed to timely file his notice
of appeal regarding the personal property lien, see NRS 40.253(8), and
because Coughlin's notice of appeal fails to identify an error regarding
the court's procedure in setting a hearing on this issue, this Court will no
consider this issue."
The testimony at Coughlin's formal disciplinary hearing on 11/14/12 included
the following:
"FORMAL HEARING - Vol. I, (Pages 51:10 to 54:17)
51
...
12
Was Mr. Coughlin, in his dealings with you as
13 an attorney, was he truthful or did he show candor in his
14 dealings with you as a lawyer?
15
MR. COUGHLIN: I'm sorry, your Honor. If I
16 can interject. It's been well over 15 minutes.
17
MR. ECHEVERRIA: That's true. Do you want to
18 wrap it up, Mr. King?
19
MR. KING: Yes.
20 BY MR. KING:
21
Q With that said, did he show candor to you?
22
A In our dealings with Mr. Coughlin, you could
4/40
2/28/13
23 not trust him at all. No agreement ever made with

24 Mr. Coughlin was honored by him.
25
For example, when Judge Sferrazza ordered that
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
52
Mr. Coughlin could have two days -- he was originally
given a week to move his stuff out before the eviction
order was served. Thereafter there was a hearing. The
judge gave Mr. Coughlin two days to go in and remove his
possessions.
Mr. Coughlin -- we went over there, opened the
doors about 8:00 o'clock. He wasn't there. About 11:00
o'clock we get an e-mail from Mr. Coughlin saying I have
appealed Judge Sferrazza's ruling. That means his ruling
is stayed. That means I can go back into the house. I'm
staying in the house, and there's nothing you can do about
it.
MR. COUGHLIN: Objection, hearsay.
THE WITNESS: Sometime later that day we got
an order from Judge Sferrazza saying that the request for
a stay had been denied. Mr. Coughlin had burned basically
a whole day doing nothing trying to get his stuff out.
That was typical....
53
1
2
3
4
5
6
7
8
9
10
11
12
top of what was going on.

Finally, when we got in the district court, we
were able to use the e-flex system, and we were able to
keep track of what was going on.
BY MR. KING:
Q Let me restate the question. The question is:
As an attorney, having a responsibility to be truthful and
to have candor with opposing counsel, was Mr. Coughlin
truthful, and did he use candor with you?
A No.
MR. ECHEVERRIA: Mr. King, wrap it up, please.
You're limited to 15 minutes.
5/40
2/28/13
13
14
15
16
17
18
19
20
21
22
23
24
25
BY MR. KING:
Q Specifically relating to Mr. Coughlin's candor
to the court, did he show candor to the courts?
A No.
Q In his demeanor -MR. COUGHLIN: Objection. Lack of foundation.
MR. KING: My last question.
MR. COUGHLIN: Pretty damming statement to
have no foundation.
MR. ECHEVERRIA: Please don't interrupt. We
haven't heard the question yet to which you've objected.
MR. COUGHLIN: The last one, whether I showed
candor to the court, and he said no.
54
1
MR. ECHEVERRIA: You object to that one? It's
2 overruled. Go ahead.
With respect to the NRS 40.385 Motion for Stay issues, I believe it may also
be relevant the extent to which my attempted filings were refused by the 2JDC
from that time, especially given NRAP 8. Please see attached emails and
CV11-03051.
Also, I am requesting an electronic copy of the entire file in DV08-01168
given I believe I was wrongfully withheld access thereto during times of
exigent circumstances in 2009 (please see attached emails and note the
5/20/09 filing by myself could not have been consider in Judge Gardner's
5/21/09 Order given such 5/20/09 filing was not entered until at least
5/24/09, despite what the file stamping thereon may indicated.
Please note WLS then Board President Breckenridge requesting and picking
up the audio cd of the Uribe TPO hearing from 3/12/09 at which the 2JDC
CAAW run TPO Office Advocate, Roxanne express aghast horror at
Coughlin's representation of a male domestic violence victim in FV0900886. Further Elcano's representations vis a vis Coughlin's competency are
not exactly bourne out by Coughlin's filing in the Davenport TPO and divorce
case upon his taking over for then WLS Board President Breckenridge, whom
6/40
2/28/13
missed the I-864 Affidavit of Support issue. Note, Coughlin, Judge

Flanagan, and WCDA DDA Halstead all worked together at Hale Lane.
Lastly, please consider that, as currently carried out by the WCSO Civil
Division, Washoe County takes the absolutely most brutal approach to
conducting eviction lock-outs, essentially reading NRS 40.253 to allow the
WCSO Civil Division race over to a tenant's rental minutes after the summary
eviction proceeding, and gain access with the help of a locksmith, and
immediately begin going through such a tenant's personalty, then locking
them out (even without their medications or eyeglasses or state issued
identifcation) whereupon the tenant is then subjected to the fraudulent
approach taken by some attorney's, such as Richard G. Hill, Esq. (see his
12/2/11 coercive letter to Coughlin) in applying NRS 118A.460 in the most
specious manner imaginable.
There is a great deal of confusion as to the law in Nevada vis a vis 24 hour lockout notices and how soon after posting one the constable or Sheriff may effectuate
the lock-out: http://www.lpsnv.com/EvictionFAQ.pdf: "7. DOES MY TENANT
HAVE RIGHTS? Yes they do. When the notice is served, your tenants rights
state that they can contest the notice with the justice court from the moment that
they receive the notice. Their reasons can vary, but they must get their Tenants
Response filed with the court of jurisdiction. It will then be approved or denied
by the judge. If it is approved, then a hearing will be scheduled. Your tenant can
also contest the 24 Hour Lock-out Notice, which is posted by the Constable. This
notice is posted 24 hours before the Constable returns to the property to do the
lock change."
Gayle Kern, Esq., ought to have been made to follow RPC 3.5A, but regardless,
she should not have been granted any Writ of Restitution or Lockout Order on
3/15/12 merely upon a default basis Coughlin filed a detailed Tenant's
Affidavit that could speak for him at the hearing, and the initial burden is on the
landlord (ie, the party moving for summary judgment under Anvui), and Kern
failed to even file a Landlord's Affidavit. Kern obtained a default summary
eviction against Coughlin on 3/15/12 (despite Coughlin's detailed 3/8/12 filing of
a Tenant's Answer and Pre-Hearing Brief), resulting in Couglhin being summarily
evicted at gunpoint hours later (despite Kern having failed to first file a
Landlord's Affidavit as required by NRS 40.253(6) (so if Coughlin was two
minutes late to that 3/15/12 hearing, why no overly rigid and formulaic
application of procedural rules against Kern?). Consequently, at Coughlin's
11/14/12 formal disciplinary hearing, NVB Judge Beesley testified as to
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Coughlin's appearance before him minutes after being evicted at gunpoint by the
WCSO (whom were violating NRS 40.253(6) in failing to post a lockout order,
then wait 24 hours before barging in with guns drawn). Somehow, Judge Beesley
never considered that Sheriff misconduct might have an effect on Coughlin's law
practice, nor, curiously, did Judge Beesley manage to mention that Coughlin's
3/30/12 filing before him in NVB 10-05104 Cadle Co. v. Keller detailed Judge
Beesley's 1977 McGeorge School of Law classmate now RMC Judge Nash
Holmes confiscating Coughlin's smartphone and micro sd card after summarily
incarcerating him for 5 days on 2/27/12, though such confiscation occurred after
Coughlin's personatly had been book in at the Washoe County Jail, and therefore
was not done incident to a search incident to arrest, and therefore required a
warrant or Order to so take out of where it was booked into Coughlin's personal
property at the jail and release to the City of Reno Marshals a day later, as
WCSO Deputy Hodge admitted to Coughlin, with local attorney Pam Willmore
standing by, on March 19th, 2012. Following the 3/30/12 filing by Coughlin
detailing this before Judge Beesley, Judge Nash Holmes entered an Order
releasing Coughlin's property entered 3/30/12. WCDA DDA Kandaras finally
signed off on that Order and Coughlin's was only then permitted to retrieve his
property on 4/7/12, though all the data thereon was wiped prior to it being
returned to Coughlin. Coughlin did not lie to Judge Nash Holmes in court on
2/27/12 in 11 TR 26800, and Judge Nash Holmes has offered nothing in the way
of factual support for her initial contention that Coughlin had lied to her that day,
which, during Coughlin's cross examination of her at his formal disciplinary
hearing on 11/14/12, resulted in the basis proffered by Judge Nash Holmes for
her suspicion that Coughlin had lied to her being thoroughly and easily disproven
given the patent inaccuracies inherent to Judge Nash Holmes contention that she
had interrogated Coughlin about recording and recording devices prior to his
requesting to be permitted to use the restroom, when, in fact, such interrogation
only occurred after the one and only restroom break in that "simple traffic
citation".
Further, Judge Nash Holmes consistently alternates between finding something
occurred by "clear and convincing evidence" only to alternately characterize her
findings as indicated such was "probable" or that she believes something
"probably occurred":
HEARING - Vol. I, (Pages 139:11 to 157:2)
139
11 ut a bathroom break?
12
A I'm sorry. What marshals when?
13
Q Well, the ones you reference on the audio from
14 the March 12th hearing?

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15
A Well, again, which -- my marshals. Could you
16 be more specific, please, in your question?

17
Q How much have they told you about the
18 hearing -19
MR. ECHEVERRIA: Mr. Coughlin, you interrupted
20 the judge. She asked you a question. Do you want to be

21 specific as to a particular conversation?
22 BY MR. COUGHLIN:
23
Q Yeah. There was one bathroom break in the
24 hearing. What were you told during the bathroom break by

25 either a marshal or the city attorney?
140
1
MR. ECHEVERRIA: With respect to any
2 particular issue, Mr. Coughlin?

3 BY MR. COUGHLIN:
4
5
Q No. Just anything. Anything connected to me?

MR. ECHEVERRIA: That's what I'm asking. Is
6 it involving you, sir?

7
MR. COUGHLIN: Yes.
THE WITNESS: Mr. Coughlin asked for a
10 bathroom break. I originally said I would not give the

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11 break. And then I said that I would, but he had to leave

12 all his materials in the courtroom. And I said that
13 because I suspected that he was tape-recording the court
14 proceedings without my permission, and without asking
15 permission first. Because he's apparently been known to
16 do that.
17
MR. COUGHLIN: Objection, hearsay. Lack of
18 foundation.
19
20
THE WITNESS: So I required one of my marshals
21 to accompany him to the restroom.

22
MR. COUGHLIN: She just gets to say a bunch of
23 hearsay?
24
MR. ECHEVERRIA: Mr. Coughlin, she is
25 responding to your question.
141
1
Go ahead, Judge.
THE WITNESS: When the marshals came back from
3 the restroom, they told me that Mr. Coughlin had, in fact,

4 been recording the proceedings because he had disassembled
5 a device and left parts of it in the bathroom. Or left -6 disassembled parts of it, and then they discovered parts
https://bay002.mail.live.com/mail/PrintMessages.aspx?cpids=cbdcbb06-1f5a-4ca8-8fb4-4cc7f3de239f,m&isSafe=false&FolderID=00000000-0000-0000-0000-
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7 of it.
8
In any case, when he was taken into custody
9 and held in contempt of court at the jail, he had

10 physically two recording devices on him, a cell phone -11 either two cell phones or a cell phone and some other
12 recording device. I assumed that was pieces of which he
13 was messing with in the bathroom.
14 BY MR. COUGHLIN:
15
Q Which marshal told you that?
16
A I'm sorry? I can't hear that.
17
Q Which marshal --
18
MR. ECHEVERRIA: Mr. Coughlin, you don't need
19 to yell.
20
THE WITNESS: It was Marshal Harley that told
21 me that, Joel Harley, H-a-r-l-e-y. He said when they went

22 in and checked the bathroom after Mr. Coughlin left, and
23 he had found evidence that he had disassembled some object
24 or something in there.
25 BY MR. COUGHLIN:
142
1
A I just described it as some sort of a
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3 recording device. Whether it was a cell phone and he took

4 the SIM card out or whatever it was, I wasn't sure. But I
5 had asked you, Mr. Coughlin, point blank in court if you
6 were recording, and you told me no. And then you asked
7 immediately to go to the bathroom, and I said no. And
8 then you begged and squirmed and said you had to relieve
9 yourself, and I had to let you go to the bathroom. And
10 then when you did that, you went into the bathroom -11 BY MR. COUGHLIN:
12
Q Really?
13
A Took apart and disassembled a recording
14 device.
15
16

MR. ECHEVERRIA: Mr. Coughlin. I've asked you
17 repeatedly to please not interrupt people.

18
19
MR. ECHEVERRIA: It was clear she wasn't when
20 you were interrupting her.

21
22
23
MR. COUGHLIN: Okay.
24
MR. ECHEVERRIA: You've asked a question of
25 the judge. She answered it. Do you have a question?

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143
1 BY MR. COUGHLIN:
2
Q Judge, was there one bathroom break during the
3 trial?
4
A I'm sorry. The crowd has recessed here, and
5 let me move across the hallway, because I can't hear

6 anything right now, there's a big crowd.
7
Q Don't worry. Just my law license, Judge. No
8 biggie.
9
Was there one bathroom break?
10
MR. ECHEVERRIA: Mr. Coughlin, I for one do
11 not appreciate your side comments. I think you should

12 focus seriously on the issues to be addressed here. The
13 judge simply asked for accommodation so she could hear.
14
MR. COUGHLIN: I only have so much time, your
15 Honor.
16
MR. ECHEVERRIA: I know. Quit wasting it.
17 BY MR. COUGHLIN:
18
19
20
21
A I'm sorry, I can't hear you again. Say it
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22 again.
23
MR. ECHEVERRIA: Did you review the audio of
24 the trial?
25
THE WITNESS: I have not reviewed them
144
1 recently, no. I did at the time. I did when I entered my
2 contempt order and sent my package to the discipline
3 board.
4 BY MR. COUGHLIN:
5
Q Why does the audio of the trial indicate that
6 you did not ask any questions about recording until after
7 the one bathroom break?
8
A I'm not sure that's the case. I don't know.
Q That is the case.
10
11 BY MR. COUGHLIN:
12
Q Yet you testified today that Mr. Coughlin
13 asked to use the bathroom right after I asked him about

14 recording. How do you explain that?
15
A I don't know the sequence of events. I don't
16 recall -17
Q You just said you --
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18
A I listened to the audio at the time when
19 things happened. And when you came back from the

20 bathroom, either way I determined from -- I concluded that
21 you were most likely recording without my permission.
22
Q Earlier your testimony was that you asked
23 Mr. Coughlin if he was recording, and he got real squirmy

24 and asked to use the bathroom. Is that correct?
25
A Yes.
145
1
A No.
Q You just said, I don't know the sequence of
4 events.
5
A Well, I don't recall the sequence of events.
6 I know that I asked you if you were recording. You denied

7 you were. I asked you a couple times if you were
8 recording, if you had gotten permission to record, what
9 you were doing. And at some point it was determined that
10 you most likely were.
11
Q You know there is an audio of these things
12 you're testifying to, right, that we can like compare to

13 what you're saying; right, Judge?
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14
MR. ECHEVERRIA: Mr. Coughlin, please exhibit
15 a civilized tone.
16 BY MR. COUGHLIN:
17
Q You're aware there's an audio?
18
A Yes, there's an audio. I have not --
19
Q That we can compare --
20
A -- I'm giving you my best recollection at this
21 time.
22
MR. ECHEVERRIA: Mr. Coughlin, you're trying
23 my patience with your continuing interruptions. That's

24 not evincing the conduct of a competent lawyer. You
25 should wait until the witness finishes before interrupting
146
1 her.
2
MR. ECHEVERRIA: Go ahead. Ask your next
4 question.
5 BY MR. COUGHLIN:
6
Q So the marshals said Mr. Coughlin left some
7 disassembled part of a recording device in the bathroom,

8 and they retrieved it from there; is that correct?
9
A I don't recall the exact words. The
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10 impression I got from what the marshal said is that you

11 had gone into the bathroom, disassembled some sort of
12 recording device, and they went in the bathroom after you
13 and checked that and determined that. That's my
14 recollection of the events.
15
Q Is that murky recollection of yours maybe the
16 reason why the law requires, in a contempt not occurring

17 in the immediate presence of a judge, that somebody
18 actually put their name on an affidavit and sign it?
19
MR. KING: Mr. Chairman, as Bar counsel, a
20 member for Bar Counsel office, I find -21
THE WITNESS: Mr. Coughlin, you were not found
22 in contempt on that reason alone. You were found in

23 contempt for engaging in behavior of the same kind it
24 appears that you're doing now, and much more than that.
25 And you were found in contempt for your entire conduct
147
1 throughout the course of the proceedings, including
2 repeatedly asking questions I ordered you not to ask,
3 delving into areas I had ruled were inadmissible, being
4 disrespectful, making faces, pretending like you were a
5 mime, sitting down, slumping down, standing up, walking
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6 around, and doing a number of other things that were

7 completely improper in the manner of conducting a trial.
8 BY MR. COUGHLIN:
9
Q Is it proper procedure for you to --
10
A -- among one of the many reason why I found
11 you in contempt of court, sir.

12
Q Is it proper for you to call something summary
13 criminal contempt when you cite to a civil contempt

14 statute?
15
A I don't know what is proper in your book,
16 Mr. Coughlin. I know that the behavior that I saw, I know

17 that I held you in contempt, I held a precise -- you
18 committed direct contempt in front of me in my court -19
Q Criminal contempt or civil contempt?
20
A -- I held you in contempt on the spot, and
21 then I went and wrote the order.

22
MR. ECHEVERRIA: Mr. Coughlin, you continue to
23 interrupt. I'm getting very tired of it. That's improper

24 behavior. As you said, your law license is at stake here.
25 You should exhibit behavior that would justify you keeping
148
1 it. Have I made myself clear?
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MR. COUGHLIN: Yes.
MR. ECHEVERRIA: Thank you.
Go ahead, Judge. Had you finished?
THE WITNESS: I finished with that answer,
6 yes.
7
MR. ECHEVERRIA: Go ahead, Mr. Coughlin.
8 BY MR. COUGHLIN:
9
Q Judge, did your order characterize it as
10 misdemeanor criminal contempt?

11
A I do not have my order in front of me, so you
12 can consult my order. I believe it was misdemeanor

13 contempt. I believe it was criminal, direct criminal
14 contempt.
15
MR. COUGHLIN: I'll note on Page 3 at line 14
16 it says, Misdemeanor of criminal contempt, a violation of

17 NRS 22.010.
18
MR. ECHEVERRIA: Which order are you referring
19 to, Mr. Coughlin?

20
MR. COUGHLIN: February 28th order. Page 3,
21 line 14.
22
MR. KING: I think it's Exhibit No. 4.
23
MR. ECHEVERRIA: Okay.
24 BY MR. COUGHLIN:
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25
Q Judge, is NRS 22.010 a civil contempt statute?
149
1
THE WITNESS: Mr. Coughlin, you can consult
3 the statutes. I don't have my books right in front of me.

4 NRS identifies in Chapter 22 contempt. And the Reno
5 Municipal Code has sections relating that or incorporating
6 those sections into the Reno Municipal Code.
7
Either way, what you did in front of me was
8 direct contempt, and I held you in direct contempt, and

9 you went to jail for five days because of it.
10 BY MR. COUGHLIN:
11
Q Is it permissible for a judge to call a civil
12 contempt statute a criminal contempt statute, vis-a-vis -13 this is 22.010, a civil contempt statute. And the law in
14 Nevada does have NRS 199 -- I believe it's 240 -- which is
15 the criminal contempt statute. Is it permissible for you
16 to cite to a -- easier to meet civil contempt statute, and
17 then recharacterize it as criminal contempt?
18
19
THE WITNESS: Mr. Coughlin, I'm not going to
20 argue the law with you. You have the statutes there. You
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21 can consult them yourself.

22 BY MR. COUGHLIN:
23
Q On Page 3 at line 4, sub .9 --
24
MR. ECHEVERRIA: Which exhibit, sir?
25
MR. COUGHLIN: Exhibit 4, your Honor.
150
1 BY MR. COUGHLIN:
2
Q You wrote, defendant lying to the court in
3 response to direct questions posed by the court.

4
What were the lies in your vague order that
5 lacks any specificity to support a summary contempt

6 finding, what were those lies that you failed to elucidate
7 in your order?
8
MR. ECHEVERRIA: Mr. Coughlin, that question
9 is argumentative. Do you want to rephrase it?

10
MR. COUGHLIN: Sure.
11 BY MR. COUGHLIN:
12
Q What were you referring to when you wrote,
13 "Defendant lying to the court in response to direct

14 questions"?
15
A Well, it would be explained in the order
16 there. I don't remember everything at this time because I

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17 don't have it in front of me. But I do believe that you

18 lied about or misrepresented that you were not recording,
19 because I believe you probably were. I don't know. I
20 believe you probably were.
21
At the same time there were things that you
22 and the prosecutor were arguing about with regard to

23 discovery. And she disagreed with you and said you were
24 lying to her about that. And there were other items that
25 you went back and forth about that appeared to me that you
151
1 were not totally honest about.
2
3
Q So when -MR. ECHEVERRIA: Excuse me. Mr. Coughlin, let
4 the record reflect that it's 12:18. I'll afford you two
5 more minutes.
6
MR. COUGHLIN: Thank you, sir.
7 BY MR. COUGHLIN:
8
Q When you say, alternately you were probably
9 lying. And then you put in your order, "I find by clear
10 and convincing evidence that he lied," is that ambiguous
11 there? How do you reconcile that?
12
A How do I reconcile what?
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13
Q The fact that your order says you find by
14 clear and convincing evidence?

15
A Because that's what I wrote. I did find by
16 clear and convincing evidence. I found by absolutely

17 convincing evidence that you were behaving improperly in
18 court, as you are now, apparently.
19
Q You're saying you found by clear and
20 convincing evidence that a licensed attorney lied to the

21 court. And then you characterize that as probably, well,
22 I kind of think he was. I think he was, because I know
23 some unattributed hearsay that I'm going to base it on.
24 I'm going to get the order I think is wrong about the
25 bathroom break. I'm not going to have a marshal sign an
152
1 affidavit. Then I'm going to remix a criminal contempt
2 statute with a summary contempt statute and pick and
3 choose and make it as retaliatory as I possibly can.
4 Isn't that a fair characterization of your approach as a
5 judge?
6
MR. ECHEVERRIA: Judge, you don't need to
7 answer that question. That was way out of line, and

8 extremely argumentative.
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THE WITNESS: Thank you.
10
MR. ECHEVERRIA: Do you want to ask a
11 legitimate question, Mr. Coughlin?

12 BY MR. COUGHLIN:
13
Q What basis do you have to assert in your order
14 that defendant lying to the court in response to direct

15 questions posed by the court with regard to his recording
16 the proceedings?
17
A The opinion is self-explanatory. I do not
18 have it in front of me, Mr. Coughlin. You have access to

19 the tapes and the opinion. And I stand by what I wrote,
20 and I stand by the proceedings that day.
21
Q But it's kind of hard to pick inconsistencies
22 in your testimony today and those materials when you

23 refuse to testify now, isn't it?
24
MR. ECHEVERRIA: Argumentative, Mr. Coughlin.
25 You are not assisting yourself here.
153
1
MR. COUGHLIN: I'm asking her. It's a
2 question.
3
MR. ECHEVERRIA: No.
MR. COUGHLIN: Is that not true that she is
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5 subverting the legal process by refusing to testify

6 instead of saying, well, read the order and read -- listen
7 to the recording, and therefore she is not subjecting
8 herself to putting forth any further inconsistencies.
9
MR. ECHEVERRIA: Mr. Coughlin, the time for
10 argument is later, not now.

11
MR. COUGHLIN: Okay. So I'm objecting. It's
12 nonresponsive.
13 BY MR. COUGHLIN:
14
15
Q What was your basis -MR. ECHEVERRIA: That objection is overruled.
16 Now it's 12:20. If you have anything further of

17 significance that's relevant to the issues in this case,
18 please ask that question, I'll allow you one more.
19 BY MR. COUGHLIN:
20
Q What was communicated to you during the
21 bathroom break, and by whom?

22
MR. KING: Asked and answered.
23
MR. ECHEVERRIA: I think you've asked that.
24
MR. COUGHLIN: I don't think she answered it.
25
MR. ECHEVERRIA: She did. Do you have another
154
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1 question, Mr. Coughlin?

2
MR. COUGHLIN: Sure.
3 BY MR. COUGHLIN:
4
Q Did you or anyone with the Reno Municipal
5 Court transmit or otherwise deliver Judge Linda Gardner's

6 order for sanctions to the State Bar of Nevada?
7
A I'm sorry. I didn't hear all that. Did I
8 what? You'll have to repeat the question.

9
Q Did you or anybody with your court, the Reno
10 Municipal Court, transmit or otherwise deliver Judge Linda

11 Gardner's April 2009 order sanctioning me to the State Bar
12 of Nevada?
13
A I'm sorry. Deliver to whom?
14
MR. ECHEVERRIA: The State Bar, Judge.
15
THE WITNESS: Oh. After -- let me explain
16 quickly. My trial was my first experience in exposure to

17 Mr. Coughlin. After everything happened, and I held him
18 in contempt, then Judge Gardner told me that his sister,
19 Judge Gardner, has a life experience with Mr. Coughlin,
20 and he provided me a copy of her opinion from a couple
21 years earlier. And that may have been in the package I
22 forwarded to the court. I forwarded everything I could
23 possibly include that would show Mr. Coughlin's ability to
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24 practice law. Including Mr. Coughlin's 200-page motion

25 that he faxed to the court.
155
1
MR. ECHEVERRIA: Thank you, Judge. It's now
2 12:22, and we'll excuse you. And we appreciate you taking

3 the time -4
MR. COUGHLIN: Can I ask one more question
5 about the pending -6
MR. COUGHLIN: -- competency evaluation or --
MR. ECHEVERRIA: Mr. Coughlin.
MR. COUGHLIN: -- with the trial? It's a good
10 question.
11
MR. ECHEVERRIA: It's an interruptive
12 question, and it's improper conduct.

13
MR. COUGHLIN: You're not going to let her
14 answer that, huh? You are not going to make her answer
15 that?
16
MR. ECHEVERRIA: I'm sorry. I continue to
17 talk while you're trying to interrupt.

18
Judge, thank you for your testimony.
19
MR. COUGHLIN: She held a trial with a pending
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20 competency evaluation in violation of law.

21
MR. ECHEVERRIA: Quit interrupting,
22 Mr. Coughlin.
23
MR. COUGHLIN: I just got it on the record.
24
MR. ECHEVERRIA: Thank you, Judge. We
25 appreciate you taking your time into the lunch hour.
156
1
THE WITNESS: Thank you. I'll hang up now.
MR. KING: Thank you, Judge.
MR. ECHEVERRIA: It's now 12:23. Mr. King, do
4 you have additional witnesses?

5
MR. KING: I have -- my understanding is I'll
6 have two additional witnesses. I'm not certain that I

7 will be able to reach them, but Judge Howard and Judge
8 Elliott.
9
MR. COUGHLIN: I'd like to call Judge Nash
10 Holmes in my case in chief and ask her why she persists in

11 holding trial if she was aware of a pending competency
12 order.
13
MR. ECHEVERRIA: You had the opportunity to
14 ask her those questions.

15
MR. COUGHLIN: No, I didn't. You just refused
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16 it to me.
17
MR. ECHEVERRIA: No, I gave you --
18
MR. COUGHLIN: You did another basis for an
19 impartiality finding.
20
MR. ECHEVERRIA: I'm sorry. I have this
21 terrible habit of continually talking while you're trying

22 to -23
MR. COUGHLIN: You're not letting me ask any
24 question that would tend to implicate impropriety on the

25 part of a judge.
157
1
MR. ECHEVERRIA: You can characterize the
2 rulings as you wish. I have made the rulings."
Regardless, in both 1708 and 374, NRS 40.253 does not allow for the Washoe
County Sheriff to conduct evictions in the manner in which is currently does.
Hill's filings claim that the WCSO's procedures, by being the usual and
customary practices of the WCSO, somehow become black letter law in
Nevada, even where a statutory remedy is in place, one that the legislature
worked hard on (despite RJC Judge Pearson, in 1048, ignoring AB226's minor
tenant's rights victory where it required the landlord to, under NRS 40.253(3)(a)
identify the court that has jurisdiction over the matter... and 3(b)(1)'s dctate that
such notice advise the tenant: (1)Of the tenants right to contest the matter by
filing,... an affidavit with the court that has jurisdiction over the matter..., in
the face of the unauthorized practice of law on behalf of out of state corporation
no less, Northwinds Apartments Assoc., LLC of Washington state.
NRS 40.253(6) provides...6.Upon the filing by the tenant of the affidavit
permitted in subsection 3, regardless of the information contained in the affidavit,
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and the filing by the landlord of the affidavit permitted by subsection 5 (note,
both in 1708 and 374, neither landlord filed such a Landlord's Affidavit in a
timely manner, and Merliss in 1708 never filed one at all. If Baker and Hill want
big boy attorney's fees, they should be required to get those sorts of things right to
justify such exorbinant fees, or even begin to), the justice court or the district
court shall hold a hearing, after service of notice of the hearing upon the parties,
to determine the truthfulness and sufficiency of any affidavit or notice (Baker
continually maintained that it was only Coughlin's Affidavit which was up for
inspection, in violation of RPC 3.1) provided for in this section. If the court
determines that there is no legal defense as to the alleged unlawful detainer
and the tenant is guilty of an unlawful detainer, the court may issue a summary
order for removal of the tenant or an order providing for the nonadmittance
of the tenant.
So, really, especially in 1708, all the debate about the import and application
of the within 24 hours language is inapplicable anyways, as that phrase is
only applicable to a situation where the tenant does not file a Tenant's
Answer in respose to a 5 day UD Notice being posted.
NRS 40.253(5):.Upon noncompliance with the notice:
(a)The landlord or the landlords agent may apply by affidavit of complaint
(note, there is nothing in Ch. 40 that allows for a landlord's agent to draft
pleadings or appear on behalf of an out of state corporation, cross the bar,
and practice law on its behalf, as WNM's Sue Kign did in 074408 and 374,
and as NCS's Jeff Chandler did in 1048) for eviction to the justice court of
the township in which the dwelling, apartment, mobile home or commercial
premises are located or to the district court of the county in which the
dwelling, apartment, mobile home or commercial premises are located,
whichever has jurisdiction over the matter (in 374, RJC Judge Schroeder
issued such an Order prior to Kern even filing a Landlord's Answer). The
court may thereupon issue an order directing the sheriff or constable of the
county to remove the tenant within 24 hours after receipt of the order.
But, again, where Coughlin did comply with the 5 day notice, in both 1048, 374,
and 1708, NRS 40.253(5) language is inapplicable (The court may thereupon
issue an order directing the sheriff or constable of the county to remove the
tenant within 24 hours after receipt of the order.) Rather, it is NRS
40.253(6)'s language that controls: If the court determines that there is no
legal defense as to the alleged unlawful detainer and the tenant is guilty of
an unlawful detainer, the court may issue a summary order for removal of
the tenant or an order providing for the nonadmittance of the tenant.
There being nothing thereing speaking to some within 24 hours dicate, the
default application in civil law requires that such an an Order be served
under NRCP 6(e) where personal service is not accorded, thus requiring 3
days for mailing. Further, NRAP 8 and some 5 day stay suggested in Anvui, is
arguably applicable. There is little indication in Ch. 40 or elsehwhere to
provide some explanation of just how and in what manner such a summary
order would be carried out and whether it would allow for the approach
taken by the WCSO in such situations. While NRS 40.253(3)(b)(2) does
contain the term summary order, the appearance therein of the within 24
hours language, combined with the non-appearance of such within 24 hours
30/40
2/28/13
language in NRS 40.253(6), under traditional principles of statutory

construction, actually augers for an interpretation of subsection 6 that would
require more time for a tenant than is provided for under NRS 40.253(3)(b)
(2):That if the court determines that the tenant is guilty of an unlawful
detainer, the court may issue a summary order for removal of the tenant or
an order providing for the nonadmittance of the tenant, directing the sheriff
or constable of the county to remove the tenant within 24 hours after receipt of
the order...
It seems rather implausible to suggest that the within 24 hours language is
some dictate to the Sheriff or constable requiring such lockouts be
effectuated in some narrow window of time. Rather, particularly given the
primacy to individual's and businesses inherent to their uses as residences of
places of business (or, in 1708, as both) it would seem entirely more likely,
and reasonable, to conclude that the legislature intended for the within 24
hours language to afford tenant's at least 24 hours from the posting (if
not the constructive receipt in the mail under NRCP 6(e) if no personal
service was to be had) of such a lock-out Order to remove those items they
find absolutely essential (see Coughlin's difficulties in 1048 where deprived
of his medications, eyeglasses, contacts, some important legal files, etc, not
to mention the RPC 3.5A violation attendant to the default on 7/5/12,
especially where the RJC and NCS's Chandler knew Coughlin was in jail
incident to a 7/3/12 arrest stemming from Northwind's handyman Kreb's
falacious accusation of Coughlin disturbing the peace.
the court may issue a summary order for removal of the tenant
Also, the RJC may need to explain why it failed to file in fax filings by
Coughlin where it either did file in some by Hill and Baker in 1708 (or
consider any failure to file any 10/13/11 Affidavit of Unlawful Detainer by
landlord Merliss).
The SBN is likely resting upon some theory that the TPO and EPO granted it by
RJC Judge Pearson, which indicates that Coughlin may . First, the 1/4/13 EPO
granted the SBN indicates that Patrick Owen King, Esq., appeared at the
Extension Hearing to represent the SBN. As such, King, knowing he was
extremely likely to be a witness in such an action, had a duty to withdraw from
representation, and therefore himself violated a RPC 1.16 requir he so withdraw
where his being a witness was a virtual certainty. Further, King's TPO
application rests almost entirely on unsworn hearsay, for which King makes no
indication with regard to from whom or how he became aware of such hearsay
detailing such purported facts. For instance, the magic of hearsay may allow a
comment like its not fair that Bar Counsel King gets all this ex parte face time
with Panel Chair Echeverria that may have been said to Dena Echeverria on the
telephone to become, according to King, a statement by Coughlin to Echeverria's
staff that he was coming down to the Panel Chair's Office, threatening to get some
face time. Coughlin's 1996 Honda Accord's electrical problems (an electrical
short caused problems with Coughlin's headlights requiring a primitive
workaround requiring Coughlin to braids five elecrical wires together to turn his
vehicle's headlights on...something King alleges, through unattributed hearsay,
31/40
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was a case of Coughlin malingering around the SBN's Northern Office after 5 pm
flashing his headlights at the one or two women whom were working late
(because, one can be absolutely sure, Asst. Bar Counsel King has never worked
late a day in his life, and certainly not while employed by the SBN, thanks to SCR
106, natch), in an attempt to frighten and harass them. Then there is the curiosu
allegation by King in his TPO application that Coughlin called the SBN ahead to
announce he would be there in fifteen minutes to file something. King somehow
alleges that is threatening behavior even where he subsequently indicates that he
had sent Coughlin a letter demanding that Coughlin do just that prior to appearing
at the SBN for any reason, including to file documents.
VIOLATIONS OF NRS 178.405 AND NRS 5.010 BY RENO CITY

ATTORNEY AND WASHOE COUNTY PROSECUTORS AND RMC AND
WCPD COURT APPOINTED DEFENDERS
September 8th, 2011 Order for Competency Evaluation by Judge Schroeder
in RCR2011-063341
September 9th, 2011: Coughlin arrested at Wal-Mart in RMC 11 CR 22176
for petty larceny October 10th, 2011: Coughlin arraigned in RMC 11 CR
22176 for petty larceny charge
October 26th, 2011 (or a short time after depending upon entry of order)
Judge Sferrazza declares Coughlin competent in RCR2011-063341
February 27th, 2012: file stamped at 1:31pm in RCR2012-065630 Judge
Clifton signs an Order for Competency evaluation of Coughlin
-February 27th, 2012: despite being present at the "clandestine status
conference" (Dogan's client Coughlin was noticed, in writing, that it had been
reset to March 29th, 2012) DDA Young filed an Opposition to Motion to
Continue Trial Date and Motion to Appoint Co-Counsel on 2/27/12 at 2:55
pm in a companion case that he was also prosecuting, RCR2011-063341 in
violation of NRS 178.405. In her March 13th, 2012 grievance against
Coughlin, Judge Nash Holmes admits to communications in this regard
between her and the Washoe County Public Defender's Office. -February
27th, 2012: At 3:00 pm, despite the communications she admits to with the
WCPD, Judge Nash Holmes holds a trial where Coughlin is forced to appear
as an indigent criminal defendant proceeding with self representation in 11
TR 26800, which is suspened upon Judge Nash Holmes finding Coughlin in
"summary criminal contempt" seconds after he testifies that RPD Sargetn
Tarter lied in connection with a retaliatory traffic citations incident to Tarter
telling Coughlin to leave the law office of Richard G. Hill, Esq. on November
15th, 2012 after Coughlin was released from 3 days in jail incident to a
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criminal trespass custodial arrest upon Hill lying to officers and signing a
criminal complaint in 11 CR 26405 for criminal trespass on November 13th,
2012. Tarter ordered Coughlin to leave after Hill refused to give Coughlin
his state issued drivers license or identification, his hard drives/client's files,
his keys, or his wallet. -Judge Nash Holmes proceeds to file numerous Orders
-March 5th, 2012: in RMC 11 CR 26405, the criminal trespass case from
Coughlin's former home law office the Certified Copy of Docket done by the
Judicial Assistant, D2's Lisa Wagner, who couldn't quite seem to find or
remember the fact that Coughlin faxed in a Notice of Appeal on June 28th,
2012, and her failure to docket that led to the dismissal of Coughlin's appeal
in CR12-1262, despite Coughlin having electronic confirmation of receipt of
that fax delivering his Notice of Appeal to the RMC and to City Attorney
Hazlett-Stevens (whom coyly tries to assert he didn't get it or the paper copy
Coughlin personally delivered to the offices of the City Attorney within the
10 days set forth in NRS 189.010) Trial date set for April 10, 2012 by Court.
-05 March 2012: Notice Of Appearace As Co-Counsel And Motion To
Dismiss filed defendant. 20 March 2012: Order #1 denying defendant's
motion filed 13,February 2012 signed Judge William Gardner. RMC 11 CR
26405 -21 March 2012: Order #2 denying defendant's motion filed 5, March
2012 signed by Judge William Gardner. RMC 11 CR 26405 -21 March
2012: Motion To Strike Defendant's Motion To Dismiss Complaint filed by
Deputy City Attorney Christopher Hazlett-Stevens. RMC 11 CR 26405 -10
April 2012: Defendant appeared for trial with counsel Keith Loomis, Judge
William Gardner
1/5
presiding. Present on behalf of the City was Christopher Hazlett-Stevens.
Several pre-trial motions were heard. An Order Suspending Proceedings was
signed. All proceedings suspended until the question of competence is
determined. Case Status Hearing scheduled for 8, May 2012. RMC 11 CR
26405. See attached emails demonstrating the knowledge of and complicity
between the Washoe County Public Defenders, the court appointed Reno
Municipal Court defenders, the City of Reno Prosecutors, Washoe County
District Attorney's Office, RMC, RJC, and both court's filing office's staff
and administrators respecting the existence of these Orders for Competency
Evaluation and the brazen violation of NRS 178.405 and NRs 5.010 by these
individuals. Further, on
-April 19th, 2012, DDA Young again violated NRS 178.405 where he moved
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to have Coughlin remanded to custody (whereupon Coughlin could again

have his medication suddenly withheld from him, all while RMC Judge Nash
Holmes seeks to leverage jail staff to get Coughlin to sign some waiver of his
medical records privacy rights and where WCPD Biray Dogan announces
confidential HIPAA protected medical information relating to his client
Coughlin into the public record, in front of 40 members of the public
gathered in D10, a transgression which WCPD Jeremy Bosler later refused to
seek to ameliorate or strike from the record in any manner whatsoever).
-May 7th, 2012 (the day Coughlin's Opposition to Hill and Baker's
4/19/12 impermissible Post-Judgment Attorney Fee Sanctions Motion in
CV11-03628 (no 21 day filing ready safe harbor motion served either,
much like the approach by Springgate approved of by Judge L. Gardner
incident to here 4/13/09 Order After Trial in DV08-01168, which became
the third grievance against Coughlin underpinning the appeal in 62337 of
the Recommendation to permanently disbar him...so, just who is it who is
asserting non-meritorious contentions?). Further, Judge Flanagan's
8/28/12 Order in CV11-03628 makes clear that his 6/25/12 Order
awarding landlord Merliss (incident to Hill and Baker's attorney fee
sanction motion) was only entered in view of Judge Flanagan's opinion
that Coughlin failed to oppose their 4/19/12 Motion for Attorney Fee's
Sanctions in light of DCR 13(3). Apparently the Washoe County jail
ripping Coughlin of psychotropic medications and refusing him any
ability to file court documents, paper, envelopes, or even make phone
calls did not provide "good cause" for reconsidering that monumental
fee award. Coughlin, or those attorney's seeking sanctions under NRS 7.085
without complying with the dictates of NRCP 11? in RCR2011-063341
WCPD Goodnight and DDA Young violate NRS 178.405 by attempting TO
HOLD A TRIAL in that matter during the pendency of an Order for
Competency directored towards Goodnight's client, Coughlin. Goodnight
manages to jam Coughlin into an ill-advised Mental Health Court sign-up in
MH12-0032, which ends badly when the MHC's Reno Biondo commits fraud
in asserting that Coughlin was removed from the MHC for "failing to
following MHC policies" similar to the arguments put forth by Sharon
Dollarhide, despite the MHC, and perhaps Goodnight too, having given
Coughlin a list of medications it prohibits, and a contract for entry into the
MCH, after having informed Coughlin he was accepted into the MCH upon
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2/28/13
entering the contract. The MCH subsequently threatened Coughlin with

incarceration for taking a medication is only after the fact objected to, then,
upon having the bargained for consieration, offer and acceptance pointed out
to it, the MCH lied and disparaged Coughlin to the RJC and others, causing
Coughlin reputational damage, and Coughlin's case was remanded to the RJC
at a later date. During this period of time, D10 Judge Elliot forced Coughlin
back into custody at the WCDC, where Coughlin has been denied his
medication every single one of his 10 trips to jail this year, with no titration
down of dosing whatsoever, even where Coughlin was willing and able to
arrange for delivery of the medication at his own expense, etc.
-08 May 2012: Case Status hearing held before Judge William Gardner.
Present on behalf of the City was Deputy City Attorney Christopher HazlettStevens, for the defense Keith Loomis and defendant Zachary Coughlin.
Defendant was found to be competent. Defendant's motion to remove Keith
Loomis as counsel granted. Trial date set by the court for June 18,2012.
RMC 11 CR 26405. Strangely, despite Coughlin still being subject to an as
yet to be ruled upon Order For Competency evaluation and despite Coughlin
having just the previous day been accepted into Mental Health Court and the
RJC case RCR2011-063341 transferred there, RMC Judge William Gardner
jammed Coughlin both into proceeding without the Sixth Amendment Right
To Counsel and into some trial setting, even though NRS 178.405 and NRS
5.010 forbids it, and even though Judge Gardner admitted to being aware of
Judge Nash Holmes, his fellow RMC Judge, seeking to have Coughlin's law
license taken away based upon a SCR 117 Disability Petition (Judge Nash
Holmes, in her March 14th, 2012 letter/grievance to the State Bar of Nevada,
wherein she purports to speak for Judge William Gardner and managed to
pass on to the SBN the April 2009 Order For Sanctions by Judge William
Gardner's sister Family Court Judge Linda Gardner, that Judge William
Gardner passed to Judge Nash Holmes after receiving from his sister
sometime in
2/5
the first quarter of 2012). Incidentally, Coughlin was previously a domestic
violence attorney at Washoe Legal Services until Family Court Judge Linda
Gardner's April 2009 Order sanctioning Coughlin $1,000 personally for the
arguments he made in representing a domestic violence victim in a divorce
trial were cited by WLS Executive Director Paul Elcano as the "sole reason"
for Coughlin being fired. Coughlin filed a Petition for Writ of Mandamus in
35/40
2/28/13
respone to that Order with the Nevada Supreme Court in 54844. Coughlin
filed a Notice of Appeal of the dismissal for insufficient service of process of
his wrongful termination case against Washoe Legal Services on February
27th, 2012, and that matter is currently on appeal with the Nevada Supreme
Court in 60302. Oh, and Reno City Attorney John Kadlic is a patient of Zach
Coughlin's father, Dr. Timothy Coughlin, and the City of Reno and or the
RPD have sought to pressure Coughlin's parents into having him
"committed", despite the fact that the numerous (about 8-10 ish) wrongful
arrests Coughlin has been subjected to this year (most of which violate Soldal
v. Cook County and have been captured on video tape, amazingly) all kind of
give Mr. Kadlic a bit motivation to quiet and or discredit Coughlin (and and
arrest on June 28th, 2012 by the WCSO and various instances this year where
fraudulent Affidavits of Service by the WCSO have been involved in arrests
of Coughlin give the WCDA Office its own motivations).
Given that this trial setting and denial of Coughlin's Sixth Amendment Right
to Counsel occurred during the pendency of an Order for Competency
Evaluation of Coughlin that the RMC, Judge William Gardner, court
appointed defender Keith Loomis, Esq. and City Attorney's Christopher
Hazlett-Stevens, Esq. were well aware of, the following are void: O5 June
2012: Notice Of Appearance As Counsel ; Motion To Dismiss; Motion To
Suppress; Motion For A Continuance Of Trial And Transfer To Mental
Health Court filed by defendant. 18 June 2012: Defendant appeared for trial
pro-per, Judge William Gardner presiding. Present on behalf of the City was
Christopher Hazlett-Stevens. Several pre-trial motions were heard. Motion to
Continue filed by defendant denied. Motion to Dismiss filed by defendant
denied. Motion to Suppress denied. Motion to Recuse denied. Motion to
Transfer to Mental Health Court denied. Case tried on its merits and the
Defendant was found guilty of the charge of Trespass, a violation of R.M.C
08.10.010. .."'Y25'2012 The Defendant was sentenced as follows: Trespass, a
violation of R.M.C 08.10.0 10. : Time Served (3 days at usual $100 a day,
and a $310.00 fine for a total of $610 raked in by the RMC on a first offense
trespass charge where typically the fine is $305. Also, Richard G. Hill, Esq.
lied under oath at that June 18th, 2012 criminal trespass Trial where he
testified that the RPD identified themselves as law enforcement and issued a
lawful order or warning for Coughlin to leave the premises prior to the
landlord kicking down a door to a quasi "basement" under the former law
office. The videos of the arrest filmed by Hill demonstrate that Coughlin was
never given an opportunity to heed any warning to leave given that day prior
36/40
2/28/13
to a custodial arrest being effectuated, contrary to the Supplemental

Declaration by RPD Officer Chris Carter, Jr. RPD Sargent Marcia Lopez
subsequently admitted that the RPD neither identified themselves as law
enforcement nor issued a lawful order to emerge from the basement prior to
landlord Merliss kicking down the basement door on November 13th, 2012.
WCSO Civil Supervisor Liz Stuchell has admitted in an email to Coughlin
that Deputy Machen's November 7th, 2011 Affidavit of Service swearing to
have "personally served" the RJC REV2011-001708 Summary Eviction
Order on November 1st, 2011 was "incorrect" in that to Machen "personally
served" means "posting it to the door when no one is home. However, given
NRS 40.400 makes applicable NRCP 5(b)(2) and 6(e) to summary evictions
(even those that are noticed by the RJC, in writing, as a "Trial" and even
where, at the October 13th, 2011 "summary eviction proceeding" the RJC
ruled that Coughlin "had met his burden of establishing there is a genuine
issue of material fact concerning his retaliatory eviction defense" and the
matter was then "set for trial on October 25th, 2011 provided Coughlin
deposits $2,275 into the court's rent escrow account", all of which violates
JCRCP Rule 109 and NRS
3/5
40.253(6)) the lockout Deputy Machen oversaw on November 1st, 2011 was
based upon a void Eviction Order and Decision of October 25th, 2011 and an
October 27th, 2011 Findings of Fact...that Hill's associate Baker testified as
to having apparently provided receipt thereof to the WCSO on October 28th,
2011, and which RJC Chief Civil Clerk Karen Stancil indicates were
transmitted to the WCSO via fax according to the usual custom and practice
of the RJC...meaning, the WCSO failed to effectuate a lockout "within 24
hours" of "receipt" of either of those Orders...meaning Hill and Merliss were
trespassing on November 13th, 2011, not Coughlin, and they brought the
RPD along for the ride, whereupon the RPD effected a wrongful arrest (based
upon lies by neurologist Merliss and his attorney Hill to the effect that they
warned Coughlin to leave that day prior to the RPD showing up, which is
clearly show to be false by the videos filmed by Hill and Merliss themselves
and Hill's subsequent testimony at the June 18th, 2012 criminal trespass trial
in 11 CR 26405).
May 9th, 2012: Order finding Coughlin competent in CR12-0376, by Judge
Elliot of Department 10 resolving the February 27th, 2012 Order for
Competency Evaluation signed by RJC Judge Clifton and file stamped at 1:31
pm on that date.
37/40
2/28/13
September 5th, 2012: Order for Competency Evaluation of Coughlin by

Judge Sferrazza in RCR2011-063341
October 2, 2012: WCPD Leslie and Dogan and DDA Young violate NRS
178.405 by swapping the October 15th, 2012 Trial continuation/Competency
Hearing Date in RCR2011-063341 with RCR2012065630, and
setting/stipulating to a new hearing on October 22nd, 2012, and resetting the
Trial date to November 19th, 2012, but not before attempting to cram
RCR2012-067980 onto the calendar with RCR2012-063341 for October
22nd, 2012 (and Leslie and Dogan lied to Coughlin about whether
"mandatory status conference" was held on August 6th, 2012 in RCR2012065630, and RCR2012067980, the latter at which Leslie set a Trial date of
September 18th, 2012 despite his legal assistant Linda Gray admitting to
Coughlin that Coughlin was provided no notice whatsoever of the August
6th, 2012 hearing date in those cases. Also, Dogan and Leslie again violated
NRS 178.405 on October 2nd, 2012 where tehy reset for October 30th, 2012
a Motion Hearing on DDA Young's impermissible Motion to Amend the
Complaint in RCR2012-065630 (six months after the arrest, no specific facts
pled in either to support either charge, really). Further, Dogan failed to alert
Coughlin in any way to the fact that, in his July 31st, 2012 Motion to Amend
Criminal Complaint, DDA Young attempted to, in violation of RPC 3.8,
amend the "misue of emergency services" charge (where Coughlin is accused
of using 911 to report police misconduct) to a charge that would provide the
District Attorney more leverage against Coughlin, a retaliatory prosecution,
for a crime that would damage Coughlin's law license given the import of
SCR 111(6), despite DDA Young lacking probable cause to so amend his
charge. Dogan and Young previously conspired to retaliate against Coughlin
incident to their "clandestine status conference" of February 27th, 2012,
which just so happened to be the date that Coughlin filed a Notice of Appeal
in his case against Washoe Legal Services 60302 and the date that Judge
William Gardner transferred jurisdiction from RMC D1 Judge Dilworth to
RMC D3 Judge Nash Holmes in 12 CR 000696, a case where Coughlin was
subject to a custodial arrest for jaywalkign on January 12th, 2012 incident to
Coughli's peacefully filming Richard G. Hill, Esq.'s contractor's crew from a
public sidewalk, disposing of property left at Coughlin's former home law
office due to Hill locking a gate thereto during the time Coughlin was
afforded to remove such property and where Hill had boarded up on of the
entrances to the property as well, in addition to remove the only ladder to the
4/5
38/40
2/28/13
upstairs attic/storage space at the property. On February 27th, 2012 in 11 TR

26800 Judge Nash Holmes told Coughlin she would have him thrown in jail
if he mentioned Richard G. Hill's name one more time. On January 31st,
2012, at an extension hearing on the TPO Richard Hill received against
Coughlinf or Coughlin's alleged jaywalking on January 12th, 2012, RJC
Judge Schroeder roared at Coughlin "do you want to go to jail!" when
Coughlin broached the subject of Hill's abuse of process. Judge Schroeder is
listed in the RJC docket as presiding over the February 27th, 2012
"clandestine status conference" that ultimately resulted in Judge Clifton
signing the Order for Competency Evaluation. It is unclear if any actual
hearing before a judge even took place that day, however.
5/5
Local judges seem to dutifully report some far flung applications alleged
violations of SCR's related to the media and reporters vis a vis hunches they
have about whether an attorney is recording the proceeding (which is in the
public record) or has "recording devices" in his pocket, yet violations of NRS
178.405 seem to receive scant application of Canon 2.15.
Sincerely,
Zach Coughlin
Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
7402 ZachCoughlin@hotmail.com
1 4 12 0204 1708 03628 Appeal Receipt tiff and Supplemental Justice Court Proceedings.pdf
12 21 11 1708 03628 Order Resolving Contest Property Lien NO NUMBERS.pdf
3 30 12 0204 03628 Order Denying Coughlin's Appeal of Summary Eviction Order.pdf
10 13 10 transcript of Motion to Stay execution of summary eviction order Venetian v Two Roads
compare to 60331 0204.pdf
8 23 12 0204 Complaint SBN v Coughlin stamped bf.pdf
11 14 12 0204 Transcript of Hearing with Index 170008ch-Full.pdf
12 14 12 stamped 0204 Order by Chair Echeverria Findings of Fact Conclusion of Law seeking to disbar
Coughlin bz no line numbers.pdf
39/40
2/28/13
10 17 11 emergency motion to stay summary eviction 1708 etc. 60331 AND 61383 COUGHLIN V MERLISS
26406 1708 26800 0204.pdf
10 17 12 Coughlin's Emergenc Motion commercial tenant no cause forbidden 0204 1708 60331 61383
0204-3.pdf
10 18 11 0204 1708 marked received by RJC Dreme Smith Coughlin's NOtice of Appeal of 10 13 11
Sferrazza Order after summary eviction hearing 03628 divests RJC jurisdiction.pdf
10 18 11 Notice of Appeal divesting RJC of jurisdiction CV11-03628 ENTIRE EFLEX COMBINED FOR
APPENDIX IN 60331 AND 61383 COUGHLIN V MERLISS 26406 1708 26800 NG12-0204 BF.pdf
10 19 11 baker letter to clifton emergency inspection with 10 20 11 sferrazza note order have p draft
order will isgn it 1708 0204.pdf
10 19 11 Justice Court Civil Appeal cv11-03051 couglhin v merliss 1708 0204 .pdf
10 26 11 0204 03051 1708 03528 Purdy marked as received by M. Purdy Mtn and Affid proceed on
appeal IFP Merliss v Coughlin eviction.pdf
10 27 11 to 11 2 11 Motion to Stay CV11-03051 03126 1708 emails to eflex purdee 26405 60331
purdee.pdf
10 27 12 emails on 03051 emergency appeal maybe a motion for stay 1708 26405 03126 conyers
orduna wdc 0204 purdy.pdf
10 27 12 emails on 03051 emergency appeal maybe a motion for stay 1708 26405.pdf
10 28 11 1048 am email to Purdy mpurdy@washoecourts.us 03051 appeal motion for stay compare
03126 0204 60331 61383.pdf
10 28 11 1054pm email to eflex and courtadmin@washoecourts.us 03051 03126 0204 10 PAGES.pdf
10 28 11 03126 motion and affidavit for ifp attached to from 10 26 11 civil suit merliss marked as
received by M. Purdy Mtn and Affid proceed on appeal IFP Merliss v Coughlin eviction.pdf
Download all
40/40
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RE: does Richard Hill have standing to file a grievance

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

Sent: Friday, March 23, 2012 9:12 AM
To: Patrick King; cdbaker@richardhillaw.com
Subject: does Richard Hill have standing to file a grievance
American Jurisprudence Trials
file:///R|/...20clear%20and%20convincing%20evidence%20standard%20echo%20from%20nash%20holmes%2026800.htm[12/10/2012 2:37:38 PM]
Database updated April 2011

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

From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list.
Sent: Fri 3/23/12 12:08 PM
To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Cc: David Clark (DavidC@nvbar.org)
March 23, 2012
Dear Mr. Coughlin,
Just moments ago I received an e-mail letter from the Clerk of the Court in Department 3. She
said that you appeared wearing pajamas over your clothes and were demanding and
argumentative. Apparently I will be receiving a report from the Marshals. As Assistant Bar
Counsel I would like to help you. However, my primary responsibility is to protect the public
and the administration of justice by insuring that Nevada Lawyers are complying with standards
required of the profession. It appears that you are not. I believe that there are ways to get you
assistance that may protect your license to practice law. I would sure appreciate the
opportunity to talk with you about resources and assistance that may help you through this
difficult time.
Patrick King, Assistant Bar Counsel

To: Patrick King
Subject: RE: does Richard Hill have standing to file a grievance
Mr. King,
This is the very first time you allege anyone other than Mr. King filed or alleged a
grievance. Please provide any documentation or proof related to these apparent
file:///R|/...ot%20note%20from%20clerk%20of%20court%20department%203%2003628%201708%2026800%201708.htm[12/10/2012 2:37:13 PM]
communications from judges that you are only now bringing up.
Sincerely,
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com Nevada Bar
No: 9473
From: PatrickK@nvbar.org
Subject: RE: does Richard Hill have standing to file a grievance
Date: Fri, 23 Mar 2012 17:18:34 +0000
Dear Mr. Coughlin,
I have repeatedly expressed my interest in having a meeting with you to discuss the grievances against you. You
claim to be too busy to meet with me, yet you have time to write lengthy e-mails and apparently to do legal research.
You asked if Mr. Hill has standing to file a grievance against you. Not only does he have standing to file a
grievance, as a lawyer in Nevada he may have an ethical obligation to report to the State Bar. As I have explained to
you, the grievances against you came not only from Mr. Hill but also from Judges from different Courts. These grievances,
and the evidence attached with them, rather clearly puts into question your competence to practice law. As I have
explained to you, I will make the evidence and exhibits available to you when you come to inspect them at my office. I
will not send you reports or document, especially since you claim your mail is being compromised.
As for the grievances you have made, nothing that you have submitted appears to show an ethical violation that
could be proved by clear and convincing evidence, which is the standard of proof required in disciplinary matters. As
such, at this time we have not opened any files based on the information you have submitted.
Sincerely,
Patrick King

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

Database updated April 2011
Defending Lawyers in Disciplinary Proceedings
31 Am. Jur. Trials 633 (Originally published in 1984)
III Attorney-Client Grievances
10 In general
11 Sources of complaints and grievances; checklist
12 Former criminal clients
13 Particular problem clients
14 Fee disputes; checklist of factors of reasonableness
15 Arbitration; forms
16 Fee dispute committee hearings; illustrative testimony
Chapter 13 debtors' attorney violated Nevada rule of professional conduct defining

professional
misconduct to include engaging in conduct involving dishonesty, fraud, deceit, or
misrepresentation
and engaging in conduct prejudicial to administration of justice, where attorney, acting in
bad faith,
filed documents which he or someone in his office generated to falsely certify debtors'
completion of
required credit counseling course and which he knew, or should have known, that debtors
did not
sign or otherwise adopt, and also certified documents as being completed by debtors. 11
U.S.C.A.
109; Nev.Rules of Prof.Conduct, Rule 8.4. In re Pagaduan, 429 B.R. 752 (Bankr. D. Nev.
2010).
Mr. King, could you please update me on that status and progress of the various grievances
I filed recently in addition to providing a detailed summary of the content of all of your
correspondences, written or otherwise, and telephone communciatiosn with Richard Hill or
anyone with his office. Further, please state whether Casey Baker is part of the grievance,
as Hill asserts he is filing it on Mr. Baker's behalf.
Sincerely,
Or, is Hill attempting to leverage the State Bar of Nevada's Bar Counsel to create "busy
work" for opposing counsel?
Zach Coughlin, Esq., PO BOX 60952, RENO, NV, 89506, tel: 775 338 8118, fax: 949 667 7402; ZachCoughlin@hotmail.com
Nevada Bar No: 9473
FILED
Electronically
03-26-2012:11:45:37 AM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2847752
CASE NO. CV11-03628
ZACHARY COUGHLIN vs MATTHEW MERLISS
DATE, JUDGE
OFFICERS OF
COURT PRESENT
APPEARANCES-HEARING
________________
03/26/12
ORDER TO SHOW CAUSE
HONORABLE
Zachary Coughlin, Esq. was present in Court, acting in proper person.
PATRICK
Casey Baker, Esq. and Richard Hill, Esq. were present in Court on behalf of the
FLANAGAN
Defendant, who was not present.
DEPT. NO. 7
10:05 a.m. Court convened.
M. Conway
The Court addressed the parties and requested they clarify their positions regarding the
(Clerk)
Motion Requesting an Order to Show Cause and address
S. Koetting
- the December 21, 2011 Order issued Judge Peter J. Sferrazza
(Reporter)
- this Courts Order dated January, 11, 2012 and
- Interference with the Order relating to the removal of the Plaintiffs property.
Counsel Baker responded.
The Court reviewed Supreme Court Order, Case No. 55668, Ristenpart v. the Second
Judicial District Court, in which this Court was ordered to vacate the contempt order, and
the Hicks v. Feiock, and City Council of Reno v. Reno Newspapers decisions.
Counsel Baker advised the Court that it is his opinion that the contempt matter is a civil
matter but the Court has the authority to order a fine and/or jail time.
The Court reviewed the Order issued on January 11, 2012 in which it denied the
Plaintiffs Motion for a Temporary Restraining Order or an Injunction preventing the
property owner from deposing of the tenants property or in the alternative a Motion for
Stay.
COURT FINDS that Plaintiff Zachary Coughlin has not violated its Order dated January
11, 2012.
COURT FINDS the parties may have a legitimate dispute relative to Plaintiffs actions
relating to the removal of the Plaintiffs property but that this dispute is in front of Judge
Sferrazza.
COURT ORDERED: Defendant Motion for an Order to Show Cause holding Zachary
Coughlin in Contempt: DENIED.
10:32 a.m. Court stood in recess.
****** IMPORTANT NOTICE - READ THIS INFORMATION *****
PROOF OF SERVICE OF ELECTRONIC FILING
A filing has been submitted to the court RE:
CV11-03628
Judge:
PATRICK FLANAGAN
Official File Stamp:
03-26-2012:11:45:37
Clerk Accepted:
03-26-2012:11:46:07
Court:
Second Judicial District Court - State of Nevada
Case Title:
ZACHARY COUGHLIN VS. MATTHEW

MERLISS (D7)
Document(s) Submitted:
***Minutes
Filed By:
Maureen Conway
You may review this filing by clicking on the
following link to take you to your cases.
This notice was automatically generated by the courts auto-notification system.
If service is not required for this document (e.g., Minutes), please disregard the below language.
The following people were served electronically:
CASEY BAKER, ESQ. for MATTHEW MERLISS
RICHARD HILL, ESQ. for MATTHEW MERLISS
ZACHARY COUGHLIN, ESQ. for ZACHARY
COUGHLIN
The following people have not been served electronically and must be served by traditional
means (see Nevada electronic filing rules):
-----
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03/07/2013 17:51 FAX
775 334 4226
I4J 0002/0002
Criminal Plvlsion
IN THE MUNICIPAL COURT OF THE CITY OF RERO

8
COUNTY OF WASHOE, STATE OF NEVADA:Y
MAR -'lc30,
Munfi l!J
Pj
' ,/c'l').I.1Ui
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. ,
CITY OF RENO,
AMENDED
Plaintiff,
CRIMINAL COMPLAINT
vs.
CASE NO. 13-100306
Zachary Coughlin ,
DEPT. NO.
Defendant.
DOB September 27, 1976
_______
I, Brian Sooudi, Deputy City Attorney, hereby complain that on or about January 3,2013,
at or near 9456 Double R. Blvd, City of Reno, State of Nevada, the above named defendant did
violate Nevada Revised Statute 33.350 Violation of a Temporary or Extend ed Order for
Protection Against Harassment in the Workplace 8S incorporated through Reno Municipal

Code 1.04.015 to wit: The Reno Justice Court i.sued a Temporary Order for the Protection
Against Harassment in the Workplace on December 20, 2012, with an expiration date of
J anuary 4, 2013. This Order prohibited the Defendant or an agent of the Defendant from
Contacting the Nevada State Bar. The Defendant was served this Order on December 26,
2012. On January 3,2013, Defendant had a male individual contact the location attempting to
file documents on behalf of the Defendant.
The City is requesting this Court to Issue a summons for the above count.
The
Defendant was originally arrested on February 8, 2013, and charged with a gross misdemeanor
in Reno Justice Court. The Washoe County District Attorney's Office indicated that the violation
is misdemeanor and since it occurred within. city limits the proper court of jurisdiction is the Reno
Municipal Court.
Pursuant to
hereby deelare upon information and belief and under
'1:l.rD1"::Lt.H'fA.-'f1'\regoing is true and correct to the best of my knowledge.

March 7, 2013
(Dated)
3/09
03/07/2013 17:50 FAX
775 334 4226
Criminal Division
IN THE MUNICIPAL COURT OF T HE CITY

COUNTY OF WASHOE, STATE OF NEVADA
CITY OF RENO,
AMENDED
CRIMI NAL COMPLAINT
Plaintiff,
vs.
Zachary Coughlin
CAse NO. 13-2445

J
DEPT. NO.
Defendant.
DOB September 27, 19 76
______
I, Brian Sooudi, Deputy City Attorney, hereby compl ain that on or about January 11,
2013, at or near 9456 Double R. Blvd, City of R e no , State of Nevada, the above named
defendant did v iolate Nevada Revised Statute 33.350 Violation of a Tempora ry or Extended
Order for Prote ction Against Harassment In the Workplace as incorporated through Reno
Municipal Code 1.04.015 to wit: The Reno Justice Court issue an Extended Order for the
Protection Against Harassment in the Workplace on January 4, 2013, with an expiration date of
January 4, 2014. The Defendant was served th is Order on January 5, 2013. This Order
prohibited the Defendant or an agent of the Defendant from contacting the State Bar of Nevada
by any means including facsimile (fax). On January 17, 2013, the Nevada State Bar received a
371 page fax with a cover page documenting it coming from "zachcoughlin."
The City is requesting this Court to issue a summons for the above count .
The
Defendant was originally arrested on February 8, 2013, and charged with a gross misdemeanor
in Reno Justice Court. The Washoe County District Attorney's Office indicated that the violation
is misdemeanor and since it occurred within city limits the proper court of jurisdiction is the Reno
Municipal Court.
Pursuant to NRS 171.102, I hereby declare upon information and belief and under
s true and correct to the best of my knowledge.
March 7, 2013
(Dated)
3/09
- ,'
(;ERtw(;AIE Of SERVICE
1
2
3
4
5
Pursuant to NRCP 5(b), I certify that 1
am
an employee of the Reno Municipal Court,
Reno, Nevada, and that on this date I served a true and correct copy of the foregoing document,
Amended Complaints on the party(ies) set forth below:
Placing said document in a sealed envelope placed for collecting and mailing
in the United States mail, at Reno, Nevada, postage prepaid, following ordinary
business practices.
Facsimile (FAX).
Reno/Carson Messenger Service.
Federal Express or other overnight delivery.
10
Inner-office mail following ordinary business practices.
11
Personal Delivery to City Attorney
12
Electronic mail to City Attorney
13
14
15
16
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18
19
Zachary Coughlin
1471 E. 9th ST
Reno, NY 89512-2906
20
21
22
23
24
25
26
27
RIlNO
MUNICIPAL COURT
P.O. Box 1900
R_NVI9SOS
(702) 334.2290
28
DATED this 11th, day of
NOTE: SUBMITTED FOR FILING PRIOR

TO 5 PM ON 1/3/12 TO SBN
BOTH BY FAX AND PERSONAL DELIVERY
CASE NUMBER: ng12-0204 ng-0435 ng-0434
STATE BAR OF NEVADA

NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,

PETITIONER
10
11
V.
) NG12-0204, NG12-0435, NG12-0434
)
)
ZACHARY BARKER COUGHLIN,
NV BAR 9473
12
RESPONDENT
13
14
15
MOTION FOR NEW TRIAL; MOTION TO ALTER OR AMEND CHAIR ECHEVERRIA'S

ORDER OF 12/14/12; MOTION FOR RECONSIDERATION
16
17
Zach Coughlin representing himself submits the above titled filing on his own behalf.
18
I, Zachary B. Coughlin, do hereby declara, pursuant to nrs 53.045, under penalty of perjury, that the
19 following is true to the best of my knowledge, for which i have percipient recollections of, except for
those matters which are stated upon information and belief (and Buckwalter allows for a Declaration
20 in Liue of An Affidavit, so a notary is not required here).:
21
22
23
24
25
26
27
28
Based upon NRCP 59 (a), (e) and NRCP 52, as applied through SCR 119 and SCR 105(4) prism,
timely given NRCP 6(e) and two intervening court holidays.
I. . NATURE AND SCOPE OF REMEDY
II. GROUNDS
(A) ERRORS AND IRREGULARITIES IN GENERAL,
(B) MISCONDUCT OF PARTIES, COUNSEL, OR WITNESSES,
(C) RULINGS AND INSTRUCTIONS AT TRIAL,
(D) DISQUALIFICATION OR MISCONDUCT OF OR AFFECTING JURY,
(E) IRREGULARITIES OR DEFECTS IN VERDICT OR FINDINGS,
(F) VERDICT OR FINDINGS CONTRARY TO LAW OR EVIDENCE,
(G) SURPRISE, ACCIDENT, INADVERTENCE, OR MISTAKE,
(H) NEWLY DISCOVERED EVIDENCE,
III. PROCEEDINGS TO PROCURE NEW TRIAL.
IV. PROCEEDINGS AT NEW TRIAL
- 1/100 MOTION FOR NEW TRIAL; MOTION TO ALTER OR AMEND CHAIR ECHEVERRIA'S ORDER OF 12/14/12; MOTION FOR
RECONSIDERATION
1 V. STATUTORY NEW TRIAL AS OF RIGHT

2
3
4
5
6
7
8
9
10
11
12
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20
21
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23
24
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28
Terrell v. Mississippi Bar, 635 SO.2d 1 377 Miss., 1 994 Bar Complaint Tribunal was not requircd to hold SepardlC
hearing on issue of imposition of discipline in anorney discirl inary hearing. where attorney did not file motion to
bifurcate hearing. Clements v. Alabama State Bar, 20 1 2 WL 2680044 C=45ATTORNEY AND CLIENT ..5lThe Office
of Attorney C=45l(C)Disciplinc :=45k 47Proceedings C=45k57k. Review. Ala.,20 1 2 Page I Attorney's brief failed to
contain sufficient argument or citations to authority, and thus attorney waived issue on appeal in disciplinary proceedings,
of whether Disciplinary Board of the State Bar violated her due process rights by failing to bifurcate proceedings arising
from two unrelated bar complaints; attorncy's brief cited general principlcs of law rcgarding due process, but failed to
provide any particular argument as to how the Board's failure to conduct separate hearings violated due process. U.S. CA.
Const.Amend. 1 4 . p- Disciplinary Matter Involving Triem, 929 P.2d 634 Aiaska, I 996 Bar Counsel's rcfercnces to
attorney's discipline record and other ongoing proceedings against attorney during hearings conducted before misconduct
deternlination was made was not prejudicial even though bifurcated misconduct determination and sanction
recommendation would have been preferable; independent review of entire record provided safeguard and all three current
proceedings could have been consolidated. State Bar Rules 12(i), 22((). H Smith v. State, 490 S.W.2d 902 T ex.C iv
.App.Corpus.Christi, 1 972 Where there was bifurcated trial of disciplinary action and trial court did not set punishment in
such way that reviewing court could justify or correct judgment when it found rcversible error with respect to two of
misconduct charges, entire proceeding would have to be remanded for new trial. State Bar Rules, art. 12, 21, Vernon's
Ann.Civ. St. following art. 320a-1.
The Florida Bar v. D'Ambrosio, 25 Su.3d 1109 =4:'iATTORNEY Ac'lD CLlE.'IT (:;;;;;;>4511be Office of AUorney
e=>4SI(C)lliscip]inc =4Sk 47PrO<.;edillgs :=45k47.1k. ln gencflIl. Fla.,2009 Pagel Respondent attorney could not
prevail 0lI allegation in attorney di....'iplinary pmceedinjp that Har had improperly _"stacked cases" against him, where
attorney bad voluntarily agr<'ed to consolidate the two cases against him for the: purpose\i of making II single
reoommendaholl of discipline. H Attorney Gricvalll.'e C{'>m'o of Maryland v. Ruddy, 981 A.2d 637 Md.,2009 Bar
counsel's consolidation of complaint agaim! allumey made by his opposing counsel in estate proceeding of aUomey's
laIC: aunt. in which attorney served as personal reprcscnlativc of estate and complaint filed by attorney's brother in
connection with estate proceeding, did not impennissib!y give implied credibility to complaint filed by Idtorney's brother,
or sugg..t a conflict of interest on pan of bar cOlUlsel. Ibough opposing counsel in cSUlte proceeding was also member of
Allorney Grievam;e Conulli..sion (AGe). as bar counsel hlKl duty to invcsljg.. ate all complaints filed with AGC that
wer", 1101 frivolous or unfounded, and complaint was simply me..hanism by which bar. In re Adelman, 717 ...Y.S.2d 17
N.Y.App.Div.I.Dtpl.,2000 CODoIidation of two "serious crime" disciplinary proceedings pending against attorney
served 10 promote interest of judicial economy. where both proceedings were Ixlsed on similar facls and similar criminal
offenses committed by attorney. McKinney's Judiciary L..w 90, subd. 4, par. d; KY.Ct.Rul.., 603.12(b). The 60838,
SCR 111(8) mandate is not connected enough or similar enough to justify going against the express dicate set out in SCR
111(8), especially where it affords the SBN a prejudicial advantage.C Rhodes v. SUlle Har. 775 P.2d IO..5 Cal .. I 'I!N
St..le Har is not required 10 consolidate iJl\'..stigation of aUeged mi..",onduf;t with pr"..lIisting disciplinary
proceedingRhlXks v. State Bar. 775 P.2d lm5 Cal..19R9 SUlte Har's failure to eo...olidate investigation of ..lkged
mi..eondu..t wilh preexistil)g di....iplillary proc"'eding did 1)01 act as res judicata IIr to sub\<quenl dis,iplinary
prc".eeding involving alleged misconduct. Stale Bar J'rocedure Rules 262. 511 C Rhodes v. Slate Bar. 775 P.2d lm5
('a1..1989 E..'cn if doubk je''Pardy principle applied in ..(torn..y disciplinary proceedings, instituling pmceedings on
..lleged mi5(;ondm:t that could have be",n, oul was not. ton..olldaled with prcex. isting disciplinary proceeding did Dot
violate double j",opardy clau..e wil..re State Bar considered counts tor disciplinary purpos..'S only_ Stat'" Bar Procedur'"
Rules 262, 511; USCA. Const.Amend. (81.,1971 COlllllJlidation for hearing in disciplilUlry proce..ding of Iwo assertedly
'unrelated ac:CUSlltions" did nol prejudice attorney where one of such matters ",as dismissed. RuIn of Procedure ofSu.te
Rar. rule 27; West's Ann.HIlS. & Prof.Code following section 6087. NOne of Coughlin's matters have been dismissed, so
it is prejudicial. Disciplinary Malter Involving Tricm, 929 P.2d 6H AIlI!<ka. I996 Bar Counsel's references to atlorneys
discipline record and uther ongoing proceedings a!o;"ainst attorney during hcarings conducted beforc misconduct
determination was made was not prejudicial even though bifuIcated miscouduct determination and saoction
recommendation wuuld haw been preferable: independent review of entire reeord provKkd safeguard and all tmee cun",nt
proceedings <.:ould have bet'll ..oRSolidaled. State Bar Rul.... 1 2(i), 22(1)
Since there has been so many issues with the Panel and SBN managing to "get" Coughlin's exhibits when attached as
cd/dvd's (and to faithfuly provide them to the Panel as agreed to (nevermind when Coughlin himself did so anyways) or to
the Nevada Supreme Court in the 12/24/12 filign of the Record on Appeal (which was filed too early in a lame attempt to
curtail Coughlin's right to file a NRCP 59(a),(e) or NRCP 52 Motion, the attached as cd/dvd's Exhibit 1 to this filing of
RECONSIDERATION
1 1/3/12 is provided at the following hyperlinked link, ocr'd text search, google optimized, which this motion will be as well
when attached to other filings in other court's as an exhibit:
2
4
5
6
7
http://sdrv.ms/VzWqse
"1.
Coughlin is an attorney licensed to practice law in the State of Nevada. At all relevant times
prior to and at the time of the filing of the Complaint in this matter, the Respondent's principle office,
as filed with the State Bar of Nevada in accordance with the Rule of Professional Conduct ("RPC")
79(1)(a), was Post Office Box 3961, Reno, NV 89505. See Hearing Exhibit 1 at 0001, lines 7-10
(State Bar of Nevada vs. Zachary B. Coughlin, Esq., Case No: NGI2-0204, NGI20435, NG I 2-0434,
Complaint at PI (filed August 23, 2012"
The above is completely untrue, and Chair Echeverria was made aware of this both by Coughli's
testimony on 11/14/12 and by the materials attached to at least give of Coughlin's filings, three of
10 which were made prior to the hearing, but all of which were prior to the 12/14/12 Order by Chair
Echeverria. Further, Coughlin's multiple changes of address this year were a material issue in this
11 matter, and the above statement reveals a great deal about the dishonest approach taken by the Chair
throughout these matters, especially where the changing of Coughlin's address (despite Couglin
12 adhering faithfully to SCR 79 at all relevant times) resulted, in part, in a deprivation of Coughlin's
SCR 105(2)(c) rights, and the SBN's callous refusal to make a small accomdation for a domestic
13
violence victim (Coughlin in FV12-00187) ought now be held against them and the Panel were th
14 10/9/12 NOITD was mailed via only certified mail and the SBN purposefull refused to copy Coughlin
thereon by fax or email, and the SBN's placing insufficient postage on that 10/9/12 NOITD certified
15 mailing resulted in "Tim" of the downtown USPS postal station refusing to release it to Coughlin, and
that mailing is confirmed as having been "returned to sender" upon a review of the USPS Track &
16
Confirm records attached hereto.
9
17
18
The Chair's 12/14/12 Order (which was signed only by the Chair in contrast the unanimous signing
by all 5 Panel members in In Re Mirch, indicating a lack of consensus amongst the Panel members,
19
reads: "4.
Coughlin's conduct during the trial of the petit larceny case on November 30, 2011, in
20 which Coughlin appeared in propria persona, was so disruptive that Judge Howard found Coughlin in
direct contempt of court and sentenced him to jail that same day to be released on December 3, 2011
21 at 8:00 PM. Judge Howard specifically found Coughlin's conduct to be disorderly and was either
contemptuous or behavior insolent toward the judge in that Coughlin refused:
22
23
24
"... to obey directives of the Judge, continuing lines of inquiry after being advised by the Court to
refrain from doing so; demeaning the Court with statements such as "WOW" in response to court
rulings; laughing during testimony and further questioning the court and its authority."
25
26
See Hearing Exhibit 11 ORDER FOR SUMMARY PUNISHMENT OF CONTEMPT COMMITTED

IN THE IMMEDIATE VIEW AND PRESENCE OF THE COURT, November 30, 2011."
27
28
Therein, Chair Echeverria is clearly attempting to set up his later purposeful mischaracterization of
Judge Howard's Order as one of "two criminal contempt" convictions, when, in fact, Judge Howards
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
11/30/11 ORDER FOR SUMMARY PUNISHMENT OF CONTEMPT COMMITTED IN THE

IMMEDIATE VIEW AND PRESENCE OF THE COURT specifically cites to a civil summary
contempt statuts, NRS 22.030, not the "criminal contempt" statute, NRS 199.340 (note, Judge Nash
Holmes' 2/28/12 Order Finding the Defendant in Contempt of Court and Imposing Sanctions in RMC
11 TR 26800 (which, contrary to Judge Nash Holmes testimony, was not "served on him (Coughlin)
at the jail" and was not mailed to a valid address for Coughlin, even upon the RMC receiving it back
as "return to sender" (invalid address) (a purposeful failure to send that Order to a valid address for
Coughlin, much less the email or fax address and numbers Coughlin provided the RMC, especially
where Judge Nash Holmes and the RMC staff went out of their way to cull all of the Orders, audio
transcripts, and filings by Coughlin across all RMC departments, and was certainly aware of
Coughlin's 817 N. Virginia St. address used in November and December 2011, then was further
aware of the 1422 E. 9th St. #2 address Coughlin used between January and March 2012 (and was
even aware of the domestic violence attacks Coughlin ws subjected to in FV12-00188 and
concomitant difficulty in getting the Golden Valley USPS postal station to allow Coughlin a key to
his mailbox at that address, then was made aware of the temporary PO Box 60952, Reno 89506 that
Coughlin used briefly between May 14th, 2012 until April 15th, 2012, whereupon Coughlin (again, at
all times appropriately updating his address with the courts and the SBN consistent with the dictates
of SCR 79) began using PO Box 3961, Reno 89505, until he file an Official USPS Change of Address
(See Exhibit X) on October 10th, 2012 having his mailed forwarded to his current 1471 E. 9th St.,
Reno, NV 89512. Stanford alumn legacy admit John Echeverria, however, seemingly fails to grasp
the very human toll the fraudulent manner in which summary evictions are procurred and carried out
in Washoe County have on its citizens, especially those whom are domestic violence victims.
14
15
16
17
18
19
20
"NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any
one of the following kinds shall be guilty of a misdemeanor:
1. Disorderly, contemptuous or insolent behavior committed during the sitting of the court, in its
immediate view and presence, and directly tending to interrupt its proceedings or to impair the
respect due to its authority;
2. Behavior of like character in the presence of a referee, while actually engaged in a trial or
hearing pursuant to an order of court, or in the presence of a jury while actually sitting in the
trial of a cause or upon an inquest or other proceeding authorized by law;
21
3. Breach of the peace, noise or other disturbance directly tending to interrupt the proceedings of
a court, jury or referee;
22
4. Willful disobedience to the lawful process or mandate of a court;
23
5. Resistance, willfully offered, to its lawful process or mandate;
24
6. Contumacious and unlawful refusal to be sworn as a witness or, after being sworn, to answer
any legal and proper interrogatory;
25
7. Publication of a false or grossly inaccurate report of its proceedings; or
26
8. Assuming to be an attorney or officer of a court or acting as such without authority"
27
Both contempt order at issue in this matter (the 11/30/11 Judge Howard Order and the 2/28/12
28
Judge Nash Holmes Order (which was not attached to the SBN Complaint, and therefore was not
RECONSIDERATION
appropriately noticed to Coughlin, and any punishment based thereon should be stricken for violation
of procedural due process, as that Order cannot even be said to be incorporated by reference into the
2 8/23/12 Complaint, nor even identified in the SBN's vague, non-specific Designation of Witnesses
and Summary of Evidence of 10/12/12 (which was not timely provided to Coughlin in violation of
3
SCR 105(2)(c) where the earliest Coughlin could have received that, through no fault of his own, ws
4 on 10/22/12 for a 11/14/12 hearing, where "at least 30 days" constructive notice thereof is required by
SCR 105(2)(c).
1
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
" NRS 22.030 Summary punishment of contempt committed in immediate view and presence of
court; affidavit or statement to be filed when contempt committed outside immediate view and
presence of court; disqualification of judge.
1. If a contempt is committed in the immediate view and presence of the court or judge at
chambers, the contempt may be punished summarily. If the court or judge summarily punishes
a person for a contempt pursuant to this subsection, the court or judge shall enter an order that:
(a) Recites the facts constituting the contempt in the immediate view and presence of the court
or judge;
(c) Prescribes the punishment for the contempt.
2. If a contempt is not committed in the immediate view and presence of the court or judge
at chambers, an affidavit must be presented to the court or judge of the facts
constituting the contempt, or a statement of the facts by the masters or arbitrators. (THIS IS
WHERE MARSHAL HARLEY NEEDS TO SIGN ON THE LINE AND FURTHER,
WHERE THE RMC NEEDS TO EXPLAIN ITS FAILURE TO PROPOUND THE
MARSHAL REPORT INCIDENT TO THE "DISASSEMBLING A RECORDING DEVICE
AND HIDING PARTS OF IT IN THE RESTROOM" NARRATIVE JUDGE NASH
HOLMES TESTIFIED TO BY ALLUDING TO UNSWORN BARELY ATTRIBUTED
HEARSAY TO MARSHAL HARLEY, WHOM SHE THEN REFERS TO IN THE PLURAL
AT VARIOUS POINTS)
3. Except as otherwise provided in this subsection, if a contempt is not committed in the
immediate view and presence of the court, the judge of the court in whose contempt the
person is alleged to be shall not preside at the trial of the contempt over the objection of
the person..."
Judge Howard's 11/30/11 Order fails to meet the Houston v. Eighth Judicial District Court
standard of specificity as to the facts consistuting the contempt, and further, nothing during the Trial
23
could be said to have sufficiently warned Coughlin as to how he might comply with any such
24
admonishment, further Coughlin has, and here again, specifically denies any and all of the allegations
in the Complaint and or any of the various Orders incorporated therein, or as is the case with Judge
25 Holmes 2/28/12 Order, Coughlin denies any of the accusation therein even where the SBN's
Complaint cannot be said to have pled such alleged misconduct as a charge in that SCR 105
26
Complaint. Regardless, neither the 11/30/11 nor the 2/28/12 contempt orders provide anythign other
27
than a circular, conslusory, vague support for their conclusions, nor provide anythign in the way of
specificity as to what facts, exactly support such Orders (compare to Judge Elliott denying Coughlin's
28 Appeal in CR11-2064 where Coughlin went on and on with specifity as the the basis and legal
22
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
support for his arguments, Judge Howard and Nash Holmes do nothing more than essentially copy
and paste the language of the contempt statute and draw a conclusions, beyond Judge Nash Holmes
purporting to, ever so conveniently, make a record of that which does not appear in the record
(alleging Coughlin to have made mime-like faces or to have "looked in his jacket as if to look for
another way to ask a question" or to have, alternatively sat down or stood up, etc., etc....further, Judge
Nash Holmes misquotes Coughlin in her Order, Coughlin did not make the exact statements she
alleges, particularly where her Order attempts ot characterize Coughlin's statements regarding seeking
input as to what questions he may ask as a command issued by Coughlin ("give me a list" was,
actually, more along the lines of "perhaps, if you gave me a list of questions that were acceptable it
would enable me to proceed more expeditiously"). Further, Judge Nash Holmes consistently
mentions, on the audio transcript of the 2/27/12 Trial and 3/12/12 continuation thereof, that she
merely "thinks there is probably an issue" with respect to the whether Coughlin violated the various
RPC's she mentions. Additionally the SBN providided absolutely no legal citation for the implicit
contention that a pro se attorney in a criminal prosecution owes some RPC duty to his "client", or in a
summary eviction proceeding or appeal thereof, and certainly, it is not fair to so find where Sellers
would not allow for a pro per attorney litigant to receive an attorney's fee award under NRS 69.030.
Beyond mentionign that Coughlin said "Wow", Judge Howard's Order is nothing if not circular and
conclusory, and even where Judge Howard and Judge Holmes get a bit more specific in alleging
Coughlin "continued lines of inquiry", its not as if either Judge actually specified which line of
inquiry was continued, and when, specifically a sufficiently detailed and clear warning was issued
enablign Coughlin to reasonably know how to comply with it (and, regardless of Judge Nash Holmes
criticisms of Coughlin 3/7/12 Notice of Appeal Filing (and it is misleading to say the "document" was
214 pages, when, in actuality the document filed was 54 pages with some 150 pages of
attachments...especially where Richard G. Hill, Esq. Regularly makes filings with voluminous
attachments).
16
17
18
19
20
21
22
23
24
25
26
27
28
Judge Nash Holmes 2/28/12 Order cites to NRS 22.010 (not even a summary in nature statute) and
NRS 22.100:
"NRS 22.100 Penalty for contempt.
1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall
determine whether the person proceeded against is guilty of the contempt charged.
2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine
may be imposed on the person not exceeding $500 or the person may be imprisoned not
exceeding 25 days, or both.
3. In addition to the penalties provided in subsection 2, if a person is found guilty of contempt
pursuant to subsection 3 of NRS 22.010, the court may require the person to pay to the party
seeking to enforce the writ, order, rule or process the reasonable expenses, including, without
limitation, attorneys fees, incurred by the party as a result of the contempt."
A review of the Title headings under which these various contempt statutes fall make clear that
neither of the contempt Orders mentioned in the Chair's 12/14/12 Findings of Fact, Conclusions of
Law (FOFCOL) are "criminal contempt" or "misdemeanors". Therefore, the obvious attempt by the
SBN and Chair to leverage some SCR 111(5) "a conviction is conclusive proof of guilt" for the
purpose of transmogrifying a "simple traffic citation trial" into some sort of summar disciplinary
proceeding, is completely inappropriate and reprehensible, tending to indicate that some
RECONSIDERATION
accountability and training may need to be injected into the "work" of Bar Counsel King, his
supervisor David Clark, and Chair Echeverria, and the other members of the Panel (including Michael
2 K. Johnson, Esq., whom spent the majority of the hearing being very engrossed in whatever it was he
was looking at on his smartphone, in between the numerous "cigar breaks" Chair Echeverria insisted
3
upon taking, whereupon Pat King would bring out his dog to play around the halls of the SBN's
4 Northern Office while King was wearing cargo pants.
5
6
7
8
The Title headings for the various types of contempt statutes in Nevada deterimine that the
citations by Judges Holmes and Howard in their contempt orders (all of which spring from NRS
Chapter 22, which is in "Title 2 Civil Practice" rather than "Title 15 Crimes and Punishment", and
therefore, not coming within the purview of SCR 111 in any way, shape or form, nor can Judge Nash
Holmes nor any of the other witnesses be said to have been qualified as an expert or in a position to
provide expert testimony):
9
10
11
http://www.leg.state.nv.us/NRS/ :
"TABLE OF TITLES AND CHAPTERS NEVADA REVISED STATUTES
TITLE 2CIVIL PRACTICE
12
Chapter 22 Contempts
13
NRS 22.010 Acts or omissions constituting contempts.
14
NRS 22.030 Summary punishment of contempt committed in immediate view and presence of
15
16
NRS 22.100 Penalty for contempt.
17
TITLE 15CRIMES AND PUNISHMENTS
18
199 Crimes Against Public Justice
19
20
21
22
23
NRS 199.340 Criminal contempt"

"NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be
deemed
contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding
court, or engaged in judicial duties at chambers, or toward masters or arbitrators while sitting
on a reference or arbitration, or other judicial proceeding."
24
Chair Echeverria's FOFCOL is clearly erroneous on page 3 where it finds: "6. On

25 November 15, 2011 Coughlin was arrested and charged with three violations of the Reno Municipal
Code....Trial commenced at 3 p.m. and was concluded by the Court at 4:30 p.m., without a verdict,
26 after the court held Coughlin in criminal contempt of court for his behavior and activities
committed during the course of the trial and in the presence of the Court. See Hearing Exhibit 4.
27
ORDER FINDING THE DEFENDANT IN CONTEMPT OF COURT AND IMPOSING
28
SANCTIONS. "
RECONSIDERATION
2
3
4
5
6
7
8
9
10
11
12
Couglin was not held in "criminal contempt of court". Judge Nash Holmes Order (and
Coughlin hereby preserves and does not waive, nor did he at the hearing on 11/14/12, his
objection to the fact that the SBN failed to plead or notice Coughlin that Judge Holmes
2/28/12 Order would be a basis for discipline here or become an issue at the 11/14/12 hearin
(and the same argument applies to Hill's greivance letter to the SBN regarding Coughlin,
especially where it was so inappropriate that the SBN was too embarassed to present it in an
exhibit, so much so, that it risks having the 2/14/12 letter to Coughlin from King thrown out
for failure to present the best evidence an in light of the rule of completeness, for it is King
whom is doing the "edits", as opposed to King's baseless assertions that the videos and audio
transcripts Coughlin sought to introduce were "all edits". Nonsense. , and further where such
2/28/12 Order was never appropriately served upon Coughlin sufficient to allow inclusion
within those matters relevant to the inquiry before the Panel on 11/14/12. In re Mirch.
Burleigh. Coughlin was not "arrested" on November 15th, 2011. He was given traffic citation
by the RPD containing three citations, two of which were dismissed upon Coughlin showing
proof of registration and insurance. The audio transcript Coughlin provided for the 2/27/12
Trial that ultimately ensued shows that Coughlin was deprived of his Sixth Amendment Right
to Confront the Officer issuing the citation, where RPD Sargent Tarter is not even endowed with the right to
issue traffic citations, and refused to divulge the true reason for why he had to call in an officer who was (though
who was not there to witness the alleged infraction) to write the citation).
13
14
15
16
17
18
Further, Coughlin filed with the SBN a Nevada NRS Open Records REquest and FOIA Act Request on 4/16/12
and again thereafter, that went unresponded to by the SBN, that entitles Coughlin to a copy of and access to all
materials presented to the screening panel and all materials provided by anyone to the SBN in any way related to
Coughlin, including Judge Beesley's purported letter to the SBN, and the 3,000 page 11/7/12 production by the
SBN is deficient in that King has obviously reordered and reaarranged materials such that one reviewing it
cannot tell what came from where, or who presented what to the SBN and when. Witness, Judge HOlmes
2/14/12 greivance is found within the section deemed NG12-0204 Richarg G. Hill grievance file. Coughlin's
right to the screening materials, Committe 916 So. 2d 74. See also Westlaw headnotes 92K2374 for issues
related to the legislature's right to encroach upon the judiciary as to the practice of law, particularly where the
SBN is not stricly under the dominion and control or "an arm of" the Nevad Supreme Court.
19
20
21
22
23
Olka Bar Assn v. Moss 794 P.2d 402 for support for Coughlin's right to have these proceedings bifurcated, particularly
where the scattershot, carpet bombed, voluminous allegations an entirely too circumscribed time allowed Coughlin to
confront them resulted in the hearing being little more than a farce. Also, Okla Bar Assn v. Brewer 794 P. 2d 397,
very similar to the "courtesy" the SBN attempted to perform here for the RMC, RJC, RPD, WCSO, WCDA, Reno City
Attorney's Offce, and Second Judicial District Court. The SBN is protecting everyone but the public, and Coughlin is
an extemely important attorney to the public and the legal profession as a whole, and the SBN is required to protect
such an asset to justice, not organize a gang bang on it, leveraging the public fisc and funds available to the RMC,
RJC, RPD, WCSO, WCDA, and 2JDC.
24
25
Coughlin incorporationsby referenc the entirety of the record on appeal from rjc rev2011-001708 (the summary
eviction "Trial" from Coughlin's former home law office" and the appeal therefrom in cv11-03628:
26
http://sdrv.ms/Tt4dYf
(including the 3/27/12 Order conclusively establish that Coughlin did not committ the misconduct HIll alleges, where the
6/28/12 attorney's fee award was merely an application of DCR 13(3), holding that a failure to oppose is deemed and
28
admission, and where any failure to oppose by Coughlin was excusable where he was wrongfully incarcerated by Judge
Elliot at the time of the filing of that attorney's fee award, subject to a choatic living working situation incident to a
27
RECONSIDERATION
criminal and violent attack by a former client and his associate (confidentially revealed by sealed letter to Bar Counsel,
Panel and Supreme Court), and subject to a NRS 178.405 violating attempt to hold a Trial on May 7th, 2012 by DDA
2 Young in rcr2011-063341 and the willfull ineffective assistance of counsel of the wcpd and Goodnight, especially where
Goodnight admitted minutes before that trial to not having once viewed the excuplatory video/audio of Nicole Watson, a
3 hostile witness with a motive to coverup (and subsequently caught being implored to be quite/dissuaded from
contradicting his lies any further by DDA Young's and RPD Officer Duralde's star witness Nathaniel K. Zarate "Nate
4 Zarate" in video0100 and video0099 (previously provided to Bar counsel and WCDA and WCPD and where the RJC
claim to have "not received" a multitude of cd/dvds Coughlin attached to filings, even where Chief Criminal Clerk Robbin
5 Baker admits to having so receied such attachments.
1
Nevada District Court Rule 13(3), when viewed in combination with Judge Flanagan's 3/27/12 Denial of HIll's
6
Second Motion for Order to Show Cause, vitiates any alleged support the Panel found in Judge Flanagan merely reciting
Hill's argument in quoting to them in a mere procedural history/summary of either sides arguments quote to HIll's Motion
7
read into the record on 11/14/12.
8 "DCR Rule13.Motions: Procedure for making motions; affidavits; renewal, rehearing of motions.
1. All motions shall contain a notice of motion, with due proof of the service of the same, setting the matter on the
9
courts law day or at some other time fixed by the court or clerk.
10
11
2. A party filing a motion shall also serve and file with it a memorandum of points and authorities in support of each
ground thereof. The absence of such memorandum may be construed as an admission that the motion is not meritorious
and cause for its denial or as a waiver of all grounds not so supported.
3. Within 10 days after the service of the motion, the opposing party shall serve and file his written opposition
12
thereto, together with a memorandum of points and authorities and supporting affidavits, if any, stating facts showing why
the motion should be denied. Failure of the opposing party to serve and file his written opposition may be construed
13
as an admission that the motion is meritorious and a consent to granting the same."
Further is was error to allow in testimony related to the criminal trespass where the SCR 111(4) Petition in 61901
is an admission by Bar Counsel that it is not appropriate subject matter for the 11/14/12 hearing (ie, not a "serious"
15 crime...further the failure in c11-2064 of Judge Elliott to actually hodl the hearing required by WDCR 19 provides a basis
for vitiating the import of any Order Affirming the conviction in 60838. additionaly, it was not appropriate for Judge
16 Flanagan to hear a contempt hearing where Coughlin had objected to his presiding over the matter in light of their former
shared emploment at Hale Lane (now Holland & Hart), in light of NRS 22.030(2) for alleged contemptous conduct not
17 occuring in the Court's immediate presence.
14
18
Chair Echeverria's Order purports to somehow incorporate "findings of fact" that include a copy and pasting of part of
Judge Holmes 2/28/12 Order (the inclusion of which has been detailed as impermissible herein previously), and Couglin
19
disputes every factual assertion therein anyways, and insufficient support or specificity is found in that Order regardless,
20 and there is not scr 111(5) application for a civil contempt citation incident to an administrative citation traffic trial,
regardless, and RPC 3.1 specifically allows lawyers (and necessarily pro per attorney indigent defendants) to zealously
21 advocate in their defense (as such, a lower bar than some Mirch vexatious or frivolous civil lawsuit accusations. Curious
how Chairmain Susich put together a Panel (well, if you believe he put it together) that had absolutely no criminal law
22 expertise incident to a SCR 111(8) mandated hearing wherein the SBN chose to interject mutliple pending criminal
prosecutions into the matter.
23
See included in Exhibit 1 the 5 14 12 and 7 31 12 0204 RX history email to @nvbar.org with attachment to email to
@nvbar.org from Zach Coughlin rx history since February 2008 thoroughly disproving the SBN, NNDB's Susich's SCR
25 117 Petition and Panel Chair Echeverria's contention vis a vis mitigating factors, Couglin being larcenized by his former
domestic partner of 4.5 years in June 2012, precipitating, upon such discovery in early August, a wrongful summary
26 eviction, Coughlin not being able to afford two psychotropic medicatiosn he has taken for years and years very suddenly
without any titration, and a wrongful arrest by the RPD on 8/20/11 where the witness testiony of Goble, Zarate,
27 Templeton, Lichty, and RPD Officer Duralde, and Couglin establish officer misdconduct incident to a Fourth Amendment
violation in rcr2011-063341, witness misconduct (lying to the RPD and 911 to effect arrest of Coughlin, Zarate and
28 Dawson attempting to dissuade material Witness Watson, Watson stubbornly refusing to testify or be served, wrongful
24
RECONSIDERATION
exclusion of video Watson knew was being recorded wherein she makes a statement against interest having an
exculpatory quality as to Coughlin, etc., etc. denial of every inviolable right of a criminal defendant by Judge Sferrazza
2 with the aid of both wcpd and wcda, and refusal to follwo RJC and NRS dictates where license attorney Coughlin filed a
substitution of counsel and or a notice of appearance (via some 9 month failure of the RJC to strike, only to allege a
3 "Faretta" issue prevented allowed Couglin to proceed pro per for 8 innings, then allowing him to take the mound in the
ninth after Leslie purposefull gave up 20 runs (some of which he manufactured) and thereafter refusing to allow Coughlin
4 to cross examine the arresting officer, wrongfully remixing Order of 10/22/12 vis a vis subpoena witness fees (which
shoudl not hve been necessary anyways, but for wronful plowing through on 9/5/12 after competency issue raise, becuase
5 Judge Sferrazza clearly wanted to release RPD Officer Duralde from his subpoena before proceeding with the competency
evaluation and inevitable (though purposefully delayed by both Judge Sferrazza and the wcpd's Leslie" introduction of
6 Coughlin as pro per defendant, and the coercive misconduct by Jduge Sferrazza, Leslie and DDA Young to force
Coughlin to waive his Fifth Amendment rights, impound his trial materials and hard drives, etc.,etc. On 8/27/12/ 8/29/12/
7 9/5/12, 11/19/12 and 11/20/12, and the wrongful and willfull failure to follow the mandatory precedent presented by State
v. Shepp, thereby prejudicing Couglins by making him defender yet another accusation (and one made via a too late,
8 retliatory, prejudicial amending of the complaint that Coughlin was not permitted to oppose and which the wcpd provided
ineffective assitance of counsel in relation to, as it further did at the suppression hearing of 8/29/12.
9
Judge L. Gardner's April 2009 ORder was not appropriately pled or noticed, and further, is not an appropriat subject
1
matter for the instant hearing where it was a mere attorne's fees sanction (based on a motion during his closing argument
by Springgate that failed to comply the NRCP 11 21 day safe harbor requirement incorporated into NRS 7.085, further,
Coughlin incorporates all basis for altering or amending any finding of misconduct incident thereto as set out in his
11
Petition for Writ of Mandamus in 54844. As evidnce in the Index Couglin made of the 8/23/12 Complaint (because Bar
Counsel surely did not make one), the 2/28/12 ORder by Judge Holmes was not pled or notice, nor was Judge HOward's
12
12/16/11 ORder (though admitted as an exhibit, though it largely speaks to irregularities in Judge Howard's ruling incident
to NRS 1.235, etc.
13
10
14
15
INDEX TO EXHIBITS 8/23/12 Complaint
SBN v. Coughlin: NG12-0204, NG12-0434, NG12-0435:
1. Exhibit 1: 11/30/11 RMC Judge Howard Judgment of Conviction and Court Order in 22176 candy bar and 3/15/12
16
Judge Elliott Order Affirming Ruling of the RMC in appeal CR11-2064
17
18
2. Exhibit 2: 11/30/11 RMC Judge Howard Order for Summary Punishment of Contempt Committed in View and
Presence of the Court in 11 CR 22176
19 3. Exhibit 3: 3/12/12 RMC Judge Nash Holmes Order of 3/14/12 in 11 TR 26800 with "clear and convincing" burden of
proof language Bar Counsel requested she place therein
20
21
22
23
24
I. NATURE AND SCOPE OF REMEDY.

0.5. Nature and scope of remedy in general.
26 1. Power and duty of court in genera1.
2. Causes in which new trial is authorized.
27 3. ConditIon of cause in general.
4. Effect of entry of judgment. 5. Existence of or resort to other remedy. 6. Discretion of court. 7. Right to new trial in
28 general. 8. New trial as to one or more co-parties. 9. New trial as to part of issues. , 10. Estoppel, waiver, or agreements
25
RECONSIDERATION
1 affecting right. 11. Successive applications. (1). In general. (2). Limitation as to number of new trials. 12. Operation and
effect of applicatio.
2
II. GROUNDS.
3 (A) ERRORS AND IRREGULARITIES IN GENERAL.
13. Failure of justice in general.

4 14. Nature and theory of cause.
15. Parties.
5 16. Process.
17. Motions and other interlocutory proceedings;
6 18. Pleadings.
19. Mode of trial.
7 20. Proceedings preliminary to trial.
21. Conduct of trial in general.
8 22. Irregularities or misconduct of officers.
23. Rendition of decision.
9 24. Form and entry of judgment.
25. Effect of change in law subsequent to trial.
10 26. Necessity of objection.
27. Harmless error.
11
(B) MISCONDUCT OF PARTIES, COUNSEL, OR WITNESSES.

12 28. Conduct of party.
29. Conduct of counsel.
13
30. Conduct of witness.
31. Necessity of objection.
14
32. Harmless error. .
(C) RULINGS AND INSTRUCTIONS AT TRIAL.
15 33. Rulings ground for application in general.
34. Motions for continuance.
16 35. Reception of evidence:
36. Arguments and conduct of counseL
37. Rulings on incidental questions and matters.
17
38. Submission of case or questions to jury.

39. Instructions. (1). In general. (2). Discretion of court. (3). Inapplicable instructions. (4). Particular actions or issues; In
18
general.
19
39.5. Failure or refusal to instruct. (1). In general. (2). Particular actions or issues.
40. Necessity of objection and exception at trial. (1). In general. (2). Reception of evidence. (3). SubmiSsion of case or
20 questions to jury. (4). Instnictions and failure onefusal to instruct.
21
(D) DISQUALIFICATION OR MISCONDUCT OF OR AFFECTING JURY.
42. Disqualification of jurors. (1). In general. (2). Bias or prejudice and formation or expression of opinion. (3). Prior
22
service as juror. (4). Relationship to or connection with party,counsel, or person interested.
43. Mistake as to identity of juror. 44. Misconduct of jurors in.general
23
(1). In generaL (2). Statements and expressions of opinion during trial. (3y Consideration of rtlatters not in evidence. ' (4).
View or inspection and investigations by jurors. 45. Use of intoxicating liquors. 46. Separation. 47. Communications by or
24
with jurors. 48. Misconduct of others affecting jury. 48.1. In general. 49. Parties or counsel. 50. Officers. 51. Bystanders.
52. Manner of arriving at verdict. 53. Necessity of objection at trial. 53.). In general. 54. --Knowledge or means of
25 knowledge of facts. 55. Failure to object. 56. Effect as to result. (E) IRREGULARITIES ,OR DEFeCTS IN VERDICT
,OR FINDINGS. ' 57. Rendition and reception of verdict. 58. Verdict in general. 59. Special verdict and fin<Hngs. 60.
26
Inconsistent fmdings. " , 61. Decision and findings of court. 62. Report and findings ofrefe'ree. 63. Necessity of objection
orexceptipn. 64. Harmless error. (F) VERDICT DR FINDINGS CDNTRARY TD LAW DR EVIDENCE .. 65. Power and
27
duty of court in general. 66. Verdict,contrary to law or instructions. 67. Verdict cOl1trary to evidence. 68. In general.
68.1. Contrary verdict in general. 68.2. Discretion. 68.3. Verdict opposed-to opinion of court. Particular actions or issues.
28
(1). In general. (2). Contracts. (3). Torts. ' -(4),--In general.
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
(5). Negligence. (6). Automobile cases. 69. Credibility of witnesses. 70. ' Sufficiency Of evidence. 71. Conflicting
evidence. n. --Weight of evidence. , (1). In general. (2). Weighing evidence as court function. (3). Discretion of court. (4).
Preponderance of evidence. (5). Clear, great or overwhelming, or manifest weight or preponderance. (6). Verdict
supported by evidence; conflicting evidence. (7). Particular actions or issues. (7.1). In general. (8). Contracts. (9).
--Negligence and torts in general. (10). Automobile cases. 73. Special findings by jury. 74. Amount of recovery in
general. 75.-Im'ldequate damages. (1). In general. (2). Nature of action in -general. (3). Actions on contracts. (4). Actions
for personal injuries. (5). Actions for death. (6). Actions for libel and slander. 76. Excessive damages. (1). In general. (2).
Nature of action in general. (3). Actions on contracts. (4). Ations for personal injuries., (5). Actions for death. (6).
Actions for libel and slander. 77. Mistake, passion, or prejudice of jurors. (1). In general. (2). Excessive damages ,in
general. (3). Actions for libel and slander. (4). Inadequate damages. 78. Successive verdicts. (1). In general. (2). Statutory
restrictions. (3). Amount of recovery. 79. Decision and findings of court.
80.
Report and findings of referee.
81.
Necessity of objection or exception.
(G) SURPRISE, ACCIDENT, INADVERTENCE,
OR MISTAKE.
82. Power and duty of court in general. 83. Amendment of pleading. 84. Notice and time or place of trial or hearing. 85.
Absence or disability of party. 86. Absence or withdrawal of counseL 87. Incompetency or neglect of counsel. 88.
Absence of witness or evidence. 89. Evidence in general. 90. Testimony and conduct of witness. 91. Inadvertence or
mistal<e of party or counsel. 92. Rulings and instructions. 93. Making bill of exceptions, case, or statement of facts. 94.
Accident or defect not attributable to party. 95. Prudence and diligence in guarding against surprise or accident. 96.
Diligence in averting consequences. 97. Necessity of objection or application for relief at trial. 98. Effect as to result.
(H) NEWLY DISCOVERED EVIDENCE.
99. Power and duty of court in general. 100. Nature of evidence discovered. 101.
Time of discovery.
102. Diligence in procuring evidence. (.5). In general. (1). Necessity for diligence.
(2). Cumulative and impeaching evidence.
(3). Sufficiency of showing .of diligence in general.
(4). Search for witnesses.
(5). Interviewing or examining witnesses.
(6). Efforts to obtain documen103. Relevancy, materiality, and competency. 104. Cumulative evidence. (1). In general.
(2). What constitutes in general. (3). Nature of action or issue and character of evidence. 105. Impeachment of witness.
106. Conflicting, contradicted, or contradicting evidence. 107. Credibility. 108. Sufficiency and probable effect. (1). In
general. (2). Nature of action or issue and character of evidence in general. (3). Actions on contract. (4). Actions for
personal injuries. (5). Extent of injury and amount of recovery. III. PROCEEDINGS TO PROCURE NEW TRIAL. 109.
Mode and form in general. 110. New trial on court's own motion. 111. Parties entitled to apply. 112. Joint applications.
113. Jurisdiction of application. 114. Court or judge to which application may be made. 115. Time for application. 116.
--In general. 116.1. --What constitutes trial. 116.2. --Commencement of time. 116.3. --Compliance with requirements.
117. --Limitations as to time or term of court. (1). In general. (2). Premature application. (3). Limitations as to term of
court. 118. --Extension of time. 119. --Effect of delay or laches. 120. --Excuses for delay. 121. --Stipulations as to time
and waiver of objections to delay. 122. Parties on application. 124. Requisites of motion in general. (1). In general. (2).
Setting out evidence and instruction. 25. Statement of grounds in general. 126. Specification of errors. 126.1. In general.
127. Necessity. 12S. Requisites and sufficiency in general. . (1). In general. (2). Reception of evidence. (3). Submission of
questions to jury and instructions. (4). Disqualification or misconduct of or affecting jury. (5). Verdict or findings contrary
to law or evidence. (6). Amount of recovery. 129. Including errors in one assignment. 130. Scope and effect. 131. Bill of
exceptions, case, or statement of facts. (1). In general. (2). Requisites and sufficiency in general. (3). Incorporating
evidence. (4). Settlement and allowance. (5). Time for settlement, filing, and service . . (6). Extension of time and waiver
of objections to delay. (7). Amendment and striking from files. (S). Compelling allowance or settlement and proceedings
for settlement. 132. Brief,report, or transcript of evidence. (.5). In general. (1). Necessity. (2). Requisites and sufficiency.
(3). Time for filing or approval and waiver of objections to delay. (4). Approval and revocation thereof. 133. Minutes of
court or judge. 134. Stenographer's report. 135. Notice of motion or of intention to apply. 135.1. In general. 136.
Necessity. 137. Form and requisites. 13S. Service III. PROCEEDINGS TO PROCURE NEW TRIAL.(Cont'd) 139.
Waiver of notice or of defects. 140. Affidavits and extrinsic evidence in general. (1). In general. (2). Counter affidavits.
(3). Grounds of motion. 141. Affidavits and testimony of jurors. 142. In general. 143. Impeachment of verdict. (1). In
general. (2). Misconduct of or affecting jurors. (3). Assent to verdict. (4). Mistake or inadvertence. (5). Manner of arriving
RECONSIDERATION
a.t verdict and computing damages. 144. Sufficiency and effect, and counter affidavits. 145. Evidence as to statements of
jurors. 146. Affidavits as to surprise, accident, or mistake. 146.1. In general. 147. Necessity and sufficiency in general.
2 148. Counter affidavits. 149. Affidavits as to newly discovered evidence. 149.1. In general. 150. Necessity and sufficiency
in general. (.5). In general. (1). Necessity. (2). Requisites and sufficiency in general. (3). Nature of evidence. (4). Time of
3 discovery and diligence. 151. Counter affidavits. 152. Amendment of motion or affidavits. 153. Filing motion, notice, and
affidavits. 154. Dismissal or abandonment. 155. Time for hearing and decision. 156. Continuance or postponement. 157.
4 Hearing. 15S. Rehearing; 159. Determination in general. 160. Grant of new trial ineffectual or not beneficial, 161.
Conditions on granting or rdusing new trial. (1). In general. (2). Payment of costs, expenses, and attorney fees in general.
5 (3). Nature of grounds. (4). Performance or breach of condition. 162. Remission or reduction of excess of recovery. (1).
In, general.. (2). Excess of amount claimed. (3). Unliquidated damages and effect of passion or prejudice. (4). Interest. (5).
6 Offer to remit and compliance with order. 163. Order granting or refusing new trh\!. (1). In general. (2). Construction and
operation. (3). Objections and exceptions. 164. Order for judgment instead of new trial. 165. Vacating or setting aside
7 order on motion for new trial. 166. Petition after term of court, and proceedings thereon. (1). In general. (2). Time for
filing. (3). Petition. (4). Trial. 167. Actions for m;w trial. (.5). In general. (1). Nature and scope of remedy. (2). Grounds.
8 (3). Proceedings. 168. Application to appellate court and proceedings thereon. IV. PROCEEDINGS AT NEW TRIAL.
169. Preliminary proceedings. 170. Scope of inquiry and powers of court. 171. Amendment of pleadings and other
9 proceedings.' 172. Effect of proceedings at former trial. 173. Mode and conduct of trialin general. 174. Reception of
evidence. 175. Questions for jury. V. STATUTORY NEW TRIAL AS OF RIGHT. 176. Nature of rig Causes in which
10 new trial is authorized. (.5). In general. (1). Actions involving title and right to possession of real property in general. . (2).
Actions to quiet title. (3). Actions for partition. (4). Actions for cancellation of instruments. (5). Actions to enforce trusts.
11 (6). Joinder of causes of action or defenses. 179. Nature of trial or proceeding. 180. Parties entitled to new 181. Waiver of
right. , 182 .. Right to successive new trials., 183. Proceedings to procure new trial. 184. Conditions and performance
12 thereof. 185. --In general. 186. --Payment of costs. 187. Payment of damages. 188. Proceedings at new trial.
1
13
Coughlin hereby ncorporates by reference all materials found at the following two youtube.com channels, which
14 contained NRS acceptable copies of certified audio transcripts and or true and accurate copies of videos coughlin either
filmed himself (and not "edited" to mislead) or videos that, as in the "Zach's arrest 1 through 14" series, were filmed by
15 Richard G. Hill, Esq. and his client Dr. Matthew Joel Merliss and provided to the Reno City Attorney, which produced
them to Coughlin, or other discovery or Brady material (however late the prosecutors provided it, and in light of NRS
16 52.245 and NRS 52.185- NRS 52.252 and nrs 52.255 and nrs 52.260 in light of nrs 53.045):
http://www.youtube.com/user/NevadaGadfly
17
http://www.youtube.com/user/NEVADARADICAL
18
http://sdrv.ms/XmRkVL
19
Last Link is to copies of certified audio transcripts obtained directly from RJC and RMC cases identified therein and
relevant in this matter.
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22
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25
26
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PLEASETAKENOTICEthat pursuant to Suprem e Court Rule ("SCROO)1 05(2) a VERIFIEDRESPONSEORANSWERto this

Complaint must be filed with the Office of Bar Counsel, State Bar of Nevada, 9456 Double RBoulevard, Ste. B, Reno, Nevada, 8952 1 ,
within twenty (20) days of service of this Complaint. Procedure regarding service is addressed in SCR1 0 9. Complainant, State Bar of
Nevada ("State Bar"), by and through its Assistant Bar Counsel Patrick O. King, is inform e d and believes as follo ws: Zachery Coughlin
("Respondent"), Bar num ber 9473, is a me m b e r of the State Bar of Nevada admitted on March 25, 200 5. Respondent's date of birth is
Septem b er 27, 19 7 6. The address that Respondent has on file with the State Bar of Nevada, in accordanc e with Rule of Professional
Co n du c t ("RPC") 7 9 (1 )(a ) is Post Office
Box 396 1 , Reno NV 8950 5. Respondent engag e d in acts of misc o ndu ct warranting the
RECONSIDERATION
1
imposition of professional discipline. The State Bar alleges as follo w s: 1. Multiple grievanc es were received by the Office of Bar
2
4
5
6
7
Counsel bet we e n the period of January 14 and March 15, 20 1 2 , con c er n i n g Respondent. Due to the serious
fro m of conviction. found jail. alleg edly em erg e n cy Appearance, Entry Guilty, Right Arraignm e nt; allegations of misc o ndu ct, grievanc e
files were opened and an investigation was initiated by Assistant Bar Counsel Patrick King. 2. Respondent was advised of the
gr ie va n c e s via U.S.m a i l e- mail and by a brief meeting with Mr. King at the State Bar Office in Reno. Respondent did not co op erate
with the investigation and rather than respond to the grievanc es as requested, Respondent sent nonresponsive and disparaging e- mails.
3. Respondent has not made a request to be placed on disability status, nor has he ackno w l e d g e d that he may have mental infirmity,
illness, or addiction. 4. The investigation of the grievanc es against Respondent sho ws a serious pattern of misco ndu ct. 5. On
Septem b er 9, 20 1 1 , Respondent shoplifted a candy bar and cough drops a Wal-Mart store with an approxi m ate value of fourteen dollars
($14.0 0). On Nove m b er 30, 20 1 1 , Municipal Court Judge Kenneth R. Howard found Respondent guilty of the offense Petit Larceny, a
violation of RMC8.1 0. 04 0. Respondent appealed the judg m ent of The judg m ent of conviction was affirmed on appeal. See Exhibit 1.
6. During the trial Respondent's conduct was so disruptive that Judge Howard Respondent in direct conte m pt of Court and sentenc ed
him to serve three (3) days in See Exhibit 2. 7. On August 20, 20 1 1 , Respondent was arrested on a seco nd larceny charge for stealing a
cell phone. Those charg es are currently pending in Reno Justice Court. 8. Respondent was again arrested on January 1 3, 20 1 2 , for
alleg edly abusing 91 1 services, a gross misde m e a n o r. 9. On February 2 1. 20 1 2 . Respondent filed a docu m e nt entitled, Notice of of Plea of
Not Waiver of to Motion to Dismiss
,
in one of his pending criminal matters, Case No. RCR- 0 1 2 0656 3 0, City of Reno
2
v.
Zachary Coughlin. The docu m e nt clearly sho ws
9
Respondent's unprofessional, disruptive conduct, and lack of respect for the court and opposing counsel.
10
11
12
10. Respondent was arrested on Novem b er 1 3, 20 1 1
by Reno Police Departm ent and charged with trespassing, a
misde m e a n o r, for which he was later convicted.

1 1. The circu mstanc es leading to the abo ve - m ention ed arrest are as follo ws: at an
13
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hearing Justice o f the Peace Peter Sferrazza ordered that Respondent vacate the ho m e he was renting effective Nove m b er 1,
15
16
17
20 1 1 . After the locks were chang ed and the notice was posted on the front door the owner, Dr. Merliss, disco v ere d that so m e o n e had
brok en into the ho m e and was barricaded in the base m e nt. The Reno Police tried to coax wh o e v er was in the base m e nt to open the door.
18
Dr. Merliss was forced to kick open the door where the Reno Police found Respondent. Respondent had broken into the ho m e and
19
living in the base m e nt. Respondent was arrested for criminal trespass and was subsequ ently convicted of that charg e.
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1 2. Respondent, representing himself as cocounsel, filed a 36- page m otion to dismiss on March 5, 20 1 2 . The m otion was
denied by Judge William Gardner and was determined to be without merit. The m otion, on its face, dem o nstrates that Respondent lacks
co m p et en c e to practice law.
1 3. Once Respondent was evicted, an order was obtained to rem o v e his belonging s fro m the ho m e. Respondent interfered
with the contractor wh o was hired to rem o v e Respondent's personal belongings. The police were called and after talking with
Respondent they reco m m e n d e d that he find so m ething else to do. Respondent refused to their advice and was subsequ ently arrested by the
27
28
Reno police.
RECONSIDERATION
14. In the case of City or Reno vs. lacnary BarKer cougntin, Case No. 1 1 TR 2680 0 2 1, a trial was held on a traffic
citation issued to Respondent. The matter was called at approxi m ately 3:00 p.m. and concluded without a verdict at about 4:30 p.m.
after the court held Respondent in criminal conte m pt of court for his behavior and activities co m m itted in the direct presenc e of the
court during trial.
7 15. In a March 1 2, 20 1 2 Order, Municipal Court Judge Dorothy Nash Homes found by "clear and convincing evidenc e" that Mr.
8 Coughlin co m m itted num erous acts of attorney misc o ndu ct. See Exhibit 3. Judge Holmes explained in her Order that after Respondent
9
served his five- day conte m pt of court sanction imposed by the court on February 27, 20 1 2 , Respondent faxfiled to the court a 224 - page
rambling references to his personal life and was
10
docu m e nt. Judge Holmes found that the docu m e nt contained
11
incoherent.
16. In her Order, Judge Homes found by clear and convincing evidence that Respondent
12
13
violated Rule of Professional Conduct ("RPC") 1.1 (Competence), RPC 1.3 (Diligence), RPC 3.1
14
(Meritorious Claims and Contentions), RPC 3.2 (Expediting Litigation), RPC 3.3(a) (Candor toward
15
the Tribunal), RPC 3A(e) (Fairness to Opposing Party and Counsel). RPC 8.4 (c) (Engaging in
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17
18
19
Dishonesty. Fraud. Deceit or Misrepresentation) and RPC BA(d) Engage in conduct that is Prejudicial
to the Administration of Justice).
17. Respondent filed Affidavits of Poverty in Support of his Motion to Proceed
20
Informa Pauperis, wherein he fails to disclose that he is a licensed attorney and instead under
21
Employment and Self-Employment he identifies himself as a "Jack of All Trades".
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25
18. Despite a claim of poverty in the above mentioned affidavits, Respondent told the Court
that his incarceration for contempt would adversely affect his clients.
19. On March 22, 2012, Respondent appeared at the Reno Municipal Court wearing (smiley face) flannel
pajamas. Respondent became argu m entative and Marshals 2S. On April 10, 200 9, District Judge Linda Gardner of the Second
Judicial District Court executed an "Order After Trial," in case No. DV08-01 1 6 8. In that case, Respondent represented the
26 Defendant/Counter Claimant. In her Order Judge Gardner explained Respondent's inappropriate behavior in part as follo ws: The m ost
troubling aspect of this case was Mr. Coughlin's rude, sarcastic and disrespectful presentation at trial; Mr. Coughlin's inability to
27 understand a balance sheet; his failure to conduct disco v ery and his lack of kno wl ed g e with regard to the rules of evidenc e and trial
28
procedure. All of this was co m p o u nd e d with a continuously antagonistic presentation of the case that resulted in a shift fro m a fairly
simple divorce case to a contentious divorce trial lasting an excessiv e am ount of time. 27. In light of the forgoing Respondent violated
RPC1. 1 (Competenc e); RPC1.2 (Diligence); RPC3. 1 (Meritorious Claims and Contentions): RPC3.3 (Candor to the Tribunal): RPC
RECONSIDERATION
1
3.4 (Fairness to Opposing Party and Counsel); RPC3.S (Impartiality and Decoru m of the Tribunal); RPC4. 1 (Truthfulness in
2
Statem ents to Others): RPC4.4 (Respect for the Rights of Third Persons); RPCSA(Relations with Opposing Counsel); RPC8.1
(Disciplinary Matters); RPC8.2 (Judicial and Legal Officials); and RPC8.4 (Misconduct). WHEREFORE,Complainant prays as
follo ws: 1. That a hearing be held pursuant to Nevada Suprem e Court Rule 10 5: 2. That Respondent be assessed the costs of the
disciplinary proce eding pursuant to Suprem e Court Rule 1 2 0( 1); and
"The Nevada Code of Judicial Conduct sets forth the applicable standards from which our judges are provided guidance
for ethical conduct. In regard to whether judges may or should provide recommendations or endorsements for candidates
6
for appointment to judicial office, Canon 2B of the Nevada Code of Judicial Conduct generally provides guidance as
follows: "A judge shall not allow family, social , political or other relationships to influence the judge's judicial conduct or
7
judgment. A judge shall not lend the prestige of judicial office to advance the private interests of the judge or others; nor
shall a judge convey or permit others to convey the impression that they are in a special position to influence the judge. A
8
judge shall not testify voluntarily as a character witness."
9
10
SBN King's Summary of the Case his 12/24/12 filing in 62337 does not accurately restate or summarize Chair
Echeverria's 12/14/12 Order: "1. Summary of Nature of the Case. Zachary B. Coughlin ("Respondent")
was temporarily suspended from the practice of law in the State of Nevada on June 7, 20 12, pursuant
to an SCR 111 petition filed by the Office of Bar Counsel. The Formal Disciplinary Hearing in that
12 matter was consolidated with three separate grievances concerning his sanctioned conduct before
Reno Municipal, Justice and District Court Judges."
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15
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20
21
22
However, the SBN never filed a Motion to Consolidate. It simply unilaterally decided to skirt
SCR 111(8) and the Court's 6/7/12 Order in 60838, which, in quoting verbatim SCR 111(8), ruled
that: "Accordingly, pursuant to SCR 111(8), we refer this matter to the appropriate disciplinary
board for the institution of a formal hearing before a hearing panel in which the sole issue to be
determined shall be the extent of the discipline to be imposed." Notice the Court's 6/7/12 Order
does not say "go ahead and consolidate anything else you feel like into a SCR 105 Complaint, too".
Witness Bar Counsel King's machinations and attempts to obfuscate and "consolidate" two separate
grievances (ng12-0204, and ng12-0434) and one "ghost-grievance" (ng12-0435) into some SCR 105
Complaint (ie, an "action", not a "hearing") that purports to also included that which SCR 111(8) and
the Court's 6/7/12 required be "the sole issue to be determined" by the "hearing panel", ie, "the extent
of the discipline to be imposed" in connection with the one specific conviction of a "serious" crime,
petit larceny, of "a candy bar and some cough drops" from a Wal-Mart as set forth in the SCR 111(6)
Petition in 60838.
In the prosecution underlying that 60838 Petition, the store admits Coughlin selected and paid for
$83.82 worth of groceries where it alleges Coughlin consumed the "candy bar and some cough drops"
24 while shopping, and then failed to pay for them in 60838. So, beyond playing Clerk of Court, Panel
Chair, Board Chairman, Bar Counsel, and other roles, the SBN's King attempts to play en banc
25 Nevada Supreme Court Justices as well in unilaterally deciding to remix the Court's 6/7/12 Order and
26
SCR 111(8) (add legislator, as well) by "consolidating" multiple grievances into an SCR 105
Complaint compared to participating in a "formal hearing in which the sole issue to be determined
27 shall be the extent of the discipline imposed".
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28
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Kings continues on to remix the 12/14/12 Findings of Fact, Conclusions of Law of Chair
Echeverria (King alleged to Panel's decision was "unanimous" (there is no proof of that anywhere) in
his TPO application in the Reno Justice Court, RCP2012-000607 (the RJC failed to respond to
Coughlin's subpoena or subpoena duces tecums, mistakenly believing that it was the original
subpoena they were served by Nicholas Hassett, and therefore, they would be able to avoid a
contempt finding for failing to respond or appear under some NRCP 45 requirement to file the
original. However, the RJC, Steve Tuttle, and Karen Stancil were misinformed in that regard, and
their malfeasance augers for a mistrail or new trial to the extent a continuance was denied by the
Chair and Coughlin's defense was prejudiced by the RJC's misconduct.

The abuse of process to cover up their own fraudulent conduct by the SBN (including Bar
Counsel King and Clerk of Court/Custodian of Records Laura Peters) and the Washoe County Public
Defender's Jim Leslie, Esq. (in RCP2012-000599) leverages the RJC's own complicity and conflicts
of interests/bias (see RJC issues/irregularities attendant to a multitude of sins, including "disappearing
cd/dvd exhibits attached and submitted for filing by Coughlin and admitted to by Chief Criminal
Clerk Robbin Baker, incident to Deputy Plamondon and Reyes misconduct and numerous courthouse
sanctuary violations by WCSO/RJC Bailiffs, and Judges Sferrazza/Clifton issues in rcr2011-063341
and rcr2012-065630, and rev2011-0001708 (failure to file 12/26/11 Notice of Appeal of 12/20/11
Order Resolving Motion to Contest Personal Property Lien and failure to include such in
Supplemental Proceedings filed in appellate court on 1/4/12 in CV11-03628), wrongful lockout
orders by Judge Schroeder in rev2012-000374 (fax header on order is prior to start time noticed for
hearing) and rev2012-001048 (email and calls to RJC and Chief Civil Clerk Stancil and Sparks
Justice Court and SJC fax of 6/28/12 to RJC regarding incorrect forum listed in 5 day notice, and
failure of Washoe County Sheriff to transport Coughlin from jail, incident to arrest in rcr2012-067980
to the summary eviction set aside hearing of 7/5/12 and failure to file Coughlin's kited Tenant's
Affidavits in multiple cases connected to three Northwind's rentals, and RJC Judge Pearson's (whom
granted the TPO's against Coughlin to Leslie and the SBN.) failure to follow Nevada law in 1048 as
to NRS 40.253 requirement that 5 day notice list forum to file Tenant's Answer, and in allowing nonattorney from Nevada Court Services to cross the bar and make argument for "client", in addition to
drafting and filing legal pleadings that went far beyond mere "notices", but required actual legal
analysis, and failure of RJC to provide Coughlin a summary eviction hearing or hearing on illegal
lockout in numerous instances where required under the law (ie, where order was stale in rev2011001708 upon Coughlin's 11/2/11 filing of a Motion for Relief from Illegal Lockout (10/25 and
10/27/11 Orders were served outside the "within 24 hours of receipt" statutory dictate and Orders
lacked the required "within 24 hours language" regardless, and in rev2012-001048, Judge Pearson's
7/31/12 Order exceeding scope of 7/24/12 Notice of Hearing and going so far as to rule on a unit not
even involved in that case, and further, upon posting of "Amended 5 day Unlawful Detainer Notice"
by Nevada Court Services, eviction Order was void or withdrawn, requiring new proceeding or at
least a illegal lockout hearing (otherwise, its allowing NCS to have cake and eat it too (get tenant out
prior to affording actual required 5 day notice, yet able to claim did provide 5 day notice...its nonsense), failure of RJC to file Coughlin's 3/16/12 Notice of Appeal in rev2012-000374 (and Clerk
Stancil's and Jonas's curious sudden unsworn "statements" in rev2011-001708 one month after
purported attempts to "obtain Coughlin's permission" to set 11/22/11 Hearing on Coughlin's 11/16/11
Motion to Contest Personal Property Lien...compared to not needing Coughlin's permission to violate
courthouse sanctuary doctrine by WCSO Bailiff Plamondon on 11/3/11 to serve unsigned "Notice" by
RJC Administrator Tuttle of 11/7/11 (Monday morning) hearing...Irregularities with Judge Sferrazza
in rcr2011-063341 incident to fraudulent "authorized service by email" assertion by Reno City
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
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18
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20
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27
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Attorney Creig Skau to obtain Coughlin's attendance at otherwise improperly/insufficiently notice

11/13/12 Hearing on Ex Parte Motion to Quash Subpoenas (and Judge Sferrazza's renegging on
10/22/12 Order deferring requirement for Coughlin to pay witness fees/subpoena duces tecum fees up
front, claiming on 11/19/12 to have been referring to "service fees" despite 48 minute mark of
10/22/12 Hearing in 063341 verbatim indicating "witness fees/subpoena duces tecum fees" and the
terms or notions of "service fees" not being address at all in any manner whatsoever, along with the
impermissible 11/8/12 Ex Parte Hearing (15 minutes long!) involving Judge Sferrazza, WCPD Biray
Dogan (whose certificate of service on 11/7/12 is fraudulent in that Coughlin never received any such
fax containing any such Motion to Quash by Dogan or the WCPD), DDA Young, and Reno City
Attorney Skau (not to mention Reno City Attorney Bony's letter to Judge Sferrazza in rcr2011063341 getting filed in rcr2012-065630 (which was "randomly assigned" under JCRRT to Judge
Lynch, although, for some reasons, former WCDA DDA domestic violence unit Judge Clifton took
ownership of that case, so much so that he violated NRS 1.250 in refusing to respond by Affidavit to
Coughlin's Application for Recusal (incident to fraudulent circumstances wherein Coughlin was
expressly informed by Clerk Robbin Baker that Trial start time was moved to 1:30 pm on 12/11/12 in
065630, considering Judge Clifton then failed to acknowledge Coughlin's Application for
Recusal/Conflicting out WCDA, RJC, and Judge Clifton in alleging the 9:58 am 12/11/12 filing was
"after the time set for the start of trial" and where Judge Clifton refused to accept a Declaration in lieu
of Affidavit properly following NRS 53.045 in that Application for Recusal, and similarly failing to
properly process subsequent Motion for Recusal by Coughlin during that Trial based upon evident
impartiality (something RMC Judge Gardner was guilty of on 11/30/11 in RMC 11 CR 22176, which
resulted in the conviction that the Court's 6/7/12 Order in 60838). RJC Criminal Division Filing
Officer Supervisor Cathy Wood admitted to Coughlin on 12/11/12 that Robbin Baker, curiously, did
not come in to work that day, the very day that Baker's previous assertions to Coughlin regarding the
"start time of the Trial has been moved to 1:30 pm on 12/11/12 to accommodate another Trial set for
that morning instead". Further, Judge Clifton's assertions in Court in response to Coughlin's
protesting that the RJC's Baker had notified him of the start time onf the 12/11/12 Trial in 11 CR
065630 (which is a Judge Lynch case anyways, making all the more suspect Judge Clifton's continued
domain over it, particularly given the newly discovered irregularities attendant to District Court
Judge Steven P. Elliot (whom suddenly decided to retire shortly after these allegation were made)
inappropriately being "randomly assigned" (in accordance with local rules of the Second Judicial
District Court) four different criminal matters wherein Coughlin is a party (three criminal appeals,
including the appeal of the conviction the subject of 60838, CR11-2064 (from RMC Judge Howard's
11/30/11 petty larceny conviction of Coughlin in RMC 11 CR 22176, where Judge Howard failed to
follow the required procedure under NRS 1.250 upon Coughlin moving for his recusal citing evident
impartiality and irregularities, denial of continuance agreed to in writing by City Attorney Pamela
Roberts, Esq., denial of court appointed counsel despite mandatory Bench Book cited authority of
Aignersinger where Judge Howard failed to specifically rule that jail time was not a possibility prior
to the trial (especially considering the 3 days incarceration and denial of any stay beginning
immediately after the rendition of a guilty verdict by Judge Howard at 8:30 pm at night, given he held
his Department's entire staff and several Marshals there overtime in his quest to avoid granting
Coughlin any sort of continuance sufficient to overcome the unlawful rent distraint applied by
Richard G. Hill, Esq. to excuplatory video, audio, and other materials belonging to Coughlin proving
Wal-Mart had previous to the 9/9/11 arrest in that petty larceny case, expressly threatened to abuse
process against Coughlin in retaliation for his complaining about the fraudulent conduct of Wal-Mart,
its employees, and managers incident to the convenient and selective application of its stated and
RECONSIDERATION
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posted Return Policy. Further, Judge Howard, in the last 3 minutes of the audio transcript from that
11/30/11 Trial, attempted to mislead Coughlin regarding the appealability of the civil summary
contempt, NRS 22.030, Order issued near the start of the Trial (at which point Coughlin requested an
attorney, and where it was clear error to proceed without supplying Coughlin one). Chair
Echeverria's FOFCOL of 12/14/12 contains a clearly erroneous finding/ruling where it indicates
Coughlin was "twice convicted of criminal contempt". In reality, neither summary contempt Order
was criminal in nature (in 22176 Judge Howard cited to NRS 22.030, a civil summary contempt
statute...though his Order clearly fails to Houtson v. Eighth Judicial requirement that the basis for the
summary contempt order be specifically set forth and supported by specific facts, where the 11/30/11
Order does little more than reprint, in a circular manner, the text of NRS 22.030, aside from
mentioning Coughlin "continued lines of inquiry after being told not to" (which was clear error where
the only continuing a line of inquiry by Coughlin was done for a different purpose than for which
such inquiry was made at the time of any of the vague "admonishments" of Judge Howard (none of
which could reasonably be said to place Coughlin on notice as to how he might comply with such
warnings, other than to simply drop defending himself entirely). The 2/27/12 rendition of the
summary contempt Order by Judge Nash Holmes (whom incorrectly asserted that she "had him
(Coughlin) served the 2/28/12 Order while he was in jail incident to the 5 day "summary contempt"
incarceration in 11 TR 26800 (for which, on 2/28/12 was filed Judge Nash Holmes's Order Finding
12
Regardless, Couglin definitely reported his conviction in 60838 to Bar Counsel's Machado and
Clark, arguably in a timely manner under SCR 111(2), or within a few days thereof, depending upon
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whether any "tolling" of the 30 day deadline is applied incident to time spent incarcerated.
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It was clear error where the SBN was allowed to put on testimony and evidence from Richard
G. Hill, Esq., whom was not even attorney of record in the trial court summary eviction/unlawful
detainer "Trial" (that would be his former associate Casey D. Baker, Esq.), nor in most of the appeal
to the District Court in CV11-032628 (where Hill alleges, contradictorily, to have "read practically
every single document Coughlin filed in these matters", yet, conveniently, squirms out of the
impeachment of his baseless allegations that Coughlins "failed to raise" the NRS 40.253 bar against
utilizing summary evictions against commercial tenant's where the landlord proceeds only upon a No
Cause Summary Eviction Notice and Coughlin tenancy being that of a home law office (clearly the
10/19/11 filing in rev2011-001708 expressly contradict that contention by Hill, as do the portions of
the transcript (and Hill and his office where provide, in an attachment to a filing, the JAVS audio
transcripts of the 10/13/11 "summary eviction proceeding" and 10/25/11 "Trial" (later remixed to a
different characterization despite Baker's admission on the record on 10/25/11 that "The use of the
term "Trial" was unfortunate, Your Honor" and despite notice in writing 10/13/11 identifying the
10/25/11 date as a "Trial", and numerous statements by Judge Sferrazza on both 10/13/11 and
10/25/11, on the record, that the 10/25/11 date was a "Trial" and that he had already ruled Coughlin
had "established a genuine issue of material fact, so I set this matter over for Trial, and that is what
we are here for today...".
The SCR 111(4) Petition by Bar Counsel King in 61901 is conclusive proof that the criminal
trespass conviction of Coughlin by RMC Judge William Gardner in RMC 11 CR 26405 was not a
"serious offense" sufficient to justify an SCR 111(6) petition. Therefore, to whatever extent Hill's
testimony was relevant or admissible (presumably to support a selected few of the RPC violations
alleged?), Coughlin was prejudiced with the clear error attendant to Chair Echeverria consistently
ruling as "irrelevant" any testimony, evidence, or questioning by Coughlin (including that during his
RECONSIDERATION
cross-examination of Hill) baring on just such issues. Further, it was clear error for the Panel and its
Chair to disregard the mandatory authority presented by Claiborne, and a lack of candor to the
2 tribunal an lack of fairness to opposing counsel by King to continually argue that Claiborne is not
mandatory authority.
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As to the ridiculous abuse of process attendant to both WCPD Jim Leslie's and SBN Patrick King's TPO
application. Couglhin did not "contact the Court Reporter at her home" as King alleges. Coughlin never even spoke with
the Court Reporter. He left a voice mail at a phone number held out to the public in a court reporting publication as a
number for Carol Hummel, CCR in her professional capacity after the SBN and Panel failed to answer Coughlin's requests
for information related to ordering or obtaining a transcript. Further, such allegations certainly bring into question the
legitimacy of WLS's Paul Elcano and the SBN's Coe Swobe repeatedly contacting Coughlin's immediate family members
in attempts to coerce a cheap settlement from Coughlin in connection with the lawsuit against Washoe Legal Services.
Certainly NVB Judge Beesley's concern did not extend to ever making a single phone call to Coughlin or meeting with
him in Chambers, and Coe Swobe never mentioned anything of Beesley's call to him regarding Coughlin, and Beesley and
the SBN have failed to produce the "letter" Judge Beesley indicates he wrote to the SBN regarding Coughlin (and the
dating of that letter has obvious relevance, particulary considering the RMC Judge Nash Holmes and WLS Elcano
connection Beesley shares in that all three went to McGeorge School of Law in 1977, Coughlin attached exhibits to a
3/30/12 NVB filing before Judge Beesley in Cadle Co. v. Keller (10-05104) detailing RMC Judge Nash Holmes'
warrantless confiscation of his smartphone and micro sd data card and 5 day summary contempt incarceration of 2/27/12
in RMC 11 TR 26800 in explaining the prejudicial effect such matters had upon his representation of his client, Keller,
and considering Judge Beesley's previous partnership with WLS's Karen Sabo (a co-defendant of Elcano's in the wrongful
termination suit) at Beesley Peck, LTD. Further, Elcano and Echeverria went to Reno High School together in 1962 along
with Norman and Maurice Beesley, and NVB Judge Greg Zive, as well as the former RJC Judge Fidel Salcedo whom
Judge Sferrazza indicate, on the record, he needed to take a five minute recess to meet with on November 19th, 2011 in
063341. Judge Beesley failed to indicate whom any of the Judges were that he spoke with about Coughlin in his
extremely curtailed and cursory testimony on 11/14/12, which was only noticed to Coughlin on 11/13/12, along with the
Supplemental Designation of Witness and Summary of Evidence indicating WLS's Elcano would be testifying (that
Supplemental DoWSoE bears a file stamped date of 11/7/12, but NRCP 6(e) requires three days for mailing before
constructive notice is provided, and Monday, November 12th, 2012 was a USPS holiday where the mail was not
delivered, making the date of constructive notice 11/13/14, the day immediately preceding the 11/14/12 hearing.
Additionally, Coughlin was never provided any filings by the SBN of the subpoenas for the four SBN witnesses (NVB
Judge Beesley, RMC Judge Nash Holmes, Richard G. Hill, Esq., and WLS's Paul Elcano). WLS's Elcano and Chair
Echeverria and Second Judicial District Court Judge Steven P. Elliot (whom failed to recuse himself from the wrongful
termination suit by Coughlin against WLS and CAAW where Judge Elliott sat on CAAW's Executive Board, or even
failed to disclose the conflict, only to "randomly" be assigned four straight criminal cases where Coughlin was a party (the
competency evaluation case CR12-0376, wherein Judge Elliott's wrongfully remanding Coughlin into custody for 8 days
beginning on the day Richard G. Hill, Esq. filed his Motion for Attorney's Fees that resulted in the Order by Judge
Flanagan admitted into evidence at the 11/14/12 Hearing despite it not being provided to Coughlin by the SBN until
11/7/12 (in a box with 3,000 other pages of documents) nor plead or noticed in an way whatsoever (which is insufficient
under the standard set out in Mirch respecting the notice requirements accorded Respondent's as to Orders
"attached to the Complaint".

Coughlin did not say he "wants some face time with" Chair Echeverria. Coughlin
commented to Dena Echeverria that is seems all the "ex parte face time Bar Counsel Pat King gets
with Chair Echeverria" provides him a distinct advantage, which is does. King's allegation
concerning "Paula" are absurd and an attempt to cover up the fact that "Paula" admitted to Coughlin
on November 6th, 2012, when she came outside to ask Coughlin if she could help him upon seeing
Coughlin out front of the SBN Office (and Paula's office is immediately off to the right of the front
door to the SBN's Office) and Paula admitted that King had left and locked the door to the SBN Filing
Office several minutes prior to 5 pm, thereby ostensibly cheating Coughlin out of a November 6th,
2012 filing date (a common occurrence in this case, the SBN closing its door and locking them prior
to 5 pm. It is patently false to suggest Coughlin was "flashing his light" to "attract attention". King
and Peters have been threatening to abuse process via TPOs since approximately October 30th, 2012,
which just happened to coincide with Peter's lies regarding the express permission she communicated
RECONSIDERATION
to Coughlin allowing him to fax file documents beginning to cause conflict between King and Peters,
as neither wanted to admit their errors. This was exacerbated upon King and Peters discovering that
2 the only copy of the 10/9/12 Notice of Intent to Take Default sent by certified mailing only to
Coughlin (not even copied by email or fax) was "returned to sender for insufficient postage" due to an
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error by the SBN in affixing only $1.25 worth of postage to a mailing that required at least $5.25
4 (exacerbated by the failure to follow the previously established practice in next to every other mailing
of a filing by the SBN of sending such a filing in duplicate via first class mail, as indicated by the
5 various Affidavit of Mailings, Proofs of Service, and Certificate of Mailings by Peters on SBN filings
and NNDB Chairman and Panel Chair Orders. King further lies in his TPO application where he
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attests, under penalty of perjury, that Coughlin's 12/12/12 email to the SBN and WCPD linked to a
7 video, where, in fact, it merely linked to a short audio clip at www.hark.com. What is perhaps most
disrespectful to the Bar and the Nevada Supreme Court is the extent to which Peters lies and Kings
8 lies are so easily disproven by digitally verifiable means such as email, fax confirmations (an issue
with the RMC in failing to file Coughlin's Notice of Appeal in the Judge William Gardner criminal
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trespass case RMC 11 CR 26405, and the Judge Steven P. Elliot appeal in CR12-1262).
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TATE BARS HEARING EXHIBITS

1 Index of Documents Selected for Hearing Packet by SBNs Pat King in attempt to skirt his lie
that he lacked a certified copy of every Order attached to filings contained therein and containing
numerous fraudulent Proofs of Service by the SBN.page 333 (just at 332 to every number for V3)
2 Attorney Fees Order of $42,050 by Judge Flanagan in CV11-03628 6/28/12 pursuant to
4/19/12 Motion for Attorneys Fees by Richard G. Hill, Esq., within appeal of summary eviction in
RJC rev2011-001708 by Judge Sferrazza
page 388
3 Order After Trial by Judge Linda Gardner from April 2009 that WLS cited as the sole reason
for firing Coughlin from domestic violence attorney position page 391
4 Contempt Order 2 28 12 Judge Holmes 26800 Order Finding Defendant in Contempt and
Imposing Sanctions, page 405 5 Order attached to Complaint 3 12 12 Judge Holmes attached to
Complaint Order 26800 fed clear and convincing burden for RPC standard by SBN page 409 6
Letter dated February 14, 2012 to Mr. Coughlin from Mr. King 2 14 12 partial letter from SBN
King excised Hills 1 14 12 ng12-0204 grievance, so no notice of it, not pled page 415 7 Twopage letter dated March 9, 2011 from Mr. Coughlin to State Bar Coughlins 3 3 12 fax to SBN
regarding delayed receipt of 2 14 12 letter from King re Hill
page 418 8 Two page letter
dated March 14, 2012 from Judge Holmes to SBN Northern Office 3 14 12 complaint against
Coughlin to SBN North page 86 9 Affidavit of Poverty 3 7 12 Affidavit of Poverty lacking caption
or certification by RMC D3 page 88 10- Order in Case 11CR 22176 RMC Judge Howard 12 15 11
Order denying IFP for Transcript Preparation and New Trial and Recusal page 91 11- Order for
Summary Punishment RMC Judge Howard 11 30 11 Order for Summary Contempt incident to
defense of 60838 conviction 95 12- Order Affirming Rules Judge Elliott 3 15 12 Order Affirming
RMC Judge Howard Ruling CR11-2064 page 98 13- Order Granting Respondents Motion to
Dismiss Appeal Judge Elliott 8 27 12 CR12-1262 Order Dismissing Appeal of Trespass Conviction
by Judge William Gardner in 26405 page 101 14-New Verified Response Coughlin 11 14 12 New
Verified Response after Chair Echeverrias threatening misstatements of the law re default page 104
15- Redone and Verified Response with two DVD discs Coughlin 11 15 12 Declaration and
RECONSIDERATION
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Verified Response 164 16- Emergency Ex Parte Motion Chair Echeverrias 11 14 12 incomplete
and secretive exhibit entered sua sponte, in his attempt to one up Judge Nash Holmes as to
transmogrifying a plenary formal disciplinary hearing into a summary contempt/disciplinary hearing,

where no copy of Exhibit 16 was presented to Coughlin at the time Exhibit 16s admission, and where
that which is represented in Exhibit 16 is an incomplete copy of the filing itself (an edit, Bar
Counsel King might say, if Coughlin was seeking its admission, where the Exhibits that were
attached to what Exhibit 16 purports to be, are not present (because neither the SBN nor the Panel
Chair (and Panel Member Kent indicated he wouldnt care to review any materials on an attachments
in cd/dvd form ever submitted by Coughlin anyways) seem to be able to burn a cd/dvd very easily,
much less review the materials collected therein and presented by Coughlin in various filings). 197
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Reliance upon SBN/Clerk of Court Peters/Panel/NNDB Board's assertions that Coughlin could file documents by faxing
to the SBN, that Coughlin's could issue his own subpoenas as any licensed attorney could despite being suspended and
therefore did not need to obtain subpoenas issued by the Clerk of Court of the SBN or baring the Court's seal, and that
Couglin did not need to pay a witness fee to those he had subpoenas served upon, nor a fee for subpoena duces tecums,
and that the 8/23/12 certified mailing of the Complaint would never be asserted to be any sort of Proof of Service or
Return of Service or otherwise presented as in satisfication of SCR 109 and that the SBN would not move for or find a
default until a second certified mailing had been returned to sender AND a Notice of Intent to Take Default had been
mailed to Coughlin upon any future return of the second certified mailing of the Complaint attempt in which such
NOITD would provide for at least 2 weeks (14 days) from constructive receipt of such mailing before any Default would
be entered or deemed effected, and that the September 25th, 2012 hearing date was calendared and to be devoted solely
to the matters specified in the 6/7/12 Order in 60838.
Mills v. Superior Court (1969) 2 Cal. App. 3d 214 [82 Cal. Rptr. 469]: "On at least two occasions during the 20day period after judgment was entered against them, defendants were advised by the clerk of the small claims court that
they had 30 days from the date of judgment within which to file their appeal. fn. 2 Relying upon the clerk's advice,
defendants did not learn it was erroneous until they consulted an attorney shortly after the 20 days had expired. The
attorney filed their notice of appeal on April 11, 1969, which was 25 days after entry of the small claims judgment.
Defendants' notice was accompanied by a cash deposit in lieu of appeal bond. Petitioner thereafter filed in respondent
superior court a written objection to the appeal on the ground it was not timely. By letter from their attorney, defendants
then requested respondent court to allow their appeal because of their reliance on the clerk's advice. On July 24, 1969,
the superior court entered a minute order permitting the appeal...he question remains: Can such jurisdictional time be
extended by a defendant's reliance on the small claims clerk's mistaken advice as to its duration?...To an extent not
duplicated in courts of higher jurisdiction, the statutory plan for small claims courts promotes reliance by litigants upon
the clerk's advice. In that circumstance, it would be manifestly unjust for us to hold that defendants' time to appeal was
not extended by their reliance on the clerk's faulty information. Moreover, recent decisions of the state Supreme Court
cast doubt on whether Estate of Hanley, supra, 23 Cal. 2d 120, and Lane v. Pellissier, supra, 208 Cal. 590, are controlling
today where clerical error has misrepresented the time to appeal even a superior court judgment. In People v. Martin
(1963) 60 Cal. 2d 615 [35 Cal.Rptr. 769, 387 P.2d 585], a motion to dismiss a late appeal was denied where "the course
of action adopted by the [trial] court misled defendant into delaying his appeal." (Id., p. 619.) The criminal appeal
involved in the Martin case was described as presenting an "analogous situation" in Slawinski v. Mocettini (1965) 63
Cal. 2d 70 [45 Cal.Rptr. 15, 403 P.2d 143], where the Supreme Court extended the plaintiffs' time to file a civil appeal by
holding that, absent any evidence that plaintiffs should have known of the discrepancy, their appeal time began to run
from the entry date shown in the copy and notice of a formal order which defense counsel had prepared and served upon
them, rather than from the date three days earlier when a statutorily effective order was entered in the clerk's minutes. In
substance, plaintiffs' time to appeal in Slawinski was extended because the defendants there were estopped to contend the
contrary. (See Witkin, Cal. Procedure (1967 Supp.), Appeal, 124B, pp. 965-966.)...FN 4. Defendants' verified answer
to the petition for prohibition alleges the above facts concerning the clerk's advice, and it avers, in effect, that the same
facts were brought to the attention of respondent superior court by the letter from defendants' attorney requesting the
court's "informal determination ... that ... the appeal should be allowed. ..." Petitioner does not suggest either that such
advice was not given by the clerk or that defendants' reliance upon that advice was not the basis for respondent's order
permitting the appeal. Moreover, in the absence of any record of the superior court hearing, we must assume that the
RECONSIDERATION
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facts were established to support that order. (See, Wessel v. Superior Court (1918) 177 Cal. 308, 311-312 [170 P. 606];
Tomlinson v. Superior Court (1944) 66 Cal. App. 2d 640, 644 [152 P.2d 517]; Frey v. Superior Court (1913) 22
Cal.App. 421, 424 [134 P. 733].)" Mills v. Superior Court (1969) 2 Cal. App. 3d 214 [82 Cal. Rptr. 469.
SBN Kings Summary of the Case his 12/24/12 filing in 62337 does not accurately restate or
summarize Chair Echeverrias 12/14/12 Order: 1. Summary of Nature of the Case. Zachary B.
5 Coughlin (Respondent) was temporarily suspended from the practice of law in the State of Nevada
on June 7, 20 12, pursuant to an SCR 111 petition filed by the Office of Bar Counsel. The Formal
6 Disciplinary Hearing in that matter was consolidated with three separate grievances concerning his
sanctioned conduct before Reno Municipal, Justice and District Court Judges.
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However, the SBN never filed a Motion to Consolidate. It simply unilaterally decided to skirt
SCR 111(8) and the Courts 6/7/12 Order in 60838, which, in quoting verbatim SCR 111(8), ruled
that: Accordingly, pursuant to SCR 111(8), we refer this matter to the appropriate disciplinary
board for the institution of a formal hearing before a hearing panel in which the sole issue to be
determined shall be the extent of the discipline to be imposed. Notice the Courts 6/7/12 Order
does not say go ahead and consolidate anything else you feel like into a SCR 105 Complaint, too.
Witness Bar Counsel Kings machinations and attempts to obfuscate and consolidate two separate
grievances (ng12-0204, and ng12-0434) and one ghost-grievance (ng12-0435) into some SCR 105
Complaint (ie, an action, not a hearing) that purports to also included that which SCR 111(8) and
the Courts 6/7/12 required be the sole issue to be determined by the hearing panel, ie, the extent
of the discipline to be imposed in connection with the one specific conviction of a serious crime,
petit larceny, of a candy bar and some cough drops from a Wal-Mart as set forth in the SCR 111(6)
Petition in 60838.
As to the ghost grievancing involving brother and sister Judges William and Linda Gardner, at
the 11/14/12 RMC Judge Nash Holmes admitted to providing the SBN, in the box of materials she
18 voluntarily presented to the SBN without any prompting from anyone other than her fellow RMC
Judges William Gardner and Kenneth Howard and RMC Court administrator Cassandra Jackson and
19 her City of Reno Marshals (though any Marshal statement or report related to the alleged lying by
Coughlin (which Coughlin has always denied, despite Chair Echeverrias attempts to recharacterize
20
Coughlins filings and statements to suit his agenda), including Marshal Joel Harley, Scotta Coppa,
21 Thompson, Deighton, and Chief Roper.
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Further Bar Counsel Pat King attempted to mislead Coughlin into thinking the Clerk of Court for
the Second Judicial Court where Judge Linda Gardners Department 14 is found was the person
23 whom sent Bar Counsel the April 2009 Order by Judge Linda Gardner that WLSs Elcano cited in his
May 1st, and May 7th, 2009 letters to Coughlin as the sole reason for terminating Coughlin
24 employment as a domestic violence attorney, despite Elcano admitting to Coughlin in February 2009
that Judge Linda Gardner and Master Edmondson had given Coughlins work positive reviews and
25
that Linda Gardner owed Elcano a big favor because he did something big for her a long time
26 ago, so she owes me. Elcano is very close friends with Dan Orlich. DV02-03052 INRE:
WILLIAM L. GARDNER AND DORA J. ORLICH
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RECONSIDERATION
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From: Patrick King (PatrickK@nvbar.org) This sender is in your safe list. Sent: Thu 4/19/12 2:28
PM To: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com) April 19, 2012 Zach Coughlin
Dear Mr. Coughlin, A screening panel of the Northern Nevada Disciplinary Panel met on Tuesday
April 10, 2011 to address the grievances filed against you. The panel directed me to proceed to a
formal disciplinary hearing. As such, I will be preparing a formal Complaint. I understand from the
e-mail below, that you do not believe you should have been found guilty of the theft at Wal-Mart
and that you should not have been found in contempt of Court. However, it must concern you that
you were found in contempt of Court by more than one Judge in two different trials. You wanted
to know how I learned of or obtained a copy of Judge Gardners Order after trial that was
filed in 2009. It was sent to me by the clerk of the court at my request, pursuant to my
investigation.
From: Townsend, Lori Ltownsend@washoecounty.us Sent: Wednesday, April 11, 2012 11:34
AM To: Patrick King Subject: Zachary Coughlin Attachments: RCR2011-065630.pdf; RCR2011065630-Motion.pdf; RCR2011-063341.pdf
11
Hi Patrick-
12
Here are the two outstanding criminal cases against Mr. Coughlin in Reno Justice Court. Case
number RCR 2011-063341 is set for trial on May 7th at 9:00 am; Case RCR 2011-065630 is the
one awaiting the results of the competency evaluation. I also included a notice/motion that he filed
in the gross misdemeanor case. I did not include a pleading entitled Pre Trial Motions he filed in
the misdemeanor case (it is in excess of 200 pages), but if you would like to see that, I can send
you a copy. He is also emailing staff members with links to his YouTube pages. Please let me
know if you need anything else. RCR2011-065630.pdf RCR2011-065630-Motion.pdf
RCR2011-063341.pdf Lori Lori Townsend Judges Secretary ..eno Justice Court P. O. Box
30083 Reno, NV 89520 775-325-6550
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Notice that even the RJC Judicial Secretary does not understand or seem to care that NRS 178.405
requires all cases in the RJC be stayed pending the results of the 2/27/12 Competency
Evaluation. The horrific spectacle Coughlin was subjected to on May 7th, 2012, wherein shortly
after being released from an abominable violation by Judge Elliott and 8 day incarceration
incident thereo, Couglin was forced to hurriedly do the trial preparation that his WCPD Joe
Goodnight refused to do (minutes before the May 7th, 2012 Trial Goodnight admitted to Coughlin
that he had not review the tape wherein Nicole Watson admitted to seeing and hearing the man
with a six-pack of beer hold aloft the phone he had picked up off the ground in the middle of the
downtown Reno skate plaze in front of City Hall, next to the Truckee River, and announce that he
would throw it in the river if someone doesnt claim it immediately.... It was on that May 7th,
2012 Trial date before Judge Sferrazza who has an obvious bias against Coughlin left over from
an acrimonious summary eviction/Trial in Rev2011-001708 and the ensuing 11/7/11 and
12/20/11 Hearing dates thereafter, that the deadline to file an Opposition to Hill and Bakers April
19th, 2012 Motion for Attorneys Fees (from which Hearing Exhibit 2 spawned). Couglin did file a
preemptive Opposition to any such Motion for Attorneys Fees on January 19th, 2012, though it
was never expressly considered by Judge Flanagan, and in that regard, it was DCR 13(3) that
resulted in the attorneys fee Motion by Hill being granted, rather than an adoption of the
hyperbole and self interested rhetoric contained within that Motion. At the 11/14/12 Hearing,
RECONSIDERATION
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King and Hill were reduced to quoting a portion of Judge Flanagans Order that was a mere
procedural recitation of the arguments in the Motion, then left to attempt to mislead the tribunal
and display a lack of fairness to opposing counsel in doing so. Further, there is an excusable
neglect, suprise, good cause, or inadvertence basis for setting aside, altering, or amending the
12/14/12 Order by Chair Echeverria where Coughlin had no reasonable opportunity to digest the
3,000 page produced by the SBN on 11/7/12 (especially considering the dubiously set November
19th, and 20th resumption of the Trial before Judge Sferrazza in the iPhone case (where he denied
any continuance, expressly ruling that Coughlin had had sufficient time to prepare, despite the
obstructionist tactics of a public defener, Jim Leslie, that Couglin was only able to have removed
from the case on October 22nd, and where Leslie failed to turn over Coughlins file and material
evidence (such as unredacted call records for the iPhone and dispatch logs. Leslie never did turn
over the dispatch to RPD recordings he subpoened on 10/3/12, and where Coughlins appearance
at an Emergency Ex Parte Motion to Quash his subpoenas in 063341 was fraudulently procured by
City Attorney Skau (see page 000187 of Ex. X, the collection of emails from Couglin to
@nvbar.org email addresses wherein Coughlins 11/19/12 grievance against Reno City Attorney
Creig Skau, Esq. Begins. Beyond materially misrepresenting to Couglin whether Judge Sferrazza
had authorize service by email sufficient to effect service, Skau and the City Attorney failed to
propound exculpatory 911 calls and recordings between RPD and dispatch in the cd provided
Coughlin in response to a subpoena on 11/13/12 in rcr2011-063341. Further Skau demonstrated a
lack of candor to the tribunal in making arguments counter to the Gricela Alvarez waiver of any
service requiremetn for variou subpoenas upon City of Reno employees, and Judge Sferrazzas
cusory and conclusory statements upon the first mention of Alvarez by Coughlin indicate even
more ex part communications that those confined to the audio record in 063341 took place been
the City Attorneys and or Judge Sferrazza and the RJC.
Oddly, Bar Counsel Kings 3,000 page production to Coughlin on 11/7/12 contains a bate stamped
email from RJC Judicial Secretary Lori Townsend (wherein she sends King a copy of Coughlins
2/21/12 filing in RCR2012-065630 (the case Judge Clifton mysteriously took over for Judge
Lynch on the very day that the Order for Competency Evaluation was signed by Judge Clifton, at
which time he somehow knew that Judge Elliott was to be randomly assigned the District
Court case such an evaluation spawns in CR12-0376, as Judge Clifton, in his own handwriting,
wrote in D10 and Judge Elliotts name in an indication of an impermissible skirting of 2JDC Rule
2 requiring all criminal matters be randomly assigned. So, the RJC, RMC, NNDB, Panel, and
Bar Counsel have a problem...how to assert privilege as to work product and investigatory
materials/screening panel materials where King provided the email from the RJCs Lori
Townsend, yet now Townsend and the RJC/King will invariably wish to assert the ol it was sent
to me by the clerk of court at my request line that King trotted out in the above email of 4/19/12.
Clearly, from Judge W. Gardners not coy enough statements on the record in 11 CR 26405 on
both 4/10/12 and 5/8/12, the RMC and the SBN were in strategy talks to do whatever was
necessary to have Coughlin disbarred, including informing Judge William Gardner of the dates of
the screening Panel (and Chairman Susichs SCR 117 Petition indicates a date of 4/16/12, whereas
King has it pegged at 4/10/12, same as what Judge W. Gardner indicated to Couglin on the record
on 4/10/12. The SBN has continued to reneg on its agreement with Coughlin to divulge the
identifies of the members of the screening Panel, and certainly Mary Kandaras and David
Hamilton are completely conflicted out of such participation. As well as NNDB member Richard
G. Hill, Esq. And Kathleen Breckenridge. Further, in his TPO Application King indicates the
Panels decision was unanimous yet it was only signed by Chair Echeverria, and the Panel
RECONSIDERATION
1
2
Decision in Mirch bore all 5 Panel members signatures (including WLS Board President Kathleen
Breckenridges, whom missed the I-867 issue that Couglin detailed upon taking over the
Davenport case for her at WLS (for WLS employee Lidia Davenport).
Judge Elliott graduated from Stanford University in 1971. He worked for the law firm of
Echeverria and Osborne in Reno and served as an Assistant City Attorney for the City of Sparks. He
5 completed the Course for Prosecutors sponsored by the National Association of District Attorneys at
Northwestern University. He was a founder of the Washoe County Domestic Violence Task Force.
6 Judge Elliott has been active in community organizations. He has served as a director of
the Committee to Aid Abused Women Advisory Board. He is a past president of the Reno Area
7
Stanford Club.
4
WDCR Rule 2. Organization of the court; chief judge; court administrator. 1. All civil and criminal
cases shall be randomly assigned.
10
11
Somehow, Judge Elliot managed to be randomly assigned four straight criminal appeals wherein
12
Coughlin is a party following his being randomly assigned Coughlins wrongful termination
lawsuit against Paul Elcano, Washoe Legal Services, and the Committee to Aid Abused Women
13 (CAAW). This included the appeal of the Wal-Mart petty larceny conviction at issue in the SCR
111(6) Petition resulting in Coughlins current temporary suspension, in 60838, from which the
14 6/7/12 Order referring
15
16
17
18
19
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=30277
Compare Judge Nash Holmes statements from 3/12/12 in 11 tr 26800 the audio transcript reads 7
minutes into the audio record the RMC provided the SBN to her statements at Coughlins formal
disciplinary hearing before the SBN and NNDB on 11/14/12. On 3/12/12 Judge Holmes indicated:
Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering from some
extreme form of mental illness. During the trial I asked the defendant attorney repeatedly if he was
21 recording the proceedings he denied that vehemently a few times and then he quote took the fifth a
few other times and then he requested to be excused to go to the bathroom and the Marshal later
22 reported to me that while the gentleman was in the bathroom he disassembled a recording device in
his pocket and took the memory out of it and it was later found in that, uh, by the Marshal no one else
23
had gone into the bathroom and that was retrieved and it was put into his possession at the Sheriffs
24 office and when they booked him into jail for the contempt charge that was booked into evidence and
I asked the Sheriffs office to hold that into evidence. I believe he has violated Supreme Court Rule
25 229(2)(B) which was amended by ADKT 440, August 1st, 2011....
20
26
27
28
Compare Judge Nash Holmes testiomony on 11/14/12:

HEARING 11/14/2012
Page 140
RECONSIDERATION
1
2
MR. ECHEVERRIA: With respect to any particular issue, Mr. Coughlin? BY MR. COUGHLIN: Q
No. Just anything. Anything connected to me?
MR. ECHEVERRIA: Thats what Im asking. Is it involving you, sir?
MR. COUGHLIN: Yes.
THE WITNESS: Mr. Coughlin asked for a bathroom break. I originally said I would not give the
break. And then I said that I would, but he had to leave all his materials in the courtroom. And I said
6 that because I suspected that he was tape-recording the court proceedings without my permission, and
7
without asking permission first. Because hes apparently been known to do that.
MR. COUGHLIN: Objection, hearsay. Lack of foundation.
5

THE WITNESS: So I required one of my marshals to accompany him to the restroom.
10
MR. COUGHLIN: She just gets to say a bunch of hearsay?
11
MR. ECHEVERRIA: Mr. Coughlin, she is responding to your question.
12
HEARING 11/14/2012
13
14
15
16
17
18
Page 141
Go ahead, Judge.
THE WITNESS: When the marshals came back from the restroom, they told me that Mr. Coughlin
had, in fact, been recording the proceedings because he had disassembled a device and left parts of it
in the bathroom. Or left -disassembled parts of it, and then they discovered parts of it.
In any case, when he was taken into custody and held in contempt of court at the jail, he had
physically two recording devices on him, a cell phone -either two cell phones or a cell phone and
some other recording device. I assumed that was pieces of which he was messing with in the
bathroom. BY MR. COUGHLIN:
19
20
Which marshal told you that?
21
22
23
24
Im sorry?
I cant hear that.
Q
Which marshal -MR.
25
ECHEVERRIA:
26
Mr. Coughlin, you dont need
27
to yell.
28
THE WITNESS:
RECONSIDERATION
It was Marshal Harley that told
me that, Joel Harley, H-a-r-l-e-y. He said when they went in and checked the bathroom after Mr.
Coughlin left, and he had found evidence that he had disassembled some object or something in there.
BY MR. COUGHLIN:
HEARING 11/14/2012
5
6
Page 142
A I just described it as some sort of a recording device. Whether it was a cell phone and he took the
SIM card out or whatever it was, I wasnt sure. But I had asked you, Mr. Coughlin, point blank in
court if you were recording, and you told me no. And then you asked immediately to go to the
8
bathroom, and I said no. And then you begged and squirmed and said you had to relieve yourself, and
9
I had to let you go to the bathroom. And then when you did that, you went into the bathroom -BY
MR. COUGHLIN:
7
10
Q Really?
11
A Took apart and disassembled a recording device.
12
13
MR. ECHEVERRIA: Mr. Coughlin. Ive asked you repeatedly to please not interrupt people.
14
15

MR. ECHEVERRIA: It was clear she wasnt when you were interrupting her.
16
17
MR. COUGHLIN: Okay.
18
MR. ECHEVERRIA: Youve asked a question of the judge. She answered it. Do you have a
question? HEARING 11/14/2012
19
Page 143
20
BY MR. COUGHLIN:
21
Q Judge, was there one bathroom break during the trial?
22
A Im sorry. The crowd has recessed here, and let me move across the hallway, because I cant hear
anything right now, theres a big crowd.
23
24
25
Q Dont worry. Just my law license, Judge. No biggie. Was there one bathroom break? MR.
ECHEVERRIA: Mr. Coughlin, I for one do not appreciate your side comments. I think you should
focus seriously on the issues to be addressed here. The judge simply asked for accommodation so she
could hear.
26
MR. COUGHLIN: I only have so much time, your Honor.
27
MR. ECHEVERRIA: I know. Quit wasting it. BY MR. COUGHLIN:
28

RECONSIDERATION
A Im sorry, I cant hear you again. Say it again. MR. ECHEVERRIA: Did you review the audio of
the trial? THE WITNESS: I have not reviewed them
HEARING 11/14/2012
Page 144
recently, no. I did at the time. I did when I entered my
7
8
9
10
11
12
contempt order and sent my package to the discipline
board.
BY MR. COUGHLIN:
Q Why does the audio of the trial indicate that you did not ask any questions about recording until
after the one bathroom break? A
Im not sure thats the case.
I dont know.
Q
13
That is the case.
14
MR. ECHEVERRIA:
15
Mr. Coughlin -BY
16
MR. COUGHLIN:
17
Q Yet you testified today that Mr. Coughlin asked to use the bathroom right after I asked him about
recording. How do you explain that? A I dont know the sequence of events. I dont recall -Q
18
You just said you -A
19
I listened to the audio at the time when things happened. And when you came back from the
bathroom, either way I determined from -- I concluded that you were most likely recording without
my permission.
20
21
22
23
Q Earlier your testimony was that you asked Mr. Coughlin if he was recording, and he got real
squirmy and asked to use the bathroom. Is that correct?
A Yes.
HEARING 11/14/2012
24
Page 145
25
26
A No.
27
Q You just said, I dont know the sequence of events.
28
RECONSIDERATION
1
2
A Well, I dont recall the sequence of events. I know that I asked you if you were recording. You
denied you were. I asked you a couple times if you were recording, if you had gotten permission to
record, what you were doing. And at some point it was determined that you most likely were.
Q You know there is an audio of these things youre testifying to, right, that we can like compare to
what youre saying; right, Judge? MR. ECHEVERRIA: Mr. Coughlin, please exhibit a civilized tone.
4
BY MR. COUGHLIN: time.

3
QAQA
Youre aware theres an audio?Yes, theres an audio. I have not -That we can compare --- Im giving
you my best recollection at this MR. ECHEVERRIA:
Mr. Coughlin, youre trying
my patience with your continuing interruptions. Thats not evincing the conduct of a competent
9
lawyer. You should wait until the witness finishes before interrupting
HEARING 11/14/2012
10
11
12
Page 146
her.
13
MR. ECHEVERRIA: Go ahead. Ask your next question. BY MR. COUGHLIN: Q So the marshals
said Mr. Coughlin left some disassembled part of a recording device in the bathroom, and they
14
retrieved it from there; is that correct? A I dont recall the exact words. The impression I got from
15 what the marshal said is that you had gone into the bathroom, disassembled some sort of recording
device, and they went in the bathroom after you and checked that and determined that. Thats my
16
recollection of the events.
17
18
Q Is that murky recollection of yours maybe the reason why the law requires, in a contempt not
occurring in the immediate presence of a judge, that somebody actually put their name on an affidavit
and sign it?
MR. KING: Mr. Chairman, as Bar counsel, a member for Bar Counsel office, I find -THE WITNESS:
Mr. Coughlin, you were not found in contempt on that reason alone. You were found in contempt for
20 engaging in behavior of the same kind it appears that youre doing now, and much more than that.
21
And you were found in contempt for your entire conduct HEARING 11/14/2012
Page 147
19
22
throughout the course of the proceedings
23
24
25
26
27
28
RECONSIDERATION
things to get from courts list:
7/5/12 Hearing in 12CR12420 (file hard copy noa too)
3
4
5
any emails to @reno.gov announcing new address especially for 10/11/12 amending of Complaints
remember that DDA Youngs amend complaint filed 11/6/12 seems to have forgotten to change the
language prior to the to wit portion as it still has the where no actual or perceived emergency
exists language...?motion to dismiss? Something to argue at Trial? Krebs TPO hearing of 8/5/12 in
rjc rcp2012-000287
northwinds rcj rev2012-000148 pearson Duane Jakobs of Northwinds Apartments, Nevada Court
Services, unauthorized practice of law anything from wcdc regarding kites, attempts at filing
7 (especially Notice of Appeal in 11 CR 26405 dated in Coughlins handwriting 7/10/12, but not file
stamped until 7/18/12, whereas RMC Judge Gardners Order denying Coughlins 6/26/12 Motion for
8
New Trial is dated 7/11/12...the conflict attendant to Gardner incarcerating Coughlin wrongfully by
9 raising his bail impermissibly high, based upon a public health and safety rationale, coercing
waiver of Coughlins HIPAA rights, Loomis misconduct, etc., all adding up to Coughlins Notice of
10 Appeal not being filed (not timely filed as to the 7/10/12 Notice of Appeal and not filed at all as to the
6/28/12 Notice of Appeal in CR12-1262.
6
11
12
File stamped cover pages in following case for following dates:

Park Terrace Townhomes HOA v. Coughlin RJC Rev2012-000374 (3/23/12,
13
14
cv11-03628: 11/9/12 NOTICE OF POSTING BOND ON APPEAL WITH RICHARD G. HILL,

ESQ. AND FAILURE OF JUSTICE COURT TO FILE IN APPELLANTS NOTICE OF APPEAL
SUBMITTED 12/26/11 IN RELATION TO 12/20/11 HEARING ON MOTION TO CONTEST
16
PERSONAL PROPERTY LIEN
15
17
18
19
20
21
22
23
30. Motion to dismiss; illustrative forms

The scope of motions to dismiss grievances is limited only by the ingenuity and experience of the
defense attorney. They can take practically any form, but should, if possible, be supported with case
citations and a brief in support. Forms for two typical motions, (a) motion to dismiss on the ground of
res judicata, and (b) a motion to dismiss for lack of standing, Judge Gardners grievance NG12-0204
seems to be a ghost grievance, and Judge Nash Holmes admitted in her 11/14/12 testimony that she
may have included the 4/10/09 Order in DV08-01168 in the box of materials she submitted to the
SBN on 3/14/12.
24
25
INDEX SBNS ALPHABETICAL LIST OF DOCUMENTS
26
27
Description
Page and Volume No:
28
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Affidavit of Laura Peters, Custodian of Records (Filed October 9,2012) 33-34 I Amended
Supplemental to Respondents Emergency Motion to Set Aside (Filed November 30, 2012) 541-544
II Certificate of Service by Mail of Record On Appeal 1098 II
Complaint and First Designation of Hearing Panel Members (Filed August 23,2012) 1-28 I
Coughlins Designation of Witnesses and Summary of Evidence (Filed October 31, 2012) 159-162 I
Declaration of Zachary Barker Coughlin (Not Filed) 607-612 II
Emergency Ex Parte Motion to Dismiss, Motion for More Definite Statement, Motion Showing Good
Cause (Filed November 13, 2012) 298-350 I
Ex Parte Motion to Quash Subpoenas Duces Tecums and Subpoenas to Compel Testimony (Filed
November 3, 2012) 177-195 I Findings of Fact, Conclusions of Law (Filed December 14, 2012)
1069-1092 II Motion to Bifurcate (Filed October 16, 2012) 107-152 I
Motion to Dismiss (Filed October 15, 2012) 40-43 I

Motion for Order to Show Cause (Not Filed) 44-106 I
Motion for Mistrial of Formal Disciplinary Hearing (Not Filed) 613-1068 II Motion for New Trial or
Formal Disciplinary Hearing (Filed November 30,2012) 353-540 II Motion for Reconsideration or to
Reinstate Appeal (Not Filed) 563-606 II Motion to Quash Subpoenas Directed to Municipal Court
Judges and Court Staff (Filed November 2, 2012) 166-176 I Motion to Set Aside, Alter or Amend
Order, Opposition to Motion to Quash (Filed November 8, 2012) 217-297 I Notice of Formal
Hearing; Designation of Witnesses, Summary of Evidence (Filed October 12, 2012) 35-39 I Notice of
Intent to Proceed on a Default Bases (Filed October 9, 2012) 29-32 I Notice of Non-Service of Intent
to Take Default from Approximately October 9th, 2012 (Filed November 8, 2012) 201-204 I Notice
of Reno Municipal Courts Failure to File Coughlins Timely Notice of Appeal (Not Filed) 545-562 II
Opposition to Respondents Motion to Bifurcate Hearing, Motion to Dismiss (Filed October 21,2012)
153-156 II Order (Filed October 31, 2012) 163-165 I
17
Order (Filed November 7,2012) 198-200 I
18
Order (Filed November 16, 2012) 351-352 II
19
20
Order Appointing Formal Hearing Panel (Filed October 30, 2012) 157-158 I Supplemental
Designation of Witnesses (Filed November 7, 2012) 196-197 I Supplement to Respondents
Designation of Witnesses and Summary of Evidence, Notice of Objection
22
and Reply to Opposition to Bifurcate (Filed November 8,2012) 205-215 I Temporary Order for
Protection Against Harassment in the Workplace (Filed December 20, 2012) 1093-1097 II Transcript
(Held September 12, 2012) 1-332 III
23
Exhibits from Hearing 333-574 III
21
24
INDEX COUGHLINS CHRONOLOGICAL LIST OF DOCUMENTS
25
26
Description
Page and Volume No:
27
28
RECONSIDERATION
Complaint and First Designation of Hearing Panel Members (Filed August 23,2012) 1-28 I Notice of
Intent to Proceed on a Default Bases (Filed October 9, 2012) 29-32 I Affidavit of Laura Peters,
2 Custodian of Records (Filed October 9,2012) 33-34 I Notice of Formal Hearing; Designation of
Witnesses, Summary of Evidence (Filed October 12, 2012) 35-39 I Motion to Dismiss (Filed October
3
15, 2012) 40-43 I

1
4
5
6
7
8
9
10
11
12
13
14
15
Motion for Order to Show Cause (Not Filed, submitted 10/2/12 and again on 10/15/12 signed, and
ruled as Filed October 16th in Chair Echeverrias 10/31/12 Order) 44-106 I
Motion to Review and Inspect Bar Records; Motion to Bifurcate Hearing; Motion to Dismiss for
Complaints Failure to Sufficiently State the Charges with Specificity and Support and for Utter
Failure of Bar Counsel to Perform Reasonable
Investigation (Filed October 16, 2012) 107-152 I
Opposition to Respondents Motion to Bifurcate Hearing, Motion to Dismiss (Filed October 21,2012)
153-156 II Order Appointing Formal Hearing Panel (Filed October 30, 2012) 157-158 I Coughlins
Designation of Witnesses and Summary of Evidence (Filed October 31, 2012) 159-162 I Order (Filed
October 31, 2012) 163-165 I
Motion to Quash Subpoenas Directed to Municipal Court Judges and Court Staff (Filed November 2,
2012) 166-176 I Ex Parte Motion to Quash Subpoenas Duces Tecums and Subpoenas to Compel
Testimony (Filed November 3, 2012) 177-195 I Order (Filed November 7, 2012) 198-200 I
Supplemental Designation of Witnesses (Filed November 7, 2012) 196-197 I Notice of Non-Service
of Intent to Take Default from Approximately October 9th, 2012 (Filed November 8, 2012) 201-204 I
Motion to Set Aside, Alter or Amend Order, Opposition to Motion to Quash (Filed November 8,
2012) 217-297 I Supplement to Respondents Designation of Witnesses and Summary of Evidence,
Notice of Objection
and Reply to Opposition to Bifurcate (Filed November 8, 2012) 205-215 I Emergency Ex Parte
Motion to Dismiss, Motion for More Definite Statement, Motion Showing Good Cause (Filed
17
November 13, 2012) 298-350 I Notice of Reno Municipal Courts Failure to File Coughlins Timely
Notice of Appeal (Not Filed, submitted 11/16/12) 545-562 II Motion for Reconsideration or to
18 Reinstate Appeal (Not Filed, submitted 11/16/12) 563-606 II Order (Filed November 16, 2012) 351352 II
16
19
23
Motion for New Trial of Formal Disciplinary Hearing and Notice of Hill and Bakers Malfeasance
(Filed November 30,2012) 353-540 II Amended Supplemental to Respondents Emergency Motion
to Set Aside (Filed November 30, 2012) 541-544 II Notice that Laura Peters October 9th, 2012
Affidavit is Whopper Chocked; and Motion For Mistrial of Formal Disciplinary Hearing (Not Filed,
submitted on 12/3/12) 613-1068 II Declaration of Zachary Barker Coughlin (Not Filed, submitted on
12/7/12) 607-612 II Findings of Fact, Conclusions of Law (Filed December 14, 2012) 1069-1092 II
Transcript (Held November 14th, 2012) 1-332 III
24
Exhibits from Hearing (Held November 14th, 2012) 333-574 III
20
21
22
25
26
Temporary Order for Protection Against Harassment in the Workplace (Filed December 20, 2012)
1093-1097 II Certificate of Service by Mail of Record On Appeal 1098 II (Filed 12/24/12 missing
Coughlins CD/DVD Exhibits)
27
28
RECONSIDERATION
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
The Certificate of Service by Mail (bate stamped page 02925 in the big box signed for upon the
first delivery attempt by Coughlin on 11/7/12) signed by Laura Peters on October 9th, 2012 indicates
only the Notice of Intent to Proceed on a Default Basis was mailed to Coughlin (via certified mail
only, ie, not copied via first class mail as well). That 10/9/12 Certificate of Service by Mail by Laura
Peters does not indicate the Affidavit of Laura Peters Custodian of Records (supposedly file
stamped 10/9/12) was included in any such mailing. Coughlin never received the mailing of the
Notice of Intent to Proceed on a Default Bases (Filed October 9, 2012) 29-32 I, given the SBN
placed an insufficient amount of postage on it and counter clerk Tim of the downtown Reno USPS
Postal Station indicated to Coughlin (whom saw the large manilla envelope) that he could not release
it to Couglin, but rather, notated in his own handwriting on the envelope that it was being returned to
sender (which the USPS Track & Confirm reveals that it was on 11/8/12) in light of insufficent
postage. Coughlin placed the SBN on a a LITIGATION HOLD NOTICE with respect to that
envelope and mailing (which further implicates the assurances, promises, and representations as to the
applicable procedural rules and practice attendant to such Notices of Intent to Take Default, and
matters related to Defaults, the SBNs policy with respect to under what circumstances it would assert
a Proof of Service of the Complaint, and when an Answer would become due (the SBN represented to
Coughlin on 9/11/12 that a second certified mailing of the Complaint and Initial Designation would
go out to Coughlin the following day, and upon the SBN receiving a signed certified mailing return
receipt card from Coughlin the 20 days to respond to the Complaint would be measured from the date
Coughlin signed for that return receipt card, and barring that, upon the second certified mailing being
return to sender at the SBN, a Notice of Intent to Take Default would be sent to Coughlin by certified
mail as well, and would explicitly state that Coughlin had 14 days from the constructive receipt (3
days for mailing under NRCP 6(e)) of that Notice of Intent to Take Default before any Response or
Answer from him would be too late to be considered absent a showing of good cause from him.
Assuming the SBN had followed through on actually sending out a purported second certified mailing
of the Complaint and Initial Designation on 9/12/12 (which Peters admits to misleading Coughlin
about in her Affidavit of Laura Peters (file stamped 10/9/12, though the bate stamping for it in the
11/7/12 3,000 page production to Coughlin, which was the first and only time Coughlin was served or
mailed any such Affidavit by Peters, and which lacks a caption or Proof of Service of any sort.
21
Peters sworn Affidavit baring a file stamp of 10/9/12 (though lacking a caption or Proof of
Service and being bate stampe 02795 to 02796, and therefore placed immediately before Chair
23 Echeverrias 10/31/12 Order (which starts at bate stampe 02797, with the cover page of the Formal
Hearing Pleadings, SBN. Zachary Coughlin, Case Nos. NG12-0204, NG12-0434, NG12-0435
24 having a bate stamp, 02794, of the page immediately preceding the Affidavit of Laura Peters that
begins on bate stampe page 02795 (which means the bate stamping for that Affidavit of Laura Peters
25
and the file stamp date on it make no sense, nor does the lack of a caption, the absence of an reference
26 to that Affidavit in the Notice of Intent to Take Defaults Certificate of Service of 10/9/12, etc., etc.).
That 10/9/12 Affidavit of Laura Peters attests under penalty of perjury after being sworn:
22
27
28
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
LAURA PETERS, under penalty of perjury, being first duly sworn, deposes and says as follows:
That Affiant is employed as a paralegal for the discipline department of the State Bar of Nevada
and in such capacity is the custodian of records for the State Bar of Nevada; That on September 11,
2012, at approximately 4:45 p.m., Zachary Coughlin called Affiant to confirm that a hearing was
still scheduled to take place on September 25, 2012. Affiant explained that the hearing would not
take place on September 25th and that date had been scheduled prior to the filing of a formal
Complaint. Mr. Coughlin reacted as if he had no knowledge of a Complaint. Affiant then
explained that, in fact, a copy of the Complaint, sent via certified mail on August 23,2012, from
the Reno office of the State Bar, had been returned and marked unclaimed. Affiant further
explained that since service had not been affected, a new certified copy would go out the next
day. Affiant requested that when Mr. Coughlin received said copy, he should return the postcard
attached to the mailing and his twenty (20) day period in which to answer the Complaint would
start running at that point. However, in speaking to Assistant Bar Counsel Patrick King, it was
determined that personal service should be affected upon Mr. Coughlin. Reno Carson messenger
service was engaged to attempt personal service despite Mr. Coughlin not providing the State Bar
with a physical address.
On September 25, 2012, Mr. Coughlin arrived at the Reno office of the State Bar allegedly
expecting a hearing to take place. At that time, Mr. Coughlin was again told, both by Affiant and
Assistant Bar Counsel Patrick King, that no hearing would be taking place that day and that an
answer to the State Bars Complaint had not been received. Affiant personally served Mr.
Coughlin with a copy of the Complaint on his visit to the Bar office on September 25th as
witnessed by Paula Campbell, an employee of the State Bar. Mr. Coughlin insisted that the
hearing which had been previously scheduled for that day should be taking place because he
needed to be removed from temporary suspension. Mr. Coughlin has also been instructed by
Assistant Bar Counsel Patrick King that he cannot file pleadings with the State Bar via e-mail,
which he continues to attempt. The Motion to Dismiss, which Mr. Coughlin now insists should be
granted as it has gone unopposed by the State Bar, was never presented to Affiant for filing
but was rather emailed prior to Affiants conversation with Mr. Coughlin on September 11th
when Mr. Coughlin under no uncertain terms told Affiant that he had not yet received the
Complaint. FURTHER YOUR AFFIANT SAYETH NOT. Dated this 9th day of October, 2012.
The most glaring lies in the above Affidavit of Laura Peters occur where she swears: The Motion
to Dismiss, which Mr. Coughlin now insists should be granted as it has gone unopposed by the
21 State Bar, was never presented to Affiant for filing but was rather emailed prior to Affiants
conversation with Mr. Coughlin on September 11th when Mr. Coughlin under no uncertain terms
22
told Affiant that he had not yet received the Complaint. It is categorically false for Peters to
23 indicate that Coughlin said one way or the other whether or not he received the 8/23/12 Complaint
during their 9/11/12 communications. A marked point was made by Coughlin to Peters as that time
24 as to just that very issue, ie, whether Coughlin was then indicating whether, one way or the other, he
had, in fact, received any such Complaint. (Note, Washoe Legal Services admits it actually received
25
legible copies of Coughlins Complaint in 60317 and 60302, however, all manner of arcane service
26 and process insufficiency arguments were put forward, some sua sponte by the Judges themselves,
including Judge Elliott in the suit CV11-01955 where Coughlin added CAAW as a party, where
27 Judge Elliott failed to divulge that he sat on CAAWs Executive Board, in the appeal in 60317, where
even a video of the service of the Summons and Complaint on a senior paralegal, Bertha Mann, and a
28
mor than a receptionist, Jessica Garzae was insufficient to provide Proof of Service, even where a
20
RECONSIDERATION
Declaration of Service was signed by a non-party, over 18 years old, captured on video). But Peters
biggest lie occurs where she swears: The Motion to Dismiss, which Mr. Coughlin now insists
2 should be granted as it has gone unopposed by the State Bar, was never presented to Affiant for
3
filing but was rather emailed prior to Affiants conversation with Mr. Coughlin on September
11th. How Peters possibly thinks she can get away with that is unclear, given those are digital
4 transmission she is referring to, and that Coughlin has, and has presented to the Bar, Peters, NNDB,
and Panel proof of emailing and faxing the Motion to Dismiss to Peters, SBN, and the NNDB on
5 September 17th, 2012, which is obviously after the emailed prior to Affiants conversation with Mr.
Coughlin on September 11th. The simple fact is Peters and the SBN, NNDB, and Panel gave
6
Coughlin permission to fax file on 9/11/12, and Couglin fax filed his Motion to Dismiss on 9/17/12,
7 and the SBN failed to timely oppose it. See Ex. 1 (confirmation of delivery of faxing emailing Motion
to Dismiss to SBN on 9/17/12 and emailing it again to Peters on 9/24/12 and proof that no such
8 Motion to Dismiss was ever email to the SBN or Peters prior to 9/11/12).
1
It was just such a failure to timely oppose a Motion for Attorneys Fees that resulted in Judge
Flanagan awarding $42,050 in attorneys fees to Richard G. Hill, Esq. In the Order of 6/28/12 that
10 was admitted as Exhibit 2 at the 11/14/12 Hearing despite Bar Counsel having never pled or noticed
11
Coughin as to the possibility or intent to proffer or argue that Order awarding Hill attorneys fees as
proof of any of the allegation in the Complaint. Further, the SBN and Chair Echeverrias extreme
12 attempts to prevent Coughlin from querying Court Report Carol Hummel as to whether that 6/28/12
Order by Judge Flanagan was actually a certified copy (and whether any such certified copy was, in
13 fact, presented at the time of the Hearing, or, whether it was only provided to Ms. Hummel after the
Hearing. Regardless, Coughlin was never presented a certified copy of that Order, nor was he shown
14
one. And Kings representation during the hearing that he had certified copies of all of the court
15 documents I am seeking to admit here today is obviously undermined by the fact that the 4/10/09
Order by Judge Linda Gardner is not certified, and further by the impermissible practice of RMC
16 Clerk Donna Ballard certifying documents from a different court than the one for which she works.
9
17
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19
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21
22
23
24
25
26
27
28
Couglin called and wrote Reno Carson Messenger Service seeking to arrange a place to meet and
be served the Complaint. From approximately September 27th, 2012 to when Coughlin changed his
SCR 79 address with the SBN and wrote to Bar Counsel and provided his new 1471 E. 9th St. address,
Coughlin was fearful of local law enforcement in addition to having residual fear leftover from the
domestic violence he was subjected to that resulted in his receiving two TPOs in FV12-00188 and
FV12-00187 on 1/23/12 and did not wish to reveal his physical address to an Office of Bar Counsel
that had given little indication that is was anything other than complicit in the malfeasance of a select
few in local law enforcement, Hill and Baker, and some others that will go unnamed at this point.
Nonetheless, Couglin took every reasonable step to avoid any claim that he dodge personal service by
the SBN. Reno Carson Messenger Service simply did not call or write Coughlin back or otherwise
seek to meet him anywhere to effect personal service, nor did the SBN respond to Coughlins offer in
that regard. At this point, the SBN has nothing on file or presented to the Panel to provide Proof of
Service other than the original 8/23/12 Certificate of Service attached to the Complaint that SBN
Clerk of Court (that is what she and Bar Counsel King have held her out as on numerous occasions to
Coughlin, including on 9/25/12, when Coughlin appeared for the Hearing that Peters admits had been
calendared and for which Couglin had received written Notice of from Peters. King fraudulently
included that original 8/23/12 Affidavit of Mailing signed and sworn to by Peters, wherein she swears
to have served Coughlin the Complaint, which even if Coughlin were unable to prove exactly what
Peters and the SBN/Panel/NNDB represented to him (he can, though) on September 11th, 2012,
Peters Own Affidavit of Laura Peters of 10/9/12 admits that her 8/23/12 Affidavit of Mailing is
RECONSIDERATION
incorrect and fraudulent and that Kings presenting it as an Exhibit to the Panel is misconduct and
demonstrates a lack of candor to the tribunal and an utter disregard for the requirement to display
2 fairness to the opposing counsel and party, Coughlin. Coughlin preserved his objection in that regard
at the 11/14/12 Formal Disciplinary Hearing. Further, given that the 11/7/12 delivery to Couglin of
3
3,000 pages of documents, wherein, for the first time, Coughlin was provided a copy of that 10/9/12
4 Affidavit of Laura Peters, was not timely served, nor was any explanation for the filey to so timely
serve it offered by the Panel, SBN, NNDB, or Peters, any failure of Coughlins to have that Affidavit
5 admitted as an exhibit should be excused. However, Coughlin did, in fact, move to have all
documents on file or presented for filing entered as an exhibit, which Bar Counsel and the Panel
6
refused, though, the 12/24/12 Record on Appeal seems to suggest that Bar Counsel, at least in part, is
7 feeling the need to put forward at least a little effort to appear to be providing an accurate record,
though the multitude of key ommissions of Couglin CD/DVD exhibits and the failure to file stamp a
8 number of filings, and the failure to include even non file stamped submissions, is a troubling
reminded of how compromised the Office of Bar Counsel truly is.
9
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15
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20
21
SBN definitely put together the 12/24/12 Record of Formal Disciplinary Proceedings in a
fraudulent manner, well beyond not file stamping Coughlins filing, or recognizing the express
permission given to Coughlin to fax file...SBN and Clerk of Court/Custodian of Records Peters failed
to transmit the CD/DVDs attached to Coughlins Exhibit 15 at the 11/14/12 Hearing (but there, at
least the SBN/Peters transmitted a 1 page per CD/DVD photocopy of what the disc looked like (not
the files on it, but the physical representation of the disc itself)...however, on numerous filings by
Coughlin, the SBN/Peters failed to include even a picture of the disc Coughlin attached to his filings
(and in some instances, sensing the SBN would try to gain an advantae by doing this Coughlin both
attached a disc, as well as a hard copy of what was saved on the disc where printale (ie, bate stamped
pdf filed containing pages and pages of court files and emails revealing conflicts and fraud between
the SBN, RMC, RJC, 2JDC, WCDA, WCSO, RPD, City of Reno, Reno City Attorneys Office, SBN,
NNDB, OBC, Panel, WLS, Echeverria, Gayle Kern, Esq., Nevada Court Services, Lew Taitel, Esq.
Keith Loomis, Esq., Roberto Puentes, Esq., Henry Sotelo, Esq., RMC Court Staff and Judicial
Assistants, 2JDCs Chief Appeals Clerk Lori Matheus (whom has an established practice of getting
her hands and influence on every case involving Coughlin, whether it is an appeal or not and at one
point rejected 19 of 23 of Coughlins eFlex submissions, including extremely materials submission
implicating WLS, RMC Judge Nash Holmes, 2JDC Judge Steven P. Elliot, and the WCDAs Office.
22
Further, there is an error in the SBNs Alphabetical Index of Documents regarding the date the
23 Hearing was held where it reads: Transcript (Held September 12, 2012) 1-332 III when the Hearing
(and necessarily the Trancript) was held November 14th, 2012.
24
Also, the SBNs 12/24/12 filed Record on Appeal obviously attempts to encourage the
Justices/Nevada Supreme Court attorneys assigned to review this matter to not read the record by a
25
fraudulent practice or purposefully going out of its way to arrange the filings in such a way that one
26 reviewing the record as submitted by the SBN would have to flip over the bound Volumes 1-3 for
each and every page turned to have the pages appear right side up. This simply does not and could
27
not happen by chance if you think about it. The SBN had to go out of its way to either physically
28
manipulate the appearance, binding, and bate stamping of the three volumes, or manipulate the print
RECONSIDERATION
settings digitally, such that the appearance and orientation of every single page (when considering
how the pages are bound, and the fact that the SBN has chosen to use duplex printing to print on both
2 sides of every page, something N. S. Ct. Clerks Office Castillo remarked on the unusual nature
thereof (after she indicated Coughlin had, in fact, apprised her of the fact that the various CD/DVDs
3
were missing, not only from Exhibit 15 of the 11/14/12 Hearing, but from numerous filings by
4 Coughlin as well).
Additionally, the unusual appearance of an Alphabetical Index of Documents on File even more
clearly reveals the extent to which the SBN/Clerk of Court/Custodian of Records/Panel/NNDB are
extremely keen to downplay the procedural irregularities involved in the fraudulent, willful, and
7 invidious denial of due process throughout this formal disciplinary matter. The traditional practice
8
by the SBN and Clerks of Court is to include a chronological Index of Documents. But, the SBN et
al know that that would put into stark relieve the SBNs failure to file key documents submitted by
9 Coughlin (particularly where SBN Kings failure to opposes them would have adverse consequences
to his prosecution and make him look like even more of a compromised, biased, and negligent
10 prosecutor than he already appears.
6
11
Additionally, the SBN has taken to fraudulently altering the titles of the documents Coughlin
submitted for filing (which the SBN did not file stamp anyways). In the SBNs Alphabetical Index of
13
Documents the following item does not reflect the actual title of the document found at bate stamped
page 613 in Volume II: Motion for Mistrial of Formal Disciplinary Hearing (Not Filed) 613-1068
14 II. The actual title of that document Coughlin submitted for filing is Notice that Laura Peters
October 9th, 2012 Affidavit is Whopper Chocked; and Motion For Mistrial of Formal Disciplinary
15
Hearing.
12
16
17
18
19
And additionally instance of the SBN altering the titles of Coughlins filings in its Alphabetical
Index of Documents appears where the SBN lists Motion to Bifurcate (Filed October 16, 2012) 107152 I for Coughlins filing a Motion to Review and Inspect Bar Records; Motion to Bifurcate
Hearing; Motion to Dismiss for Complaints Failure to Sufficiently State the Charges with Specificity
and Supporty and for Utter Failure of Bar Counsel to Perform Reasonable Investigation
And it is very important to remember that, despite the SBN listing a filing date of October 9th, 2012
for Affidavit of Laura Peters, Custodian of Records (Filed October 9,2012) 33-34 I, Coughlin never
21 received any such filing by the SBN until November 7th, 2012 when it was buried within 3,000
pages (printed on only one side of the page) produced by the SBN (Coughlin signed for the box of
22
documents the first time the USPS attempted to delivery it on November 7th, 2012 (despite SCR
23 105(2)(c) entitiling Coughlin to access to such materials at least 30 days prior to the 11/14/12
formal disciplinary hearing, and access to all those materials and any new materials within 3 days
24 of that 11/14/12 hearing date. As such, Coughlin was deprived of (any such materials received by the
SBN between the crucial time frame between when the November 7th, 2012 big box production
25
was, according to Peters sent out to the printer and when that within 3 days of the 11/14/12
26 hearing date is interpreted to fall (NRCP 6(e) might be instructive, though arguably that applies to
other sorts of matters not applicable to the access rights under SCR 105(2)(c)). During a October 31st,
27 2012 attempt to access such materials to which Coughlin was entitled under SCR 105(2)(c), Clerk
Peters refused to allow Coughlin such access and indicated they were going to the printers the next
28
day in according with Chair Echeverrrias 10/31/12 Order. However, the November 7th, 2012 big
20
RECONSIDERATION
box did not include Coughlins filing of 10/31/12. Further, that big box bate stamped collection
places the Affidavit of Laura Peters, Custodian of Records (Filed October 9,2012) 33-34 I directly
2
after
1
3
4
5
Further, the SBN has fraudulently failed to file Coughlins Motion for Order to Show Cause (Not
Filed, submitted 10/2/12 and again in hard copy with an original signature on 10/15/12 signed under
NRS 53.045 penalty of perjury and filed and served on Bar Counsel in 60838 as well, and ruled as
Filed October 16th in Chair Echeverrias 10/31/12 Order) 44-106 I
Harris and the Nevada State Bar do not dispute the facts that underlie this matter. Harris has been
licensed to practice law in Nevada since 1974. Between January 2008 and September 2009, Harris
7 misappropriated approximately $788,000 from client trust accounts and his firms general client trust
account, using the funds for his personal gain. At the conclusion of the hearing, the panel found that
8 Harris had violated RPC 1.15 (safekeeping of property) and RPC 8.4 (misconduct). While the
findings and recommendations of a panel are persuasive, this court reviews a panels decision
9
recommending suspension de novo. SCR 105(3)(b); In re Stuhff, 108 Nev. 629, 633, 837 P.2d 853,
10 855 (1992). The findings of misconduct by the panel must be supported by clear and convincing
evidence. SCR 105(2)(e); In re 108 Nev. At 635, 837 P.2d at 856.
11
One thing seems clear, whether its Coughlin, Mirch, Crowley, or Boles, any attorney in the State
of Nevada that challenges the status quo and or local law enforcements vice grip on on certain
12
branches of government will be attacked by the SBN. Crowley v. Nash Holmes, 107 F.3d 15, No. 9513 16874. (Crowley alleges a violation of his Fourth Amendment right to be free from warrantless
searches and seizures as well as a violation of 18 U.S.C. 2510-2511. The district court granted
14
summary judgment to defendants on the ground that the radio signals produced by a cordless
15 telephone are not protected by either the Wiretap Act or the Fourth Amendment). A public
defender like Jim Leslie or Biray Dogan can, by way of analogy, be an overnight hospitalist who
16 walks around offing patiens by stabbing them in the name of saving the hospital money (which,
typically results in a raise to the hospitalist), and Bar Counsel will dispose of any grievance you file
17
against Biray Dogan quicker than you would believe. Name one time, ever, the SBN has prosecuted
18 a prosecutor. No, rather the SBN seems to have a bit of a boutique practice snuffing out solos whom
run afoul of powerful firms, and or, as here, judges (typically judges of the lifelong prosecutor turned
19 judge variety). Same goes for a grievance against another court appointed defender of a criminal
indigent, Keith Loomis, Esq., who, like Chair Echeverria, maintains his office within 75 yards of the
20
SBNs Northern Office.
21
Further, Coughlin should have been provided an attorney by Washoe Legal Services to defend
himself against the April 2009 Order sanctioning him by Judge Linda Gardner. Rather, Elcano and
22
WLS refused to allow Coughlin access to necessary materials (his work files and email) to defend
23 himself, all while WLS and Elcano harassed Coughlin by contacting his immediate family in
attempting to leverage influence. Elcanos May 4th, 2009 letter to Couglin reads, in part Your
24 current suspension was a result of the order entered by Judge Gardner in the Joshi matter;...You may
appear on your own behalf to litigate the order of sanctions entered by Judge Gardner....You
25
requested a formal response to your complaint concerning Rhonda. This was investigated by me
26 within 48 hours of your complaint. There is no question that your office behavior (which included
yelling, and calling her a hall monitor, etc.) upset her, and as a direct result she made a comment to
27 you. She was counseled as to the type of language she used, and specifically told that even though she
was upset this language (bite me) was not appropriate for the workplace. I did not realize you
28
wanted a formal response to this incident. Please consider this your formal response...I will review the
RECONSIDERATION
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tape in the Joshi matter, your fifty page motion for reconsideration and any other written material you
provide to me. If your conduct was as represented by Judge Gardner you will be terminated. This
termination will be based exclusively on the manner in which you conducted this hearing, and will
not be related to any ultimate outcome regarding the sanctions order. Washoe Legal Services told
Coughlin he was on his own as far as defending himself against Judge Linda Gardners Order
sanctionin him, despite the fact that the days immediately preceeding that 3/12/09 Trial date,
Coughlins time was largely consumed doing a side project for Elcano to address the fact that
Elcano, in moving WLS to 299 S. Arlington Ave from the Gabrielli Building at 650 Tahoe St., had
entered into WLS into a lease with a private landlord wherein WLS, a 503(c) non-profit, was likely to
be responsible for the property taxes, to Elcanos suprise. Couglin hurriedly prepared a thorough 20
page appeal to the Department of Taxation in time for the 3/10/09 deadline for its submission, and up
to a month prior to and during this period of time, now former WLS Officer manager Robin Kunce
and WLS paralegal Deborah Pringle informed Couglin that he would not be able to any checks cut for
any of the various discovery Coughlin wished to send out for the Joshi divorce Trial, as Kunce would
need six weeks to get a check cut for something like a subpoena. Further, Coughlin gave Pringle a
simple assignment to go to the Washoe County Law Library and obtain a specific ALR article on the
Siragusa issues involved in the Joshi Trial, and she was unable to perform that task, and at the time,
Couglin sent Pringle an email identifying what it was he was asking her to get, which now supports
Coughlins contention that the positions he took in the Joshi Trial, and which he subsequently spelled
out in great detail in the Mandamus Action stemming therefrom in 54844 and in his various Motions
for Reconsideration, where in no way vexatious or unsupported or due to a failure on Coughlins part
to undertake discovery (for which Springgate served no more discovery requests than did Coughlin.
Further, Springgates closing argument Motion for sanctions failed to comply with the 21 day safe
harbor provisions of NRCP 11, made applicable by express incorporation thereof within NRS 7.085,
which Springgate cited to and which Judge Gardner incorporated into her Order. Futher, Judge
Gardners Order is incorrect in asserting that the testimonial evidence elicted by Couglin fails to
touch on any of the statutory basis set forth as considerations in determining alimony, specifically,
Ms. Joshi testified that the forewent educational opportunities in raising her children. Additionally,
the months previous to this Trial, Coughlin was harangued by the same CAAW Judge Elliott (whom
failed to announce the conflict or recuse himself from presiding over the suit wherein Coughlin sued
WLS and CAAW in CV11-01955 and made rulings that require getting to the merits of the case
even where he dismissed the case for insufficient process and or insufficient service of process (even
where a signed Declaration of service by a non-party over 18 was filed, along with a video of the
service itself upon one of WLSs longest tenured employees, paralegal Berta Mann and Jessica
Garzae, whom Elcano and Sternlicht had long touted as having responsibility far beyond that of a
receptionist, although, under certain circumstances, a receptionist may be authorized to accept service
of process on an Executive Director and or corporations behalf.)
23
24
25
26
27
28
Harris began going to the Thursday Night Group in 2010. Coughlins has been going to Coes
Thursday Night Group since 2003. Becket went to a rehab for like a week, then that former DA had
his NRS 199.280 conviction set aside, and boom, two months worth of a suspension later or so, hes
back in the game. The prosecutorial retaliation demonstrated against Couglin here (by a bevy of
former lifelong prosecutors turned Judges in RMC Judge Howard, Judges William and Linda
Gardner, Judge Nash Holmes, Judge Clifton, and current prosecutors DDA Young, City Attorneys
Roberts, Hazlett-Stevens, Drake, Ormaas, etc., etc. is all the more untoward upon a thorough review
of all the different Beckett disciplinary cases. Coughlins attendance at the Thursday Night Group
RECONSIDERATION
began to lessen upon his suspension from Washoe Legal Services and firing several weeks thereafter,
Paul Elcano directing Couglin, in writing to Call Coe and Elcano and Swobe calling Coughlin and
2 Coughlins immediate family and attempting to apply pressure to Coughlin, first to assent to some
conditions, then, upon termination, to drop his wrongful termination lawsuit. Couglin did good
3
work at Washoe Legal Services and consistently had enthusiastic reviews by his clients, and tripled
4 the case load previously held by Larry Belasco and Caryn Sternlicht. And no prejudicial,
concomitant SCR 117 Disability Petition for Stephen R. Harris, Esq., either. Where are Coughlins
5 victims. Where are the unhappy, complaining clients?
1
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Also, its kind of suspicious how NNDB Chairman J. Thomas Susich's 6/18/12 SCR 117 Petition
against Coughlin, at Exhibit 3, just happens to be missing the page consisting of the emailed
admission by WCSO Civil Division Supervisor Liz Stuchell that Deputy Machen's 11/7/11 file
stamped Affidavit of Service in the summary eviction from Coughlin's former home law office before
Judge Sferrazza in RJC Rev2011-001708 is fraudulent (or at the least incorrect...apparently Richar G.
Hill, Esq. is endowed with a certain largesse by his fellow NNDB members to utilize supposition,
outright conjecture stated as fact, and other baseless allegations (see his Declaration found in and the
filings themselves by he and his assoicate Casey D. Baker of 11/20/11 in 001708 and 1/21/12 in the
appeal in 03628 wherein the alleged finding of "a crack pipe and a bag of weed" at Coughlin's former
home law office is made, along with mentions of "a vial of something", a "large quanity of pills", lots
of unsworn hearsay attributed to the contractor (the 3/23/12 and 3/27/12 videod Show Cause Hearing
before Judge Flanagan is essential here, however, Coughlin has been unable to afford it and Chief
Judge David Hardy has denied each and every IFP Couglin has submitted, even where Hardy violated
Judicial Canons (or at least, the opinion letter Judge Sferrazza attached in his 2007 application to
become a RJC Justice of the Peace (which highlighted the objetionable practice so thoroughly utilized
by Judge Linda Gardner and Coughlin's former RMC appointed defender in the trespass matter,
Lewis Taitel, Esq. (and the irony in RJC Judge Pearson's likely committing judicial misconduct
attendant to his work in RJC 2012-001048 in the 7/31/12 hearing WCPD Jim Leslie, Esq. so
steadfastly refused to obtain, which involved Taitel's business partners in the unauthorized practice of
law, which Judge Pearson (whom campaigned so very critically against Taitel) permitted Nevada
Court Services to not only committ the unauthorize practice of law, but went on to fail to uphold the
law in NRS 40.253 in excusing the patent deficiencies in the 5 day notice of 6/14/12 (which was
fraudulent to begin with in that it alleged personal service on a closed, locked door that Northwind's
manage Duane Jakob and NCS's licensed process server Ryan Wray attempted to break into at
Coughlin's rental #29 at Northwinds Apartments at 1680 Sky Mountain Dr., Reno, 89523 (where the
RPD continually violated Soldal v. Cook County, and considering the admission by RPD Sargent
Sifre on the Brady material tape WCDA DDA Young ultimately releated, there is at least some
implications of a conspiracy between the RPD, WCSO, and RJC to deprive Couglin of his rights as a
tenant, even where that means prejudicing him as a criminal defenant (which is particulary regrettable
given Judge Sferrazza's apparent misconduct in refusing to allow a licensed attorney (Couglin was up
until June 25th or so, giver or take SCR 115's 15 days falling on a weekend (and 2JDC Clerk Orduna
Hastings may have been wrong to fail to file the Motion for Summary Judgment Coughlin submitted
on behalf of then client Eastman in CV11-00820 (a mitigating basis here as well is the attack by
Eastman and fraudulent conduct of Jeff Nichols incident to events occurring between the wrongful,
fraudulent, RPD violating default summary eviction obtained by Gayle Kern, Esq. on 3/15/12 from
Judge Schroeder (whose work on the Richard G. Hill, Esq. TPO of 1/12/12 and at the 1/31/12
extension hearing may be judicial misconduct, and whom is curiously cited in the docket for 065630
RECONSIDERATION
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19
as presiding over the MSC of 2/27/12, though Judge Clifton managed to have that case "transferred"
to him on 2/27/12 (as shown by the handwritten, though unsigned note in the file from the RJC that
Coughlin obtained prior to Judge Sferrazza implementing, essentialy martial law and a refusal to
allow Coughlin to access materials at the RJC absent extraordinary oversight and involvement by
WCSO Bailiffs (including John Reyes, whom Coughlin filed for a protection order against incident to
his constant harrassment and telling Coughlin, while Coughlin was seated next to Leslie in the
waiting area of the RJC on October 9th "I am going to put my foot up your ass" (which Judge
Sferrazza failed to rebuke upon Coughlin pointing out to him on 12/20/12 that Hill and Bailiff Reyes
and Chief Bailiff Sexton had share a laugh over Hill commentary in Court at that Hearing on
Couglin's Motion to Contest Personal Property Lien of 11/16/11 (curious calling of court personnel as
"witnesses" by Judge Sferrazza and appearance of unsworn "statements' by RJC Chief Civil Clerk
Stancil and Clerk Jonas incident to scheduling arguments related to RJC failure to provide hearing
within 10 days required by NRS 40.253(8), and Hill's 11/22/12 email that violating RPD forbidding
implyign in improper ability to influence a tribunal...which Hill does regularly and which is why the
SBN is so keen to avoid having Hill's 1/14/12 "grievance" against Coughlin submitted in an unsigned
letter to the SBN (wherein Hill fakes thinking Coughlin accidnetally file something in the Carpentier
case when it is expressly clear that Coughlin mentioned the matters he did in that 1/13/12 filing in
Carpentier v. Aames (which in common with the eviction appeal in 03628 the fact that D7 Judge
Flanagan presided over it, and therefore, Couglin went out of his way to avoid any appearnace of ex
parte communication by copying Hill on the filing, which Hill then fraudulently attempted to allege
Coughlin has filed in some stupor not realizing which case he filed it in...very clever, Rich...well, not
really, but, you know what I mean) who filed a Notice of Appearance substituting himself in for the
WCPD (or at least in as co-counsel) to file anything on his behalf (though Judge Sferrazza may be
backing of that now that more attention is brought to 063341) , and arguably
TIME IS OF THE ESSENCE, therefore, Petitioner prays that this Court entertain this petition
immediately, and amend its Order to impose discipline that is fair and consistent with discipline that
has been imposed on other Nevada attorneys.
Petitioner requests that this Court take judicial notice of the following documents pursuant to Nev.
Rev. Stat. 47.150. Also see Andolino v. State, 99 Nev. 346, 662 P.2d 631, 1983 Nev. LEXIS 440
(1983) (I.e., A court must mandatorily take judicial notice if requested to do so by counsel and if
provided the necessary information):
-Orders of the Nevada Supreme Court in In Re Stephen R. Harris, Esq. (case 61942, Order of
Reinstatement of 11/8/12, though an unpublished Order under SCR 123, Laub indicates is
21 permissible to utilize for comparison) Somehow, despite Harris misappropriating $755,000 from his
clients, he faced no temporary suspension, and was only charged with two violations the the RPC, and
22
for those two violations was accorded every single protection set forth under SCR 105(2)(c), whereas
23 Coughlin still maintains he did not steal the candy bar and cough drops he is accused of stealing,
and was accorded none of the rights set out in SCR 105(2)(c), has been subject oto a temporary
24 suspension now for as long as Harriss own suspension itself was in effect , and Coughlin received
nowhere near the Hearing hours afford Harris and Grundy despite the Complaint against Couglin
25
being a everythign in the RPD but the kitchen sink variety copying and pasting, to which
26 Coughlins Motion to Bifrucate was summarily dismissed within 12 hours of Chair Echeverria being
assigned this matter, wherein he continually stuck his tongue out at Coughlin throughout the hearing
27 in some Boss Hogg affectation. In the Matter of
20
28
Discipline of Stephen R . . Harris, Docket No. 57507 (Order of Suspension, February 24, 2012). and
RECONSIDERATION
-the 3/27/12 Order Denying Respondent Merlisss Motion for Order to Show Cause (also found in
Ex. 1 at bate stamp X, that 1/21/12 Motion by Hills Associate Baker with a Hill Declaration included
2 therein as an Exhibit) by Judge Flanagan (and the SBN may have demonstrated a lack of fairness to
opposing counsel and or insufficient candor to the tribunal where that 3/27/12 Order was possessed
3
by the SBN, as proven by its inclusion in the 11/7/12 delivery to Coughlin from the SBN of a 3,000
4 page box of documents wherein the 3/27/12 Order is found from pages 02733-02735, which
demonstrates to a large extent that the alleged misconduct by Coughlin Hill testified to was actually
5 litigated therein and a res judiciate or preclusive effect should be applied establishing Coughlin did
not commit misconduct as to any and all allegations by Hill or Baker pled in their 1/21/12 Motion to
6
Show Cause, and including any conduct by Couglin up and through the 3/27/12 Order by Judge
7 Flanagan where Hill and Baker were provided two different Hearings wherein they were afforded an
opportunity to put on evidence of and make argument related to any such allegations of misconduct
8 by Coughlin (and, in fact, Hill and Baker subpoened witnesses, made argument, and filed documents
therein, demonstrating a great deal of due process was accorded their allegations, and they were
9
denied in the appeal of the summary eviction wherein Hill was opposing counsel (and from which
th
10 Hearing Exhibit #2, Judge Flanagans June 28 , 2012 Order awarding Hills client, landlord Merliss
$42,050 in attorneys fees): attached hereto within Exhibit 1 (bate stamp number X).
1
11
12
Exhibit 4 State Bar of Nevada Northern Nevada Disciplinary Board Decision, Findings of Fact and
Decision; Exhibit 5 Order of Disbarment dated April 10, 2008;
13
Ex 6, Order Denying Petition;
14
15
Exhibit 7 Motion to Dismiss in case no CR07-1197;

Ex 8 Order dismissing CR07-1197 with prejudice; and
Exhibit 9 State Bar of California nolo contendere plea by Kevin Mirch.
16
17
18
19
20
21
22
23
24
Judge Flanagans 3/27/12 Order Denying Respondent Merlisss Motion for Order to Show Cause
held as follows:
Procedural History: On January 20, 2012, Respondent, Matt Merliss [hereafter Merliss], filed his
Second Motion for Order to Show Cause, and the matter was submitted for decision on February 8,
2012. An Order to Show Cause was entered February 8, 2012, setting the hearing date for same on
March 23, 2012, to commence at 11 :00 a.m. On March 13, Appellant, Zachary Barker Coughlin
[hereafter Coughlin], filed his Supplement to Motion to Vacate or Stay Hearing on Order to Show
Cause. The matter was heard on March 23, 2012, and due to time constraints, the hearing was
continued and completed on March 26,2012. This Court, having heard evidence, argument and
apprised of the pleadings herein Orders that Respondent Merlisss Motionfor Order to Show Cause
to hold Appellant Coughlin in contempt of this Courts Order of January 11, 2012, is DENIED.
25
26
27
28
The proximity of the 3/23/12 Hearing on Hills Motion for Order to Show Cause and so many of
the other alleged instances of misconduct by Coughlin for which the SBN put on documentary
evidence, and testimony, and made argument to at the 11/14/12 Hearing provides a mitigating factor
here, to wit, within a 30 day radius of the 3/23/12 Hearing, the following occurred and or documents
were filed by Coughlin, providing context to any deficiencies found in Coughlins filing before the
RECONSIDERATION
NVB and Judge Beesley, the 2/12/12 filing in 065630 in the RJC that RJC Judicial Secretary Lori
Townsend voluntarily sent the SBN (and where in her attached email to the SBN she, unprompted,
2 offered to forward the SBN another filing by Coughlin critical of the WCDA, RPD, WCSO, RJC,
and WCPD in 063341): -2/21/12 Filing in RJC RCR2012-065630 by Coughlin attached to NNDB
Chairman Susichs SCR 117 Petition and set forth in paragraph X of SBN Kings 8/23/12 Complaint.
1
4
5
6
7
8
9
10
11
12
13
14
15
16
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-2/27/12 Trial in RMC 11 TR 26800 before Judge Nash Holmes and 5 day summary incarceration
wherein Coughlins 1996 Honda Accord was towed from the Sienna parking lot, requiring some $270
to get it out of impound, as a time when Coughlins bar dues and CLE requirements necessitated
Coughlin spending approximately $1,000 therein (on a number occasions throughout the relevant
times frames in question here, Coughlins Mother, Mary Eleanor Barker, has loaned him money on
an emergency basis. Coughlins parents divorced when he was 3 years old and his mother has been
-the final installment of a flat fee arrangement from then client Keller having been paid around
February 2012, Coughlin suddenly lacking any dependable income given the failure to pay him
services by then client Dana Harris in two family law matters (one implicating UIFSA law and
presenting the WCDAs Office with a potentially disadvantageous set of precedent should Coughlins
filing therein been successful before Judge Walker, whose Judicial Assistant is, upon information and
belief, Laura Watts-Vial, a relation to the WCDA David Watts-Vial whom sent Coughlin a 11/13/12
letter insufficiently responded to Coughlins supboenas of various Washoe County employees and
thereby prejudicing Coughlins defense at the 11/14/12 disciplinary hearing, and whose letter
curiously mentions providing SBN King certified copies of all of the attached Orders indicating an
impermissible state funded degree of teamwork between the RJC, RMC, WCDA, WCSO, and SBN
in discrediting an attorney, Coughlin, whom was advocating for tenants rights, UIFSA fairness,
foreclosure defense of homeowners issues in Carptentier v. Aames (also before Judge Flanagan in
CV08), and prosecutorial and police misconduct matters, and indigent criminal defendants rights
issues. The implication here is that the powers that be will ruthlessly crush with an iron hand anyone
who deigns to attempt to seek legal redress against the status quo, even where leveraging
impermissible means is required.
Another fact that is pertinent in retrospect, is that in the underlying summary eviction matters in
RJC Rev2011-001708 and the appeal in CV11-03628, Hill threatened Coughlin with the the
19 deprivation of a timely Hearing on Coughlins 11/16/11 filed Motion to Contest Personal Property
Lien, disbarment, a designation under State v. Jordan as a vexatious litigant, massive attorneys fees
20
award or sanction, and criminal charges, many of which have come to fruition. (See Ex. 1 bate stamp
21
X for emails from Hill making such threats in writing
18
22
23
24
25
26
27
28
In bar disciplinary matters, a higher degree of proof is required than in ordinary civilproceedings.
Clear and convincing evidence must support any findings of misconduct. See In re Stuhff, 108
Nev. 629, 634-35, 837 P.2d 853, 856 (1992); seealso SCR 105(2)(e). This court has held that clear
and convincing evidence must besatisfactoryproof that is: so strong and cogent as to satisfy the
mind and conscienceof a common man, and so to convince him that he would venture to act upon
thatconviction in matters of the highest concern and importance to his own interest. Itneed not
possess such a degree of force as to be irresistible, but there must beevidence of tangible facts from
which a legitimate inference ... may be drawn.Gruber v. Baker, 20 Nev. 453, 477, 23 P. 858, 865
(1890), cited in Stuhff, 108 Nev. At 635, 837 P.2d at 856. Clear and convincing evidence has been
defined by othercourts as evidence establishing every factual element to be highly probable, see
Butler v. Poulin, 500 A.2d 257, 260 n. 5 (Me.1985), or as evidence [which] mustbe so clear as to
RECONSIDERATION
1
2
leave no substantial doubt, see In re David C., 152 Cal.App.3d 1189, 200 Cal.Rptr. 115, 127
(1984).
In re Discipline of Drakulich, 111 Nev. 1556, 1566-67, 908 P.2d 709, 715 (1995).
4
5
6
7
8
9
10
11
12
The American Bar Association Standards for Imposing Lawyer Sanctions suggest an analysis of
four factors to be considered in determining an appropriate disciplinary sanction: the duty violated,
the lawyers mental state, the potential or actual injury caused by the lawyers misconduct, and the
existence of aggravating or mitigating factors. In re Discipline of Lerner, 197 P.3d 1067, 1077 (Nev.
2008).
I am indigent (I live in a 5th wheel trailer, my rent is $75 a month plus some incidentals. I drive a
1996 Honda Accord with 120K miles. I have $0.00 in my bank account. I subsist on potatos from
food pantries, the occasional $20 from my 70 year old mother, and what little money I can make as a
jack of all trades/researcher, though the majority of my waking moments over the last year have bee
spent defending myself against various fraudulent and retaliatory allegations by Richard G. Hill, Esq.
And Casey Baker, Esq., and associated retaliatory arrests and prosecutions, every last one of which
has been related in one way or another to the wrongful No Cause summary eviction/Trial
violative of NRS 40.253(6) in that RJC Judge Sferrazza required a $2,275 rent escrow deposit not
permissible under Nevada law (no corollary to JCRLV 44 in the Reno Justice Court, see Nevada
JCRCP 83 and AB226 and NRS 40.253 generally and NRS 118A.380 and 118A.385...
13
The American Bar Association Standards for Imposing Lawyer Sanctions suggest an analysis of
four factors to be considered in determining an appropriate disciplinary sanction: the duty violated,
14
the lawyers mental state, the potential or actual injury caused by the lawyers misconduct, and the
15 existence of aggravating or mitigating factors. In re Discipline of Lerner, 197 P.3d 1067, 1077 (Nev.
2008).
16
17
This is a bar grievance against Richard G. Hill, Esq. And Casey D. Baker, Esq. Given their failure
18
to withdraw from representation in the trial court eviction/unlawful detainer matter connected to my
former home law office in rjc rev2011-001708 and the appeal therefrom in cv11-03628, and the two
19 Nevada Supreme Court Appeal from that appeal in the District Court in 60331 and 61383. This also
supplements my previous grievances against Hill for making a false statement to a public officer and
20 contributing to my false arrest on 11/13/11 in rmc 11 cr 226405 (pending filings in 61901 detail this,
as do the following:
21
22
23
http://www.youtube.com/watch?v=VcVDVjFK64g
http://www.youtube.com/watch?v=V6I3t7tTlPI
http://www.youtube.com/watch?v=Eh2xyc-9cg0
24
25
26
27
28
Further, RMC Judge Nash Holmes, incident to the bate stamping and page numbering in Bar
Counsels Sierra big box copy of the file that I signed for on 11/7/12 (a nice 6 days before the
11/14/12 formal disciplinary hearing, Pat King drops over 3,000 pages of documents on me and acts
like he and the NNDB/Panel complied with SCR 105(2)(c)...whereas at all times prior to that, despite
faux offers to allow me to, the SBN and King always refused to allow me access to any such
materials contemplated under SCR 105(2)(c), wherein I am entitled to 27 days worth of access to
upon the Panel (ie, not Bar Counsel or the Clerk of Court) serving me, under SCR 109 (in the same
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
manner in which the Complaint was served...and given the Complaint was never served on me in
NG12-0204, etc...) serving me with Notice of the Hearing. Clerk of Court Peters is advised to
correct to material misrepresentations in her sworn Affidavit of 10/9/12 immediately, and file stamp
all filings submitted by facsimile or fax by Respondent Coughlin gets involved and the same goes for
Pat Kings misreprensentations as to the rule and policies made applicable to Respondent Coughlins
use of subpoenas in that matter as communicated to Coughlin by King and Peters on behalf of the
SBN, Bar Counsel David Clark, the NNDB, and the Panel. Speaking of the materials provided by
Judge Nash Holmes (at least according to the bate stamped presentation by King, which clearly does
not seem to be all that reliable, nor complete, as there is not indication of what materials, specifically,
were included in the submssions by Judge Nash Holmes. Further, during Coughlin and Kings March
26th, 2012 interaction at the SBN, wherein Coughlin appeared at the SBNs Office to take King up on
his offer to allow Coughlin access to and review of the materials submitted along with the
greivances...King stormed off with the box of materials, refusing to allow Coughlin to review them,
when it was made clear to King that Coughlin was there only to review the materials, and not have
King attempt to turn the interaction in an informal conference under SCR 105 prior to Coughlin
even having an opportunity to review the materials submitted in support of the grievances. Further,
from Kings presentation, it appears Judge Nash Holmes forwarded a police report from a then
pending criminal case, 11 CR 26405, the the SBN, which is not permissible.
12
13
14
15
16
17
18
19
But, back to Hill and Baker. In the RPD police report from the criminal trespass custodial arrest and
Complaint signed by Richard G. Hill, Esq., there is a curious discrepancy in comparision to Hills
subsequent testimony at the 6/18/12 Trial in CR12-1262. In the police report by RPD Officer Chris
Carter, Jr., it is reported that it was Dr. Merliss who was at the former law office and noticed this or
that in the week prior to the arrest, not Hill himself. Upon information and belief, that was a weak
attempt by Hill to avoid the well established dictate (memorialized in RPC 3.7) that an attorney shall
move to withdraw from representation where there exists a reasonable likelihood that he will be
called as a witness in the case. In fact, Hill was a witness in that trial court case, at the 12/20/12
Hearing on Coughlins Motion to Contest Personal Property Lien.
Rule3.7.Lawyer as Witness.
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21
(a)A lawyer shall not act as advocate at a trial in which the lawyer is likely to be a necessary
witness unless:
22
23
24
(1)The testimony relates to an uncontested issue;

(2)The testimony relates to the nature and value of legal services rendered in the case; or
25
26
(3)Disqualification of the lawyer would work substantial hardship on the client.
27
(b)A lawyer may act as advocate in a trial in which another lawyer in the lawyers firm is likely
28
to be called as a witness unless precluded from doing so by Rule 1.7 or Rule 1.9.
RECONSIDERATION
Hill was passing notes to Baker during the 12/20/12 proceeding, despite the rule of exclusion, and
utilizing the RJC Bailiffs to pass some of the notes, while also making crude jokes to the RJC
Bailiffs about how he would like to shoe some things up Coughlins ass too.. to two Bailiffs
whom had previously made commentary related to Coughlins ass.

2
Http://www.youtube.com/watch?v=0OqLCeFGEaQ http://www.youtube.com/my_videos_edit?
5 video_id=0Y8rZWxSW1g&ns=1 (and the links therein to the other segments of the RJC JAVS audio
transcripts attached herein, for your convenience, which were already served on you and attached to
6 filings by Coughlin in the appeal, cv11-03628).
7
8
9
Materials in N. S. Ct. cases 61901 and 61383 and 60331 are relevant to this grievance an herein
incorporated by reference. Bar Counsel King is conflicted out of investigating this, as is Clerk of
Court/Investigator Laura Peters, for many reasons, including his work with Hill and Baker on Milsner
v. Carstarphen in 2011 and early 2012, in the appeal before the N. S. Ct.
http://caseinfo.nvsupremecourt.us/public/caseView.do?csIID=29550
10
Dr. Merliss lied to the police in the videos linked to above, resulting in the wrongful arrest and
prosecution of Coughlin in Reno Municipal Court case 11 cr 26405 and now before the Nevada
12 Supreme Court as a disciplinary matter of an attorney in 61901:
11
13
14
15
The SBNs whole allegation of RPC 3.1 meritorious claims violations completely overlooks the
fact that criminal defendants are entitled to defend themselves with a zeal not allowed anywhere else
in the law.
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19
20
21
22
23
24
25
26
27
So-called Anders brief is an appellate procedure that is not appropriate for a trial court. Mr. Chavez
represented in his opening brief that a search of published cases from all 50 states and the federal
circuit courts reveals no case in which an Anders brief was filed at trial, Br. Of Appellant at 15; ?the
State has identified no such case in response, nor have we located one. The Anders procedure covers
the appellate situation where an attorney feels an entire appeal is without merit and therefore wants to
withdraw. See Anders, 386 U.S. At 744; ?State v. Theobald, 78 Wn.2d 184, 185, 470 P.2d 188
(1970). Applying this procedure to a discrete issue in a trial court is a misapplication, no matter how
an attorney characterizes the motion. A criminal defense lawyer may decline to assert an issue that he
or she considers frivolous. RPC 3.1 However, in light of the constitutional right of a criminal
defendant to assistance of counsel, he or she may assert issues that would otherwise be prohibited
under professional rules of conduct. RPC 3.1 cmt. 3. But here we have more than that. We conclude
this was ineffective assistance. And, just as significantly, the concern raised here on appeal was over a
suggested conflict of interest, which, of course, was not developed at all in the trial court.
3.1 Rule .Meritorious Claims and Contentions. A lawyer shall not bring or defend a proceeding,
or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that
is not frivolous, which includes a good faith argument for an extension, modification or
reversal of existing law. A lawyer for the defendant in a criminal proceeding, or the
28
RECONSIDERATION
1
2
respondent in a proceeding that could result in incarceration, may nevertheless so defend the
proceeding as to require that every element of the case be established
Hill and Baker arguably violated RPC 3.1 themselves where they persisted in their outrageous
Motion for some $42,050 in attorneys fees based upon matters already actually litigated and decided
4
against them incident to the 3/27/12 Order by Judge Flanagan denying their 1/21/12 Second Motion
5 for Order To Show Cause.
Compare to Loomiss refusal to assert claim of right defense to trespass charge on 4/10/12 in 11
CR 26405 despite Hills admission to charging $900 for November, the same as was previously
7 charged for full use and occupancy and despite WCSO Liz Stuchells admission in her 2/5/12 email
to Coughlin (stale or void eviction order), in addition to stay arguments (attach Venetian v. Two
8 Roads transcript to rebut Hills testimony as to 12/22/12 misconduct vis a vis NRS 118A.385.
6
Beyond that, the Nevada Supreme Court Clerks Office has failed to file some extremely
inflammatory and relevant materials (attach here and explain relevance for 61901 and 60331 and
11
60317 and 61383).
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WCPD Goodnigth never provided to his client Coughlin any of the subpoenas he issued and or had
served on anyone. Not the Reno Police Department, the RPD Custodian of Records, or any of the
witnesses. Goodnight did misrepresent in his written responses to Coughlins questions regarding
such subpoenas and subpoena duces tecums the scope of such items that Goodngith purported to have
issued and had served. This became extremely relevant in rcr2011-063441 in light of the Hearing on
the Suppression Motion (Coughlin filed his own Pre-Trial Motion (which included a Motion to
Suppress that actually did provide some actual examples of case law interpreting both the reasonable
suspicion/Terry Stop analysis (especially with respect to the baggy clothing, lack of cooperation,
demeanor, and resistance to follow officer commands buzzwords that RJC Judge Clifton (a WCDA
Chief Criminal DDA for 25 years whom has been held out in domestic violence legislative materials
as having years of experience working with and training law enforcement officers, providing even
more of a basis for recusing himself from RCR2012-065630) on 2/15/12 and Goodnight filed a
Motion to Suppress (it sort of appeared that Goodnights sudden replacement announced minuts
before the 7/16/12 Trials start in 063341, WCPD Chief Criminal Deputy (since when does the Chief
Criminal Deputy do misdemeanor petty larceny Trials? Some might say only when the County
really, really needs the defendant to be convicted in a manner that would evince just enough
advocacy to avoid exposing the WCPD, and therefore, the County to liability for malpractice or any
of the resources depleting ineffecting assistance of counsel issues...Regardless, Goodnight and
Coughlin complete their final Trial preparation meeting for the July 16th, 2012 Trial date in 063341 at
4:30 pm on Friday, July 13th, 2012, and no one has ever provided any explanation to Coughlin as to
why Goodnight was mysteriously removed from representing Coughlin minutes before the Monday,
July 16th, 2012 Trial...as which time WCPD Jeremy Bosler, Esq. Appeared and moved for a
continuance before Judge Sferrazza. At that time WCDAs Office DDA Zach Young, Esq. Purported
to Judge Sferrazza to know that Coughlin had caused the WCPD to move for a continuance.
However, upon Coughlin pointing out to the Court that Coughlin himself had now idea why his
attorney for the last year (the arrest of 8/20/11 in 063341 was the first of what would set off ten
different incarcerations of Coughlin over the next eleven months, including the arrest by Reno Sparks
RECONSIDERATION
1
2
Indian Colony Police (in violation of NRS 178.1255s prohibition against tribal police making
misdemeanor arrests) petty larceny of a candy bar and some cough drops wh
4
5
6
7
8
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10
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17
In his 6/18/12 testimony in RMC 11 CR 26405 (appealed in CR12-1262 where the RMC
fraudulently failed to file Coughlins 6/28/12 Notice of Appeal, which Judge Elliott failed to address
in dismissing Coughlins appeal, see 61901, Bar Counsels 10/15/12 SCR 111(4) Petition, which not
only establish by res judicata that that criminal trespass conviction is not a serious crime sufficient
to support an SCR 111(6) Petition, but also demonstrates and impermissible practice by Bar Counsel
of seeking to bring duplicative prosecution or Petitions against Coughlin where the 8/23/12 file
stmape Complaint in SBN v. Coughlin relies heavily upon that criminal trespass conviction (which,
arguably is outside the purview of a proper SCR 105 Complaint given the res judicata effect of the
SBN filing an SCR 111(4) non-serious offense Petition in 61901), including more lie filled
testimony by Richard G. Hill, Esq (compare the transcripts from the two RJC eviction hearing (the
summary eviction proceeding on 10/13/11 and the unlawful detainer Trial on 10/25/11 (at which
Judge Sferrazza denied Coughlin the right to bring counterclaims and crossclaims, but allowed Hill,
his associate Casey D. Baker, Esq. And the absentee Californian landlord Dr. Matthew Joel Merliss,
MD, to benefit from Judge Sferrazzas departure from the dictate against requiring rent escrow
deposits in summary eviction proceedings (NRS 40.253(6)) once the Court has found, as Judge
Sferrazza expressly did on the record on both 10/13/11, and again, at the start of the 10/25/11 court
dates in 001708, that Coughlin had established a genuine issue of material fact with respect to his
defenses to the summary eviction. Upon Couglin informing Judge Sferrazza even further that NRS
40.253 required any further attempts to disposses Couglin of the premises must occur within an
unlawful detainer plenary Trial, Judge Sferrazza attempted to coerce from Couglin agreement to
proceed with a summary eviction proceeding on 10/25/12 by threatening to require Couglhin to
deposit even more rent escrow into the RJC upon rent becoming due on November 1st, 2011 (even
though, in Nevada, by statute, rent is never late until the fifth day after it becomes due).
18
19
A writ of mandamus is available to compel the performance of an act that the law requires as a
duty resulting from an office, trust, or station or to control an arbitrary or capricious exercise of
21 discretion. International Game Tech. v. Dist. Ct., 124 Nev. 193, 197, 179 P.3d 556, 558 (2008)
(citations omitted). When an adequate and speedy legal remedy exists, however, writ relief is not
22
available. Id. As we have explained, an appeal typically is an adequate and speedy legal remedy. Id.
23 Furthermore, even if an appeal does not constitute an adequate and speedy legal remedy in a
particular case, we generally will not exercise our discretion to consider petitions for extraordinary
24 writ relief that challenge district court orders denying motions for summary judgment, unless: (1) no
factual dispute exists and summary judgment is clearly required by a statute or rule or (2) an
25
important issue of law requires clarification and judicial economy favors granting the petition. Id. At
26 197-98, 179 P.3d at 558-59.
20
27
28
Here, an appeal is not an adequate and speedy legal remedy given the infancy of the underlying
litigation and considerations of sound judicial administration. In addition, G.C. Wallaces petition
raises several important issues of law regarding summary eviction proceedings that will likely recur.
RECONSIDERATION
As noted by the district court in its order denying G.C. Wallaces motion for summary judgment, the
entire area of law surrounding Summary Eviction and which Court has jurisdiction over it is currently
2 creating both confusion and debate among the Bench and Bar of the Eighth Judicial District. Thus,
3
G.C. Wallaces petition raises issues requiring clarification, and judicial economy warrants
entertaining this petition. Moreover, G.C. Wallace and Reef Centra do not dispute the salient facts of
4 this matter. Accordingly, we exercise our discretion to consider G.C. Wallaces petition....We note
this caveat because preclusive effect would most likely attach to claims that are actually litigated
5 during the summary eviction proceeding. See Sewell v. Clean Cut Mgmt., Inc., 463 Mich. 569, 621
N.W.2d 222, 225 (2001) (although a summary eviction judgment does not bar other claims and
6
remedies, it is conclusive on claims that are actually litigated). G.C. Wallace
9
10
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14
15
16
17
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21
Futher, Judge Sferrazza and the RJC arguably lacked jursidiction to hold either the 10/13/11 or
10/25/11 court dates given the amount in controversy requirement should Coughlin have been
permitted to bring counterclaims or cross claims would have exceeded the $10,000 jurisidictional
limit, requiring the matter be heard in District Court. Instead, Hill effectively ws able to relitigate his
Motion for Attorneys Fees in District Court where his initially successful Motion for Attorneys fees
was set aside upon that 33 year veteran of the Bar learning that attorneys fees are not recoverable
in summary eviction proceedings in Justice Court. NRS 69.030. Hills experience and NRS 69.030
did not prevent Hill and his associate Casey D. Baker, Esq. (and Hill was provided the audio
transcript of both the 10/13/11 and 10/25/11 court dates by Coughlin as an attachment in the appeal in
CV11-03628, and regardless, Hill has a supervisory duty over Bakers work, and Hill even argued, as
a basis for justifying his outrageous attorneys fee Motion, that Judge Flanagan only granted in light
of his belief that DCR 13(3) required as much where Coughlin, arguably, did not oppose that 4/19/12
Motion for Attorneys Fees by Hill and Baker (Coughlin was wrongfully incarcerated by, who else,
Judge Steven P. Elliot in CR12-0367, the proceeding that spawned from the 2/27/12 Order for
Competency Evaluation file stamped 1:31 pm...the exact time set for the Mandatory Status
Conference in the misuse of emergency services (911) prosecution of Coughlin stemming from te
1/14/12 arrest by the RPD in RCR2012-065630). Coughlins then WCPD Biray Dogan and DDA
Young held the MSC anyways on 2/27/12 despite Dogan having notified Coughlin in writing that it
had been reset for 3/29/12. At the 11/27/12 Hearing in 065630, in which RJC Judge Clifton claimed
to only have a few minutes Judge Clifton managed to get an extraordinary amount done for the
WCPD and WCDA and a great deal of Coughlins dur process rights excised, in a remarkably short
period of time. One, 25 year veteran of the WCDAs Office Criminal Division, now RJC Judge
Clifton made sure to sua sponte query Dogan as to whether the continuance of the 2/27/12 MSC
was a result of a request made by Coughlin.
22
Judge Clifton did this to provide ammunition for later refusing any request for continuance of the
23 12/11/12 Trial date that Couglhin was jammed into, which was convenient (pre-trial motions due 15
days prior to Trial...so only let Coughlin get rid of Dogan 14 days prior to Trial, very effective) in
24 that Coughlins request to have Dogan removed as his attorney (so that Coughlin could finally have
subpoenas issued and served, and could finally start filing some documents in his own defense
25
without being under the constant express stated threat by RJC Judges that they would have Coughlin
26 incercerated if he attempted to file anything while having a WCPD as his attorney of record).
Dogans response to that querry by Judge Clifton was not entirely accurate in that Coughlin merely
27 pointed out to Dogan that there was a conflict between the MSC in 065630 and the simple traffic
citation Trial before RMC Judge Nash Holmes set for 1:00 pm on 2/27/12 in RMC 11 TR 26800. It
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was Dogan who decided to stipulate, along with DDA Young to resetting the MSC for 3/29/12. DPD
RECONSIDERATION
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Dogan failed to mention, in the emails between himself, DDA Young, and RJC Staff the conlficting
court dates behind such a move. Dogan pretty much never says anything that would help his clients
or result in a preservation of their rights or arguments other than the occasional gosh, hes really
sorry for what he did, Your Honor. He feels deep and painful regret for his actions. Please go easy
on him... or something substantially similar to that. Dogan purposefully and spitefully announced
the name of a medication Coughlin was taking at the 4/26/12 hearing date before Judge Elliott in
CR12-0376 despite Couglin having on numerous occasions made a very marked point about his
desire that such information remain confidential in the utmost, and where Coughlin had specifically
remind Dogan not to divulge such confidential, highly prescription medication information
immediately prior to Dogan standing up in court and doing so, on the record, in front of about 40 or
so members of the public, bar criminal defendants, and court staff. To compound that transgression,
Dogan and his supervisors, Jeremy Bosler, Esq. And Chris Fortier, Esq. (whom is co-listed with
Dogan as attorney of record on that matter) expressly refused to move to strike such confidential
material from the transcript and record in that case, despite Coughlins express written requests that
they do so and despite the written and verbalized promises by Lakes Crossing (the entity the RJC and
Dogan, in his 2/28/12 written correspondence to Coughlin required Coughlin to utilize for the
evaluation...a practice consistent with the 2 other competency evaluation Coughlin was required to
undertake by the RJC and WCPD this year, despite the WCPD never once having to articulate in
writing or verbally a single basis for their triplicate requests for such evaluations (the basis for such
requests in all three instances was either to buy the WCPD some time to finally conduct some legal
research or preparation (though only for the purpose of covering its own interests, never the clients,
and only after the client had artfully forced the WCPDs hand) or to flat out retaliate against the client
(WCPDs Hylins 9/8/12 Motion (nothing more than handing a clerk at the counter an SB89 form,
no written Motion, no appearance before a Judge involved whatsoever) only occurred upon Coughlin
upsetting Hylin by pointing out the extent to which Hylin was refusing to advocate in any way (and
Hylin was merely filling in for DPD Gorman, whom had only returned from maternity leave earlier
that week and where DPD Goodnigth would be transferred the case within one week anyways),
whereas Dogan moving for an Order for Competency Evaluation on 2/27/12 was clearly retaliatory in
nature given how upset Dogan was by Coughlins 2/21/12 filing in 065630 (which RJC Judicial
Secretary Lori Townsend voluntarily sent to the SBN to retaliate against Coughlins criticisms of the
coercive atmosphere attendant to the teamwork between the RJC, WCPD, and WCDAs Offices...and
Townsend sent Bar Counsel that 2/21/12 filign by Coughlin in 065630 and offered to send Bar
Counsel Coughlins 2/15/12 filign in 063341 as well...all making Judge Sferrazzas 10/22/12
suggestion in 063341 that, despite his then being aware of Bar Counsels intent to hold a formal
disciplinary hearing in the very near future (a circumstance for which he announced to Coughlin he
would not grant any continuance to Coughlin, even where Judge Sferrazza only allowed Coughlin to
have WCPD Jim Leslie, Esq. Removed as counsel on 10/22/12 (and Sferrazza made clear to Coughlin
his choices were limited to appearing pro se or having Leslie represent him, and that, despite Wheby
and the obvious conflict between Leslie and Coughlin, no other attorney would be appointed, and
Judge Sferrazza continued therein a represhensible practice by the RJC Judges where the WCPDs are
not subjected to even a hint of consternation or inspection as to the effectiveness of their
representations, even where, as there, Coughlin put forward a voluminous amount of documentation
and media (or, in some case, at least attempted to where Judge Sferrazza refused to hear it)...an
inequity detailed in the Ouimet case.
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RECONSIDERATION
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The third request by the WCPD, by Jim Leslie, for a competency evaluation of Coughlin, on
9/5/12 was less motivated by retaliation but rather by Leslie being argued into a corner by Coughlin
and Leslie's own arrogant belief that he could jump into the case in Goodnight's place with no
preparation, and single handedly save "County assets" while denying Coughlin any due process, and
"disenfecting" the record on appeal of any of the matters to which Coughlin sought to preserve his
objections for appeal. Immediately prior to Leslie suddenly moving for a competency evaluation in
Court during the Trial, Coughlin had again pointed out to Leslie the outrageousness of Leslie's
attempting to deprive Coughlin of every single inviolable right he had as a criminal defendant. Leslie
deprived Coughlin of the right to decide whether to accept a plea or go to Trial on 8/29/12 when, after
Coughlin stating, under oath, that he "freely and voluntarily" accepted DDA Young's plea deal, Leslie
demanded to Judge Sferrazza that he not accept Coughlin's plea. Further, Leslie had previously that
day demanded that Judge Sferrazza allow Leslie to make argument as to why Coughlin should not be
allowed to have Leslie removed and appear pro se. That is incredibly rare, a public defender arguing
that his client should not be allowed to represent himself, and speaks to the extent to which Leslie
fraudulently wished to deprive Coughlin of his due process rights, mostly motivated by Leslie's own
self interest (to further his own career by "scoring" the County a big win, even where Coughlin had
repeatedly stated, in writing, the many government officials, that he just wanted to move on with his
life, did not plan to sue anybody, sought some sort of compromise resolving the criminal prosecutions
and any civil litigation fears the County, State, of City had (to the extent permissible and legal to do
so, Couglhin as sure to add a caveart thereto in his written correspondences). Throughout his
"representation" Leslie and the WCPD's Office deprived Coughlin of the right to subpoena witnesses
in his defense.
Leslie actually attempted to disparage Coughlin to the Court in a fraudulent manner where he
attempted to excuse the inappropriate practice of the WCPD of redacting the names and addresses of
witnesses (in a simple misdemeanor petty larceny case) as well as redacting any locations, phone
numbers, dispatcher identity information and other valuable information for culling inconsistencies
and building a defense from the discovery it provides to its clients upon being received from the
WCDA (an office wide policy that is ridiculous and prejudicial in the extreme, and shameful). The
redacting of the phone numbers for the two 911 calls made by someone other than Couglin (whom
made his own at 11:25:52 pm), and the numbers for the four calls to or from the iPhone during the
time in question severly prejudiced Coughlin's ability to identify witnesses, have them subpoened and
or served, and otherwise build his defense. Leslie, Goodnight and the WCPD redacted the addresses
for witnesses that were publicly available in court filings in those instances where it actually provided
copies of such filings to Coughlin (and Goodnight did provide copies of such filings identifying trial
witnesses, whereas Dogan and Leslie failed to even inform Coughlin of such filing by either the
WCDA's Office or the WCPD. Upon being caught in this, Leslie lied about the rationale for failing
to provide Coughlin the address its investigator had for material reluctant witness Nicole Watson,
alleging that he had "heard Mr. Coughlin had threatened to serve the subpoena on her himself and
that" Leslie was "concerned for the safety of Ms. Watson". That is classic, Jim Leslie faux concern,
petty, spiteful, throwing his client under the bus behavior, especially considering the following email
from Coughlin to the WCPD:
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com] Sent: Thursday, May 31, 2012 6:41
PM To: Goodnight, Joseph W; Rains, Jennifer Subject: RE: RJC trial date RCR 2011-066341
Mr. Goodnight, Ms. Rains, Will you file a Motion for Reconsideration or enforcement of the MHC
agreement as presented or an interlocutory appeal? Mr. Goodnight, I have located Nicole Watson,
please mail me a copy of the subpoena you allege that you created for her and I will have it served
RECONSIDERATION
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on her. Is DDA Young offering any plea deal that would amount to stipulating to disturbing the
peace or some other charge that does not require reporting under SCR 111. Sincerely, Zach
Coughlin
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Coughlin's writing "I will have it served on her" is not something a licensed attorney whom
intends to personally serve a witness (and therefore vitiate the effect of any such service given it
would not be done by a non-party) would say. However, in the RJC, Jim Leslie's lies do not have to
be all that convincing for them to be accepted wholesale by Judges Sferrazza and Clifton all too
willingly.
Coughlin's former attorney Goodnight actually mislead Coughlin as to what had actually been
subpoened in his written responses to Couglin's written requests, informing Couglin that he had
subpoened the 911 dispatch tapes in 063341 where he had actually only subpoened any recordings
made by the RPD Officer's themselves (this would become of extreme material relevance at the
Suppression Hearing where RPD Officer Duralde testified falsely that dispatch had informed he and
his fellow officer's on scene of "a possible fight", where the facts and record subsequently
demonstrate that Duralde and the other officer's were already on scene and therefore not provided the
one text from dispatch (available to them only on the video screens within their patrol cars) that
mentioned to now disprove, fraudulent assertion (as shown to be false in the video of the moments
prior to the RPD arrest and the Trial testimony of Goble, Duralde, Zarate, Templeton, and Lichty) by
Goble to 911 operator Scott Weese that "someone just socked a minor". Simply put, the RPD had
received no information from dispatch other than to "check for a possible larceny of a cell phone.
Suspect still on the scene. Loud verbal distrubance", yet in DDA Young's 2/23/12 Opposition to
Motion to Suppress and at the Suppression Hearing and Trial, DDA Young and Officer Durale
consistently practiced the "buzz word" sprinkling testimony and police report training and preparation
RJC Judge Clifton provided RPD and WCSO Officer so consistently over the last 25 years (see
legislative materials describing Judge Clifton experience) in Duralde and Young constantly harping
on "the reports from dispatch of a 'possible fight'" to support their arguments that the Terry Stop pat
down, and subsequent second pat down by Duralde (both conducted while Couglin already in hand
cuffs, which was the case 40 seconds into Duralde arriving on scene and being told nothing by
anyone testified to at Trial (unless one counts unsworn, unattributed hearsay, which Judge Sferrazza
consistently allowed the State to offer into evidence ("just to show why the Officer took the steps he
next took"...even, curiously, at Trial, and after the Suppression Motion had, apparently, been ruled on
(and whether the "door was closed" on that Motion and Order or not seemed to depend solely on
whether remixing that Order would make any subsequent conviction stronger and less appealable or
not) . Leslie did the same thing at the end of the 8/29/12 Trial date in his smokescreen
representations to Judge Sferrazza as to "holding the witnesses to their subpoenas" where the WCPD's
Office never filed any such subpoenas (something DDA Young failed to do as well, though he
certainly was permitted to call his witnesses, and the WCPD and Leslie have a practice (endorsed by
Judge Clifton on 11/27/12) of failing to inform their clients of filings by the prosecution (Leslie failed
to inform Coughlin of Duane Jakob's being identified as a witness the State would be calling in the
8/23/12 filign in RCR2012-067980...something that makes Leslie's repeated refusal to procure and or
provide to Coughlin the audio transcript of the 7/5/12 and 7/31/12 hearing dates in RJC rev2012001048 (the summary eviction matter based upon a fraudulent 6/14/12 Declaration of Service of a 5
Day Unlawful Detainer Notice by Nevada Court Services Ryan Wray, whom tried to break and enter
and trespass into a rental Coughlin's that had no windows and the door closed and locked, with
RECONSIDERATION
Northwind's Manager Duane Jakob's with him. NCS's R. Wray filed a fraudulent Declaration of
Service on 6/14/12 alleging to have "personally served" Coughlin, which cut the NRCP 6(e) 3 days
2 for mailing off of the 5 judicial days the Notice informed Coughlin he had to file a Tenant's Affidavit
in Spark Justice Court. That Declaration of Service on the bottom of the 5 day Notice of UD wedged
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into the door frame of Coughlin's rental did not indicate that it had been "personally served", but the
4 version Northwind's and Wray subsequently filed with the RJC did. It is improtant to note that the
6/14/12 5 Day Notice listed the wrong forum to file the Tenan'ts Affidavit. NRS 40.253 requires such
5 notices to set forth, in writing, the appropriate forum for the tenant to file a Tenant's Answer or
Affidavit.
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Simply put, RJC Judges Schroeder (whom signed the 6/27/12 Summary Eviction Lockout
Order despite such a deficiency even where the RJC, Washoe County Sheriff's Office, Sparks Justice
Court, and Chief Civil Division Clerk Karen Stancil were made aware, well in advance (Coughlin
spoke with RJC Chief Civil Clerk Stancil about the anticipated problem of jurisdiction in light of the
wrong forum being listed on the 5 Day notice on at least two occasions on the telephone on or about
June 15th, 2012, and sent written correspondence on 6/26/12 to the RJC, Sparks Justice Court (which
faxed the RJC a 13 page fax containing, in part, the Tenant's Answer Coughlin submitted for filing to
the SJC on 6/26/12, which the Sparks Justice Court refused to file in light of the jurisidctional defect
attendant to the rental being located in Reno, not Sparks. The RJC has refused to allow Coughlin to
see the entirety of that 13 page 6/28/12 fax to the RJC from the SJC, and the RJC, Clerk Karen
Stancil, and Court Administrator Steve Tuttle refused to comply with the lawfully issued and properly
served subpoenas and subpoena decus tecums by Coughlin in the formal disciplinary matter. The
RJC and County failed to voice any objections to such subpoenas in any manner, written or verbal,
and simply failed to appear or respond, to which Panel Chair Echeverria refused to hold them in
contempt or grant Coughlin a continuance. Finally, on 9/5/12 (and Leslie did the same thing on the
other Trial date wherein he appeared and at the Suppression Hearing on 8/29/12). (Leslie took over
the 063341 case suddenly and mysteriously from Goodnight, whom has indicated to Coughlin that
Leslie does not like him and has made Goodnight feel that his job security is threatened in a directly
proportional relationship to the extent to which Goodnight provides Coughlin zealous advocacy;
Leslie at various points commandered Dogan's representations of Coughlin and placed Dogan under a
no contact order in relation to Coughlin for months, interrupted only by Dogan's fraudulent flipflopping assertions to Couglin that Dogan provided Couglin his "discovery" (as, the WCPD's
response to Coughlin's request for "his file" and "all materials to which he has a right" has
consistently been met with a refrain, by the WCPD's Leslie, Dogan, and Bosler (though Goodnight
did provide the documents he filed and those he received as filed by the WCDA, something Dogan,
Leslie, and Bosler, and RJC Judges Clifton and Sferrazza consistently have informed Coughlin he
does not have any right to be provided, even where Coughlin has expressly requested as much,
especially with respect to DDA Young's Opposition to Coughlin's Motion to Appear as Counsel and
DDA Young's 7/31/12 Motion to Amend the Criminal Complaint in 065630 (where Young sought to
amend the "misuse of 911" charge to something falling more squarely into the SCR 111(6) "serious
offense" requiring an automatic temporary suspension of one's law license territory after Couglin, on
a good faith basis during plea negotiations, provided Bar Counsel reports and legal researc shedding
light on what offenses have and have not been considered to fall within the purview of SCR 111(6)
and what sorts of plea deals and arrangements are considered "convictions" (especially where DDA
Young put forward plea offers that involved entering a plea of guilty to a charge to be withdraw upon
successful completion of some conditions). Leslie
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RECONSIDERATION
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Leslie, in all three criminal matters wherein he has represented Coughin (and the same is true
of Dogan, and to a lesser extent, Goodnight) steadfastly refused to subpoena witnesses, or, in a
narrow instance fraudulently misled the Court and Coughlin as to "holding the witnesses to their
subpoenas (Robert Dawson admitted to Coughlin on or about September 19th that Leslie told him he
didn't not need to appear for any court dates, including the 8/29 and 9/5/12 Trial dates. Further,
Leslie and the WCPD were curiously silent as to the ability to supboena witnesses in misdemeanor
cases via certified mail under NRS 174.345, and how that related to the year long inability of the
WCPD to have a subpoena served on a McQueen High School senior, Nicole Watson, whom
Coughlin captured on video and audio tape on 8/26/12 admitting to have seen and heard "the man
with a six-pack of beer" pick up the iPhone Goble alleges was his, from the ground where it had been
set in the downtown Reno skate plaze by the Truckee River, at 11:15 pm, and hold it aloft and
threaten to "throw it in the river" if someone did not claim it immediately. Someone, despite
consistently allowing the RPD and the State's witnesses to enter just about any hearsay testimony they
wished to into the record, Judge Sferrazza refused to admit any testimony by those there to hear
Watson make that admission, or any video/audio recordings of Watson making it, despite the material
relevance it bore to the issue of "ownership" of the property allegedely stolen (especially vis a vis a
lost, mislaid, abandoned, or "rescued from the River" property as larceny analysis). It was clear error
for Judge Sferrazza to refuse to allow evidence or testimony into the record in 063341 regarding
Watson's admitting to hearing and seeing the man picking up the phone threaten to throw it in the
river if someone did not claim it immediately ( Party admission: statement made by a party (witness
testimony has established Waston and alleged victim Goble were friends and part of a group of
friends collected at the skate plaza on 8/20/11) is admissible against the party as substantive evidence
(Goble and his friends step into the place of the State as "a party"; Unavailable declarant required:
Watson's year long dodging of a subpoena and the WCPD's refusal to even attempt service by
certified mail under NRS 174.345, stubborn refusal to testify, etc.), Statement against interest: a
statement against Watson and her friends Zarate, Goble, et al's own pecuniary, proprietary, or penal
interest (in the same videos/audios witness Zarate is seen dissuading Watson from incriminating
himself any further where Watson's admission as to the unidentified man holding the iPhone he
picked up off the ground aloft and threatening to "throw it in the river if someone doesn't claim it
immediately" would incriminate Zarate for making a false statement to effect the arrest of Coughlin
given RPD Duralde's testimony at Trial that Zarate told him he saw Coughlin "run up and grab the
phone from the ledge where my friend Cory set it down next to where we were hanging out"); excited
utterance and or present sense impression, present state of mind, declaration of intent: Watson's
admission concerning a startling event (suddenly being interview on video by Couglin one week after
the arrest of 8/20/11) and made while declarant is still under the stress of excitement caused by the
event), additionaly, if not allowable to prove the truth of the matter asserted, such a statement by
Watson arguably is permissible under the same "effect on the listener"/"show why he/she took the
actions they next took" argument Young was so often the beneficiary of a favorable ruling by Judge
Sferrazza upon making.
Further, WCPD Leslie went out of his way to try to establish, especially during his "crossexamination" of alleged victim Cory Goble in the iPhone case 063341, that a "citizen's arrest"
sufficinet to defeat the problem presented to the State's case by NRS 171.136:
NRS 171.136 When arrest may be made.
1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day,
and at any time of day or night.
RECONSIDERATION
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m.,
except:
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(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
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(c) When the person is found and the arrest is made in a public place or a place that is open to the
4 public and:
(1) There is a warrant of arrest against the person; and
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(2) The misdemeanor is discovered because there was probable cause for the arresting officer
to stop, detain or arrest the person for another alleged violation or offense;
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(d) When the offense is committed in the presence of a private person and the person makes an
7 arrest immediately after the offense is committed;"
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Lovelace v. Commonwealth, 522 S.E.2d 856 (Va. 1999). Defendants search after he was detained by
a police officer for apparently drinking an alcoholic beverage in public, which revealed a bag of
drugs, was unlawful and the drugs were suppressed. Under state law the officer could only have
issued a defendant a summons for an alcohol-related offense, defendant had not failed or refused to
discontinue the suspected unlawful activity so as to warrant a full custodial arrest, the of-ficer felt no
threat to his safety, and he felt nothing similar to a weapon or to evidence relating to defendants
drinking an alcoholic beverage in public when he conducted a Terry pat-down of defendant. The
court relied upon the reasoning of the decision in Knowles v. Iowa, 525 U.S. 119 (1995, in which the
United States Supreme Court rejected a search incident theory in a situation involving the simple
issuance of a traffic citation. We conclude that Knowles is applicable. The encounter between
Lovelace and the officer, while not involving a traffic offense, was nonetheless similar in nature and
duration to a routine traffic stop. We reach this conclusion primarily because the initial reason for
detaining Lovelace was his alleged commission of a Class 4 misdemeanor for which the issuance of a
summons was authorized under Code S 19.2-74(AH 2). Only if Lovelace had failed or refused to
discontinue the unlawful act could the officer have effected a custodial arrest and taken the defendant
before a magistrate. Code 19.2-74(A)( 2). However, there is no evidence in the record that Lovelace
acted in such a manner. The fact that the officers could have issued only a summons for the alcoholrelated offense also negates the Commonwealths argument that the existence of probable cause to
charge Lovelace with drinking an alcoholic beverage in public allowed Womack to search him. After
Knowles an arrest that is effected by issuing a citation or summons rather than taking the suspect
into custody does not, by itself, justify a full field-type search.
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In the case before RJC Judge Clifton RCR2012-065630, despite the charge being amended to a
NRS 199.280 Resisting a Publice Officer (to leverage to appearance of the term resisting in SCR
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111(6)) DDA Young put on testimony an evidence pretty much exclusively devoted to the original
misuse of 911 charge, including the extensive 12/11/12 testimony of ECOMM Supervisor Kariann
25 Beechler, whom sadly and unexpectedly passed away two days later on 12/13/12. NRS 52.252 sets
forth the criteria by which an offering party can authenticate 911 telephone calls by a signed affidavit
26 of the 911 custodian of records. However, the conversation itself is still Hearsay, as defined by NRS
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51.035, and thus inadmissible unless an exception applies. Judge Clifton allowed Beechlers
testimony that she felt the voice on the 911 calls belong to Coughlin bases upon her comparing it to
28 the sentence or two she heard Couglhin say to the Bailiff prior to Court on 12/11/12, and hearing
23
RECONSIDERATION
Couglhin advocate on his own behalf at Trial that day. In most cases, the party seeking to admit a
911 conversation into evidence can probably overcome a hearsay objection on the basis of present
2 sense impression or excited utterance. In some cases, an authenticated 911 recording regarding a
particular incident may contain more than one telephone conversation. Consider the situation where
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the initial call was cut short because the call was dropped or the situation where a 911 operator calls a
4 caller back to verify certain facts or details. It is quite possible, even likely, that the initial caller is no
longer excited by the second or third callback. Therefore, if you are objecting to a 911 recording
5 sought to be admitted at trial, and the recording is comprised of more than one conversation (e.g.
several callbacks) consider whether the caller is actually still excited, or whether too much time has
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now transpired for the offering party to properly rely on the exceptions of excited utterance and
7 present sense impression. Just because the first part of the recording comes in doesnt necessarily
mean the callbacks should.
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NRS 52.252 Admissibility of copy or transcript of recordings of telephone calls made through
system providing telephone number to be used in emergency. The content of recordings of
telephone calls made through a system established to provide a telephone number to be used in an
emergency, if otherwise admissible, may be proved by a copy or transcript of the recording which
is authenticated by a custodian of the records of the system in a signed affidavit. The custodian
must verify in the affidavit that the copy or transcript is a true and complete reproduction of the
original recording and that the original recording was made at the time of the telephone call and in
the course of a regularly conducted activity.
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It is disingenuous at best for the State to offer 911 calls that it it admits mistakenly combine the
calls it feels are the most damaging to Coughlins defense with other more mundane calls, where it
is obvious DDA Young just wants to play a call he feels is damaging over and over, where NRS
52.252 requires a true and complete reproduction.
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Http://www.youtube.com/watch?v=lZ8uIWek6js&feature=youtu.be
In some instances Coughln provided and or linked to (the SBN and Panel should not be permitted
to allege notice to Coughlin of the 2/21/12 filing in 065630 or the 3/5/12 filing in 26405 simply by
alleging one or the other was attached in 60975 or provided in a box of 3,000 pages of documents
provided to Coughlin just three days prior to the 11/14/12 Formal Disciplinary Hearing (NRCP 6(e),
applicable via SCR 119 ans SCR 105(4), specifies that for time periods of less than 11 days, only
judicial days are counted. Coughlin signed for the 3,000 page production of documents provided for
as a consolation to the excising of Coughlins rights under SCR 105(2)(c) by Chair Echeverrias
10/31/12 Order, upon the first attempt to deliver such materials on 11/7/12. Monday, November 11th,
2012 was a court holiday and the SBN was closed, and the day of the event (the delivery on 11/7/12)
is not counted...therefore, Coughlin was accorded 3 days to review materials to which he was entitled
under SCR 105(2)(c) (though such materials, given they were sent out to the printer on November
1st, 2012 (which is odd given the filings Coughlin personally delivered to the SBN on October 31st,
2012 did not make it into that 3,000 page collection, which contains a section purporting to be the
pleadings on file in this matter, the last of which, incongruously, is a 10/9/12 Affidavit of Laura
Peters that is bate stamped after Chair Echeverrias 10/31/12 Order, and which lacks a caption, and is
not indicated as attached to the 10/9/12 Notice of Intent to Take Default that Couglin never received
anyways given the SBNs error in placing insufficient postage theron (and, as admitted in the
RECONSIDERATION
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Certificate of Mailing thereto, as shown in the bate stamped 3,000 page collection of 11/7/12) was
sent via only certified mailing, and for which Pat King made smug and malevolent commentary to
Coughlin upon being placed on a LITIGATION HOLD NOTICE as to the envelope and
handwritten notations thereon that Coughlin saw downtown Reno USPS postal station longtime
counter clerk Tim notate was being returned to sender in light of insufficient postage being
affixed thereto (Couglin personally eye witnessed that 8.5 x 11 inch manilla envelope bore only $1.25
in postage affixed via the SBNs red Pitney Bowes printed postage mechanism (which, for such a
certified mailing, was at least $5.00 insufficient, and its not Coughlin responsibility to pay that, the
SBN failed to copy Coughlin via email and fax despite express written requests by Coughlin that is do
so (see attached emails and other correspondences from Coughlin in Ex. 1 detailing his status as a
victim of domestic violence (conclusive proof thereof provided by the certified copies of the Orders
for Protection granted Coughlin on 1/23/12 by Master Edmondson in FV12-00188 and FV12-00187
against the housemates/sublessors involved in the fraudulent, retaliatory arrest of Coughlin on 1/14/12
in RCR2012-065630 (from which the 2/21/12 filing by Coughlin mentioned, yet not attached, the the
SBNs 8/23/12 Complaint stems). Newly discovered evidence exists as to the fraud attendant to that
arrest, and excusable neglect for Coughlin not propounding or arguing it earlier where WCDA DDA
Young committed a Brady violation in failing to propound it to Coughlin in a timely manner
(attached email from Young Ex. 1). In that recording by the RPD that DDA Young finally
propounded (and fraud by WCPD Dogan in failing to file, despite Coughlins express demands,
requests for production and requests for discovery and subpoenas, and subpoena duces tecums, much
less Dogan and Leslies lies and fraudulence in failign to provide Coughlin two of the three cds of
911 Coughlin DDA Young propounded (where, instead of so providing such excuplatory materials
and discovery to which Coughlin was entitled, Jim Leslie and the WCPD, via the same WCDA DDA
David Watts-Vial who fraudulently conspired with Pat King to rig the hearing so that the RJC, and
various County employes (including those of the Second Judicial District Court) failed to respond to
the subpoenas lawfully issued by Coughlin (Coughlin was granted the right to issue his own
subpoeans by the SBN/Clerk of Court/NNDB, and Panel (which David Clark, Esq. Admits to) and
any NRCP 45 requirement upon Coughlin to pay witness fees or fees for subpoena duces tecums was
declared inapplicable to Coughlin in this matter, by the SBN/Clerk of Court/NNDB, and Panel.
Similar to the WCDAs failure to propound Brady material until too late for Coughlins use at the
11/14/12 disciplinary hearing, was the Reno City Attorneys in the 1/12/12 custodial arrest for
jaywalking case mysteriously transferred from Judge Dilworth to Judge Nash Holmes on 2/27/12 by
RMC Administrative Judge W. Gardner (clearly, the mysterious coincidences attendant to 2/27/12
being the date of a mysterious transfer of 065630 in the RJC from Judge Lynch to Judge Clfiton, in
combination with another mysterious transfer on that same date, 2/27/12, of the jaywalking arrest
(which
http://youtu.be/0HfqXnGKMFA
A slide show of material evidence and court filings to the audio of JAVS recordings of court
hearings from the RJC is hardly edits inadmissible, and or a fraudulent misreprentation:
http://youtu.be/_ew7zY2v4cI
26
27
28
The SBNs they are all edits so the Panel shouldnt consider any of the videos,: no context
and the implicaton that Coughlin has somehow fraudulently altered anything is ridiculous. King is
simply whining sour grapes because he barely knows how to do email. On 3/26/12 King stated to
RECONSIDERATION
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
Coughlin that he believes websites send emails. King clearly doesnt know how to burn a copy of a
cd/dvd, and he fraudulently represented to Coughlin, in justifying his refusal to provide Coughlin
with any indication of where or to whom Coughlin may copy Panel members and the Chair on
Coughlins filings and those exhibits attached thereto (which King and the SBN fraudulently failed to
include in the 12/24/12 Record on Appeal in 62337), King agreed to copy the Panel Chair and all
Panel Members on all fo Coughlins filing, including the attachments (even the cd/dvds attached as
exhibits). At the 3/26/12 appearance by Coughlin at the Northern SBN Office to take King up on his
written offer to allow Coughlin to review the materials submitted with the greivances from multiple
judges (funny, only one grievance from any Judge has ever been produced...if NVB Judge Beesley
or Judge Linda Gardner wanted to file a grievance they should have signed their name on the line and
stood behind one, but they didnt, so Kings representations to Coughlin on 3/26/12 of having
received grievances from at least 3 Judges is fraudulent. King needs to produced the letter from
Judge Beesley. Coughlin was never provided it, and therefore no sort of notice could possibly be
inferred sufficient to accord Coughlin due process protections incident to any findings by the Panel
stemmign from anythign related to Judge Beesley, the NVB, Coughlins work therein, or the
ridiculous attempts by the SBN to put on extremely hostile and self interested witnesses as expert
witnesses (especially where King and Chair misstate that Elcano is a licensed attorney (he is not,
nor has he been for nearly a decade, though he is a hunt and peck typist, and arrogant enough to
believe he is an authority of domestic relations law when, clearly, he is not...his background was
largely in medical malpractice, which, just so happens to be the fiedl in which Chair John Echeverria
practices primarily...and Chair Echeverria failed to comply with the procedural requirement so NRS
1.235 upon Coughlin moving for him to disqualify himself in light of conflicts/bias, etc., though
Echeverria was forced to admit he and Elcano were boyhood chums (the went to Reno High School
in 1962 together along with Norman and Maurice Beesley, NVB Judge Greg Zive, RJC Judge Fidel
Salcedo (whom RJC Judge Sferrazza mentions as needing to meet with for five minutes on the record
during the 11/19/12 Trial date in 063341), RJC Judge Albright (whom gave
JAVS recordings of court hearings Coughlin paid for (in most instances) at $35 a disc from the RJC,
or the ForTheRecord audio recordings of RMC hearings in 11 CR 22176, 11 TR 26800, 11 CR 26405
18 (Yes, the SBN finally provided a few copies of recordings of hearings that Judge Nash Holmes
provided the RMC that were leftovers from what, allegedly, was provided the Panel on 4/10/12
19 (though, curiously, the 2/2/10 Hearing in 11 CR 26405 wherein court appointed defender Roberto
Puentes, Esq. Obtains an Order allowing his withdrawal as Coughlins attorney is noticeably absent
20
from what the RMC and Judge Nash Holmes provided the SBN, and the SBN the Paenl...could it be
21 because Judge William Gardner, even after Coughlin prompted him to divulge any conflicts of
interest, failed to point out that Judge Linda Gardner is his sister, even where, the statements by Judge
22 William Gardner in the FTR recordings of the 4/10/12 Trial date (where the RMC, court appointed
defender Loomis, and City Attorney Hazlett-Stevens all violated NRS 178.405, even without
23
considering NRS 5.071 and the fact that Loomis was provided the Order for Competency Evaluation
24 of 2/27/12 by Coughlin, and where Judge W. Gardner misstates whether Judge Nash Holmess Orders
in 11 TR 26800 indicated any competency issues vis a vis Coughlin.
17
25
26
27
NRS 171.104 Arrest defined; by whom made. An arrest is the taking of a person into custody, in a
case and in the manner authorized by law. An arrest may be made by a peace officer or by a
private person.
28
RECONSIDERATION
1
2
3
4
5
6
7
8
NRS 171.123 Temporary detention by peace officer of person suspected of criminal behavior or of
violating conditions of parole or probation: Limitations.
1. Any peace officer may detain any person whom the officer encounters under circumstances
which reasonably indicate that the person has committed, is committing or is about to commit a
crime.
2. Any peace officer may detain any person the officer encounters under circumstances which
reasonably indicate that the person has violated or is violating the conditions of the persons parole or
probation.
3. The officer may detain the person pursuant to this section only to ascertain the persons identity
and the suspicious circumstances surrounding the persons presence abroad. Any person so detained
shall identify himself or herself, but may not be compelled to answer any other inquiry of any peace
officer.
4. A person must not be detained longer than is reasonably necessary to effect the purposes of this
section, and in no event longer than 60 minutes. The detention must not extend beyond the place or
10
the immediate vicinity of the place where the detention was first effected, unless the person is
11 arrested.
12
13
14
15
16
(Added to NRS by 1969, 535; A 1973, 597; 1975, 1200; 1987, 1172; 1995, 2068)
NRS 171.1231 Arrest if probable cause appears. At any time after the onset of the detention
pursuant to NRS 171.123, the person so detained shall be arrested if probable cause for an arrest
appears. If, after inquiry into the circumstances which prompted the detention, no probable cause for
arrest appears, such person shall be released.
(Added to NRS by 1969, 535)
NRS 171.1232 Search to ascertain presence of dangerous weapon; seizure of weapon or evidence.
1. If any peace officer reasonably believes that any person whom the peace officer has detained or
is about to detain pursuant to NRS 171.123 is armed with a dangerous weapon and is a threat to the
18
safety of the peace officer or another, the peace officer may search such person to the extent
19
reasonably necessary to ascertain the presence of such weapon. If the search discloses a weapon or
any evidence of a crime, such weapon or evidence may be seized.
17
20
2. Nothing seized by a peace officer in any such search is admissible in any proceeding unless the
search which disclosed the existence of such evidence is authorized by and conducted in compliance
21
with this section.
22
NRS 171.1255 Arrest by officer or agent of Bureau of Indian Affairs or police officer employed by
Indian tribe.
24
1. Except as otherwise provided in subsection 2, an officer or agent of the Bureau of Indian
Affairs or a person employed as a police officer by an Indian tribe may make an arrest in obedience to
25
a warrant delivered to him or her, or may, without a warrant, arrest a person:
(a) For a public offense committed or attempted in the officer or agents presence.
26
(b) When a person arrested has committed a felony or gross misdemeanor, although not in the
27 officer or agents presence.
(c) When a felony or gross misdemeanor has in fact been committed, and the officer or agent has
28
reasonable cause for believing the person arrested to have committed it.
23
RECONSIDERATION
(d) On a charge made, upon a reasonable cause, of the commission of a felony or gross
misdemeanor by the person arrested.
2
(e) When a warrant has in fact been issued in this State for the arrest of a named or described
person for a public offense, and the officer or agent has reasonable cause to believe that the person
3
arrested is the person so named or described.

(f) When the peace officer has probable cause to believe that the person to be arrested has
4
committed a battery upon that persons spouse and the peace officer finds evidence of bodily harm to
5 the spouse.
2. Such an officer or agent may make an arrest pursuant to subsection 1 only:
6
(a) Within the boundaries of an Indian reservation or Indian colony for an offense committed on
7 that reservation or colony; or
(b) Outside the boundaries of an Indian reservation or Indian colony if the officer or agent is in
8 fresh pursuit of a person who is reasonably believed by the officer or agent to have committed a
felony within the boundaries of the reservation or colony or has committed, or attempted to commit,
9
any criminal offense within those boundaries in the presence of the officer or agent.
10 For the purposes of this subsection, fresh pursuit has the meaning ascribed to it in NRS 171.156.
11
NRS 171.126 Arrest by private person. A private person may arrest another:
1. For a public offense committed or attempted in the persons presence.
12
2. When the person arrested has committed a felony, although not in the persons presence.
3. When a felony has been in fact committed, and the private person has reasonable cause for
13
believing the person arrested to have committed it.
14
NRS 171.128 Magistrate may order arrest for committing or attempting to commit offense in
magistrates presence. A magistrate may orally order a peace officer or private person to arrest
16 anyone committing or attempting to commit a public offense in the presence of the magistrate, and
may thereupon proceed as if the offender had been brought before the magistrate on a warrant of
17
arrest
15
18
NRS 171.136 When arrest may be made.

1. If the offense charged is a felony or gross misdemeanor, the arrest may be made on any day,
19
and at any time of day or night.
20
2. If it is a misdemeanor, the arrest cannot be made between the hours of 7 p.m. and 7 a.m.,
except:
21
(a) Upon the direction of a magistrate, endorsed upon the warrant;
(b) When the offense is committed in the presence of the arresting officer;
22
(c) When the person is found and the arrest is made in a public place or a place that is open to the
23 public and:
(1) There is a warrant of arrest against the person; and
24
(2) The misdemeanor is discovered because there was probable cause for the arresting officer
to stop, detain or arrest the person for another alleged violation or offense;
25
(d) When the offense is committed in the presence of a private person and the person makes an
26 arrest immediately after the offense is committed;
(e) When the offense charged is battery that constitutes domestic violence pursuant to NRS 33.018
27
and the arrest is made in the manner provided in NRS 171.137;
28
RECONSIDERATION
(f) When the offense charged is a violation of a temporary or extended order for protection against
domestic violence issued pursuant to NRS 33.017 to 33.100, inclusive;
2
(g) When the person is already in custody as a result of another lawful arrest; or
(h) When the person voluntarily surrenders himself or herself in response to an outstanding
3
warrant of arrest.
1
5
6
7
8
9
10
11
SEARCH INCIDENT TO ARREST MISDO SUMMONS

Lovelace v. Commonwealth, 522 S.E.2d 856 (Va. 1999).
Defendants search after he was detained by a police officer for apparently drinking an alcoholic
beverage in public, which revealed a bag of drugs, was unlawful and the drugs were suppressed.
Under state law the officer could only have issued a defendant a summons for an alcohol-related
offense, defendant had not failed or refused to discontinue the suspected unlawful activity so as to
warrant a full custodial arrest, the of-ficer felt no threat to his safety, and he felt nothing similar to a
weapon or to evidence relating to defendants drinking an alcoholic beverage in public when he

conducted a Terry pat-down of defendant. The court relied upon the reasoning of the decision in
Knowles v. Iowa, 525 U.S. 119 (1995, in which the United States Supreme Court rejected a search
incident theory in a situation involving the simple issuance of a traffic citation.
12
We conclude that Knowles is applicable. The encounter between Lovelace and the officer, while not
involving a traffic offense, was nonetheless similar in nature and duration to a routine traffic stop. We
13
reach this conclusion primarily because the initial reason for detaining Lovelace was his alleged
14 commission of a Class 4 misdemeanor for which the issuance of a summons was authorized under
Code S 19.2-74(AH 2). Only if Lovelace had failed or refused to discontinue the unlawful act could
15 the officer have effected a custodial arrest and taken the defendant before a magistrate. Code 19.274(A)( 2). However, there is no evidence in the record that Lovelace acted in such a manner. The fact
16
that the officers could have issued only a summons for the alcohol-related offense also negates the
17 Commonwealths argument that the existence of probable cause to charge Lovelace with drinking an
alcoholic beverage in public allowed Womack to search him. After Knowles an arrest that is
18 effected by issuing a citation or summons rather than taking the suspect into custody does not, by
itself, justify a full field-type search.
19
20
NRS 171.153 Right of person arrested to make telephone calls.

1. Any person arrested has the right to make a reasonable number of completed telephone calls
from the police station or other place at which the person is booked immediately after the person is
22
booked and, except where physically impossible, no later than 3 hours after the arrest. Such telephone
23
calls may be limited to local calls, except that long distance calls may be made by the arrested person
at his or her own expense.
24
2. A reasonable number of calls must include one completed call to a friend or bail agent and one
completed call to an attorney
21
25
26
27
28
Without any reason whatsoever, the Washoe County Detention Facility deprived Couglin of
the right to make a single phone call for over 20 hours upon WCSO Deputy Machen arresting
Couglin on 6/28/12 based upon the void and fraudulently obtained eviction Lockout Order in RJC
Rev2012-001048. Next, the Washoe County jail staff allowed Couglin only one phone call to his
RECONSIDERATION
1
2
4
5
6
7
8
mother on July 3rd, 2012 before Coughlin was beaten without provocation by WCSO Deputy
Hoekstra.
NRS 171.177 When person detained must be taken before magistrate. Except as otherwise
provided in NRS 171.122 and 171.178, whenever any person is detained by a peace officer for any
violation of a county, city or town ordinance or a state law which is punishable as a misdemeanor, the
person must be taken without unnecessary delay before the proper magistrate, as specified in NRS
171.178 and 171.184, in the following cases:
1. When the person demands an immediate appearance before a magistrate;
2. When the person is detained pursuant to a warrant for the persons arrest;
3. When the person is arrested by a peace officer; or
4. In any other event when the person is issued a misdemeanor citation by an authorized person
and refuses to give a written promise to appear in court as provided in NRS 171.1773
NRS 171.1771 Issuance of citation when person detained by peace officer. Whenever any person is
detained by a peace officer for any violation of a county, city or town ordinance or a state law which
is punishable as a misdemeanor and the person is not required to be taken before a magistrate, the
11 person shall, in the discretion of the peace officer, either be given a misdemeanor citation, or be taken
without unnecessary delay before the proper magistrate. Any such person shall be taken before the
12
magistrate when the person does not furnish satisfactory evidence of identity or when the peace
13 officer has reasonable and probable grounds to believe the person will disregard a written promise to
appear in court.
14
(Added to NRS by 1973, 156)
10
15
NRS 171.1772 Issuance of citation after arrest by private person. Whenever any person is
16 arrested by a private person, as provided in NRS 171.126, for any violation of a county, city or town
ordinance or state law which is punishable as a misdemeanor, such person arrested may be issued a
17 misdemeanor citation by a peace officer in lieu of being immediately taken before a magistrate by the
peace officer if:
18
1. The person arrested furnishes satisfactory evidence of identity; and
2. The peace officer has reasonable grounds to believe that the person arrested will keep a written
19
promise to appear in court.
20
NRS 171.1965 Discovery by defendant before preliminary examination; material subject to

discovery; effect of failure to permit discovery.
1. At the time a person is brought before a magistrate pursuant to NRS 171.178, or as soon as
22
practicable thereafter, but not less than 5 judicial days before a preliminary examination, the
23 prosecuting attorney shall provide a defendant charged with a felony or a gross misdemeanor with
copies of any:
24
(a) Written or recorded statements or confessions made by the defendant, or any written or
recorded statements made by a witness or witnesses, or any reports of statements or confessions, or
25
copies thereof, within the possession or custody of the prosecuting attorney;
26
(b) Results or reports of physical or mental examinations, scientific tests or scientific experiments
made in connection with the particular case, or copies thereof, within the possession or custody of the
27
prosecuting attorney; and
21
28
RECONSIDERATION
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7
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12
(c) Books, papers, documents or tangible objects that the prosecuting attorney intends to introduce
in evidence during the case in chief of the State, or copies thereof, within the possession or custody of
the prosecuting attorney.
2. The defendant is not entitled, pursuant to the provisions of this section, to the discovery or
inspection of:
(a) An internal report, document or memorandum that is prepared by or on behalf of the
prosecuting attorney in connection with the investigation or prosecution of the case.
(b) A statement, report, book, paper, document, tangible object or any other type of item or
information that is privileged or protected from disclosure or inspection pursuant to the Constitution
or laws of this State or the Constitution of the United States.
3. The provisions of this section are not intended to affect any obligation placed upon the
prosecuting attorney by the Constitution of this State or the Constitution of the United States to
disclose exculpatory evidence to the defendant.
4. The magistrate shall not postpone a preliminary examination at the request of a party based
solely on the failure of the prosecuting attorney to permit the defendant to inspect, copy or
photograph material as required in this section, unless the court finds that the defendant has been
prejudiced by such failure.
.
13
Judge Clifton adheres a lot more to the "affidavit requirement" he reads into NRS 1.235 than he does
to that found in:
14
NRS 171.188 Procedure for appointment of attorney for indigent defendant.
15
1. Any defendant charged with a public offense who is an indigent may, by oral statement to the
district judge, justice of the peace, municipal judge or master, request the appointment of an attorney
to represent the defendant.
16
17
18
19
20
21
2. The request must be accompanied by the defendants affidavit, which must state:
(a) That the defendant is without means of employing an attorney; and
(b) Facts with some particularity, definiteness and certainty concerning the defendants financial
disability.
3. The district judge, justice of the peace, municipal judge or master shall forthwith consider the
application and shall make such further inquiry as he or she considers necessary. If the district judge,
justice of the peace, municipal judge or master:
22
(a) Finds that the defendant is without means of employing an attorney; and
23
(b) Otherwise determines that representation is required,
24
25
26
27
28
the judge, justice or master shall designate the public defender of the county or the State Public
Defender, as appropriate, to represent the defendant. If the appropriate public defender is unable to
represent the defendant, or other good cause appears, another attorney must be appointed.
4. The county or State Public Defender must be reimbursed by the city for costs incurred in
appearing in municipal court. The county shall reimburse the State Public Defender for costs incurred
in appearing in Justice Court. If a private attorney is appointed as provided in this section, the private
attorney must be reimbursed by the county for appearance in Justice Court or the city for appearance
in municipal court in an amount not to exceed $75 per case.
RECONSIDERATION
NRS 171.1772 Issuance of citation after arrest by private person. Whenever any person is
arrested by a private person, as provided in NRS 171.126, for any violation of a county, city or town
3 ordinance or state law which is punishable as a misdemeanor, such person arrested may be issued a
misdemeanor citation by a peace officer in lieu of being immediately taken before a magistrate by the
4
peace officer if:
1. The person arrested furnishes satisfactory evidence of identity; and
5
2. The peace officer has reasonable grounds to believe that the person arrested will keep a written
6 promise to appear in court.
(Added to NRS by 1973, 1157; A 1975, 1201; 2001, 2023)
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
NRS 171.1773 Form and contents of citation: When person detained by peace officer.
1. Whenever a person is detained by a peace officer for any violation of a county, city or town
ordinance or a state law which is punishable as a misdemeanor and the person is not taken before a
magistrate as required or permitted by NRS 171.177, 171.1771 or 171.1772, the peace officer may
prepare a misdemeanor citation manually or electronically in the form of a complaint issuing in the
name of The State of Nevada or in the name of the respective county, city or town, containing a
notice to appear in court, the name and address of the person, the state registration number of the
persons vehicle, if any, the offense charged, including a brief description of the offense and the NRS
or ordinance citation, the time when and place where the person is required to appear in court, and
such other pertinent information as may be necessary. The citation must be signed by the peace
officer. If the citation is prepared electronically, the officer shall sign the copy of the citation that is
delivered to the person charged with the violation.
2. The time specified in the notice to appear must be at least 5 days after the alleged violation
unless the person charged with the violation demands an earlier hearing.
3. The place specified in the notice must be before a magistrate, as designated in NRS
171.178 and 171.184.
4. The person charged with the violation may give a written promise to appear in court by signing
at least one copy of the misdemeanor citation prepared by the peace officer, in which event the peace
officer shall deliver a copy of the citation to the person, and thereupon the peace officer shall not take
the person into physical custody for the violation. If the citation is prepared electronically, the officer
shall deliver the signed copy of the citation to the person and shall indicate on the electronic record of
the citation whether the person charged gave a written promise to appear. A copy of the citation that
is signed by the person charged or the electronic record of the citation which indicates that the person
charged gave a written promise to appear suffices as proof of service.
(Added to NRS by 1973, 156; A 1991, 16; 1999, 1141)
NRS 171.1774 Form and contents of citation: When issued after arrest by private person.
1. In those instances described in NRS 171.1772, the peace officer summoned after the arrest shall
24 prepare a misdemeanor citation manually or electronically in the form of a complaint issuing in the
name of The State of Nevada or in the name of the respective county, city or town, and containing:
25
(a) A notice to appear in court;
(b) The name and address of the person;
26
(c) The state registration number of the persons vehicle, if any;
27
(d) The offense charged, including a brief description of the offense and the NRS or ordinance
citation;
28
(e) The time when and place where the person is required to appear in court;
23
RECONSIDERATION
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
(f) Such other pertinent information as may be necessary; and

(g) The signatures of the private person making the arrest and the peace officer preparing the
citation.
3. The place specified in the notice must be before a magistrate, as designated in NRS
171.178 and 171.184.
at least one copy of the misdemeanor citation prepared by the peace officer, in which event the peace
officer shall deliver a copy of the citation to the person, and thereupon the peace officer shall not take
the person into physical custody for the violation. If the citation is prepared electronically, the officer
shall deliver the signed copy of the citation to the person and shall indicate on the electronic record of
the citation whether the person charged gave a written promise to appear. A copy of the citation that
is signed by the person charged or the electronic record of the citation which indicates that the person
charged gave a written promise to appear suffices as proof of service.
(Added to NRS by 1973, 1157; A 1991, 16; 1999, 1142)
NRS 171.1775 Preparation of citations: Use of citation book or electronic device;
maintenance of records relating to citation book or electronic device.
1. Every county, city or town law enforcement agency in this state shall provide in appropriate
form misdemeanor citations containing notices to appear which must meet the requirements of NRS
171.177 to 171.1779, inclusive, and be:
(a) Issued in books; or
(b) Available through an electronic device used to prepare the citations.
2. The chief administrative officer of each law enforcement agency is responsible for the issuance
of such books and electronic devices and shall maintain a record of each book, each electronic device
and each citation contained therein issued to individual members of the law enforcement agency. The
chief administrative officer shall require and retain a receipt for every book and electronic device that
is issued.
18
19
NRS 171.1774 Form and contents of citation: When issued after arrest by private person.
20
22
1. In those instances described in NRS 171.1772, the peace officer summoned after the arrest shall
prepare a misdemeanor citation manually or electronically in the form of a complaint issuing in
the name of The State of Nevada or in the name of the respective county, city or town, and
containing:
23
(a) A notice to appear in court;
21
24
25
(b) The name and address of the person;

(c) The state registration number of the persons vehicle, if any;
26
(d) The offense charged, including a brief description of the offense and the NRS or ordinance
citation;
27
(e) The time when and place where the person is required to appear in court;
28
(f) Such other pertinent information as may be necessary; and

RECONSIDERATION
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
(g) The signatures of the private person making the arrest and the peace officer preparing the
citation.
3. The place specified in the notice must be before a magistrate, as designated in NRS 171.178
and 171.184.
at least one copy of the misdemeanor citation prepared by the peace officer, in which event the
peace officer shall deliver a copy of the citation to the person, and thereupon the peace officer shall
not take the person into physical custody for the violation. If the citation is prepared electronically,
the officer shall deliver the signed copy of the citation to the person and shall indicate on the
electronic record of the citation whether the person charged gave a written promise to appear. A
copy of the citation that is signed by the person charged or the electronic record of the citation
which indicates that the person charged gave a written promise to appear suffices as proof of
service.
In the "simple traffic citation" Trial before Judge Nash Holmes in RMC 11 TR 26800 (stemming
from the traffic citations issued Coughlin by RPD Sargent Tarter outside Richard G. Hill, Esq.'s
office immediately after Tarter told Couglin to leave the area, the Officer isuing the citation did
not appear to testify at trial, in violation of Coughlin's Sixth Amendment Right To
Confrontation. Regardless, Tarter called in an Officer Smith whom was not even present on
scene at the time of the alleged infraction, likely because Tarter himself is not designated with
the autority to issue traffic citations as a Sargent with the RPD:
16
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NRS 171.17751 Designation of certain state, county and city officers to prepare, sign and serve
citations.
1. Any board of county commissioners or governing body of a city may designate the chief officer
of the organized fire department or any employees designated by the chief officer, and certain
of its inspectors of solid waste management, building, housing and licensing inspectors, zoning
enforcement officers, parking enforcement officers, animal control officers, traffic engineers,
marshals and park rangers of units of specialized law enforcement established pursuant to NRS
280.125, and other persons charged with the enforcement of county or city ordinances, to
prepare, sign and serve written citations on persons accused of violating a county or city
ordinance.
2. The State Health Officer and the health officer of each county, district and city may designate
certain employees to prepare, sign and serve written citations on persons accused of violating
any law, ordinance or regulation of a board of health that relates to public health.
3. The Chief of the Manufactured Housing Division of the Department of Business and Industry
may designate certain employees to prepare, sign and serve written citations on persons accused
of violating any law or regulation of the Division relating to the provisions of chapters 118B,
461, 461A and 489 of NRS.
4. The State Contractors Board may designate certain of its employees to prepare, sign and serve
written citations on persons pursuant to subsection 2 of NRS 624.115.
RECONSIDERATION
5. An employee designated pursuant to this section:
(a) May exercise the authority to prepare, sign and serve citations only within the field of
enforcement in which the employee works;
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4
5
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12
(b) May, if employed by a city or county, prepare, sign and serve a citation only to enforce an
ordinance of the city or county by which the employee is employed; and
(c) Shall comply with the provisions of NRS 171.1773.
As such, any "contempt" Order stemming from any Trial held upon such an invalid citation is
void, as are any RPC violations Judge Nash Holmes purported to find "by clear and convincing
evidence" in her 3/12/12 Order (which itself she lacked the jurisdiction to enter given the
divesting of her jurisdiction to do so upon Coughlin's filing a Notice of Appeal on 3/7/12, which
was timely under NRS 189.010, but to which Judge Nash Holmes violated NRS 189.030 in
refusing to order the preparation of the transcripts thereof (to the prejudice of Coughlin's
defense therein and in the appeal, and in the formal disciplinary hearing stemming therefrom)
and in her Order striking Coughlin's Motion to Proceed In Forma Pauperis (how can the SBN
admit into evidence and assert RPC violations based upon documents that have been stricken
from the record by Judge Nash Holmes. Talk about cake and eat it too, to borrow a phrase from
RJC Judge Clifton on 11/27/12 in 065630).
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14
15
16
17
18
Additionally, in the criminal trespass prosecution in 61901 (RMC 11 CR 26405, and the appeal
therefrom in CR11-2064) Couglin was prevented from putting on argument and testimony as to
the deprivation of his Sixth Amendment Right to Confrontation where neither RPD Officer
Carter, nor Sargent Lopez appeared at Trial on 6/18/12 (nor on 4/10/12), and where Richard G.
Hill, Esq. Signed the criminal complaint, despite his admittedly not making a citizen's arrest.
Further, Coughlin's three different RMC court appointed defenders all refused to subpoena the
officer upon Couglin's requesting they do so. Additionaly, the Criminal Complaint in that
matter was deficient in that it completely failed to allege a prima facie case to support the
charge in that no trespass warning is mentioned in the Complaint.
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20
21
I am writing to request that the materials mentioned in the Sbn's 12/24/12 filing in 62337 (including,
but not limited to, the following:Filed Record of Bar Proceedings, Pleadings and Transcript of
Hearings. Vols. 1 through 3) be scanned and made available to me vie the eFlex system (as I was
afforded access to the ROA Vol 1 to 5 in 60302...well, actually, I was not afforded access to Vol. 2 in
23 that matter, and that prejudiced me in the preparation of my filings therein, but...) or, that I be
provided a fee waiver for any copying charges so that I may be afford a copy of everything (I mean
24
absolutely everything) that the State Bar of Nevada, NNDB, and or Panel transmitted to the Supreme
25 Court of Nevada and your Office. While I spoke with Ms. Castillo today, she indicated something
along the lines of "wouldn't you arleady have these materials?"...but that is the thing...the Clerk of
26 Court of the State Bar of Nevada, Office of Bar Counsel, Bar Counsel King, Chair Echeverria, etc.
have been extremely unfair, threatening, misleading, (and some would say outright fraudulent) in
27
attempting to deny me access to this record (including violating SCR 105(2)(c) and threatening, and
28
perhaps obtaining Orders of Protection (or TPO's or TRO's from a Reno Justice Court that has a
22
RECONSIDERATION
multitude of basis for being conflicted out of such matters....including Clerk of Court Townsend's
emails and transmission to Bar Counsel (which are odd, given Judge Sferrazza then claimed to refuse
2 to testify at the 11/14/12 Hearing in light of his remaining to preside on rcr2011-063341, a case
wherein I was a party, and where, incidentally, I was not provided the Record on appeal in that appeal
3
to the District Court in that matter CR12-2025 (I believe that is required, especially where I was, I
4 believe, granted in forma pauperis status in the trial court in rcr2011-063341...however, as of today,
12/24/12, I still have not received the some 800 page ROA in cr12-2025 (I am not an efiler anymore
5 in the Second Judicial District Court given my indigency I could not afford the $300 yearly dues), nor
have I received the 12/20/12 Supplemental Proceedings in that matter.
6
1
The "Record" filed by the SBN on 12/24/12 lacks many different cd/dvd's that I filed as exhibits. In
one Hearing Exhibit instance (Exhibit 15) there is at least a visual depiction fo the two cd's. In
9
numerous other instances, there is not even a visual depiction of the cd/dvds I attached as Exhibits to
10 my filings. Regardless, it is fraudulent for the SBN to have filed the "Record" and not included those
materials. I am afraid to "contact" the SBN with my concerns dues to a coercive abuse of the TPO
11 process by the SBN with the RJC, so I ask that you forward my concerns to the SBN to avoid any ex
parte communications allegations where legally permissible. I am simply placed in a rock and a hard
12
place vis a vis violatin the various TPO's or RMC, RJC Orders against faxing or "contacting" or
13 emailing, or doing anything, seemingly, consistent with seeking to access justice...
14
15
16
Additionally, I believe it is impermissible for the SBN to orient and bate stampe and bind the
"volumes" in the manner in which they were presented to your office, in addition to the illegible
photocopying in the copies I was provided.
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25
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In both the State Bar of Nevada v. Coughlin matter (NG12-0204, 0434, and 0435, now on Appeal,
apparently in 62337) and in that RJC case rcr2011-063341 there have been numerous issue regarding
whether my filings were file stamped or filed in, and disputes related thereto. As such, it is extremely
important, and of an exigent nature, to me that I be afforded access to these materials. In the SBN
matter, it simply is not fair for the SBN to get to wear the "filing office" hat, along with the hat of the
prosecutor...and leverage such an impermissible duel role to a, some might say, fraudulent degree, in
preventing me from reviewing the record, and, it seems, from even filing anything (I guess I could
risk it and file something with the SBN today...and hope the RPD and RJC do not deem me in
violation of some TPO...which I do not even know if I am been served or not...and where Washoe
County and, seemingly, the Reno Justice Court and its Bailiff's continually violate "courthouse
sanctuary" doctrine...by leveraging an out of the blue 12/5/12 Order by RJC Chief Judge Sferrazza
preventing me from having the same rights to file documents by fax that any other party in an RJC
matter has, or should (I know from experience in RJC rev2011-001708, the summary eviction/"Trial"
from my former home law office that was involved in 61901, 60838, 60331, and 61383, that "fax
filing" is somewhat of a secret at the RJC, where some partys and their attorneys seem to be accorded
the ability to "fax file", where others, such as myself (for months and months) were told by RJC
clerks Christine Erickson and Robbin Baker that fax filing is not allowed...until, suddenly, I was told
"a fax is an original" by Robbin Baker...though Ms. Erickson got suddenly very reticent about these
RECONSIDERATION
matters when I thereafter queried her about them....). Then there is the matter of the RJC civil
division failing to file in Coughlin's 12/26/12 Notice of Appeal of the 12/21/12
2 Order Resolving Coughlin's Motion to Contest Personal Property lien in rev2011-001708, and,
similarly, failing to file Coughlin 3/16/12 Notice of Appeal in RJC rev2012-000374 (the summary
eviction by Gayle Kern, Esq. And Sue King of Western Nevada Property Management of
4 Coughlin...Judge Linda Gardner (see 61901 and 54844) was a former associate of Kern's:
http://www.youtube.com/watch?v=5_ZhEHsoj4o The eviction depicted in that video occurred just

minutes before the hearing before Nevada Bankruptcy Court Judge Bruce T. Beesley (who went to
6 McGeorge School of Law in 1977 with two other witnesses at Coguhlin's 11/14/12 formal
disciplinary hearing, though only Judge Beesley and Washoe Legal Services's Paul Elcano's
7
testimony was improperly noticed just one day prior to the 11/14/12 hearing, in violation of SCR
8
105(2)(c) (especially where nothing unknown to Bar Counsel King was alleged discovered or testified
to).
5
Http://webcache.googleusercontent.com/search?
=
q=cache:NykP2zceXI0J:caseinfo.nvsupremecourt.us/document/view.do%3FcsNameID
=
11
%3D29550%26csIID%3D29550%26deLinkID%3D400786%26sireDocumentNumber%3D1212 36656+&cd=3&hl=en&ct=clnk&gl=us
10
13
(and RJC Judge Schroeder granted Richard G. Hill, Esq. A TPO against Coughlin on 1/12/12 in RJC
RCP2012-000018, though when Hill dropped it at the 1/31/12 extension hearing, whereupon
15 Coughlin sought to address Hill's abuse of process, RJC Judge Schroeder threatened Coughlin, saying
angrily: "Do you want to go to jail?". Coughlin was arrested for jaywalking by the Reno Police
16 Department on 1/12/12 and prosecuted in the Reno Municipal Court (Richard G. Hill, Esq. Sat on the
Central District Citizen's Advisory Board of the City of Reno).
14
17
18
I do not know if I can even email the SBN this to avoid an ex parte communications allegation, so I
ask that you copy the SBN if it is permissible to do so.
19
20
I ask that in the short term I at least be emailed or faxed the Index for all of the materials in 63227,
and the individual indexes (if any) for each of the three volumes, and the file stamped cover page pf
each filing by anyone in the entire matter (including any subpoenas by Bar Counsel, and with a
22 special emphasis on whether Bar Counsel ever did provide actual certified copies of the Orders from
the Second Judicial District Court which is relies so heavily upon, yet for which the Hearing Exhibits
23
do not reveal any such certification, despite Bar Counsel King's assertions to the contrary on the
24 record, for the 6/28/12 Order by Judge Flanagan in CV11-03628 and Judge Linda Gardner's 3/10/12
Order in DV08-01168) and a photocopy of any cd/dvd's (including those submitted by Coughlin as
25 Exhibits, which the SBN/NNDB/Panel have made fraudulent representations related thereto, where
the SBN Clerk of Court and Bar Counsel King indicated all filings by Coughlin (whom was given
26
express permission to fax file by Clerk of Court of the SBN Laura Peters and the SBN/NNDB/Panel
th
27 on September 11 , 2012) would be copied to all 5 members of the Panel (Clark Vellis, Michael K.
Johnson, Stephen Kent, and Panel Chair John Echeverria) in their ENTIRETY (including any cd/dvd
28 attachments being copied as well).
21
RECONSIDERATION
2
3
4
5
6
7
8
9
10
As demonstrated in the attachments, Panel Chair Echeverria's 11/16/12 Order attempts to prevent
Coughlin from obtaining a transcript of the 11/14/12 formal disciplinary hearing (which Chair
Echeverria refused Coughlin's request to make a recording of...and at which the "security" mentioned
in Bar Counsel King's TPO application, just happened to be Second Judicial District Court Judge
Linda Gardner's Bailiff (see 54844, and DV08-01168, the divorce Trial at which the same Bailiff was
in attendance: http://www.youtube.com/watch?v=bdNGn7g1sHE )
Incidentally, the RJC did not find a conflict requiring transferring either the SBN or WCPD Jim
Leslie's TPO applications against Coughlin to the Sparks Justice Court, as the RJC did when
Coughlin filed a TPO against RJC Bailiff (and Washoe County Sheriff's Office employee) John
Reyes in 2011 (the Sparks Justice Court denied Coughlin's TPO against Bailiff Reyes without a
hearing or response from the RJC, WCDA, Bailiff Reyes, or anyone...
12
Richard G. Hill, Esq. And Casey D. Baker, Esq. The attorney's whom succeeded in having Coughlin
summarily evicted from his former home law office in RJC rev2011-001708, had a good laugh with
RJC Bailiff Reyes and Chief Bailiff Michael Sexton on 12/20/11when Hill quipped to Reyes and
Sexton "I would like to shove some things up Coughlin's ass too!":
13
http://www.youtube.com/watch?v=HkAvvUvv7kA
11
14
The RJC finally gave Coughlin a hearing on his Motion to Contest Personal Property lien,
considering Coughlin filed, on 11/16/11 a Motion to Contest Personal Property Lien and NRS
16
40.253(8) requires a hearing within 10 days (Richard G. Hill needed to go on a six week long
vacation, and may have violated Rules of Professional Conduct where he emailed Coughlin an
17 indication that he would be able to control the RJC sufficient to prevent Coughlin getting a hearing
until Hill came back from vacation six weeks later.
15
18
19
The Sparks Justice Court failed to file in Coughlin's tenant's affidavit on 6/26/12 in response to a
fraudulent Declaration of Service by Nevada Court Services Ryan Wray of 6/14/12in RJC Rev201221 001048 (Northwinds Apartments v. Zachary Barker Coughlin) wherein Wray attested that he
"personally served" Coughlin a 5 day unlawful detainer Notice even where Wray admits that he could
22
not asceratin whether or not Coughlin was inside rental #29 at 1680 Sky Mountain Drive, Northwinds
23 Apartments, when Wray and Northwind's Manage Duane Jakob attempted to break into the rental (in
much the same manner RPD Officer Alan Weaver attempted to on approximately June 20th, 2012) on
24 June 28th, 2012, before securing a Lockout order from RJC Schroeder (whom, to Judge Sferrazza's
apparent dismay, wrote a letter of recommendation for Judge Linda Gardner in 2007 in her
25
application to become a Justice of the Peace for the RJC). Reyes and the RJC admit that Reyes told
26 Coughlin, in the waiting area of the RJC in October 2011 where Coughlin was sitting next to his then
public defender Joe Goodnight, where Jim Leslie, Esq. Was attempting to place a gag order on
27 Goodnight and harass Coughlin with his malevolent style of "preserving county assets" in the name of
denying indigent criminal defendants their Sixth Amendment Rights (and, for Leslie, this often
28
involves sicking the RPD and RJC/WCSO Bailiffs on his, Goodnight, or DPD Biray Dogan's
20
RECONSIDERATION
clients...a leveraging that Leslie has on numerous occasions threatened Coughlin with in violation of
Nevada law (extorting clients with threats of abuse of process or filing a false police report). Jim
2 Leslie, Esq. Did not seem to afraid, in his role as "stand-by" counsel of Coughlin, when at the 9:05
am mark in the following JAVS audio transcript of the Trial in rcr2011-063341 before Judge
3
Sferrazza, he attempts to aid Judge Sferrazza and DDA Young in further coercing from Coughlin his
4 inviolable rights as a criminal defendant:
1
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6
http://www.youtube.com/watch?v=pAFy9jg6VFk
Actually, Leslie scored a real hat trick as to violating his indigent criminal defendant's inviolable
8 rights, where he managed to not only coerce from his client, Coughlin, the decision as to whether or
not to take a plea, but also, the decision as to whether or not to testify and waive one's Fifth
9 Amendment rights, in addition to Leslie's refusing to subpoena even one witness for Coughlin, much
less those instances where Leslie sought to have stricken from the record filings by Coughlin (such as
10
the 2/15/12 and 8/29/12 filings by Coughlin in rcr2011-063341) that Leslie had no right to even
11 comment on (at least as to the 2/15/12 filing by Coughlin, and arguably as to the 8/29/12 filing as
well):
12
-Leslie violating Coughlin right to make decision as to whether to accept a plea bargain:
13
http://www.youtube.com/watch?v=BnQWmL4_chY
14
15
-Leslie violating criminal defendant's right to decide whether or not to waive one's Fifth Amendment
rights, in both the Suppression Hearing of 8/29/12 and Trial on 8/29/12 and 9/5/12, and the right to
subpoena and call witnesses in one's defense:
16
http://www.youtube.com/watch?v=22X6CD7otQ4
17
18
For more detail, please incorporate by reference all audio transcripts from Reno Justice Court, Reno
Municipal Court, and Second Judicial District Court hearings involving Coughlin found here:
19
http://www.youtube.com/user/NevadaGadfly?feature=watch
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21
22
23
Should an attorney be disbarred based upon such wildly contradictory and inconsistent statements
(many of which are unsworn hearsay) by Reno Municipal Court Judge Dorothy Nash Holmes, where
she arrested an attorney for summary contempt second after the attorney testified that RPD Sargent
John Tarter lied?:
http://www.youtube.com/my_videos_edit?ns=1&video_id=1uQQdukb3D4
24
The Washoe County District Attorney Office's DDA Zach Young has been able to obtain Ex Parte
Emergency Orders Barring Coughlin from faxing (even on as case that Judge Lynch was assigned to,
26 but for which, curiously, former WCDA domestic violence prosecutor (see 60302 for the multitude of
27
conflicts) Judge David Clifton has taken possession of, rcr2012-065630, even where Judge Clifton
refused to respond by affidavit within 5 days to Coughlin 12/11/12 Petition or Application to Recuse
28 or Conflict Out Judge Clifton, the WCDA, and the RJC. Interestingly, Judge Clifton also granted
25
RECONSIDERATION
1
2
Richard. G. Hill, Esq. And Casey D. Baker, Esq. And Emergency Ex Parte Order to Inspect
Coughlin's Law Office in rev2011-001708).
Http://www.youtube.com/watch?v=WPYCmDZTSXo
Initially, Mirch claims that the state bar and the disciplinary panel committed several procedural
errors that necessitate either a finding of no misconduct or a remand for a new hearing. These
6
contentions lack merit.

7
Due Process
Mirch argues that his due process rights were violated because the complaint insufficiently alleged
what actions constituted a violation of SCR 170, he received no notice that the state bar would rely on
10 prior uncharged bad acts as aggravating factors, he was not notified that the state bar would argue that
serving the complaint within three days of NRCP 4(i) 120-day limit was a violation of SCR 170 and
11 he was not informed that the state bar would argue that a failure to investigate was a violation of SCR
170.
9
12
13
1. Insufficient Complaint
14
The state bar's disciplinary complaint incorporated the district court's order dismissing the state
court action and alleged that the conduct described in the district court order violated SCR 170. Mirch
16
argues that this was insufficient notice of the charges against him because the order addressed NRCP
11, not SCR 170.
15
17
SCR 105(2) requires that the state bar's complaint "be sufficiently clear and specific to inform the
18 attorney of the charges against him or her and the underlying conduct supporting the charges." Mirch
provides no legal support for his argument that the state bar cannot incorporate the district court order
19 to set forth the conduct that supports the charges. The complaint stated what the charge was, and by
incorporating the detailed order, provided an explanation of the actions that supported the charge.
20
Both NRCP 11 and SCR 170 prohibit frivolous claims. The district court order was 12 pages long and
21
provided a detailed explanation of why the complaint was frivolous and improper. An attorney is
expected to understand the ethical rules and how those rules apply to his actions.2 As a result, Mirch
22 received adequate notice of the wrongdoing alleged.
23
The 8/23/12 Complaint by the SBN alleges to specify with sufficient particularlity not only the fact
that the SBN is alleging twelve different RPC violations by Coughlin (despite not a single complaint
against Coughlin by any actual clients (except where the SBN is apparently straining credulity is
25
prosecuting Coughln for those RPC's related to the attorney-client relationship (which would
26 necessarily bring up all sorts of unique privilege issues for this repeated pro per attorney criminal
defendant (though, as of 6/7/12, and therefore within the criminal trespass trial in 26405 and matters
27 thereafter, Coughlin's law license was temporarily suspended, any such allegations would necessarily
need to relate to the 11/30/11 Trial before Judge Howard and the 2/27/12 Trial before Judge Nash
28
Holmes in criminal/"simple traffic citation" matters, or to the civil eviction matters (though Judge
24
RECONSIDERATION
Flanagan's 3/27/12 Order diposes of most, if not all of those allegations in Coughlin's favor, and the
stretch inference via quoting a procedural recitation by Judge Flanagan that itself was quoting Hill's
2 associates Motion for Attorney's fees (when Judge Flanagan really just granted that motion based
upon an excusable failure on Coughlin's part to oppose it (where DCR 13(3) arguably required as
3
much from Judge Flanagan).

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So, how on earth can the SBN have a 5 page Complaint that purports to support twelve different
Rules of Professional Conduct (not twelve separate violations of a couple RPCs...but twelve different
RPCs violated who knows how many times? And its anybody's guess what "facts" support which
allegation in the scant 5 page Complaint (and its not like the Designation of Witnesses or Summary of
Evidence that was only provided to Coughlin, which bares three different grievance numbers (NG120204, NG12-0434, and NG12-0435), yet fails to identify any of those three grievances numbers with
any particular grievant or date such a grievance was received (there is a reason for all that vagueness
and secrecy, and its steep in the impropriety of Bar Counsel and a few prosecutors turned Judges and
the cadre of a current prosecutors and former prosecutors turned court appoint defense counsel they
work so closely with year after year (and of court the WCDA and Reno City Attorney, whose
malfeasance here included attempting to alienate Coughlin from his family by sending officers out to
Coughlin's father's medical practice to implore Coughlin's father and mother to alienate themselves
from their son in a shallow attempt by the City of Reno and RPD to mitigate any civil liability it may
have some guilty conscience over given the disastrous consequences to Coughlin's life and career
attendnat to the first arrest in a series of ten, on August 20th, 2011, where RPD Officer Duralde
committed gross misconduct in lying about the order of a "search incident to arrest" that itself was
based upon a fraudulent overcharging some random "lost, mislaid, abandoned, or "rescued from being
thrown in the river if someone didn't claim it immediately" scenario as "larceny" as "oooh, that's a
felony!" Officer Duralde said to Coughlin, followed by "there's certain benefits to charging it that
way" referring to the fact that NRS 171.136 would have forbid Duralde from making an arrest (rather
than a citation) for an alleged misdemeanor after 7 pm allegedl committed outside his presence,
especially where no citizen's arrest took place, and where the allege victim's own testimony was that
the iPhone was only worth "about $80" on the night of the arrest, by the prevailing market standards
for a three year old iPhone at that time. Duralde overhcharged Coughlin with a felony grand larceny
charge, because, as a smug Officer Duralde told Coughlin, after telling Coughlin he didn't respect
Coughlin at all in light of his being a lawyer, and saying "just don't talk anymore" (not to mention
Duralde announcing that if Coughlin did not waive his Fourth Amendment rights, "I'm going to
search your pockets and your're going to go to jail", prior to any "investigation" or culling of support
for either a pat down, much less, an arrest and search incident thereto being undertaken) there is
"certain benefits to charging it that way". Coughlin maintains his innocence in connection with that
iPhone petty larceny accusation, and has a video and audio taped confession by a hostile witness,
Nicole Watson, that at once proves the unidentified man picked up the iPhone from the concrete
ground in the middel of the skate plaza (contrary to allege victim Goble's sworn assertion that he
carefully set it on a "ledge" on the northern perimeter of the skate plaza near where his friends were
congregating, and where he claims to have been "fifteen feet away skateboarding and talking to my
friends and stuff" despite Watson and another hostile witness, Nathaniel K. Zarate, and Robert
Dawson (in another video taped confession) admitting that the iPhone was actually placed on the
concrete ground near the eastern side of the skate plaza and that Goble, at that time, was off to the far
westerly side of the skate plaza (far enough away and encumbered enough to have failed to hear the
unidentified man hold the iPhone aloft and "loudly" exclaim to all in the skate park that he was
"going to throw it in the river if someone does not claim it immediately" while standing
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
approximately 75 feet from the Truckee River. Bar counsel's pleading that matter (RCR2011063341) in the 8/23/12 Complaint (like the allusions to some "disciplinary history to be testified to by
the SBN custodian of records " (for which there is none for Coughlin beyond the instant temporary
suspension in 60838 for which this very formal disciplinary hearing was supposed to be devoted, "for
the sole purpose of determining the extent of punishment" Coughlin should face in connection with
the petty larceny conviction of "a candy bar and some cough drops" from a Wal-Mart located on
Indian Colony land, where tribal police violated NRS 171.1255 in making a misdemeanor arrest of
Coughlin (shortly after he selected and paid for $83.32 worth of groceries and was alleged to have
consumed a "candy bar and some cough drops" while shopping (the due process deprivations and
verdict contrary to the weight of the evidence, as well as the question of whether any such convictions
amounts to a "serious offense" and mitigating factors attendant to both of those arrest occurring
within a 19 day span within 3 weeks of Coughlin going off two psychotropic medications (Adderall
and Wellbuttrin, given the exigent financial concerns attendant to the breakup of a four and a half
year domestic partnership with his former co-tenant Melissa Ulloa, whom moved out of Coughlin's
former home law office two days after graduating from UNR with a journalism degree which
Coughlin in large part financed and where Ulloa secretly failed to follow their established practice of
the predecing four years in taking Coughlin's rental contribution and failing to forward it on to the
landlord along with her's for the rent for both May and June 2011 (and given the various agreed upon
rent deductions between Coughlin and Merliss, Baker and Hill's initial allegations as to rent owing
(which they subsequentl abandoned for tactical reasons in proceeding only with a No Cause Summary
Eviction Notice (despite constantly seeking to inject prejudicial allegations of failure to pay rent into
both the summary eviction proceeding of 10/13/11 (wherein Judge Sferrazza ruled Coughlin had met
the Anvui burden and proceeded to bootstrap the Notice from the summary eviction proceeding onto
a "Trial" he then set for 10/25/11, on the condition (in violation of the express dicate against any
further action by the Court upon a finding that a prima facie case had been established) that Coughlin
deposit $2,275.00 in "rent escrow" with the RJC by 10/17/11.
10/13/11 RJC Rev2011-001708, part one: http://www.youtube.com/watch?v=CMo6r08rIVY
10/13/11 RJC Rev2011-001708, part one: http://www.youtube.com/watch?v=0OqLCeFGEaQ
10/25/11 in RJC Rev2011-001708, part one: http://www.youtube.com/watch?v=0Y8rZWxSW1g
10/25/11 in RJC Rev2011-001708, part two: http://www.youtube.com/watch?v=Mio-cw09npc
20
10/25/11 in RJC Rev2011-001708, part three: http://www.youtube.com/watch?v=zCPvS9KznE8
21
10/25/11 in RJC Rev2011-001708, part four: http://www.youtube.com/watch?v=2beybfqR7a0
22
10/25/11 in RJC Rev2011-001708, part five: http://www.youtube.com/watch?v=1Bt-15woBhw
23
(see, also, transcript of both 10/13/11 and 10/25/11.
24
(see especially the 10:53:32 am mark where the lack of a corollary to JCRLV 44 in the RJC,
25 considering NJCRCP 83, makes impermmissible such "rent escrow" orders in summary eviction
proceedings. Coughlin did so deposit such "rent escrow", while objecting to such a requirement as
26 void and outside the Court's jurisidction in his 10/17/11
27
28
Further, a notation on the Order attached to the Complaint as Exhibit 1, from RMC Judge
Howard's conviction of Coughlin, is completely inaccurate where it indicates Coughlin refused a
court appointed attorney at his 10/10/11 arraingment. Actually, Judge Gardner refused to allow
RECONSIDERATION
Coughlin to conduct a conflicts check, in refusing to answer a simple question as to the names of
potential court appointed attorneys....which turned out to cause a problem in the criminal trespass
2 case where an attorney with a patent and material conlfict, Lewis Taitel, Esq., was given confidential
material and files/discovery belonging to Coughlin in becoming attorney of record on a case
3
involving the very events and former home law office from which a lawsuit (or attempted lawsuit,
4 given Coughlin's IFP was denied in CV11-03126) by Couglhlin against Taitel's business partners
(where a lawyer certainly seems to be in an impermissible profit sharing/partnership arrangment with
5 non-lawyers, compound by the fact that those very non-lawyers, Nevada Court Services (which holds
itself out as "a full service eviction consulting and process service" provider, and lists Taitel as "Staff
6
Attorney" on its websits, and share a fax machine, physical office location, and receptionist and
7 notary with Taitel, and wrote one of about 20 letters of recommendation for Taitel in his 2007 bid to
become a RJC Justice of the Peace, most all of the letters violating at least an opinion letter from the
8 Commission on Judicial Discipline as to the advisibility of Judges writing unsolicited letters of
recommendation (and the converse of that is a material issue here, given NVB Judge Beesley's
9
voluntarily interjecting himself into this grievance setting, as was also revealed to be the case in
10 numerous materials presented in a box of 3,000 pages by the BN just days prior to the 11/14/12
Hearing, in clear violation of SCR 105(2)(c).
1
11
As to Judge Nash Holmes allegations in her 3/12/12 Order attached to the Complaint (the 2/28/12
Order was not attached to the Complaint and Judge Nash Holmes testimony as to "having him served
13 the Order at the jail" was a lie, and she demonstrated a lack of candor in alleging she "had it mailed"
to Coughlin where she had it sent, on 2/28/12 to an address she knew Coughlin had been evicted from
14
and rrested at based upon the testimony at trial and where the RJC had Coughlin's more updated 817
a
15 S. Virginia St. address and a fax, and email (though no phone due to Judge Nash Holmes own
confiscation of Coughlin's two phones) for Couglin incident to two other cases involving Couglin in
16 the RMC and Coughlin's own filings in that matter 11 TR 26800 and statements at Trial on 2/27/12.
The Order purposefully leaves out the time of faxing of the first 3/7/12 fax as it was so late at night as
17
to cause minimal distruption to the Court. The Ordre alludes to "action by the Administrative Judge
18 (for 2012 it is W. Gardner) and Court Administrator, yet fails to specify any such measures or why
they were necessary. Further, the Order purports that Coughlin's filing took up a "great deal" of the
19 Court's time, though, Judge Sferrazza and Elliott and Flanagan have pointed out that it was Couglin's
duty to make citations to the record, not the court's to search for support for Coughlin's contentions,
20
so Judge Nash Holmes did not "have to" spend such time, and had she, in fact, she missed a number
21 of very relevant and pointed legal contentiosn with support from case law set out by Coughlin. Also,
Juge Howard retaliated against Couglin for orally moving to disqualify Howard upon a patent evident
22 impartiality, and such a contempt order is barred under NRS 1.250. Alas, Judge Nash Holmes
2/28/12 Order was never appropriately served on Coughlin, was not attached to the Complaint (nor
23
was any letter from Judge Nash Holmes), and therefore, either every email, fax, or other writing
24 Coughlin ever sent the SBN gets into the record and notices the SBN on Coughlin's defenses, or the
SBN is stuck with not noticing or pleading ther matters set out in the 2/28/12 Order sufficient to
25 justify admitting it at the Hearing. Addionally, where Couglin cannot get NRS 7.085 attorney's fees
sanctions award where appearing as a pro se attorney, under Sellers, then the SBN and RMC shoudl
26
not be able to ascribe a "duty to his client' to Couglin when he is appearing pro per. Further, attorney
27 client privileges effect the remained of the analysis of the alleged RPC violations. Moreover, NRS
178.405 competency stay applicable via NRS 5.071 (in light of 2/27/12 1:31 pm Order for
12
28
RECONSIDERATION
1
2
Competency Evaluation by RJC Judge Clifton (a lifelong domestic violence WCDA DDA, whom has
extensive ties to both Judge L. Gardner (Reno High School classes of 1975 and 1
So 8/23/12 Complaint does not pled sufficiently or attach Judge L. Gardner's April 2009 Order,
nor 2/28/12 Order by Judge Nash Holmes, Couglhin never properly served 11/30/11 Order for
4
Summar Punishment of Contempt by Judge Howard (handcuffed, etc. and the Contempt Order was
5 not entered or prepared prior to Coughlin being transported to jail, nor was it provided to Coughlin
upon release from jail, as supported by Coughlin's calls and emails seeking a copy thereof, further,
6 that orders is entirely conclusory and lacking in detailed factual support for its findings. "Laughing"
is hardly per se sanctionable. Lines of inquiry can be put forward for a variety of differnt permissible
7 purposes, and no support provided by Howard as to which lines or when, specifically such lines were
8
continued or that the warning was sufficinet under the Houston standard.
3
Judge Nash Holmes 11 TR 26800 Order of 3/30/12 returning Coughlin' s cell phones and other
10 property shoudl have a preculsive effect as to the "taking it out of evidence" therefore meanign
insufficient proof, support, or basis for the "lying" and or "recording without permission" allegations,
11 nor has there been nary a detail as to why such items were confiscated, kept, and returned erased, or
what, if any crime, is alleged to have occurred, or how it is possibly intelligent for either the SBN,
12
RMC, or Judge Nash Holmes to take a position implying they have something to hide as to matters
13
occurring on the record in a proceeding part of the public record. Further, Couglin did not lie to
Judge Nash Holmes, and has made that clear in a response or answer and or "verified answer" or
14 "verified response" sufficinet to comply with SCR 105. Further, the attempt by Judge Nash to allege
that Couglin purportedly having "two phone" was tantamount to having "two recording devices", and
15
therefore, sufficient proof as to lies about whether he had recording devices" is not supported by the
16
record where Coughlin asserted a lawful basis for refusign to answer any question about devices, at
which time Judge Nash Holmes changed her tact and focused on "recording"
17
18
King's Complaint misstates Judge Sferrazza's Order in indicating it "ordered Couglin to vacate" the
former home law office where the Order actually says the "Sheriff shall remove" the tenant.
19
Neither any greivance letters from Holmes, Hill, or Linda Gardner (if she is, in fact, the "grievant")
20 were admitted into evidence or the record and therefore cannot be said to notice Coughlin as to the
allegations testified to by any of the witnesses. "broken into the home" assertion in King's Complaint
21 is unsupported, as admitted by Hill in 6/18/12 testimony and that from 11/14/12. Further, the
"basement" was not "inside" the "home", therefore, it could not be something one "barricades"
22
themselves inside "after breaking into the home". Not really a "basement", and the door thereto,
23 which never had an exterior lock, led directly to the outside staircase.
24
Judge Flanagan's 3/27/12 Order Denying Hill's 1/21/12 Second Motion to Show Cause disproves
conclusively as actually litigated the baseless allegations of paragraph 13 of the Complaint.
25
26
27
The failed mailing of 10/9/12, regardless, did not give Couglin sufficient time to respond, under a
NRCP 12 application following the denial of a Motion to Dismiss, nor did the 10/31/12 Order, as 10
calendar days is the rule.
28
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Judge Howard again failed to comply with NRS 1.235 upon receiving Couglin's RMC Judge Howard
12 15 11 Order denying IFP for Transcript Preparation and New Trial and Recusal page 431.
Do not believe King ever presented Panel or Coughlin a certified copy of any 2/21/12 filing
by Coughlin in RJC RCR2012-065630. Note, Exhibit 3 to NNDB Chairman Susich's SCR 117
Petition in 60975 contains a version of Coughlin's 3/5/12 Notice of Appearance as Co-Counsel and
Motion to Dismiss in RMC 11 CR 26405 for which "page 35" is the "Index to Exhibits" (and
indicates there are three (3) pages of exhibits, of which one should be WCSO Civil Division
Supervisor Liz Stuchell's 2/5/12 email admitting that Deputy Machen's 11/7/11 Affidavit of Service
attesting to having "personally served" Coughlin with the 10/25/11 "Eviction Decision and Order"
signed by Judge Sferrazza and file stamped 10/25/11, and the 10/27/11 "Findings of Face,
Conclusions of Law and Order for Summary Eviction, also signed by Judge Sferrazza and file
stamped at 4:42 pm on 10/27/11. Hill and his associate Casey D. Baker, Esq. admitted during their
sworn testimony on 6/18/12 in the criminal trespass trial before Judge Gardner in 26405 that their
office relied upon the RJC to transmit the eviction orders to the Washoe County Sheriff's Office for
service on Coughlin and to effect the lockout. There has been a coordinated coverup between the
SBN, WCSO, WCDA, and RJC to prevent Coughlin from exposing the fact that the eviction orders
were received by the WCSO well prior to the "within 24 hours" from the time of the lockout (4:30 pm
is listed on the 11/7/11 Affidavit of Service by Machen, though, upon information an belief, such
lockout occured after 5:00 pm, regardless, the locksmith who performed the lockout has admitted the
lockout occured no earlier than 4:48 pm on 11/1/11 (locksmith is name Sean Cheathum...if NVB
Judge Beesley, whose testimony wasn't constructively noticed to Coughlin until the day before the
hearing, gets to testify as to some hearsay about Coe Swobe (which Coughlin was not permitted to
rebut, or have an opportunity to be heard as to (which was true of most everything in that 11/14/12
hearing considering the incredibly curtailed and circumscribed, scant amount of time afforded
Coughlin to put on his defense, narrowed impermissibly by a mutlitude of "relevancy" rulings by a
Panel and Chair that actively sought to coerce a confession from Coughlin and or impermissibly
sought to "steer" Coughlin's testimony away from Claiborne approved attacking of the circumstances
of the convictions set out in 60838 (both the contempt conviction and the Wal-Mart petty larceny
conviction, both incident to the due process deficient trial of 11/30/11 in RMC 11 cr 22176 before
Judge Howard) and away from the Laub approved comparing of the treatement Coughlin received in
this disciplinary matter with, say, that provided to Stephen R. Harris, Esq. (and apt comparision given
the shared testimony by NVB Judge Beesley in both, though somehow Coughlin was charged with
violating 12 different RPCs (though the lack of particularize facts and or specificty by Bar Counsel
makes impossible to estimate how many violations of each of those 12 different RPCs occured by
Coughlin), where Harris, despite misappropriating $750,000 from clients did not face a temporary
suspension, and only face a charge of violating 2 different RPC's. Further, none of Harris's SCR
105(2)(c) rights were circumscribed. All of Coughlin's were.
WCSO staff Roxy Silva and "Maureen" have refused to provide Coughlin any
documentation as to when the WCSO received the eviction ORders, though they did indicate the time
of "receipt of the Orders" as reflected by their data entry clerks taking the orders from the fax
machine and inputting them into a computer software program with a time that reflected not the time
on the fax header (RJC Chief Civil Clerk stancil admits that the Order, per RJC policy would have
been faxed to the Sheriff the day they were signed, or the next day at the latest... which would place
the faxing of both of those orders well prior to "within 24 hours" of the time of the lockout, and
therefore, the WCSO "received" the orders more than "within 24 hours" of when it effectuated the
lockout. Thus, just as WCSO Roxy Silva has bragged openly and brazenly about doing, the WCSO
RECONSIDERATION
knowingly performed a lockout on Coughlin on 11/1/11 based upon Orders that is knew were void or
stale. WCSO Stuchell failed to comply with Coughlin's 11/2/12 subpoena. WCDA David Watts2 Vial (whose relation is a judicial assistant to Judge Walker, whom Coughlin tried a matter involving
UIFSA law that threatened the WCDA's office omnipotence in that arena), further collaborated
3
fraudulently with the SBN in depriving Coughlin of his right to supboena witnesses and utilize
4 subpoena duces tecums. Further, King did not have the certified copy of Judge Flanagan's 6/28/12
Order at the time of the 11/14/12 Hearing, and that is part of the reason for Chair Echeverria's
5 11/16/12 Order attempting to prevent Coughlin from exposing that and obtaining a copy of the
transcript and hearing exhibits. Additionally, as show in WCDA DDA Watts-Vial's 11/13/13 letter to
6
Coughlin (which, under NRCP 6(e), would only have been received by Coughlin after the 11/14/12
7 Hearing) SBN King provided DDA Watts-Vial all the Orders that Watts-Vial included in his late
objections to Coughlin's subpoenas, not the other way around. Watts may have utilized public funds
8 to aid bar counsel (a common occurence also seen where the RMC provided bar counsel, gratis, a
great deal of material, then failed to comply with Coughlin's subpoenas, and further made Coughlin
9
pay for each and every audio transcript he bought (and Coughlin did buy a "certified audio transcript"
10 of each and every hearing he attempted to utilize at the hearing and that he attached to his various
filings...which Bar Counsel has fraudulently failed to transmit with the 12/24/12 Record on Appeal in
11 62337, as confirmed by Clerk Castillo (the cd/dvds are not there, and, in many instances, even a
picture of the cd/dvds that were attached to various filings are not there, in contrast to a picture o the
12
cd/dvds being attached to Coughlin's Exhibit 15 at the 11/14/12 Hearing. Further, an impermissilbe
13 lack of separation between the SBN's "filing office"/Clerk of Court and the Panel and Chair
Echeverria, and Bar Counsel has been present throughout this matter, and reveals an unacceptable
14 lack of checks and balances. the SBN admits it allowed Echeverria to take the only copy of the file to
his office for an extended period of time, and that King and Peters both have gone to Echeverria's
15
office ex parte and or had ex parte communications with Echeverria. Coughlin's reference to the
16 impermissible "face time" allowed King by Echeverria was fraudulently twisted by King in his RJC
TPO application, which also lied about the link in Coughlin 12/13/12 email to both the WCPD and
17 SBN where it indicated the link was to a "video" depicting "a violent scene" when, in fact, the link
was to an audio clip only that mentioned only thinking, learning, and philosophy and overcoming
18
being attacked by those who wield their power in a wonton, ruthless, and despicably fraudulent
19 manner, like the SBN, WCPD, and others detailed herein. The "courtesy" disbarment in Oklahome
Bar Assn v Brewer is particularly analogous to what is going on here.
1
20
21
The RJC and Judge Sferrazza (especially in 063341 where he went out of his way to ignore
the mandatory authority presented by Shepp v. State's holding that a "theif cannot receive from
22
himself the fruits of his" larceny) are retaliating against Coughlin, for, amongst other things, the
23 following:
24
"RE: letter regarding supervision of court personnel
25
From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Thu 10/27/11 2:05 AM To:
stuttle@washoecounty.us
26
Dear Mr. Tuttle,
27
I am writing to express my concern and a complaint that the area of landlord tenant law
known as summary eviction is being handled in a way in the Reno Justice Court that does not
comply with the law of the land in Nevada. Nevada Justice Court Rules of Civil Procedure, Rule 83:
28
RECONSIDERATION
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3
4
5
6
7
8
9
10
11
12
"RULE 83. RULES BY JUSTICE COURTS

Each justice or justice court in a township with more than one justice, by action of a majority of the
justices thereof, may from time to time make and amend the rules governing its practice not
inconsistent with these rules. Copies of rules and amendments so made by any justice court shall
upon their promulgation be furnished to the Supreme Court, but shall not become effective until
after approval by the Supreme Court and publication. In all cases not provided for by these rules the
justice courts may regulate their practice in any manner not inconsistent with these rules."
So, with JCRCP 83 in mind, and considering that the rules regulating summary evictions
(found in NRS 40, NRS 118a, and Nevada's Justice Court Rules of Civil Procedure (JCRCP)) are
operative (and Rule 2 of the Justice Court Rules of Reno Township (JCRRT) specifically indicates
that the JCRRT do not apply to landlord tenants cases) unless a Justice Court has implemented some
contrary rule (after complying with JCRCP 83, of course, ie, getting the Supreme Court of Nevada
to sign off on some new rule...)....then the Reno Justice Court (RJC) is doing some things that it
simply is not permitted to do. The RJC seems to be utilizing some of the Justice Court Rules of Las
Vegas Township (JCRLV), however, the RJC has not received the approval to do so from the
Nevada Supreme Court. Las Vegas and Reno are very different places, and what the Nevada
Supreme Court deems acceptable in Las Vegas, it will not necessarily approve of within the RJC.
To wit, JCRLV, such as:
13
"Las Vegas Justice Court Rule 43. In Forma Pauperis requests in
14
summary eviction cases. In summary eviction cases, the following
15
procedures for processing In Forma Pauperis (IFP) requests by
16
tenants shall apply:

(a) All IFP requests must be approved by a judge before the related
filings will be processed by the court.
17
18
19
20
21
22
23
24
25
26
27
28
(b) If a tenants IFP request is denied, and the tenant provides a

telephone number on the IFP request, the court will call the tenant by
telephone to inform the tenant of the filing and to request payment of
the filing fee if the tenant desires to proceed. The tenant must pay the
applicable fees no later than 5 p.m. on the second judicial day
following the telephone call by the court. If the tenant fails to provide
the court with a telephone number on the IFP request, the fees must
be paid no later than 5 p.m. on the second judicial day following the
courts denial of the IFP request.
(c) If payment of the appropriate filing fees is not made within the
period set forth in subsection (b), and the landlord has filed an
affidavit of complaint for summary eviction, a hearing will be
scheduled, but the court may decline to consider any of the tenants
attempted filings for which fees have not been paid.
(d) If payment of the appropriate filing fees is not made within the
time period set forth in subsection (b), and the landlord has not filed
RECONSIDERATION
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2
3
5
6
7
8
9
10
11
12
13
an affidavit of complaint for summary eviction, any documents

relating to the IFP request shall be returned to the tenant by mail.
(e) If an IFP request is approved under this rule, the related
documents will be processed as if the appropriate fees had been paid.
(f) Unless the judicial order granting the IFP request explicitly states
otherwise:
(1) A granted IFP request only applies to the one related action in
justice court; and
(2) A granted IFP request only applies to court costs and fees and
does not waive bond requirements, security requirements, or other
court reporter compensation (including transcript costs).
(g) In accordance with NRS 12.015, if a Statement of Legal Aid

Representation is submitted, the fees set forth in NRS 12.015 will be
deemed automatically waived in the Las Vegas Justice Court without
the need for a court order in individual cases. The Statement of Legal
Aid Representation may only be filed by a client of a program for
legal aid as defined in NRS 12.015, or that clients attorney, and
must indicate the specific entity that is providing legal assistance to
the indigent party.
14
15
Las Vegas Justice Court Rule 44. Rent deposits relating to claims of
16
uninhabitability under NRS 118A.355.
17
18
19
20
21
22
23
24
25
26
27
(a) In an eviction action, if the tenant proceeds under NRS 118A.355

and raises a claim of uninhabitability relating to his dwelling unit, the
tenant may not raise as a defense that the tenant is entitled to
withhold rent under NRS 118A.355 unless the tenant deposits the
withheld rent into an escrow account maintained by the Las Vegas
Justice Court in accordance with this rule. The deposit(s) may be
paid by cash, money order, debit card, MasterCard, or Visa. Deposits
may not be paid by personal check.
(b) At the time that the tenant files an answer to the eviction action,
the tenant must indicate in the answer that he has withheld rent
pursuant to NRS 118A.355, and he must deposit the current accrued
withheld rent with the Las Vegas Justice Court.
(c) If the tenant fails to make the deposit required by this rule, the
tenant does not have a defense under NRS 118A.355.
(d) Prior to the hearing on an eviction action, a landlord may file a
written opposition that explains why the tenant is not entitled to
withhold rent pursuant to NRS 118A.355.
28
RECONSIDERATION
1
2
4
5
6
7
8
(e) When the eviction action proceeds to a hearing, the court may
order:
(1) The withheld rent to be returned to the tenant;

(2) The withheld rent to be forwarded to the landlord; or
(3) Any distribution of the withheld rent that is just and equitable
under the circumstances.
(f) If a tenant files a Motion to Stay or a Motion to Vacate, either

before or after the issuance of an Order for Summary Eviction, and in
lieu of an answer, the tenant must still make the deposit required by
this rule in order to raise a defense under NRS 118A.355.
(g) A tenant may not withhold rent under NRS 118A.355:
10
11
(1) For a condition caused by his own deliberate or negligent act or

omission or that of a member of his household or other person on the
premises with his consent;
16
(2) If the landlord adequately remedies the failure or uses his best
efforts to remedy the failure within 14 days after receipt of the notice
required pursuant to NRS 118A.355;
(3) If the landlords inability to adequately remedy the
uninhabitability issue or use his best efforts to remedy the failure
within 14 days is due to the tenants refusal to allow lawful access to
the dwelling unit as required by the rental agreement or by NRS
Chapter 118; or
17
(4) If the tenant has not fully complied with NRS 118A.355.
18
(h) This rule does not apply to rent that is withheld under NRS
118A.380 for a landlords failure to supply essential services.
(i) As used in this section, unless the context otherwise requires:
(1) Dwelling unit has the meaning ascribed to it in NRS 118A.080.
(2) Eviction action means:
(A) A summary eviction action pursuant to NRS 40.253 or NRS
40.254; or
12
13
14
15
19
20
21
22
23
24
(B) A formal civil eviction pursuant to NRS 40.290 to 40.420,

inclusive.
(3) Uninhabitability has the meaning ascribed to it in NRS
118A.290.
25
The two above rule are being enforced in RJC. If Justice Courts in Nevada were allowed to do that, then Las
26
Vegas would have had no need to get JCRLV 43 and 44 printed up and approved by the Nevada Supreme Court, but it
did. It is impermissible for the RJC to seek to enforce such rules without getting the same approval, as required by JCRCP
27
83. I am not so sure the Nevada Supreme Court will find that what is acceptable for the JCRLC will be for the JCRRT,
given the entirely different historical, socioeconomic, and political histories of those respective communities. RJC filing
28
office personnel openly admit the RJC is enforcing the dictates found in Rule 43, telephone calls and all, going on to
RECONSIDERATION
assert some "house rules" that the public is not allowed access to. Obviously, that is an enormous, gigantic, unimaginable
no-no for a court of law to engage in. A Qui Tam, Class Action, or Whistle Blower lawsuit could yield recoveries,
2 potentially, into the millions of dollars. I would think about $80,000 would be a just settlement for someone who has
standing, ripeness, all that stuff, and who has the ability to organize a Rule 23 class and successfully litigate the issue.
3 Obviously, you are on notice of the practice and any negligent training, hiring, supervision, etc., would be difficult for you
to distance yourself from given your position as Court Administrator. I find it hard to imagine why this practice is
4 ongoing. I am sure the public may draw their own conclusions, and I fear that those conclusions may reflect poorly on the
legal profession and the RJC, its Judges, Administrators, and employees. JCRLV Rule 44 has, essentially, recently been
5 applied by Judge Sferrazza in Rev2011-001708, first to improperly and in direct contravention of the dictates of the
applicable mandatory authority, order $2275 into a the Court's "rent escrow account". Then, even after being apprised of
6 the connection between NRS 40.253(6), JCRCP 83, JCRRT 2, and Las Vegas JCRCP Rule 44 and the lack of a corollary
to Las Vegas's JCRCP in the JCRRT, Judge Sferrazza repurposed the improperly hijacked money, seeking to now define
7 it as an "appeal bond".
1
I appreciate your letting me take a moment to express my concerns for the rights of citizens of Reno. Please let
8
me know what you want to do.
9 Sincerely, Zach Coughlin, Esq.
10
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15
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24
121 River Rock St. Reno, NV 89501 Nevada Bar No: 9473"
Additionally, the Eviction ORder and Decision in 1708 and the 10/27/11 Findings of Fact,
Conlusions of Law, and Order of Summary Eviction in 1708 both were likely made at a time at which
the RJC and Judge Sferrazza were divested of jursidiction and or did not have jurisdiction to make in
the first place (in consideration of NRS 40.253(6) requirement that the Court take "no further action"
upon a finding that Coughlin made a "prima facie showing of a genuine issue of material fact" to
support his defense to the summary eviction, which Judge Sferrazza expressly ruled Coughlin had
done, on the record, on both 10/13/11 and 10/25/11 in RJC Rev2011-001708. Beyond that, Coughlin
depositing well over the $250 set out in NRS 40.385 (see attached transcript from Venetian v. Two
Roads for support vitiating Richard G. Hill's argument that Coughlin's email to he and Judge
Sferrazza of 12/22/11 was somehow "vexatious" or dishonest or unsupported, were, in fact, it appears
such a stay is mandatory upon Coughlin's depositing the $250, particularly where Coughlin was,
apparently, considered a residential tenant (otherwise, NRS 340.253 forbids the use of No Cause
summary evictions against commercial tenants) whose rent was "less than $1,000", so, therefore,
Coughlin surely was entitled to the stay set out in NRS 40.385, where Judge Sferrazza had required
Coughlin to deposit ten times that amount, which still had not been returned at the time of the
criminal trespass arrest. Regardless, Coughlin deposited, again, the $250 specified in NRS 40.385
(which the RJC still to this date has not returned to Coughlin), yet, was not accorded the stay that the
Judge in Venetian v. Two Roads, at least, felt was rather obviously not a matter up to his discretion.
Judge Sferrazza's statements on 11/7/12 in 1708 that "three times rent" was the "standard practice" by
RJC Judges respecting the amount required for a stay (where Judge Sferrazza purports to rule as to
what the supersedeas bond would be (where, again, no damages were awarded), even where he has
denied the stay?
Further, the Second Judicial District Court, incident to both Coughlin's filing in CV11-03051 what arguably was
a Motion for Stay consistent with NRAP 8 (and NRS 40.385), committed reversible filing office error where Michelle
Purdy refused to accept, apparently, the submission at that time with Coughlin's IFP, on October 19th, 2011, that would
26
have arguably required a stay. Further, Coughlin filed a Notice of Appeal in the RJC on 10/19/11, which even Hill and
Casey D. Baker, Esq. had to admit in their curiosu 10/20/11 faxed letter to RJC Judge Clifton (whom they also sought and
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apparently obtained an Ex Parte Order Allowing Inspection of Coughlin's home law office from...) that there was, indeed,
a question of whether Coughlins' filing of a Notice of Appeal divested the RJC of jurisdiction.
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RECONSIDERATION
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3
"Emergency Appeal attached. IFP motion for Appeal attached.
From: Zach Coughlin (zachcoughlin@hotmail.com) Sent: Fri 10/28/11
10:54 PM To: eflex@washoecourts.us; courtadmin@washoecourts.us

2 attachments
marked as received by M. Purdy Mtn and Affid proceed on appeal IFP
Merliss v Coughlin eviction.pdf (64.9 KB) , Emergency Appeal marked as
received M. Purdee WDC filing office attempt to submit with IFP.pdf
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(142.1 KB)
Dear WDC
On Thursday I attempted to submit an Emergency Appeal of the Order that
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seeks to evict me from my HOME and MY LAW OFFICE. It took me
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about an hour to scan all this and get this emailed here, after having taken
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my time, about one hour, to drive down there and try to file something.
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$225 x 2, please accept this bill for $450 or provide support for your
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contentions that the WDC and filing office personnel are not subject to the
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dictates of WDCR 12(10), NRCP 5(e), Whitman, Sullivan, et al...or waive
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my eflex subscription as courtesy stemming from the various time
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consuming incidents I have detailed here and in previous correspondences.
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Just think how nice it will be not to see me in the filing office!....To me,
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this is important, I do not seek to annoy filing office staff and respect the
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work they do and the general dedication they display. I asked the WDC
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filing office to retain the hard copy of the Emergency Appeal that I sought
to submit (I am not clear whether it could be file stamped at that point, I
imagine the IFP would need to be approved....). Judge Steinheimer has
been known to answer an IFP with a denial and directions to submit more
detailed financial status information. I don't have much time given the
nature of summary evictions. That is why I took the time to go to the filing
office and avoid any such situation or delays. The filing office agreed to
RECONSIDERATION
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mark as received the document on the back of the front page. I scanned that
and am emailing that combined with the actual document to you within. I
feel there is a chance Judge Steinheimer may find the IFP I previously
submitted will not be detailed enough. As such, I also attempted to submit
the more detailed IFP/Affidavit in Support of IFP on Thursday. The filing
office signed and dated that document but refused to retain the hard copy as
well....I am attaching that to this email also. "
Another relevant email by Coughlin:
"Emergency Appeal/Motion to Stay Eviction attached. IFP motion for Appeal attached.
Sent: Wed 11/02/11 2:27 AM
To: judge.steinheimer@washoecourts.us; judge.berry@washoecourts.us;

cdbaker@richardhillaw.com
2 attachments
marked as received by M. Purdy Mtn and Affid proceed on appeal IFP Merliss v Coughlin
eviction.pdf (69.8 KB) , Emergency Appeal and Motion to Stay Eviction or Lockout
marked as received M. Purdee WDC filing office attempt to submit with IFP.pdf (148.7
KB)
Dear Judge Steinheimer and Judge Berry,
I am sorry to have to resort to seeking to submit filings to the Court in this manner, but,
given the exigencies of trying to represent my clients in the most zealous manner possible
(some of my clients have very pressing matters, such as seeking to have Trustee Sales
postponed) while being confronted with the summary nature of an eviction
proceeding/"Trial" that has included an impermissible forced depositing of $2,275 into the
Reno Justice Court's rent escrow account, in addition to impermissible departures from the
strict notice requirements attendant to any summary possessory action, I feel I must
contact the Court in this manner. This is even more true in light of the lack of response I
have received from Mr. Conyers and the news that he has resigned very, very recently.
On Thursday I attempted to submit an Emergency Appeal of the Order that seeks to evict
me from my law office, which I also utilize as a residence.To me, this is important, I do
not seek to annoy filing office staff and respect the work they do and the general
dedication they display. I asked the WDC filing office to retain the hard copy of the
Emergency Appeal that I sought to submit (I am not clear whether it could be file stamped
at that point, I imagine the IFP would need to be approved....Further NRS
12.015 seems to require one to submit a proposed filing with an IFP Petition). I wish to
submit this Amended In Forma Pauperis Petition, containing more detailed financial status
information. I don't have much time given the nature of summary evictions. My landlord's
attorney, Casey Baker, Esq. and Richard G. Hill, Esq. seek to have a constable lock me out
of my home law office prior to a written Eviction Order even being appropriately served
upon me in writing. They seek to achieve something similar with respect to a videotaped
inspection of my law office without providing appropriate written notice, nor detailing the
reason for such an inspection nor the reasonableness for seeking one, all without
appropriate written notice of an intent to inspect, nor written notice of an Order allowing
for such an inspection. That is why I took the time to go to the filing office and avoid any
such situation or delays. The filing office agreed to mark as received the document on the
back of the front page. I scanned that and am emailing that combined with the actual
RECONSIDERATION
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document to you within. I feel there is a chance Judge Steinheimer may find the IFP I
previously submitted will not be detailed enough. As such, I also attempted to submit the
more detailed IFP/Affidavit in Support of IFP on Thursday. The filing office signed and
dated that document but refused to retain the hard copy as well....I am attaching that to this
email also. I could be wrong with regard to my contentions that the filing office is not
supposed to reject filings of this sort. If that is the case, I apologize for requesting your
attention in this matter..."

It has also become apparent that there are some "issues" with regard to when the Screening Panel took place and
whom was on the screening Panel. Further WCDA Helzer has admitted to "programming" in relation to the WCDA's
impermissible influence upon RJC Judge Clifton wherein, especially during the 11/27/12 hearing in RCR2012-065630,
RJC Judge Clifton impermissilby attempted to limit the extent to which Coughlin was permitted to communicate with the
prosecutor DDA Young regarding the various matters Young was prosecuting Couglin in (three cases, one of which
RCR2012-067980 intimately involved the complicity between the RJC and the WCSO/WCDA's Office in an attempt to
discredit and derail Couglin, as has only recently become more obvious to Coughlin incident to a Brady violation by the
WCDA and DDA Young wherein only after the 11/14/12 disciplinary hearing, and way too close to the 12/11/12 trial in
rcr2012-065630, the WCDA and Young finally turned over a recording from the 1/14/12 arrest in 065630 (mentioned in
King's 8/23/12 Complaint, along with the 1/12/12 custodial "jaywalking" arrest (which King attempts to mislead with
respect to the true nature of the arrest in his complaint, even where Judge Flanagan's 3/27/12 Order conclusively proves
Coughlin did not "interfere" with the Order in CV11-03628 on that date, though King demonstrates a lack of fairness to
opposing counsel Coughlin and a lack of candor to the tribunal where his 8/23/12 Complaint fails to specify that the
arrest was for "jaywalking". Further, King and the SBN are embarrassed by the fraudulent and conflict of interest and
appearance of impropriety incident to Hill's 1/14/12 greivance against Coughlin to the SBN (wherein Hill name checks
RJC clerks Stancil and Baker as "people to call" who will badmouth Coughlin (which is not the case, but whatever) and
Judge Nash Holmes 2/28/12 Order (which makes obvious her tenuous grasp of the difference between civil and criminal
contempt, and summary and plenary proceedings...or, perhaps, indicates a willfull fraudulence on her part to appear to be
unaware of such differences in mixing and matching those parts of those various types of contempt statutes to achieve
what was obviously her true intent (ie, make a pretexutal contempt finding to allow for an arrest and search incident
thereto so she could have Coughlin's property confiscated, whereupon she and the RMC could search and copy it, and
return it to Coughlin with all the data wiped. Further, Coughlin was not affored, contrary to her assertion, and
opportunity to pay $500 instead of being incarcerated. Additionaly, the fraud attendant to takign $100 from Coughlin's
mother in lieu of a fifth day of incarceration, then claiming Coughlin was, in fact "released", then immediately
"rebooked" is just beyond the pale and creates an appearance of impropriety that is reprehensible.
Further, the SBN is embarrassed by the extent to which the RMC and its Marshals admit that "central control"
monitors and controls all activities at the RMC, indicating an impermissible influence over the judiciary by the Reno
Marshals, and certainly, a lack of separation between the RMC Judges and the RMC filing office, which has repeatedly
refused to provide Coughlin the 2/2/12 audio transcript of the Hearing in 11 CR 26405 before Judge William Gardner
wherein Gardner failed to reveal, despite a prompting from Coughlin as to any potential conflicts or basis for recusal, the
fact that his sister is Family Court Judge Linda Gardner (whom RMC Judge W. Gardner subsequently admitted on
4/10/12 to having been passed the April 2009 Order by L. Gardner (the one Elcano cited as the sole reason for firing
Coughlin in his 5/4/09 and 5/11/09 letters to Coughlin) by his sister, which he thereupon passed around to his fellow
RMC Judges (though in a "very carefully planned out manner"...though not careful enough, apparently, as Judge W.
Gardner did not, to hear him tell it, realize that Judge Nash Holmes incuded teh April 2009 Order his sister passed him in
the "box of materials" she provided to Bar Counsel on 3/14/12, which Bar Counsel then fraudulently marked as
"received" on 3/15/12 (and the "5" in the "3/15/12" is so suspicious looking as to support an allegation, some might say,
that it has been fraudulently altered by the SBN, and there are various iterations of the "5", some in which it is more faint
than others, and some wherein a pen has obviously been reapplied to the stamping....). Further, Coughlin was never
provided any "letter" that NVB Judge Beesley purports to have sent Bar Counsel, and the timing of that letter by Judge
Beesley would be after the 4/10/12 Screening Panel date (as would be the 4/11/12 dating of RMC Marshal Coppa's letter
to the SBN and the suspiciously indefinate "on approximatley 4/16/12 dating for such a Screening Panel purportedly
mentioned in the SCR 117 Petition by NNDB Chairman Susich (whom should have been conflicted out of participating
given the fraudulent attempts by his employee NV DETR's lawyer Maureen Cole, to prevent Coughlin from suing
Washoe Legal Services in 2009).
RECONSIDERATION
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Coppa's 4/11/12 Affidavit reveals the impermissible bullying by RMC Marshals of defendants, but also
demonstrates the impermissible influence law enforcement is exerting on the filign office and even judiciary in the RMC:
"On March 22, 2012, a pproximately 1055 hrs. I (Marshal Scott Coppa) was notified by central
control to respond to Donna Ballard desk in reference to a Defendant Zachary Coughlin. Both
Marshal Thompson and I met with Miss Ballard at her desk. She informed us Coughlin has been
at Daniel Casillas window #8 for approximately 15 minutes and was becoming argumentative
with court staff. Miss Ballard further stated the Staff has answered all his questions as he was now
becoming repetitive with his questions. At one p oint Coughlin demanded to have Casillas read
the docket to him word for word and that he was going to "depose" Miss Ballard. Marshal
Thompson and I approached Coughlin in the public hallway. As I approached Coughlin I noticed
that he was wearing red smiley face flannel pajama bottoms and a white tee shirt. Underneath the
tee shirt Coughlin also had on a dress tie and a dress shirt. I informed Coughlin all his questions
have been answered by court staff and it was time for him to leave, Coughlin asked me "did they
teU you to tell me to leave." Coughlin then turned t o Casillas and asked if he could talk to him.
Both Marshal Thompson and I again asked Coughlin to leave. Coughlin asked for our names,
gathered his items from the counter and left the Court. Both Marshal Thompson and I made a
recording of this event"
Notice the RMC Marshals wish to avoid admitting that Ballard did not call them requesting assistance with
Coughlin, nor did Ballard or anyone with the Filing Office tell Couglin to leave or request to Marshal to do so. Simply
put, the RMC Marshals run the RMC, and the filing office staff is terrified of them. At least 3 RMC Marshal have
recently taking to shaving their heads. Which is one's right to do, and not necessarily indicative of anyting in
particular...but placed in the paramilitary, draconian, totalitarian displays of authority regularly exhibited by the RMC
Marshals, its a little....well...you know what I am saying....Marshal Coppa was involved in the transport of Coughlin to
the Washoe County jail on 2/27/12 by Coughlin, and Coughlin witnessed Coppa pull aside Deputy Cheung into a back
room of the jail's "sally bay" whispering about the planned confiscation of Coughli's property, including his smartphone
and micro sd card. Marshal Coppa was present when, immediately after being declared in contempt by Judge Holmes
on 2/27/12, Coughlin was handcuffed and taken into custody and searched incident to arrest in the hallway in the
backrooms of the RMC. At that point, Marshal Harley committed misconduct where, upon finding a micro sd data card
in Coughlin's suit pocket, exclaimed to Coppa "he was recording! Go tell the Judge Coughlin lied! He was
recording!". Harley had nothing more to support such a "probable cause analysis" to buttress his suspicion that Couglin
was recording other than finding a micro sd data card in Coughlin's pocket (and certainly not in some bathroom stall
after some alleged "disassembling"...but Coughlin was fraudulently prevented from questioning Harley or Coppa, in
part, due to the impermissible "teamwork" between the Reno City attorney and Bar Counsel (it is not permissible for
Bar Counsel to be Quashing Coughlin's subpoenas...where was Coughlin's opportunity to quash the subpoenas of Judge
Beelsey or Elcano, or even be made aware of any subpoenas being served or filed (Coughlin was never provided any
such materials, though did come across a "waiver of" requirement of service of a subpoena of some sort apparently
faxed from NVB Judge Beelsey to Bar Counsel, seemingly abandoned on a table in a corner of the formal hearing room
of the SBN on 11/14/12 at the hearing. That document, however, was not included in the 12/24/12 "Record on
Appeal", nor was any subpoena for Hill, Judge Nash Holmes, Elcano, or Beesley "filed within 2 days of service" as
required by NRCP 45. It was a prejudicial due process violation for Couglhin not to be provided any such subpoenas
or notice thereof, especially considering Bar Counsel and Clerk of Court Peters various threats of "getting a protection
Order" (made by Peters starting in late October 2011 and in Bar Counsels's early November "stay away" letter/quasi
trespass notice, etc.; and incident to impermissible deprivation of Coughlin's SCR 105(2)(c) right to inspect materials
"up to 3 days" prior to the Hearing of 11/14/12).
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On December 14th, 2012 Panel Chair John Echeverria signed an Order attempting to disbar me from
26 the practice of law in Nevada. There are extremely limited time frames and deadlines for me to
challenge this and preserve my objections to the deficiencies in the record and transcript.
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The Panel Chair Echeverria went to Reno High School in 1962 with Washoe Legal Services Paul
Elcano (Elcano transferred to Wooster the next year, but the went to Stanford together in the later
RECONSIDERATION
1960's along with Judge Steven Elliot, whom has curiously decided to retire all the sudden).
Echeverria graduate in 1963 from Reno High School....along with....Judge Charles McGee, and
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current Nevada Bankruptcy Judge Greg Zive...and a Norman Beesley (not sure if Norman Beesley,
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3 DMD is related to the Nevada Bankruptcy Judge who testified against me at my hearing, and for
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Stephen R. Harris, Esq. as his hearing....). Clearly, though, Judge Beesley has a basis for knowing the
4 deep rooted Echeverria ties to Nevada, as evince by the following exchange on page 9 of the
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5 11/14/12 transcript:
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"MR. KING: Thank you, Mr. Chairman. Judge Beesley, the panel consists of John
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6 Echeverria -- I'm not pronouncing the name -- but there's five panel members.
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JUDGE BEESLEY: John Echeverria. You have not pent enough time in Nevada.
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MR. KING: That is correct. Thank you for that."

1
Also, former RJC Judge Fidel Salcedo is a 1962 graduate of Reno High and Judge Sferrazza mentioned
on the record on 11/19/12 in the prosecution against me in rcr2011-063341 that he needed to take
a 10 minute recess to meet with Judge Salcedo...whom seems to be Timothy D. Coughlin, MD's
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patient, from what I could glean of their conversation during Judge Perry's funeral. Also, my Dad's
12 medical Partner, Dr. Marge Uhalde is a 1963 graduate of Reno High...former RJC Judge Harold
Albright (now a senior Judge Pro Tem) is also a RHS 1963 graduate. NVB Judge Zive went to RHS in
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1962 as well.
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Elcano, RMC Judge Nash Holmes, and NVB Judge Bruce T. Beesley all testfied at my hearing very
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negatively against me, and all went to McGeorge School of Law in 1977. Nash ordered me to a
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County Jail on 2/28/12 and take possession of and return back to the RMC with my smart phone and
a micro sd data card (both of which were returned to me erased 37 days later...and I have never
18 seen a warrant or Order allowing such "booking into evidence" of Coughlin's personal property,
particularly well after the time frame for conducting a "search incident to arrest".
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The traffic citation trial in 11 tr 26800 was only about a hour and a half, and it strains credulity to
believe Judge Nash Holmes "just got confused" or whatever it is she will attempt to say (or did
21 attempt to remix her testimony as during the hearing upon Coughlin cross-examining her) once the
audio transcript of the trial is deemed admissible (somehow Bar Counsel gets into evidence the
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6/28/12 Order by Coughlin former co-worker as Hale Lane (which counts amongst its partners Reno
23 High School Class of 1963 members Karen Dennison, Steve Peek, Richard Bennett, and Craig
Howard....now part of the largest law firm in the Western States, Holland & Hart) awarding Richard
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G. Hill, Esq. $42,060 in attorneys fees against a pro se appellant to a summary eviction/"Trial", and
25 Family Court Judge Linda Gardner's April 2009 Order sanctioning Coughlin (and cited to by Elcano as
the "sole reason" for firing Coughlin) without actually having those documents certified by any clerk,
26 much less one from the Second Judicial with the authority to do it....yet Coughlin is prevented by
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Chair Echeverria from rebutting Judge Nash Holmes fantastical account (which is completely
contrary to reality and which Coughlin has on numerous occasions indicated that he did not lie to
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RECONSIDERATION
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Judge Nash Holmes in Court on 2/27/12 in 11 TR 26800, regardless of the chicanery/spin Echeverria
is attempting to impart upon these matters now).
Basically, what seems obvious is that NVB Judge Beesley read the filing by Coughlin in his court in
Cadle Company v. Keller in the adversary proceeding 10-05104, on 3/30/12, wherein Coughlin
attaches extremely inflammatory materials related to the Judge Nash Holmes 5 day summary
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contempt incarceration beginning on 2/27/12 and subsequent confiscation of Coughlin's
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smartphone and micro sd card by the Reno Municipal Court, it's Marshals, and the WCDA/WCSO
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(with the WCSO managing to fail to serve the Summons and Complaint against Washoe Legal
Services in CV11-01955 and or CV11-01896-the cases against WLS and CAAW (with Judge Elliot
presiding over the WLS/CAAW case in CV11-01955 even where he sits on CAAW's Board of
Directors, which he failed to disclose). The State Bar of Nevada is now trying to assert the NVDETR
in house counsel J. Thomas Susich, Esq. picked the Panel (which, given the numerous ties between
Elcano , Echeverria, Judges Nash Holmes and Beelsey, and panel member Stephen Kent's McGeorge
School of Law 1980 pedigree, seems to have been a "shake and bake" type of arrangement at best)
despite the Bar's previous stance that they control and do everything. One thing is clear, though.
SCR 105(2)(c) provides for respondent's to have at least a passable opportunity to make
peremptory challenges to certain members of the NNDB being part of the 5 member Panel presiding
over a hearing...and the SBN rigged this proceeding to prevent Coughlin from having such an
opportunity by the SBN/NNDB/Panel/SBN Clerk of Court making fraudulent
assertions/promises/edicts as to the applicable rules of procedure and their reduction to practice in
this, a highly dubious quasi-judicial proceeding where, to be sure, "we playin' prison rules". Not sure
how Judge Beesley and Elcano are allowed to testify when their participation is only mentioned a
couple days prior to the 11/14/12 hearing (not to mention to 14 or so previously name witnesses
whom the smoke screen throwin' Bar Counsel never called, or seemingly, even intended to call.
Not to mention to delivery of 3,000 pages of materials on 3 days before the hearing as some sort of
"consolation" for the NNDB/Panel/Bar failing to allow Coughlin the access to those materials for the
twenty seven days between the service, under SCR 109 of the Complaint and the "within 3 days"
dicate in SCR 105(2)(c).
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As for Judge Nash Holmes...its not real hard to figure out whether the questioning about "recording"
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or "recording devices" came before or after the one restroom break she granted Coughlin:
http://www.youtube.com/watch?v=F_mbKN9U6D4 (start of the 11 TR 26800 "simple traffic citation Trial" up
22 to the one restroom break)
http://www.youtube.com/watch?v=i2EiWEaKvp0 (Judge Nash Holme's sue sponte interrogation of Coughlin
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immediately after the restroom break)
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Sure doesn't add up much when one considers Judge Nash Holmes ordered Marshal Harley to escort
Coughlin to the restroom...and that Harley and Chief Marshal Roper admit Harley never went into
the restroom but rather waited outside for Coughlin to exit the restroom, whereupon Harley
escorted Coughlin back to the court room, at which point Judge Nash Holmes immediately began
her sua sponte cross examination....so....just when would Marshal Harley have had the time to go
into the restroom, find some "disassembled recording device", and then somehow transmit a report
RECONSIDERATION
thereof to Judge Nash Holmes in sufficient to to provide her a basis for finding reasonable suspicion
to then begin cross examining Coughlin (or attempting to) immediately upon Coughlin re-entering
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the court room after the ONE restroom break (and clearly, audio file 1 of 2 from the 2/27/12 Trial in
3 RM 11 TR 26800, with a running time of 1 hour and 8 minutes, contains no questioning by Judge
Nash Holmes as to whether Coughlin was "recording" or anything about Coughlin having a
4 "recording device". Further, Coughlin never "quote, took the Fifth" (rather he mentioned the
5 Fourth Amendment several times, however, taking the Fifth is not supposes to be used by a judge to
provide an inference of guilt...however, judges are not supposed to hold trial and then declare the
6 defendant incompetent immediately after sentencing them (which is exactly what Judge Nash
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Coughln's cross-examination of Judge Nash Holmes on 11/14/12 went:

"MR. ECHEVERRIA: Also, do you have any
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HEARING - 11/14/2012
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Page 129
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,,,DOROTHY NASH HOLMES having been first duly sworn, testified as follows: DIRECT EXAMINATION
BY MR. KING:
Q Judge Holmes, could you explain to the panel how you -- whether or not you formed an opinion as
to Mr. Coughlin's competency to practice law in Nevada?
A Yes, I did. I was the presiding judge in a traffic trial where he was the defendant, and also
representing himself. And it was a traffic ticket case, and it was quite an ordeal. We basically went
through a couple, three hours of trial, and I saw his performance at that time, and it caused me to
draw some conclusions.
Q Did you end up holding Mr. Coughlin in criminal contempt?
A I did. As I said, the trial was a bit of an
HEARING - 11/14/2012
Page 130
ordeal. I held him in contempt because of numerous antics and actions, and what I considered to be
misconduct that he was performing during the representation of himself.
(Exhibit 4 marked.) BY MR. KING:
Q I'm holding in my hand an order that was signed by you dated the 28th of February, 2012, in the
matter of 11 TR, which I assume stands for traffic, 26800
21. And it's an order finding the defendant in contempt of court and imposing sanctions. Do you
recall executing such an order?
A Yes, I did. I wrote it myself, and I signed it, and I found him in contempt, in direct contempt during
the proceeding, and right after that did the order.
Q I'm reading from Page 3 of your order, which is the final page that has your signature on it before
the service, certificate of service. But in that final paragraph it says, "The court finds that the
defendant's actions were intentional and done in utter disregard and contempt for the court, and in
the presence of the court, for purposes of disrupting and delaying the proceedings and dishonoring
the rule of law and this court, and constitute the misdemeanor of criminal contempt, a violation of
NRS 22.010. Good cause appearing therefore, the following sanctions are imposed."
HEARING - 11/14/2012
RECONSIDERATION
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Page 131
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Did you write that order?
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A Yes, I did.
Q Is there anything that's occurred since you issued the order to make you believe that your order is
not accurate?
A Well, no. I've seen Mr. Coughlin a few more times, and I believe he's got some serious mental
illness issues that drive his conduct. But I don't believe that he is capable of practicing law because
of either case, whether it's because he intentionally acts that way or because he is unable to control
his actions and acts that way.
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MR. KING: I'm going to ask that Exhibit No. 4 be admitted, which is the order that I just had the
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judge confirm is her order.
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MR. ECHEVERRIA: Any objection, Mr. Coughlin?
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MR. COUGHLIN: She is not here to be able to see it.
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MR. ECHEVERRIA: Pardon me?
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MR. COUGHLIN: She is not here to see it, so she can't confirm it.
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MR. ECHEVERRIA: Did you write -- Judge Holmes, this is John Echeverria. Did you write any other
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order in the case of City of Reno versus Zachary Barker Coughlin that was dated February 28th,
2012?
HEARING - 11/14/2012
Page 132
THE WITNESS: No. I wrote one order holding him in contempt.
MR. ECHEVERRIA: That was lodged with -- was that lodged with the Reno Municipal Court on that
same day?
THE WITNESS: Yes, it was. And then I provided a copy of that to Mr. King at his request. (Note by
Coughlin, Richard G. Hill, Esq. had Coughlin served an Order to Show Cause for the summary
eviction appeal in CV11-03628 at the 2/27/12 11 TR 26800 traffic citation trial before Judge Nash
Holmes in the RMC where WCSO Deputy John Machen (the same deputy who filed a false affidavit
alleging to have "personally served" Coughlin the Eviction Lockout Order in RJC Rev2011-001708
on 11/1/11 in Machen's 11/7/11 Affidavit of Service) had RMC Marshal Joel Harley take Judge
Flanagan's Order To Show Cause of 2/8/12 (which Coughlin had already been served given his
efiler status on the case and Caplow) and intrude into a private conference room where Reno City
Attorney Ormaas and defendant Coughlin were having a plea bargaining session. This violation of
the courthouse sanctuary doctrine by Hill, the WCSO, and the appearance of impropriety created
by the leveraging of RMC Marshals to effect service of civil Orders, particularly where, in the
ensuing trial that day before Judge Nash Holmes, which involved the issuance of three traffic
citations by RPD Sargent John Tarter (one of the 35 highest paid City of Reno employees, whom,
admitted to this being the only traffic citation he issues all year) to Coughlin minutes after
Coughlin reported to Sargent Tarter the statement by RPD Officer Chris Carter, Jr. during his
custodial arrest of Coughlin in RMC 11 CR 26405 (the case that RMC Judge W. Gardner refused to
recuse himself from despite Judge Nash Holmes 3/14/12 grievance to the SBN, NG12-0435 (one of
three case numbers forming the SBN v. Coughlin 8/23/12 Complaint, which the SBN/NNDB/Panel
allege complies with the N. S. Ct.'s 6/7/12 Order and SCR 111(7)'s dictate that the criminal
conviction for petty larceny of Coughlin by RMC Judge Kenneth Howard in RMC 11 CR 22176
(resulting in the now 6 month long temporary suspension of Coughlin in 60838) involving $14.00
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
worth of a "candy bar and some coughl drops" Wal-Mart's Thomas Frontino alleged Coughlin
consumed while shopping for and paying for $83.00 worth of groceries) indicating she was making
it on behalf of all the other RMC Judges, one of which would necessarily be 2012 RMC
Administrative Judge W. Gardner. RMC Judge W. Gardner admitted, on the record during a Trial
that violated the mandatory stay during the pendency of an Order for Competency Evaluation (the
2/27/12 Order by RJC Judge David Clifton, who went to Reno High School with RMC Judge W.
Gardner's sister Judge Linda Gardner in 1975, and then worked with her in the domestic violence
unit at the Washoe County District Attorney's Office before they became judges, and where Judge
Clifton, for some reason, took possession of the "misuse of 911 emergency services" prosecution
of Coughlin despite that case, RCR2012-065630 being "randomly assigned" pursuant to JCRRT 2 to
Judge Patricia Lynch. Somehow, in his 2/27/12 Order for Competency evaluation (which, curiously
was filestamped at 1:31 pm, the time set for a 2/27/12 Status Conference between DDA Young
and Coughlin's WCPD Biray Dogan, which Dogan informed Coughlin of in writing on 2/24/12 had
been vacated until 3/29/12 in light of the conflict with the traffic citation trial before Judge Nash
Holmes in RMC 11 TR 26800 on 2/27/12 at 1:00 pm...which did not start until approximately 3:00
pm given Judge Nash Holmes judicial assistant could not locate Judge Nash Holmes, despite Judge
Nash Holmes taking the bench at 1:00 pm, and disposing of all cases other than Coughlin's, upon
which she took and extended abscence from the bench, and, upon information and belief, had
communications with the RJC, WCPD's Office, WCDA, other RMC Judges, City of Reno Marshals,
RJC Bailiff's, and or the Washoe County Sheriff's Office, and Second Judicial District Court Filing
Office Staff (including Clerk Lori Matheus) and Department 10 Judge Steven Elliott (whom worked
for Panel Chair Echeverria's father's law firm and went to Stanford University in the late 1960's
with WLS's Elcano (whom went to McGeorge School of Law in 1977 with Judge Nash Holmes and
Judge Beesley and went to Reno High School in 1962 with Panel Chair Echeverria, RJC Judge Fidel
Salcedo, NVB Judge Greg W. Zive, Norman and Maurice Beesley, Coughlin's former co-workers at
Hale Lane...and the SBN failed to timely notice Coughlin of the testimony of Judge Beesley and
WLS's Elcano prior to the 11/14/12 hearing, especially where no newly discovered evidence or
other excuse for failing to timely identify those two witnesses existed and or was offered by the
SBN.
To me, some of my biggest "new trial" or "alter or amend" arguments related to my failure to point out or get into evidence
the res judicate or whatever effect of Judge Flanagan denying Hill's Motion for Order to Show Cause in his 3/27/12
21 Order...plus my failure to point out that, while Flanagan did award Hill $42K in attorney's fees in his 6/28/12 Order, that was
due to my failing to properly oppose the motion...and my failure is excusable considering I was wrongfully incarcerated the
22 day the motion was filed by Judge Elliott (whom failed to recuse himself from the case where I sued Washoe Legal Services
and Committee to Aid Abused Women (CAAW) even though he is on CAAW's Board and his wife Mendy is totally active in all
23 that...and Judge Lynch was mysteriously transferred off the case that resulted in that CR12-0376 District Court matter
wherein Judge Elliott remanded me into custody for 8 days to coerce a waiver of my medical privacy rights incident to a
24 "competency evaluation" ordered on 2/27/12 by RJC Judge Clifton in the "misuse of 911" arrest by the RPD on 1/14/12 (two
days after Hill had me subject to another custodial arrest in RMC 12 cr 00696...at case which RMC Administrative Judge W.
25 Garnder curiously transferred from Dilworth to Holmes on 2/27/12, to go along with the traffic citation outside Richard G.
Hill's office (cited by RPD Sargent Tarter after he told Couglhin to leave Hill's office, where Coughlin appeared upon being
26 released from jail on 11/15/12 after the 11/13/12 criminal trespass arrest stemming from the criminal complaint signed by
Hill, wherein he and his neurosurgeon client lied to effect Coughln's arrest:
27 -11/13/11 video of the fraudulent criminal trespass arrest by RPD Officer Chris Carter, Jr. and Sargent Marcia Lopez, wherein
Richard G. Hill, Esq. signed the criminal complaint in RMC 11 CR 26506, presided over by RMC Judge William Gardner, brother
28 of Family Court Judge Linda Gardner (whose April 2009 Order sanctioning Coughlin $1,000 personally for opposing counsel
20
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
John Springgate, Esq's attorney fees in the Joshi divorce trial was cited in Washoe Legal Services Executive Director Paul
Elcano's May 4th, 2012 letter to Coughlin as the sole reason for terminating Coughlin's employment as a domestic violence
attorney in May 2009, resulting in a wrongful termination lawsuit against WLS and the Committee to Aid Abused Women
(CAAW) in CV11-01955 wherein Judge Steven P. Elliot failed to divulge the patent conflict attendant to his serving on CAAW's
Executive Board, or going to Stanford University with Elcano and the Chair of Coughlin's 11/14/12 formal disciplinary hearing,
John Echeverria in the late 1960s, or Elliott's previously being employed by John Echeverria's father's law firm, Echeverria and
Osborne, now on appeal in 60317). The statistical probability of Judge Elliott being "randomly" assigned four straight criminal
matters wherein Coughlin was a defendant out of nine possible Departments in the Second Judicial District Court is
0.00161051% chance of that occuring naturally ((1/9)(1/9)(1/9)(1/9)=0.00161051% probablit of D10 Judge Steven P. Elliot
being "randomly assigned" four straight criminal cases wherein Coughlin is a criminal defendant (CR11-2065, CR12-0376,
CR12-1262, CR12-2025):
http://www.youtube.com/watch?v=Eh2xyc-9cg0
"zach's arrest 011 Dr. Matt Merliss lies to get attorney arrested criminal trespass civil eviction"
-11/15/11, Couglin cited for 3 traffic citations by RPD Sargent John Tarter immediately after Tarter instructs Couglin to leave
Richarg G. Hill, Esq.'s law office at 652 Forrest St. where Couglin ventured to request his Nevada driver's license, wallet, keys,
and client's files from Hill upon Coughlin being released from a three day incarceration incident to Richard G. Hill, Esq.
fraudulently signing a criminal trespass complaint and making false statements to effect the wrongful arrest of Coughlin in
RMC 11 CR 26405 on 11/13/11 at Coughlin's former home law office at 121 River Rock St. Those traffic citations would
become the RMC 11 TR 26800 "simple traffic citation" Trial on 2/27/12 wherein RMC Judge Nash Holmes sentenced Coughlin
to 5 days summary contempt incarceration and confiscated his smartphone and micro sd data card for 37 days (at which time
the smart phone and micro sd data card were returned to Coughlin with all date thereon wiped, by the Washoe County
Sheriff's Office, which had released Coughlin's smart phone, and micro sd data card back to the RMC and the City of Reno
Marshals on 2/28/12, well after those items were booked into Coughlin's personal property at the WC jail on 2/27/12, and
therefore, not in connection with a "search incident to arrest" but rather, "per judges order" according to Washoe County
Sheriff's Office employes Deputy Hodge, Trudy Darlington, Debi Cummings, and Patricia Beckman. WCSO Deputy Hodge
admitted that the City of Reno Marshals retrieved those items from the jail on 2/28/12, and had yet to return them to the jail
as of March 19th, 2012. Upon Coughlin filing a Motion on 3/30/12 in Bankruptcy Court for the Disrict of Nevada (NVB) on
3/30/12 in an adversary proceeding (Cadle Co. v. Keller, 10-05104) wherein his client's defense was prejudiced severly by
Judge Nash Holme's wrongful summary contempt incarceration of Coughlin and subsequent conversion of Coughlin's only
phones (his smart phone and a regular flip style cellular phone, in addition to the micro sd data card) on 2/27/12.
Immediately after the filing of that 3/30/12 Motion
17 http://www.plainsite.org/flashlight/case.html?id=1867780
Filed: 3/30/2012, Entered: 3/30/2012
Brief
18 Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed by
ZACH COUGHLIN on behalf of SAMANTHA L. HALL, ROBERT KELLER (Related document(s)49 Notice of Entry of Default filed by
19 Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in Support of Opposition# (2) Exhibit
Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court Marshals and Judge Nash Holmes seize
20 attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding excusable neglect prejudice to Keller's case# (5) 3 26 12
Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record on appeal# (7) Exhibit 11 TR 26800 NOTICE OF
21
APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED) (COUGHLIN, ZACH)
22
1/13/12 Coughlin gets RPD Sargent Marcia Lopez to admit that the 11/14/12 criminal trespass arrest was wrongful in that the
RPD neither announced they were law enforcement before the landlord kicked the door down to the quasi23
basement/crawlspace under the former home law office of Coughlin's, nor did Hill, Merliss, or the RPD warn Coughlin to leave
prior to arresting him for trespass:
24
25
http://www.youtube.com/watch?v=VcVDVjFK64g
"rpd sargent lopez i have a question for you 11 cr 26405 00696 26800"
26
-1/14/12, Reno Police Department Sargent Paul Sifre orders RPD Officer Jason Schaur to again arrest Coughlin,
for the second time in 48 hours, for "misuse of emergency communications when no actual or perceived emergency
27
exists" in RCR2012-065630.
RCR 2012-065630 http://www.youtube.com/watch?v=w_dxbsEXsBY
28
RECONSIDERATION
1 12/11/12 Trial in RCR2012-065630 ("misuse of 911" arrest of 1/14/12, subsequently converted to a SCR 111(6)
leveraging "resisting a public officer" NRS 199.280(3) charge, though Coughlin is unlikely to receive the treatment
2
former Pahrump District Attorney Beckett benefitted from a la SCR 111(10) after a week of rehab and a setting
aside of his conviction two months later, upon which time he was reinstated to the practice of law, despite other
3
looming disciplinary matters, including rolling his government issued vehicle in an alcohol related matter:
4
5
6
8
9
10
11
12
13
14
15
16
Additionally, the 12/14/12 Order by Chair Echeverria

Keith Loomis, Esq. and Henry Sotelo, Esq. provided willfull ineffective assistance of counsel in the fraudulent
"disturbing the police arrest by RPD Sargent Dye and Officer Alan Weaver on July 3rd, 2012, just blocks from
where Officer Weaver has previously attempted to break and enter one of Coughlin's three rental's at Northwinds
Apartent, in violation of Soldal v. Cook County (1992 US Supreme Court case (police report from the RMC 12 CR
12420 case that
resulted in my 20 day incarceration in July 2012 (wherein you visited my in jail on numerous occasions and were
helpful
in working things out, as you were during the 9 day incarceration from April 19th, to April 26th, 2012 when Judge
Elliott,
in CR12-0376 remanded me into custody upon the violation of the NRS 178.405 mandatory stay pending a
competency
evaluation incident to DDA Young making a motion to revoke my bail and remand me into custody based upon a
fraudulent 4/18/12 letter by Lake's Crossing's evaluators Bill Davis, Ph.D. and Sally Farmer, Ph.D. (curious how
WCPD
Biray Dogan, Esq., whom Giles spoke with during that 8 day jail stay in April 2012, somehow knew it was "Dr. Bill
Davis"
specifically with whom Coughlin was required to have the competency evaluation stemming from the 2/27/12 Order
by
RJC Judge Clifton in RCR2012-065630 (a case that was originally "randomly assigned" pursuant to JCRRT 2 and
21:
JUSTICE COURT RULES OF RENO TOWNSHIP Rule 1. Title. These rules may be known and cited as the
Justice Court Rules of Reno Township, or may be abbreviated J.C.R.R.T. Rule 2. Application of Rules. Except
as otherwise provided by statue, these rules apply to all civil proceedings filed in Reno Township except small
claims and landlord tenant matters.
17
Rule 21. Organization of the court. A. All civil and criminal cases shall be randomly assigned. B. The justices of the
peace shall select one judge as the chief justice of the peace for a term of 1 year as referred to in J.C.R.C.P. 84.
18 The chief justice of thepeace shall supervise the court clerk, including all related court officers, and resolve any
calendar assignments and procedural/policy disputes between the court departments. It was reversible error in
19 RCR2011-063341 (the iPhone case wherein the 8/20/11 arrest was the first of ten subsequent incarcerations of
Coughlin over the next 11 months and upon Couglin's release from a 7 day jail stay where that petty larceny first
20 offense charge of a 30 year resident attorney with income and strong ties to the community failed to garnder an OR
for 7 days, Coughlin was greated with a Richard G. Hill, Esq. 30 Day No Cause Eviction Notice at his former home
21 law office at 121 River Rock St. for a landlord tenant matter that Judge Sferrazza was also assigned to, now on
appeal in 60331, and the $42,050 attorney's fees awared incident to the District Court appeal therefrom now on
22 appeal in 61383) (the iPhone petty larceny conviction (wherein Judge Sferrazza also managed to convict Coughlin
for "receiving stolen property" based upon the exact same item and same facts, despite the mandatory authority in
23
Stnow on appeal before, you guessed it, Judge Elliott, having recieved
his fourth straight "random" assignment of a case wherein Coughlin is a criminal defendant in CR12-2025)
24
Coughlins October 11th, 2011 Motion for Continuance, at page 2, and again, at page 38, provides yet another
instance wherein he pled the fact that his was a commercial tenancy within the summary eviction "Trial" in RJC Rev201125
001708, which runs expressly counter to Richard G. Hill, Esq.'s sworn contention that Coughlin failed to so plead a
26
commercial tenancy during his testimony at both the criminal trespass prosecution of Coughlin at Trial on 6/18/12 and at
Coughlin's formal disciplinary hearing on 11/14/12:
27
28
Page 2 reads: "POINTS AND AUTHORITIES FACTS 1. Merliss is the owner of the real property
located at 121 River Rock Street, Reno, Nevada (the "PROPERTY") and he hired Casey Baker, Esq. of
the law offices of Richard G. Hill. 2. On October 4th, 2011 Merliss caused, or allowed, the electricity to
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
be shut off at the 121 River Rock St. Reno, NV 89501 home law office that Coughlin rents from
Merliss. Coughlin was provided absolutely no notice from either Merliss or NVEnergy..3. NVEneregy
left a placard on the door of Coughlin's home law office stating If gas service has been terminated an
adult 18 years of age or older must be present at the time or reconnection. When electric service is
restored, it is the customer's responsibility to insure that the structure's main breaker is set to allow the
current to enter the facility."
Page 3 reads: "4 The VERY SAME DAY, approximately three hours after having the electricity shut off
out of the blue, with absolutely no regard to whether someone inside was depending upon a life support
apparatus that required electricity, whether hundreds of dollars of food would spoil, whether pets or
animals depending upon electricity would die, etc., counsel Baker showed up to the residence with a
videographer/assistant in tow. The assistant drove a new looking Mercedes Kompressor convertible,
while Baker found it necessary to take his own vehicle to Coughlin's residence, showing up in something
like a three ton F350, gas hogging monster truck, just an enormous vehicle. Coughlin showed up at the
2pm time designated for this bad faith inspection and found Baker and his assistant at the gate of the
fenced in home law office. Coughlin rolled down the window of the 1996 Honda Accord he was driving
and informed the two that he would be with them in just a minute and proceeded to park his car. Baker
and his assistants refused to wait for Coughlin to finish parking his car, choosing to enter the gate to the
property, apparently in a gigantic hurry to finish their task and proceed to bill just as many hours as they
possibly could. Without identifying themselves, Baker and his assistant walked onto the property and,
instead of going to the front door, began to walk around the side of the house, making themselves rather
at home."
Page 4 reads: "Coughlin made it exceedingly clear to Baker and his assistant that there was nothing
stopping them from doing their inspection, however, they got in their luxury gas hog vehicles and drove
off, leaving Coughlin to deal with the mess made by the unlawful, unnoticed shut off of essential
services to his home law office. NVEnergy demands a copy of the lease from renters in situations like
this, where the landlord has the utility bill in the landlord's name, has the power shut off on the renter,
and maintains that NV Energy is allowed to deny essential services to the renter and or make the renter a
party to the contract between NV Energy and the landlord, whose name the bill is in...8. More time is
necessary to conduct investigation and discovery to reveal the extent of damages caused by this
unlawful, unnoticed interruption of essential services, with respect to the damages caused to thin skull
plaintiff Coughlin and his home law office."
Page 5 reads: "On several occasions Merliss replied to Coughlin's written habitability requests stating
that he was globe trotting and that Coughlin should make like a pro bono property manager for Merliss
and get a couple estimates and deduct the cheapest one from the rent. Merliss dismissed Coughlin's
written complaints and demands regarding the over $1,000 of property damage done to the green wool
faux grass carpet Coughlin purchased and installed over the dirt law at the home lawn office. Merliss
hired and authorized, with the assistance of Dickson Realty Realtor Darlene Sharpe, Green Action Lawn
Service to work on the property, whereupon Green Action Law Service tore up the green carpet faux
lawn belonging to Coughlin and placed it in the street or sidewalk aside the property and refused to
return it to its rightful place, creating an emergency situation for Coughlin whereby allowing Coughlin's
personal property to so remain in the street would create an undue risk of theft of Coughlin's property
and or damage to it."
Page 6 reads: "Coughlin has submitted to Merliss and this court voluminous transcripts of emails
between Coughlin and Merliss ranging in time over the year and a half wherein Coughlin has been a
tenant, where Coughlin clearly establishes a practice of being exceedingly considerate to Merliss of any
and all costs associated with maintaining the property or curing defects (reference the gross weeks and
weeks of yellow urine stenched sludge pooling behind the toilet and Coughlin's verbose emails and
research provided to Merliss and the attempts to avoid any unnecessary expense to Merliss in identifying
the cause of that problem, which ultimately proved to be a faulty wax ring). Merliss is apparently so well
off, or lacking in organization, that he agreed to pay Coughlin $350 for taking care of the weeds in
June 2011, while simultaneously Merliss also agreed to hire a crew of 5 from Green Action Lawn
Service, in addition to apparently compensating Realtor Darlene Sharpe for her coordination of the
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
effort, to do the exact same work for which Merliss agreed to pay Coughlin, taking care of the weeds.
It is exceedingly frustrating to Coughlin to be a tenant whose basic requests are not being answered
while the landlord manages to pay twice for the same thing, such as having two different agreements to
take care of the weeds while a broken window with exposed jagged pieces of glass held to the window
frame by caulk sits for months as a hazard in Coughlin's home law office. The Lease Agreement
involved here clearly spells out that Merliss is to be liable for intentional or negligent damage he causes
to Coughlin's property."
Page 7: "11. All the materials and arguments contained in Coughlin's original tenant's Answer and
Motion for Sanctions and Motion for Clarification are hereby incorporated by reference and apply to any
and all actions brought by Merliss or his counsel, whether Summary in nature or not, whether No Cause
in nature or not, whether Unlawful Detainer themed or not.
12. Merliss entered into a Lease Agreement with Coughlin, attached here as Exhibit 1, along with
Exhibit 2 (a collection of photographs supporting Coughlin's contentions and a cd with a video of Green
Action Lawn Service's manager explaining that he would not have his men return Coughlin's property to
its rightful place and undue the damage they did, and that Darlene Sharpe had, essentially, told them that
was okay to do), and Exhibit 3 an email from Darlene Sharpe, a Dickson Realty Realtor and individual
acting as a sort of property manager and or rental agreement broker for Merliss. Exhibit 4 is the door
placard left by NV Energy when they, without providing Coughlin notice, turned off the electricity to
Coughlin's home law office. An expensive mountain bike worth approximately $700 was stolen from
Coughlin's back yard on the day NV Energy came onto the property Coughlin rents and went into the
back yard and turned off the power. 13. The Lease Agreement applicable to this action and entered into
in writing and signed by both Merliss and Coughlin states, in subsection 23. that Damages to the
Premises. IF the premises are change by fire or from any other cause which renders the premises
untenable...should this right be exercised by either Owner or Tenant, then rent for the current month will
be prorated between the parties as of the date the damage occurred...IF this agreement is not terminated,
the Owner will promptly repair the premises and there will be a proportionate reduction of rent until the
premises are 7 MOTION FOR CONTINUANCE, ETC. repaired and ready for Tenant's Occupancy. The
proportionate reduction will be based on the extent which repairs interfered with tenant's reasonable use
of the premises."
Page 8: "15. Subsection 28 in the Lease Agreement LIABILITY states that Management shall not be
liable for any damage or injury to Resident, or any other person, or to any property, occurring on the
premises or any part thereof, or in common areas thereof, unless such liability is based on the negligent
acts or omission of Management, his agent, or employee, ... (emphasis added)."
Page 38 reads: "Baker
submitted some bills, with several redactions, in an attempt to

support his motion for sanctions. Baker did not however, submit any proof that Merliss
actually paid the bill or otherwise obligated himself to pay it. Baker should be ordered
to resubmit this billing statements without the redactions. Baker and his assistant showed up
to Coughlin's law office to conduct an inspection, yet refused to indicate what the
inspection was for or what it entailed or explain why it took a licensed attorney,
apparently billing out at $225 an hour, with an assistant/videographer in tow to perform
the inspection or why someone else, someone cheaper, could not have performed the
inspection."
25
While it hardly seems fair for Chair Echeverria's 12/14/12 Order seeking to disbar Couglin to rely upon matters testified to by
NVB Judge Beesley where Coughlin was only provided constructive notice of the SBN's Supplemental Designation of
Witnesses and Summary of Evidence the day before the 11/14/12 Hearing (so much for the whole notice and opportunity to
27
be heard part of due process, huh?), to the extent necessary, a review of each and every filing by Coughlin before Judge
Beesley actually reveals, when considering all the misconduct of other's that Coughlin was forced to overcome, that Coughlin
28
did an amazing job for his client, Robert Keller:
26
RECONSIDERATION
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
36 Filed: 11/23/2011 Entered: 11/28/2011 Opposition Docket Text: Opposition with Certificate of Service Filed by ZACH
COUGHLIN on behalf of ROBERT KELLER (Related document(s)33 Motion to File Amended Complaint filed by
Plaintiff CADLE CO.) (glw)
43 Filed: 01/03/2012 Entered: 01/06/2012 Answer to Amended Complaint Docket Text: Answer to Amended Complaint ;
with certificate of service (Related Doc # 42) Filed by ZACH COUGHLIN on behalf of ROBERT KELLER (cly)
48 Filed & Entered: 03/14/2012 Motion to Extend Time
Docket Text: Motion to Extend Time TO FILE AMENDED ANSWER AND COUNTERCLAIM TO AMENDED
COMPLAINT AND ASSOCIATED MOTIONS TO DISMISS AND DISCOVERY REQUESTS with Certificate of
Service Filed by ZACH COUGHLIN on behalf of ROBERT KELLER (COUGHLIN, ZACH)
52 Filed & Entered: 03/30/2012 Brief
Docket Text: Brief in Opposition to Notice of Default and Praecipe/Intent to take Default with Certificate of Service Filed
by ZACH COUGHLIN on behalf of SAMANTHA L. HALL, ROBERT KELLER (Related document(s)49 Notice of
Entry of Default filed by Plaintiff CADLE CO.) (Attachments: # (1) Affidavit Affidavit of Counsel Coughlin for Keller in
Support of Opposition# (2) Exhibit Exhibit 1 Regarding WCSO Eviction Procedures# (3) Exhibit Reno Municipal Court
Marshals and Judge Nash Holmes seize attorneys smart phone# (4) Exhibit Email to WCSO Haley regarding excusable
neglect prejudice to Keller's case# (5) 3 26 12 Fax to RMC# (6) Exhibit 2 24 20 fax to rmc regarding deficiency in record
on appeal# (7) Exhibit 11 TR 26800 NOTICE OF APPEAL AND MOTIONS 3 7 12 WITH EXHIBIT 1 ATTACHED)
(COUGHLIN, ZACH)
53 Filed & Entered: 04/10/2012 Motion to Dismiss Adversary Proceeding
Docket Text: Motion to Dismiss Adversary Proceeding with Certificate of Service Filed by ZACH COUGHLIN on behalf of
ROBERT KELLER (COUGHLIN, ZACH) Modified on 4/11/2012 for correct filing party (Wenszell, GL). 54 Filed & Entered:
04/17/2012 Answer to Complaint
Docket Text: Answer to Complaint with Certificate of Service (Related Doc # 33 Motion to File Amended
54 Filed & Entered: 04/17/2012 Counterclaim PACER Service Center Transaction Receipt 05/21/2012 11:56:49 PACER Login:
zc0156 Client Code: Description: History/Documents Search Criteria: 10-05104-gwz Type: History Docket Text: DisplayDktText
Billable Pages: 6 Cost: 0.60
Complaint Filed by MICHAEL O'ROURKE on behalf of CADLE CO), Counterclaim by SAMANTHA L. HALL, ROBERT KELLER against
CADLE CO Filed by ZACH COUGHLIN on behalf of ROBERT KELLER (COUGHLIN, ZACH) Modified on 4/18/2012 to relate to #33
(Marsh, DL). Modified on 4/18/2012 to correct party filers and to add with Certificate of Service (Marsh, DL).
Docket Text: Answer to Complaint with Certificate of Service (Related Doc # 33 Motion to File Amended Complaint Filed by
MICHAEL O'ROURKE on behalf of CADLE CO), Counterclaim by SAMANTHA L. HALL, ROBERT KELLER against CADLE CO Filed by
ZACH COUGHLIN on behalf of ROBERT KELLER (COUGHLIN, ZACH) Modified on 4/18/2012 to relate to #33 (Marsh, DL).
Modified on 4/18/2012 to correct party filers and to add with Certificate of Service (Marsh, DL).
22
23
24
25
26
27
Springgate can be heard violating NRS 7.085 himself as the 10:37 am mark during his closing argument on 3/17/09 in
the Joshi divorce Trial resultig in an Order of 4/10/09 by Judge Linda Gardner that WLS's Paul Elcano admits to firing Coughlin
over in his May :
http://www.youtube.com/watch?v=8Q2krmLg1fs "Attorney fired from Legal Aid for this, now State Bar of Nevada wants his
disbarred!"
Neither NNDB Chairman Susich nor Bar Counsel King, unlike Coughlin have been put through Second Judicial District
Court "Judge" Lori Matheus WCDR 10 hellish bootcamp ordeal (19 of 23 of Coughlin's eFlex filings in January 2012 were
rejected upon the regime change from Clerks of Court Conyers to Orduna Hastings.
28
RECONSIDERATION
1
2
conclusions
please set aside alter or amend to 12/14/12 FOFCOL and all other orders and or grant a new Trial.
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Dated this January 3rd, 2012:

__________________________
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RECONSIDERATION
PROOF OF SERVICE/CERTIFICATE OF MAILING
i zach coughlin placed this MOTION FOR NEW TRIAL; MOTION TO ALTER OR AMEND CHAIR ECHEVERRIA'S
ORDER OF 12/14/12; MOTION FOR RECONSIDERATION ERMISSION TO FILE BY FAX WAS
4
PREVIOUSLY PROVIDED ON SEPTEMBER 11TH, 2012 in the mail with postage, and or
transmitted a digital copy to all of those who have either expressly or implicitly agreed to service via
5 digital transmission (plus Pat "Salieri" King told me the SBN takes anything I file and provides a
stamped copy to all 5 member of the Panel immediately and that I could rely on that), in the mail out
6
for delivery /pickup today in accord with SCR 105(4) and the representations made to me by those
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with the authority to make them upon which I reasonably relied. and by having it personally delivered
to the SBN
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The undersigned hereby certifies that a true and correct copy of the foregoing Order was deposited in
the United States Mail at Reno, Nevada, postage fully pre-paid; thereon for certified and class mail
addressed to the following:
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DATED THIS 3rd of January, 2012:

____________
Zach Coughlin
Respondent
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RECONSIDERATION
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INDEX TO EXHBITS:
1. Hearing Exhibit 1: various relevant materials on a cd/dvd
contents of exhibit 1 also available at the following

link:
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http://sdrv.ms/Uv9LBq
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RECONSIDERATION
Index of file:///I:/
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012 wcso just stuchell letter of 11 6 12 0204 subpoena.pdf
0204 063341 26800 AMJUR ATTNYS SUM.pdf
0204 CHRONOLOGICAL INDEX OF DOCUMENTS 62337.pdf
0204 Coughlin Disciplinary Hearing File cut uith notations revised.pdf
0204 Coughlin Disciplinary Hearing File cut up winotations revised.pdf.pdf
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0204 due process denial fertig.pdf

0204 mh12-0032 Judge Breen Letter of Recommendation for Judge Linda
Gar54844 60302 cr12-0376.pdf
03018 to 03041 Judge Linda Gardner listed by SBN King as greivant in ng
nduct blog smaller ~1.pdf

0434 Grievance File Dorothy Nash Holmes 0204 red.pdf
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0434.pdf
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063341 SHEPP v. STATE 0204 THIEF CANNOT RECEIVED STOLPROPERTY

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FROM HIMSELF.pdf
1 12 12 Hill's TPO Application and Schroeder's Order rc2012-000018.pdf
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1 12 12 rpd police report 12 cr 00696 sifre leedy look nash young kanda
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bradshaw 0204 065630.pdf
1 14 12 Richard Hill Stalking Protection Order.pdf
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1 2 12 0204 065630 067980 emails from mcovington@washoecounty.us
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young.pdf
1 2 12 0204 email from cjenkins@ethics.nv.gov regarding wcda wcsjc ethical
133 KB
violations.pdf
1 2 12 wcll westlaw printouts on bifurcating chargesw and answer theretied
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etc tagged tagged.pdf
10 27 11 rjc 1708 email tuttle @washoecounty.us 0204.pdf
125 KB
10 27 11 to 11 2 11 Motion to Stay CV11-03051 03126 1708 emails to efleee
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26405 60331 purdee.pdf
10 28 09 Petition for Writ of Mandate Couglin v Second Judicial Distric RPD
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WLS 26405 2680~1.pdf
10 4 12 ORDER STRIKING document filed in error on 10 2 12 and returning
4186 KB
00696 26405 with ex~1.pdf
11 13 12 0204 exhibit 3 with cover page Coughlin Disciplinary e from SBN big
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box bz.pdf
11 13 12 exhibit 2 with bates numbers 0204 emergency ex parte.pdf
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11 13 12 wcda wcso watts vial supboena correspondence 441pm 0204.pdf
11 19 12 61383 0204 Notice of Improper Dismissal of Appeal, Motion for to
Reinstate 12-36656.pdf
11 21 12 Notice of Irregularities 063341 with ex 1 started revised.pdf
11 28 12 62106 mandamus couglin v sbn huge 400 page 12-37502.pdf
11 3 11 Stancils quick and sneaky Notice of Hearing for 11 7 11 ring stamped
scrawled.pdf
11 30 12 stamped but dated 11 26 12 0204 notice of hill malsance 11 26 12

Copy.pdf
11 7 11 0203 WCSO Machen Affidavit of personal service then 2 7 12 Stucely
posted 26405 0204.pdf

11 7 12 for bony and christensen 063341 0204.pdf
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11 7 12 subpoenas 063341 gricela alvarez and hassett proof service or
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11 8 12 0204 WELL WOULD YOU WITH ATTACHED EX 1 TRANSCRIPTS
stamped.pdf
11 8 12 310 page ex 1 0204 well would you fit to .pdf
11 9 12 ex 1 to 0204 etc part 1.pdf
11 9 12 stamped 60302 wls garin notice of lacf access roa 12-35541.pdf
12 10 12 065630 final affidavit or declaration of coughlin 24 pages.pdf
12 10 12 065630 final motion for recusal conflict continuance tec.pdf
file:///I:/
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12_11_11_final_motion_for_new_trial_city_of_reno_v_coughlin__RMC_11_CR_ 14301 KB
nd tagged jbig2 lossy.pdf
1995 Reno High Red and Blue National Merit Finalist article Coughlin 0204
5926 KB
063341.pdf
2 21 12 0204 email from mkandaras@da.washoecounty.us re rjc locking doo1
83 KB
065630 067980 26800.pdf
2 24 12 57507 Order of Supsension for Stephen Harris, Esq. 12-05911.pdf
196 KB
2 7 12 0204 065630 26405 email from lstuchell@washoecounty.su re deputy
70 KB
ally served affidavit.pdf
2 9 12 Linda Howden's note about vacating hearing upon written decision4
39 KB
CR11-2064-2697247~1.pdf
2009 to 12 24 12 0204 emails to @nvbar.org tagged.pdf
5275 KB
2009 to 12 24 12 0204 emails to @nvbar.org.pdf
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20130103_043630 indigent Coughlin's living work space in a fifth wheel ith no
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12 10 12 ex 1 065630 final version with bates numbers.pdf

12 18 12 599 0204 mendoza attachment wcpd Leslie applicat against
Coughlin TPO.pdf
12 18 12 email wcda mendoze watts leslie tpo rjc 067980 065630 0204 wit
ation rs reduced size.pdf
12 18 12 email wcda mendoze watts leslie tpo rjc 067980 065630 0204 w full
tpo application.pdf
12 20 12 SBN TPO App stamped 607 TPO against Coughlin.pdf
12 4 12 0204 email to @nvbar.org reduced size.pdf
12-26942 Coughlin v Merliss 60331 Motion to Proceed IFP and proposed Opl
of summary eviction.pdf
20130103_044514 what the rjc and rmc have indicated to Coughlin are cer
rings relevant to n~1.jpg
20130103_044523 what the rjc and rmc have indicated to Coughlin are cer
rings relevant to n~1.jpg
20130103_044532 what the rjc and rmc have indicated to Coughlin are ce
arings relevant to ~1.jpg
20130103_044541 certified audio transcripts from RMC and RJC.jpg
20130103_044547.jpg
20130103_044554 certified audio transcripts from RMC and RJC and SBN co
resented to NNDB Sc~1.jpg
26800 3 13 158pm 3 13 1238pm 3 13 216pm 3 3012 nash grievance of 3 121
12 orders gardn~1.pdf
3 16 12 0204 email to @nvbar.org character and fitness.pdf
3 19 12 0204 11-05077 - filing 14 Motion to Withdrwa.pdf
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3 19 12 0204 11-05078 - filing 15 Taitano Motion for Extension of Time o MSJ
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Motion Withdraw.pdf
3 27 12 0204 01955 MOTION FOR NEW TRIAL, OR PLED IN THE ALTERNA
376 KB
E, MOTION TO ALTER OR.pdf
3 27 12 no numbers 0204 03628 Order Denying Hill's Motionr Order To Show
452 KB
Cause.pdf
3 8 12 Coughlin Trial Setting 11 cr 26405 april 10 8 am trial loomis ga50630
772 KB
26800 0032 0376.pdf
3 OF 5 RECORD ON APPEAL WLS 60302.pdf
19439 KB
4 11 12 RMC Marshal Coppa Affidavit concerning 3 23 12 pajamas allegatibit
222 KB
7 in 60975 tiffed.pdf
4 17 12 letter by Lake's Crossing's Bill Davis Sally Farmer attached to30 0204
444 KB
Coughlin, Z~1.pdf
4 19 12 0204 RE Mr. King's assertion in his 3 16 12 letter.pdf
53 KB
4 19 12 CR12-0376 transcript 4 pages per 650630 26405 03620331 1708
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26800 00696.pdf
4 25 12 minutes in CR12-0376 dogan young elliot competency evaluation r
11 KB
065630 rdr2011-063341.pdf
5 1 09 attachment to Elcano email 0204 60302rCoughlin2ndDraft _1_.pdf
10 KB
5 14 12 and 7 31 12 0204 RX history email to @nvbar.org with attachmentch
Coughlin rx hist~1.pdf
5 18 12 0376 certified copy of order remanding to justice court 0204 CR mhc
dogan rmc 2640~1.pdf
5 22 12 0204 10-52639 - filing 38 Supplemental to Defendant's Oppositio
omatic Stay Renew F~1.pdf
5 22 12 Keller's Oppoisition to Dale's Motion to LIft Automatic Stay anw
foreign judgment ~1.pdf
5 31 12 to 10 11 12 0204 emails to jrains@washoecounty.us5630 063341 0032
0376.htm
5 4 09 0204 60302 email and attached letter from WLS Elcano.pdf
54844 COUGHLIN VS. DIST. CT. and Linda Gardner 0204 0435 26405.pdf
6 11 07 washoe county commissioner's board rjc applications for justicetel
clifton nash c~1.pdf
6 18 12 60975 0204 117 INDEX TO EXHIBITS.pdf
6 18 12 60976 JUST 10 PAGES with Index SCR 117 Petition by NNDB Susic
204 NO NUMBERS TIFFED.pdf
6 9 12 0204 10-05104 - filing 68 Supplemental Mot for Summary
Judgment.pdf
60302 roa vol 3 Scanned0[1].pdf
7 10 07 letters thing Establishment of process for interview and select 26800
063341 2640~1.pdf
7 5 11 in re mirch EMERGENCY 0204 11-19704.pdf
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8 23 12 INDEX TO EXHIBITS FOR COMPLAINT 0204.pdf

AMJUR ATTNYS SUM.pdf
AUTHENTICATING VIDEO EVIDENCE WITHOUT WAIVING FIFTH
AMENDMENT AND HEARSPORTS OFFICER TESTI~1.pdf
CR11-2064_2617055.pdf
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WLS).pdf
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Elliott, Steven P. 02.09.10 0204 0376 26800.pdf
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Index for emails between Coughlin and @nvbar.org 0204.pdf
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Index of emails to Coughlin from @nvbar.org addresses 0204.pdf
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MHC cr12-0376 NNAMHS program materials 650630 26405 26800.pdf
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ORDER RELEASING PROPERTY 11 TR 26800 3 30 12 nash rmc rjc rpd wcso
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numbering - Copy.pdf
first part of file from puentes 11 cr 26405 1708628 0032 0376 063341.pdf
objection to masters recommendation with 3 exhibits.pdf
pictures of toilet sludge Merliss rev2011-001708.pdf
rcr11-063341 PRE TRIAL MOTION WITH BATE STAMPED EXHIBITS.pdf
rpd carter police report 11 cr 26405 puentes loomis 1708 merliss rmc g30
063341 rpd lopez~1.pdf
scr part iii misconduct scr 99 to scr 123 sbn g clark peters - Copy.pdf
wls dismissal letter citing Judge Linda Gardner's April 2009 Order as s6405
1708 60302 26800.pdf
wls gardner emails siragusa and non profit property tax emacollection 0204
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CASE NUMBER: ng12-0204 ng-0435 ng-0434
STATE BAR OF NEVADA

NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,

PETITIONER
V.
10
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
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11
)
)
) ng12-0204 ng-0435 ng-0434
)
)
)
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Emergency Ex Parte Motion to Dismiss or Quash or Otherwise Challenge Sufficiency of Service

and of Process, of Complaint and Notice of Intent to Take Default and DoWSoE; and
Preserving for Appeal Objection to All other Due Process Violations; and UNDER
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PROTEST...RESPONSE TO COMPLAINT
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hole lotta summary evictions and summary contempts goin' round these days in Northen Nevada legal
circles, at least (even "summary criminal contempts", truly a rare species). King of brings to mind
"summary executions"...Libya of yesteryear. Pol Pot...okay, that's takign it do far...but "summarily
dismissed" Appellant truly appreciates this Court's recognition of its own 6/7/12 Order Temporarily
Suspending Coughlin from the practice of law. This Court therein demonstrated the high ideals it
adheres to, recognizing (where many other local prosecutors, Courts, and court appointed defenders
did not) that it is not permissible to try to have it both ways with respect to matters of that sort
whether we want is talking about and ordered temporarily suspending one's law license pursuant to a
SCR 111(6) Petition or an order for competency evaluation in light of NRS 178.405 and NRS 5.010.
However, Garin's Responden'ts Brief (Joseph Garin is on the SBN's "Ethics"
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Committee...though the overly blurry exhibits he stands behind purporting to accurately represent the
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- 1/88 Emergency Ex Parte Motion to Dismiss or Quash or Otherwise Challenge Sufficiency of Service and of Process, of
Complaint and Notice of Intent to Take Default and DoWSoE; and Preserving for Appeal Objection to All other Due
Process Violations; and UNDER PROTEST...RESPONSE TO COMPLAINT
process and or service his Client's were served, on court approved forms calling only for a nrs 53.045
declaration suggest some inquiry is needed to verify just how concerned with Ethics Joey Detroit
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really is) in S. Ct. Case 60302 itself presents a great microcosm of the due process issues the SBN is
tryin to waylay Coughlin with here and how untoward would it be for Garin, WLS and the SBN to do
so given 60302? Plus the SBN/Panel are jamming him up with a 11/14/12 "combo hearing" that
violates every aspect of scr 105(2)(c) and this courts 6/7/12 order ("sole purpose" proceeding
singular, scr 111(7)-(8)....elcano mcgeorge '78. rmc nash HOlmes greivanc ng12-0435 mcgeorge '77
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(see 60838 and 61426 and this matter 60302).

At the richard G. hill and casey baker triple traffic citation trial in 11 tr 26800, the next day,
judge nash holmes entered her "Order Finding the Defendant in Contempt of Court and Imposing
Sanctions" on 2/28/12, wherein, amongst other things, Judge Holmes writes, on page 2 of her Order:
"The court had the defenant sworn at the beginning of the trial stating that the court has found that
most self-represented defendants tend to testify a great dal as they cross-examine opposing witnesses
so the defendant would be under oath from the start, too". One, that is ridiculous. Two, that is not as
Coughlin understood it to be (rather, Coughlin understood that if he chose to waive his Fifth
Amendment Right and Testify in his case in chief, then he would be under Oath when presenting any
such testimony. But, regardless, Coughlin did not lie, regardless of the reckless, reprehensible,
troubling allegations that Judge Nash Holmes makes so easily later in her Order of 2/28/12 (which
she doesn't bother to bolster with anything more than unattributed hearsay (especially consdering the
second bite at the apple, so to speak, she took in issuin another Order attemting to transmogrify "a
simple traffic citation trial" into a full blown Disciplinary Hearing (albeit a summary one, natch).
Further, don't recall ever hearing 'bout a RMC judge putting a City of Reno prosecutor under oath
from the start, and Pamela Roberts, Christopher Hazlett-Stevens, Jill Drake, and Allison Ormaas sure
seem to do an awful lot of testifying themselves as they cross examing witnesses (or, for that matter,
as they examine their own witnesses on direct. often asserting facts not in evidence, though it is
more typical for them to do that in their closing arguments).
"Nor does the trial judge's speculation that Appellant might use his closing argument to
present unsworn testimony,representation. First, although the majority opinion describes the trial
court's speculation as a legitimate concern, I would observe that the record suggests otherwise. From
all indications, Appellant committed these horrible crimes. During the court proceedings, however,
Appellant consistently maintained proper decorum and, even when he vehemently disagreed with his
appointed counsel, demonstrated that he was capable of calmly and rationally relating his concerns to
the trial court. Further, Appellant himself informed the trial court I know what I'm not supposed to
talk about anything other than evidence that came up in this trial. So it's not like I'm trying to testify
[.] In addition, both of Appellant's appointed attorneys indicated that they would be willing to work
with Appellant to make sure no objectionable matter comes into the closing argument. In any event,
however, I would observe that, if an assertion that the defendant is going to do something wrong
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were a basis for denying a defendant's right of self-representation, virtually no defendant would ever
be permitted to participate personally in his or her defense. Accordingly, the law does not recognize
the likelihood of a defendant's incompetent self-representation as a basis for denying the right When
delivering the closing argument, however, Appellant would be held to the same standards as a
licensed attorney, the Commonwealth would have an opportunity to object to any improper argument
or deviations from proper procedure, and the trial court would have been able to rule upon any such
objections and grant any relief that it deemed appropriate. FN20 FN18. Soto, 139 S.W.3d at 857.
FN19. See Faretta, 422 U.S. at 834, 95 S.Ct. at 2540, 45 L.Ed.2d at 581 (It is undeniable that in most
criminal prosecutions defendants could better defend with counsel's guidance than by their own
unskilled efforts.... And, although he may conduct his own defense ultimately to his own detriment,
his choice must be honored out of that respect for the individual which is the lifeblood of the law.);
Crawford v. Commonwealth, Ky., 824 S.W.2d 847, 849 (1992) (A defendant has an absolute right to
waive counsel and to represent himself and no determination as to the effectiveness of such
representation need be made.); Wake, 514 S.W.2d at 695 (No one contends that an accused must be
capable of adequately representing himself in order to make a valid waiver of counsel.). FN20. See
Faretta, 422 U.S. at 834 n. 46, 95 S.Ct. at 2541 n. 46, 45 L.Ed.2d at 581 n. 46 ([T]he trial judge may
terminate self-representation by a defendant who deliberately engages in serious and obstructionist
misconduct.). Ky.,2004. Soto v. Com. 139 S.W.3d 827.
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Judge Nash goes on to write "the court finds that defendant's contemptuous conduct consisted
of his" and amongst a laundry list of synonyms for "difficult" Judge Nash Holmes throws in a
"deceitful" blast. then on page 3 of her ORder amongst a lot of things don't have time to address now
she writes "9) defendant's lying to the court in response to direct questions posed by the court with
regard to his recording the proceedings". Huh? Please do explain Judge Nash Holmes. And please
do follow the affidavit requirement in NRS 22.010 to the extent your Order purports to rely upon
some unattributed hearsay from one of your Marshals about something in a restroom (and please do
try to get the order of events correct, ie, the one restroom break came BEFORE the only point at
which Judge Holmes went into her sua sponte interrogation of self representer Coughlin about
recording and or "recording devices", which Judge Nash Holmes launched into IMMEDIATELY
following the one restroom break... and it sure would have been intersting to hear anything ORmaas
said ex parte to the Court during that break, even if itwas ferried to the court by a Marshal.
REgardless, Judge Holmes play by play rendered two weeks later is one of the most disturbing,
misrepresentation filled discourses one could EVER come across ever, inside or outside of the law,
considering her position and the manner in which she leverages it. good lord what the world does not
need right now is a 27 year old Ct Marshal with tatoos exposed all over his short sleeved ensconced
arms, nostrils flaring angrily on a daily basis at any defendant in any way questioning being ordered
to sign things without reading them, that Marshal making $85,000 a year plus $50 in benefits being
told he is the eyes and ears of the court outside the courtroom and that his attestations to the court,
however murky, negligently made, not in an affidavit as required under NRS for those allegations
based upon conduct not in the court's immediate presence, or outright spurious, will necessarily result
in attorney's losing their licenses on a "summary criminal contempt basis". Judge Nash Holmes is
supposed to realize that, right? Right?
Judge Nash Holmes concludes her Order with "The court finds that the defendant's actions
were intentional and done in utter disregard and contempt for the court, and in the presence of the
court, for the purposes of disrupting and delaying the proceedings and dishonoring the rule of law
and this court, and constitute the misdemeanor of criminal contempt, a violation of NRS
2
22.010. Good cause appearing therefore, the following sanctions are imposed: It is ordered,
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pursuant to NRS 22.100, that the defendant be incarcerated at the Washoe County Regional
Detention Facility for the term of five (5) days, from the time he was taken into custody on this
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court's order on February 27, 2012, and that sentence shall not be reduced for any reason."
1
Huh, that's the strangest thing...
NRS 22.100 Penalty for contempt.
1. Upon the answer and evidence taken, the court or judge or jury, as the case may be, shall
determine whether the person proceeded against is guilty of the contempt charged.
2. Except as otherwise provided in NRS 22.110, if a person is found guilty of contempt, a fine may be
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imposed on the person not exceeding $500 or the person may be imprisoned not exceeding 25 days,
or both.
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Huh? That's weird. Wasn't no "answer and evidence taken" incident to Coughlin's 5 day
summary incarceration in ng12-0434 (frankly, its appalling the extent to which Judge Nash Holmes
has gerrymandered some new fangled "summary criminal contempt" hybrid out of various summary
and plenary and civil and criminal statutes to suit her agende her, and, arguably that of her RMC
cohorts). Its a lot like Judge L. Gardner, in ng12-0435, along with John Springsnake, er, John
Springgate, Esq. (just kidding, Jonny and I go have that kille mole' at El Adobe together whenever we
get a chance....plus John's got that wicked fencing technique, so I don't want no problems)...but, yeah,
the april 2009 sanction order...supposedly based on nrs 7.085 (but that invokes NRCP 11, and that
requires a 21 day safe harbor filing ready sanctions motion...not feet stamping and mean mugging
five minutes before trial if you don't cave to some illusory settlement offer...and certainly not some
verbal Motion for Sanctions made in closing arguments by Springgate....Judge Gardner had to go
NRs 22.030 but she didn't wanna (probably because she knew Coughlin was way too in control of
what he was doing to give her anything to hang it on, as there was not "derogation requiring
immediate smack down to preserve the Court's street cred and rep" there was no "obstruction", etc.
Judge Gardner found it offputting that Coughlin refused to coerce his client into letting her ex out of
the financial arrangment he himself had set up and enjoyed for so long. The credits cards were his,
sole signatory, she didn't get to nitpick the statements, didn't get to buy herself a mocha with them,
nothing. there is a price to that "power and control" (DV literature "Duluth Model" etc. etc.) and that
price is that that ALR article detailing the majority viewpoint in the law that domestic duties may not
be set off by third party debt obligations provides more than enough basis for the position Coughlin
took on his clients behalf at trial. Further, Judge L. Gardners own pretrial Order required Springgate
to bind, have marked, and index in a tidy package for Coughlin AT TRIAL those "more than 10
exhibits" that he put into evidence (not whine about how he had provided them previously in
discovery....the rules are the thing that gets you everytime...every lawyer will tell you that...and Judge
Gardner's Pre-Trial Order was the law of the case, yet the Judge sanctions Coughlin for asserting
it....and is let making mincing criticisms of Coughlin failure to cite chapter and verse in support of his
whole "am i supposed to be rifling through my papers looking for it like I am John Springgate's
assistant?". Seriously, John would have me picking up his dry cleaning if I let him. He aint my
client. Ms. Joshi was. thats real talk. you need to review the santiago v. vaxevanis TPO case to
understand the L. Gardner and WLS, Eclano STernlicht thing mor fully. See it somewher in Exhibit
1.`
Judge Nash Holmes, in effecting the rarest of "contempt" species (even rarer where levied against an
4
attorney representing a "client" even if in 11 tr 26800 then attorney Coughlin's self representation
may not fit so easily into such a designation seems to be finding a way to get around the fact that lots
5 of the stuff she vaguely cites to in the 2/28/12 ORder (you know, the bold face type-ish, gut punch,
chop block, cheapshot "findings by clear and conv allegations that Coughlin
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Its a real tooled up Order Finding Defendant in Contempt and Imposing Sanctiosn by Judge
Holmes if you look close enough. You'll not a real careful steering away from phrases from Cooke
and the line of cases detailing how incredibly narrow an exception and application the law will permit
for "summary criminal contempt"...Judge Holmes Order will not contain the buzz phrases necessary
to support a "summary criminal contempt" finding....like "immediate presence" or "every element
under watchful eye of the Judge" or "the use of the summary contempt power is proper only for
"charges of misconduct, in open court, in the presence of the judge, which disturbs the court's
business, where all of the essential elements of the misconduct are under the eye of the court,
are actually observed by the court, and where immediate punishment is essential to prevent
`demoralization of the court's authority' before the public." Pounders v. Watson,521 U.S. 982,
988, 117 S.Ct. 2359, 138 L.Ed.2d 976 (1977) (per curiam) (quoting In re Oliver,333 U.S. 257,
275, 68 S.Ct. 499, 92 L.Ed. 682 (1948)).
Rather than mentioning "immediate presence" Judge Holmes Order's reads "the court
held the defendant in criminal contempt of court for his behavior and activities committed in
the direct presence of this court during the trial"...
Curiously, Judge Nash supports her "summary criminal contempt" Order by mentioning a
non-summary contempt statutory section, NRS 22.010, then going onto to, apparently, legistlate from
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the bench a little and classify NRS 22.010 as "criminal contempt" despite the fact that nrs 22.010 is
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not a criminal statute.
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NRS 22.030 Summary punishment of contempt committed in immediate view and presence of
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1. If a contempt is committed in the immediate view and presence of the court or judge at chambers, the contempt may
be punished summarily. If the court or judge summarily punishes a person for a contempt pursuant to this subsection,
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the court or judge shall enter an order that:
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(a) Recites the facts constituting the contempt in the immediate view and presence of the court or judge;
(c) Prescribes the punishment for the contempt.
2. If a contempt is not committed in the immediate view and presence of the court or judge at chambers, an affidavit must
be presented to the court or judge of the facts constituting the contempt, or a statement of the facts by the masters or
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arbitrators.
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3. Except as otherwise provided in this subsection, if a contempt is not committed in the immediate view and presence of
the court, the judge of the court in whose contempt the person is alleged to be shall not preside at the trial of the contempt
over the objection of the person. The provisions of this subsection do not apply in:
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(a) Any case where a final judgment or decree of the court is drawn in question and such judgment or decree was entered
in such court by a predecessor judge thereof 10 years or more preceding the bringing of contempt proceedings for the
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violation of the judgment or decree.
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(b) Any proceeding described in subsection 1 of NRS 3.223, whether or not a family court has been
established in the judicial district.
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NRS 22.010 Acts or omissions constituting contempts. The following acts or omissions shall be
deemed contempts:
1. Disorderly, contemptuous or insolent behavior toward the judge while the judge is holding court, or engaged in judicial
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duties at chambers, or toward masters or arbitrators while sitting on a reference or arbitration, or other judicial proceeding.
2. A breach of the peace, boisterous conduct or violent disturbance in the presence of the court, or in its immediate
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vicinity, tending to interrupt the due course of the trial or other judicial proceeding.
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3. Disobedience or resistance to any lawful writ, order, rule or process issued by the court or judge at chambers.
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4. Disobedience of a subpoena duly served, or refusing to be sworn or answer as a witness.
5. Rescuing any person or property in the custody of an officer by virtue of an order or process of such court or judge at
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chambers.
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6. Disobedience of the order or direction of the court made pending the trial of an action, in speaking to or in the presence
of a juror concerning an action in which the juror has been impaneled to determine, or in any manner approaching or
interfering with such juror with the intent to influence the verdict.
7. Abusing the process or proceedings of the court or falsely pretending to act under the authority of an order or process of
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the court.
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One is kind of left wondering: why didn't Judge Nash Holmes just use the summary
contempt statute that Judge Howard cited to (NRS 22.030) incident to his sentencing Coughlin,
staring right then (no stay for arranging to avoid prejudice to Coughlin's clients from Judge Howard,
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no way, Jose...nor from Judge Ellion on April 19th, 2012 when he put Couglin in jail for 8 days over
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a manufactured dispute over the terms of a Competency Evaluation (Judge Elliot didn't think avoiding
prejudice to Coughlin's client's affairs was important enough to grant even the slightest stay...some
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might say these Judges wanted to wreck Coughlin's career as good an awful as possible, and weren't
20 afraid to use Coughlin's client's interests in the process to do it.
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Oh, may it is because of that inconvenient stuff in NRS 22.030 about how someone gotta sign
an Affidavit if
This bit about it not being Coughlin's fault he didn't know Judge Nash Holmes had via her
2/28/12 Order characterized the "contempt" to be the "misdemeanor of criminal contempt" sort of
"contempt" means Coughlin arguably did not violate the USPTO rule related to reporting "within 30
days" any of a the type required by 11.25. But, within 30 days of finally getting a copy of that
2/28/12 "Finding of Contempt and Order Imposing Sanctions" of Judge Holmes (Coughlin only first
became aware such a written Order existed upon receiving the SCR 117 Disability Petition the SBN
has tried to force on Coughlin...Coughlin is fine, he is not disabled. He is runnin' it. So, "within 30
days" of finally getting that Order, Coughlin reported to the USPTO, and the same can arguably be
said of reporting this Court's 6/7/12 temporary suspension. The only thing is that Coughlin was in
jail from July 3rd, 2012 to July 21, 2012 on the ridiculous and since dropped by the City of Reno July
3rd, 2012 "disturbing the peace" charge...so arguably a tolling of 17 days or so should be subtracted
from an analyses of whether Coughlin timely reported.
It was only upon finding the 2/28/12 ORder attached to the SCR 117 Petition in 60975 (which
is a spurious negligent document in its own right) that Coughlin was apprised of the fact that Judge
Holmes had put the summary contempt Order in writing. Coughlin notified the United States Patent
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and Trademark Office (USPTO wherein Coughlin is license as a Patent Attorney as of this date, or at
5 least as an agent to whatever extent Coughlin's one state law license is suspended pursuant to this
Court's 6/7/12 Order in 60838).
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For a patent attorney agent like Coughlin, there are di grounds for discipline by the USPTO:
(i) conviction of a serious crime,16 (ii) discipline on ethical grounds by another jurisdiction or
disciplinary disqualification from participating in or appearing before any Federal program or
agency,17 (16 37 C.F.R. 11.25 prescribes procedures for interim suspension and discipline based
upon conviction of a serious crime or conduct inovlving moral turpitude or conviction or a criminal
offense involving moral turpitude, dishonesty, or breach of trust.( for examples, see: D2006-20,
D2007-03, D2008-01, D2008-12, D2008-23, D2009-01, D2009-05, D2009-14 and D2009-42 in the
OED Reading Room at http://des.USPTO.gov/Foia/OEDReadingRoom.jsp. These are only a few
examples. There are more examples in 2010 and 2011 time period. These can be viewed in the
aforementioned OED Reading Room website.) 17 37 C.F.R. 11.24 prescribes procedures for
reciprocal discipline. However, OED has the option of initiating a disciplinary action based on its
own disciplinary rules and not do a reciprocal discipline. Rule 37 C.F.R. 11.25(a) requires that a
person practicing before the Office shall notify the OED Director in writing within thirty (30)
days from the date of a conviction of a crime (underscoring added for emphasis).
(That 2/28/12 Order was then, under the RMC's Certificate of Service, mailed to an address the RMC
knew full well was no longer good for Coughlin, and the RMC failed to fax, or email or otherwise
seek to remail it to Coughlin upon receiving it back upon an "undeliverable" indication by the USPS
(despite feigning some real strong efforts to get in contact with Coughlin at the time in her 3/14/12
written grievance against Coughlin to the SBN (to be fair, it is true that incident to Coughlin being a
victim of domestic violence and benefitting from two Orders of Protection from Master Edmondson,
who really would make a great Family Court Judge already) Coughlin's access to his mailbox was
interferred with by his abusers and, allegedly, upon information and belief, members of the USPS
Golden Valley Station, NV Energy (NV Energy and the USPS are no friends to victims of domestic
violence or those whose lease are valid under 118A.160, as leases can be verbal in Nevada, and the
USPS and NV Energy, essentially two monopolies, should not be allowed to demand social security
cards and written lease from anyone, much less domestic violence victims, merely because the
numbers indicate it helps their profit margins to adopt such an approach. Talking to you Buck Hyde,
Terri James, and "Ms. Passot". and the former detective working for NV Energy whose name escapes,
and Sue King unauthorize practitioner of law for Park Terrace Town Homes HOA and or Galye Kern,
Esq. could answer a few questions about the extent to which they advocated behind the scenes to
deprive Coughlin of power in his rental (despite offering to pay for it and put it in his name upon his
former housemates, whom WNM and PTTHOA admits were there with the express approval of the
HOA Board upon recieving approval from Sheila Lester and the Board incident to former WNM
manager Robyn Bataldo presenting a proposal directed thereto to it. and when those "tenants"(who
were arguably employees given the work for rent trade admitted to) rent or sublease to Coughlin....
That ain't squatting, Sheila. You might call it a subtenancy, actually. But its not "squatting"....and
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anyone interfering with Coughlin's ability to get his mail during this time, roughlin January 2012
through mid March 2012, should be liable for any consequential damages...however, it would help if
one could go to the RMC and ask to see a docket with RMC Marshal getting their Affidavits out and
clandestine, rehearsed letters to the SBN out detailing how Coughlin said he was going to "depose"
the filing office staff about the dockets....How about just print out a docket, maybe charge a
reasonable print fee, and leave the totalitarian hostility for another time, Marshal Menzel, Coppa,
Harley and Townsend? And "Clerks of Court" or Administrative Assistants calling up Bar Counsel
and reporting on this or that aspect of an attorney's clothing when he goes to the RMC filing office
counter to check on the status of cases or deadlines or upcoming hearings)... There are collection
agencies and then there are courts of law, and the distinction should always be extremely apparent to
the public.
After the conviction is reported to OED by a practitioner, the Director of OED will make a
determination as to whether the criminal offense constitutes a serious crime. Coughlin has reported
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to the SBN and the USPTO the following convictions from the last year:
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11/30/11 conviction in 11 CR 22176 Reno Municipal Court Judge Kenneth Howard petty
larceny conviction of "candy bar and some cough drops" (allegation totalling $14.00). Judge
Gardner denied Coughlin's request for a continuance despite opposing counsel in the eviction case
form Coughlin's former home law office applying an unlawful rent distraint upon exculpatory videos
proving that Wal-Mart had expressly threatened to retaliate upon Coughlin by abusing process
incident to Coughlin's complaining to Wal-Mart managers, including W. 7th St. Wal-Mart Manager
John Ellis about the apparently fraudulence inherent to Wal-Mart's manager constantly "forgetting"
the Return Policy they hold out to the public and used to crush their competitors for years. Judge
Howard refused Couglin even one continuance in this matter, even where the Reno Sparks Indian
Colony (which owns the land that Wal-Mart sits on and rents it to and profit shares with that WalMart) Police Department Officers Kameron Crawford and Donnie Braunworth, in addition to WalMart's Thomas Frontino, were caught lying on video tape in consideration of their testimony at trial
that she search incident to arrest (wherein a a few cough drops were found in Coughlin's pockets) for
the alleged commission of a misdemeanor, occuring outside the officer's presence and after 7 pm at
night
6/18/12 criminal trespass conviction in 11 CR 26405 before RMC Judge William Gardner
incident to a summary eviction of a commercial tenant where non-payment of rent was not
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pled or noticed; lockout of 11/1/11 of Coughlin from his former home law office at 121 River
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Rock St., Reno, NV.
2/27/12 "summary criminal contempt" conviction by RMC Judge Dorothy Nash Holmes shortly after
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she, upon information and belief, met with other RMC Judges and was made aware of an Order for
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Competency Evaluation of Coughlin, and thus requiring Judge Nash Holmes to cease persisting in the
obviously well coordinated, agenda into action that several RMC Judges (and perhaps some others)
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developed against Coughlin incident to there numerous closed door meeting sessions where Judge W.
Gardner insists, somehow, local attorney Richard G. Hill, Esq.'s presence, involvement, or name
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never came up once, despite Hill's fingerprints being all over all four of those prosecutions incident to
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yet another retaliatory arrest and prosecution by the Reno Police Department of Coughlin in
RCR2012-065630 ("misuse of emergency communications"/911 calls) arrest incident to the domestic
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violence Couglin and his dog, Pekingese Jackson Pawluck where a victim of, by RPD Sargent Paul
Sifre and Officer Jason Schaur, with Sargent Sifre having had Coughlin arrested just over 48 hours
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previously on 1/12/12 for "jaywalking", yep, a custodial arrest for jaywalking. Reno 911 in RMC
case 12 CR 00696, which Judge Linda Gardner's brother W. Gardner transferred to Judge Nash
2
Holmes Department from another on 2/27/12 as well..
1
If the Director determines that the offense was a serious crime, the Director will file a request with
the Director of the USPTO for an interim suspension of the practitioner from practice before the
5 USPTO. The practitioner will have the opportunity for a hearing, however, the only grounds for not
granting the request are that (i) the crime did not constitute a serious crime, (ii) the person is not the
6
person who committed the crime or (iii) the conviction was so lacking in notice or
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opportunity to be heard as to constitute a deprivation of due process 37

C.F.R. 11.25(b)(3). Irrespective of the merits of the conviction, failure of a practitioner to
advise the Director of OED of the conviction could subject the practitioner to discipline under 37
C.F.R. 10.23(c)(14), if OED learns of the conviction after the thirty (30) day reporting period has
expired. State law violations under the category of reciprocal discipline fall under suspension or
disbarment from practice on ethical grounds by a state under 37 C.F.R. 10.23(c)(5), or conviction
under a state law offense involving moral turpitude under 37 C.F.R. 10.23(c)(1). Examples of
conduct in the category involving criminal convictions include: assault with a deadly weapon;
engaging in sexually explicit conversation with a minor over the internet; hit and run and DUI; sexual
assault; encouraging an illegal alien to come to the United States; insider trading; wire fraud; and
possession and trafficking of a controlled substance. In re Tamura, D2008-23; In re Lever, D2009-14;
In re Reynolds, D1999-12; In re Maiorino, D2004-11; In re Rostoker, D2004-15; In re Marks, D200505; In re Tezak, D2006-05; In re Rose, D2006-16.
Luckily for Coughlin, all three (or it is four if you count Judge Howard finding Coughlin
convicted of "summary contempt" as well as "petty larceny" in the Wal-Mart case on 11/30/11) of his
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"criminal" convictions are convictions was so lacking in notice or opportunity
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to be heard as to constitute a deprivation of due process 37 C.F.R.

11.25(b)(3).
And, in fact, the 11 TR 26800 "summary criminal contempt" conviction is not even a real
thing, or an actual crime in Nevada, at least not statutorily....And that's the whole point: "summary
criminal contempt" should be such a rare conviction that is shouldn't get to take up space in a
statute..When Coughlin was incarcerated, he heard some Deputies saying some things though that
indicate these sorts of things are not all that rare at the RMC these days..."put the kid in a "hug a
thug" program one week, he's back on a jaywalking charge two weeks later...and she give him 6
months in jail? She's just beyond at this point, man....". And the 3 days for "summary contempt" nrs
22.030 from Judge Howard is "civil contempt", ie, not a crime or misdemeanor, not that Judge
Howard's Order is all that much of a celebration of due process particularly where he justified he
departure from Aingersigner's requirement by saying he wouldn't issue jail time (well, actually, he
said, jail time was not typical...so it wasn't like he gave a guarantee or anything as a consolation to his
both denying the Sixth Amendment Right To Counsel and even one continuance to Coughlin, whom
Judge Howard knew had just been evicted less than one month prior...and was being prosecuted for a
first offense charge of shoplifting food? Uh-huh. Guess the take home message is good gawd don't
you dare allege prosecutorial misconduct toward the work of Pam Roberts. Or don't let the wrong
folks down at the RMC hear about it. And don't file a written complaint against RPD Officer Nick
Duralde with the askrpd@reno.gov system or the coplogic thing and be unprepared a month later at
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the arraingment on the wal-mart charge if things really, really, start to go pear shaped, strangely so
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even, when thrust into a trial less than a month after getting access to the police report (where the City
Attorney, as apparently is usually the case, has had the report for nearly a month already by the time
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you get it) think things are going to go all that well....
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Upon reviewing Coughlin's recent filings in 61901 and the Motion for New Trial in 11 CR
26405, and including the video taped admission by RPD Sargent Lopez...how can one not conclude
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that Hill, Merliss, Sargent Lopez, and Officer Carter, Marshal Harley, Thomas Frontino and Kameron
Crawford and Donnie Braunworth are all in violation of the following statutes:
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NRS 199.310 Malicious prosecution. A person who maliciously and without probable cause
therefor, causes or attempts to cause another person to be arrested or proceeded against for any crime
of which that person is innocent: 1. If the crime is a felony, is guilty of a category D felony and shall
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be punished as provided in NRS 193.130; and 2. If the crime is a gross misdemeanor or misdemeanor,
10 is guilty of a misdemeanor.
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Further, whereas Hon W. Gardner, before lunch during the trial on 6/18/12 presented one set
of circumstances to Coughlin regarding Coughlin testying in his own defense...after lunch (and some
apparent retooling of his approach) Judge Gardner presented an entirely different set of circumstances
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the he announced would attach shoudl Coughlin waive his Fifth Amendment Right (and in 11 TR
14
26800, Judge Nash Holmes seems to see an assertion of a Fourth or Fifth Amendment Right as a joke,
and an obvious and righteous opportunity to draw an inference of guilts....and she is a Judge....Great.)
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So, considering Coughlin had already been incarcerated 8 days incident to two different
"summary contempt" convictions by RMC Judges Howard and Nash Holmes incident to Coughlin's
self representation...why would Coughlin testify in his own behalf in the trespass trial before J. W.
Gardner? What was there to gain? What there really much of any chance that Judge Gardner was
going to be swayed by any testimony by Coughlin? Had Coughlin not already managed to get Hill
and or Baker to admit most things Coughlin would otherwise to to establish thorugh his own
testimony (ie, Hill admits to his ridiculous storage lien demands that consist of continuing to charge
the same $900 for "storage" that was charged for "full use and occupancy", and the audio at the very
start of the 11 cr 26405 court audio on 4/10/12 reveals a hilarious discussion between court appoint
defense counsel Loomis and his "client" Coughlin wherein Loomis absolutely co-signs Richard G.
Hill, Esq.'s "double dipping" (ie Hill wants to get the big rent associate with "full use and occupancy"
while still precluding Coughlin from "use and occupancy" of the premises. But Loomis isn't about to
argue a claim or right defense on Coughlin's behalf there (if Hill is charging Coughlin the same rent
as when Coughlin was entitled to "full use and occupancy"...then doesn't that sort of imply Coughlin
is entitled to the "full use and occupancy"? One cannot imagine how intimidating it is to be in the
RMC after two separate summary contempt jail stays in previous self representation contexts,
especially when one is flat broke, and another such stay, and all the bail revocatiosn attendant thereto
would likely wipe one out...
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And in the trespass case, where Hazlett-Steven's persisted mentioning pajamas (and the video
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reveals Coughlin si wearing sweats and a t-shirt...so is it not Richard G. Hill who displays a lack of
candor to the tribunal....see also his unsupported "they taped it on the door because you ran away"
claim. Rich...your associate Casey Baker testified you were not there. Coughlin was not there.
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Baker makes no such allegation of Coughlin running away incident to some taping of a lockout order
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on the door or attempts to first effect personal service thereof. Nor does the WCSO...so really, Rich,
what do you base that on? Is this like when you said
1
See, Judge Nash Holmes 2/28/12 "Order Finding the Defendant In Contempt Of Court and
Imposing Sanctions" purports to be finding Coughlin guilty of "the misdemeanor of criminal
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contempt, a violation of NRS 22.010"...but that's the thing, though. Judge Nash Holmes is remixing
7
NRS 22.010 and adding the words "misdemeanor" and "criminal" to it, because they just ain't there.
Now, Judge Nash Holmes may have meant to invoke NRS 199.340, but she didn't.
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NRS 199.340 Criminal contempt. Every person who shall commit a contempt of court of any one of
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the following kinds shall be guilty of a misdemeanor: 1. Disorderly, contemptuous or insolent
behavior committed during the sitting of the court, in its immediate view and presence, and directly
10 tending to interrupt its proceedings or to impair the respect due to its authority;...3. Breach of the
peace, noise or other disturbance directly tending to interrupt the proceedings of a court, jury or
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referee;4. Willful disobedience to the lawful process or mandate of a court; 5. Resistance, willfully
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offered, to its lawful process or mandate;"
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That's interesting...its almost as if 35 year veteran member of the Bar, Hon. D. Nash Holmes
did some picking and choosing amongst the various civil and criminal, summary, and plenary
contempt statutes and, kind of, made a pastiched of what she like best from each one and what best fit
her agenda with respect to Coughlin....the only thing, though, it that that is not legal, and as such, the
"conviction" for "misdemeanor of criminal contempt" cannot stand. Coughlin must admit...he has
been referring to it as a "summary criminal contempt" conviction...when, in fact, it doesn't seem
Judge Nash Holmes ever so characterized it...its just that...well. when you don't get a trial, or an
arraignment, or court appointed counsel, or the right to appeal, or be allowed out of jail even where
the RMC keeps the money your mom went and paid to bail you out...its hard to think of such a
conviction as anything other than "summary" in nature. Despotic, tyrannical, wholly inappropriate,
devoid of the quality of justice or any sense of a measure and even application of traditional notions
of substantial justice and fair play are some charicterizations that some might say. Not Coughlin. He
likes being out of jail.
Stranger still is how Judge Nash Holmes goes on to support her throwing license attorney
representing himself in a traffic citation matter Coughlin in jail for 5 days, starting right then (and no
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stay to arrange for lack of prejudice to Coughlin's client, either) upon some application of NRS
22.100, where in her 2/28/12 "Order Finding the Defendant In Contempt Of Court and Imposing
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Sanctions" Judge Nash Holmes writes "it is ordered, pursuant to NRS 22.100, that the defendant be
incarcerated at the Washoe County REgion
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Strange How Hazlett-Steven's in the trespass case gets to argue all this "'using it as a
residence" prejudicial facts not in evidence...even where Judge Gardner ruled those matters not
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relevant....only for Judge Gardner himself to cite to and rely on the "had your dog there" "using it as a
residence" in his decision?.....hmmmmn.....
Glover v. Eighth Judicial Dist. Court of State ex rel. County of Clark, 220 P.3d 684 110CRIMINAL
LAW 110XXXICounsel 110XXXI(F)Arguments and Statements by Counsel 110k2134Comments on
Failure to Present Evidence or Witnesses 110k2137k. Comments by defense on failure of prosecution
to present evidence. Nev.,2009 Negative-inference argument made by defense counsel during closing
argument, that the State did not introduce voluntary videotaped unsworn statement that defendant
made to police the day that the victim was shot because the statement would absolutely devastate the
State's case, was improper, in trial of defendant for murder in which defendant claimed self-defense,
as defense counsel was arguing facts not in evidence, defense counsel was putting his personal
knowledge and belief on the scales, State's objection to defendant's attempt to admit the videotaped
statement, that the prior out-of-court statement was inadmissible to bolster defendant's in-court
testimony, was a proper hearsay objection, and it was improper for defense counsel to argue a
negative inference based on a proper hearsay objection.
Strange How Hazlett-Steven's in the trespass case gets to argue all this "'using it as a residence"
prejudicial facts not in evidence...even where Judge Gardner ruled those matters not relevant....only
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for Judge Gardner himself to cite to and rely on the "had your dog their" "using it as a residence" in
his decision?.....hmmmmn...
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from Judge W. Gardner's decision in the criminal trespass case 11 cr 26405:
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THE COURT (RMC Judge William Garnder): No, we're
done. That's it. You know how it works. The
prosecutor goes first, you go second, they finish
up. They have the burden of proof. That's it. No
more argument. That's very clear. Alright, let me
just make a couple comments here. Both parties have
identified -there's numerous issues here. The big
issue is the warning. Under our statute, both
207.200, and RMC 810.0lD, the party -it doesn't even
talk about the vex or annoy, the party who goes or
remains, either one, Mr. Hazlett-Stevens pointed
that out, into any building after being warned by
the owner or the occupant, and the owners and
occupants can be agents with ostensible, actual or
implied authority, and certainly Mr. Hill and Mr.
Baker had that authority. That's clearly established
by the evidence. Ifyou go back onto that property
after having been warned, you are guilty of a
trespass, and I guess the question is what is a
warning? And unlike many areas in the law, it's not
defined under the trespassing ordinance, or the
trespassing statute. It's a notice requirement. And
the real issue in this case -there's a number of
issues, but I do -there's no question, Mr. Coughlin,
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that you were on property that belonged to another
at 121 River Rock on November 13th, and that's in
the City of Reno, and there's no question about
that. The question is, what type of warning did you
have? You had so many types of warnings, it's hard
to figure out which one is the best. First of all,
the first warning -and by the way, when we talk
about warning here, when you look at the statute
under state law or the Municipal Code, both the
Legislature and the City Council have given some
guidance that indicate for some occupants they've
got sufficient warning if the property is posted in
a conspicuous manner in intervals of not less than
700 feet. So, something as broad as that is
sufficient warning under our trespass statute. And
the statute goes on to say it's prima facia evidence
of a trespass if the property is posted or fenced on
a property. That's prima facia. So, the question is
did you have notice? Did you have some sort of
warning not to be on that property, and here's what
the Court has determined. You received some kind of
mild notice, and a warning when you were given a 5day notice and a 30-day notice. Probably in and of
itself, probably not enough to support a trespassing
finding. But at two separate hearings in October of
2011, on the 13th and the 25th, where you were
present in Court, there can be no question that the
issue is whether or not the owner of that property
wanted you on that property more, or should you be
on that property. Then, right in open Court, Judge
Sferrazza evicted you from the property. He followed
that up with a written Eviction Decision and Order
clearly indicating that you were evicted, and that
the stay was denied. So, I don't know what -that
would be what I call super notice, or super warning,
coming from the Judge himself. Page -149 It's often
the situation we never get that kind of warning. So
not only did you get a warning, you got an Order
from the Judge that you were evicted from the
property. That was then posted on the front door of
a property that you had been in and returned to on
November pt, 2012 (sic) the day it was posted. There
was a copy left on a coffee table later at some
point in time after Mr. Hill had entered the
property and realized that there had been someone in
the property. You were emailed. Whether or not you
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received that email, I don't know, but there was at
least another attempt to email you at an address to
which you had responded, and to an address, an email
address, to which you had responded that you would
not accept emails on your -as notice. Finally, you
were mailed a Notice of Entry of Judgment to 121
River Rock. I'm sure -I would guess you didn't get
that, but the parties here did everything possible
to provide you notice, to provide you warning, and
you had actual notice, you had constructive notice,
that you shouldn't be on that property. The State of
Nevada and the Supreme Court decision which Mr.
Hazlett-Stevens quoted this morning and I have in
front of me, State v. McNichols, \ 06 Nev. 651,
clearly, clearly, says that after someone has been
evicted, a subsequent reentry in the property is a
trespass. A trespass reentry is what the Supreme
Court called it, did not create an objective of that
expectation of privacy. So, that's just the first
section. That's been proved beyond any doubt.
There's no question that portion of the statute has
been proved. And I would also submit that Mr.
Hazlett-Stevens is correct. And after going back
on that property numerous occasions, setting
up a residence with your pet in the basement,
constitutes a separate basis independent from
the notice requirement that you went on to
that property with the intent to vex or annoy
the owner. So, under any theory set forth by the
City, I find you guilty of the charge of
Trespassing. We can proceed to sentencing."
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Also pretty suspect how City Attorney Hazlett-Stevens argues Coughlin can't make
argument about the Appeal (facts not in record?), when Hazlett, later on, followed with this:
"City Attorney Hazlett-Stevens: With regard to all ofthe issues Mr. Coughlin brought up in regard to
commercial residence, commercial property, notices, whether or not they can take summary eviction
proceedings against a commercial tenant, this is not the proper forum to decide that issue.
That, Mr. Coughlin, had an opportunity to address in front of Judge Sferrazza, in his appeal in front of
Judge Flanagan, which you actually did hear in evidence today. That matter is appealed, and Judge
Flanagan already denied the appeal."
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And old prosecutor Hazlett was nice enough to preserve for the appeal, to whatever extent
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Loomis having judicial notice taken at a previous hearing went out the door with Loomis, the issue of
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the RJC being divested of jursidiction, precluded the "Trial upon Coughlin depsoiting $2,275 rent
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escrow with the court, on 10/25/11" before the RJC from goign forward given the improt of, say,
Mack v. Mack-Manley, or Foster dingwall, in that the RJC would be divested of jurisdiction upon
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Coughlin's filing a Notice of Appeal on 10/18/11, there makign the eviction order void nrcp 60b4 lack
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of jursidiction:
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MR. HAZLETT-STEVENS: No, it's in evidence, Your Honor. And I'll draw your attention to the part
that says, "Decision." And it also says, "Matthew Merliss present, Casey Baker -represented by Casey
Baker," and then it also indicates Zachary Coughlin present. And then I'll draw your attention to the
decision where it says "eviction granted effective October 31 st, 2011, at 5:00 p.m." That's what Judge
Sferrazza announced in open Court with Mr. Coughlin, according to Mr. Baker, listening, actively
listening to the Judge. He wasn't writing anything down, but he was actively listening to the Judge
when he announced that decision in open Court. And you have the Order granting eviction right there.
Now, there was another issue whether or not the proceedings were stayed pending some sort of
appeal, but that Motion to Stay was also denied in the October 25th, 2011, hearing. And you'll see in
City's 1, it Page -1 27actually says, "Tenant's verbal motion to stay, denied." The case was over at that
point.
But here is the part of Coughlin's cross examination where Hill truly demonstrates the
malpractice and misconduct he committed: Q So your office converted it to a no cause summary
eviction notice? A More precisely, sir, the decision was made to forego the rent eviction and simply
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do a 30-day no cause. Q Okay, and if subsequently the tenant was considered a commercial tenant,
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would that not be tantamount to sort of a wrong side legal surgery? A Well, I
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don't quite understand your metaphor, sir. But the fact ofthe matter is it
was a residence. The fact that you were illegally conducting a business there, a side issue,
number one. Number two, you didn't raise it in the Justice Court. Q You say it was a residence. Is it
zoned for just residential use? A I don't have any idea, sir. Q Well, why did you say it was a residence
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if you don't have something to base that upon? A That's what the lease said, and there was no lawful
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business being conducted. Q The lease said -did the lease say a commercial use was acceptable? A I
don't know, Mr. Coughlin."
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A review of the attache (partial, unofficial) transcript of the summary eviction

proceeding/"Trial", along with the Appendix reveals Coughlin clearly did raise and pled the issue, and
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cite to the law forbidding the use of summary evictions against a commercial tenant where non
20 payment of rent is neither pled nor noticed...
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I believe there is a couple quasi 60(b) basis for challenging the validity of any -to the extent this Court
views the Eviction Order as a warning, which I think is kind of the big inquiry here. Maybe not, but to
me, it seems like it's possibly what the case could come down to. To the extent the Court does
consider a valid Eviction Order appropriately served, a warning sufficient to satisfY the criminal
trespass statute, I believe there is a couple 60(b) like basis to challenge that Order. One is brought up
by Mr. Loomis, who so astutely pointed out that under the McManley case there was a Notice of
Appeal filed in the interim between the initial October 13th hearing, and then the October 25th
trial. MR. HAZLETT-STEVENS: Judge, this is getting into testimony -or evidence that's not in
testimony, testimony that's not in evidence rather. It's not there about any appeal taken. THE
COURT: Mr. Coughlin? MR. COUGHLIN: Well, I believe Mr. Loomis THE COURT: Your
argument is limited to the facts that were produced today at trial. MR. COUGHLIN: Just
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today, not what Mr. Loomis Page -136- THE COURT: That's correct, today's trial. So to that
extent, the objection -and I try to give parties a great deal of leeway in closing argument, but
when you start getting far afield of what was argued, presented via facts of the trial, that's not
proper argument. MR. COUGHLIN: Okay, and I thought it was part of the record at this
point. And ifit's not too late, I'd object to the notice by email that was introduced. THE
COURT: Okay, go ahead. BY MR. COUGHLIN: Beyond that 60(b) basis, I believe there is an
additional basis in that -there is a couple. I think under the ANVUI, A-N-V-U-I-E A-N-V-U-I, which
is kind of the main Nevada case on summary evictions of commercial tenants. That was a restaurant
in Vegas doing a lot of business, like $500K a month or something, and they got evicted, and it went
to the Nevada Supreme Court, and a lot of litigation was done over that. And the holding, the take
home holding from that was that it's basically a summary judgment standard in the summary eviction
proceedings. The tenant merely needs to present a material issue of law or fact to beat a summary
judgment motion. If they do that, the Court may do nothing further, and it has to go on to a
(inaudible) unlawful detainer approach. Served, 20 days to respond, discovery, all that. So,
my position would be that there's a 60(b) basis for viewing this -any summary eviction
order, as void in that I was a licensed attorney, at that time, at least, and I held that out
as my law office. I filed a tenant's affidavit that I was a commercial tenant. I pled that.
Mr. Hill testified today that he wasn't aware of that, and he didn't consider it a
particular Page -137 - 1 38- consideration, for his neurosurgeon client who had spent
$60 grand on this. That's where I'm at the analogy of the wrong side legal surgery,
because I think it could wind up potentially being fairly important to his client if it's
proven that a wrongful eviction occurred. If it's proven that yes, I did present a (inaudible)
issue of material fact, that this was a commercial tenancy, and to the extent judicial notice could be
taken that it was merely a No-Cause Eviction Notice that was pursued and that non-payment of rent
was not alleged, then this could be problematic, and Mr. Hill might wish he had considered that point
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whether this was a commercial tenancy, and I'm not subject to summary eviction proceedings in
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40.253, and (inaudible) pay my rent as alleged as being in fact very important."
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Also whatever Baker and Hill seek to argue now, incorrectly (because they are flailing around,
like at the criminal trespass trial, during the gotcha moments when Coughlin points out that, despite
billing their client $60K, they don't know the case or the law all that well with respect to the narrow
finer points of law that will ultimately decide the case. Sure Rich and Casey can push paper with the
best of them, and it looks legit and sounds pretty law firmish and stuff...until you start to pick it apart.
then its just junk food, plain and simple. Like, for instance, Casey Baker, Esq. gets Judge Sferrazza
to sign his FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER FOR SUMMARY
EVICIION ...: "This matter having come on regularly for an evidentiary hearing pursuant to NRS
40.254 and NRS 40. 253(6) on October 13, 2011, and continued on October 25,2011, before the
Honorable Peter J. Sferr azza, sitting without a jury; the plaintiff/landlord, Matt Merliss (HMerliss"),
having been present, and represented by counsel, Richard G. Hill, Chartered and Casey D. Baker ,
Esq. , and defendant/tenant, Zachary Barker Coughlin, Esq. ("Coughlin")" Well, shoot,
Casey...way you wrote that there, sound like the tenant is an attorney practicing law out of the spot
your landlord client is rentin' to him, don't it? Now, what that mean? Commercial tenant, No Cause
Eviction verboten unless pled non-payment of rent, they didn't, Coughlin wins, now that HIll's hollow
little reign in the trail court and District Court has come to and end.
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of
events and when she asked Coughlin her questions about recording, considering when a restroom
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break took place an exactly what it is she asked Couglin and when, and what his responses were, and
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when some allegations by "the Marshal" were made, what they consisted of, etc.. on 3/12/12 in 11 tr
26800 the audio transcript reads 7 minutes into the audio record the RMC provided the SBN:
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Judge Nash Holmes (Nash): It appears to me in this case that the defendant is suffering
from some extreme form of mental illness. during the trial I asked the defendant
attorney repeatedly if he was recording the proceedings he denied that vehemently a few
times and then he quote took the fifth a few other times and then he requested to be
excused to go to the bathroom and the Marshal later reported to me that while the
gentleman was in the bathroom he disassembled a recording device in his pocket and
took the memory out of it and it was later found in that, uh, by the Marshal no one else
had gone into the bathroom and that was retrieved and it was put into his possession at
the Sheriff's office and when they booked him into jail for the contempt charge that was
booked into evidence and I asked the Sheriff's office to hold that into evidence. I believe
he has violated Supreme Court Rule 229(2)(B) which was amended by ADKT 440,
August 1st, 2011...."
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of
unattributed hearsay, like her car sleeping allegations in her 3/14/12 letter re Coughlin to the
SBN) above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following
her statement at the 7 minute mark that "It appears to me in this case that the defendant is
suffering from some extreme form of mental illness." Further, that which Judge Nash
Holmes had communicated to her prior to the start of Trial on 2/27/12 in 11 tr 26800 needs to
be testified to under oath, rather than have Bar Counsel assert to half baked "can't ask the
judge about her mental processes" loophole, as he has done.
City Attorney Ormaas sure could be made to explain her statements on the record regarding
whether the citation or report in 11 tr 26800 contained any mention of retaliation, given she
was looking right at it and given what she said in court. Also, the whispering with Marshal
Harley, and the bits about Coughlin reporting to Ormaas what RPD OFficer Carter said to
Coughlin in 61901, and Ormaas's responses thereto on 2/27/12, and Dan Wong, ditto at an
earlier hearing on that matter...
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Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was
recording anything or whether he possessed a "recording device" until AFTER the one and
only restroom break Judge Nash Holmes mentions on the audio record. And that sua sponte
interrogation of Couglin occured IMMEDIATELY AFTER THE RESTROOM BREAK, A
BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO
TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER
COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE
WHISPERING IN EACH OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS
AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE
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QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL

(DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT
INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT STACKED
DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that was...which is
odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800,
and rcr2012-065630 and rcr2011-063341 at the time (lots of reasons for and indications that
local law enforcement and prosecutors and public defenders were non too happy with
Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between
young and dogan that neither YOung nor Dogan wish to testify about...but which seems to
have been held anyways after a written communication of its being reset was transmitted to
Coughlin by Dogan, wherein, during the time Judge Nash Holmes couldn't be found (maybe
she was at one of the group meetings amongst Judges about Coughlin that RMC
Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting
the Notice of Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for
Competency Evaluation of Coughlin in rcr2012-065630 (apparently in retaliation for
Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from a filing by
Coughlin of approximately 11/28/12, which resultd in Young promptly amending his
complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure
to allege theft or possessing/receiving "from another' under Staab makes his so charging
Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty, apparently.
That, and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp
of 2:55pm a fugitive document of his own, an Opposition to Coughlin's or the WCPD Motion
to Appear as CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in
that case despite the Order finding Coughlin competent in cr12-0376 didn't even get signed
and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the criminal
trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010) here in
Northern nevada..
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Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did
file a Notice of Appeal 3/7/12...despite "summary criminal contempt" being a final appealable
order, Judge Nash HOlmes continues to refuse to follow NRS 189.010-050 (so Coughlin has to
type the transcript, yay....
This brings us to the merits of the appeal. Because a summary contempt proceeding dispenses
with procedural safeguards ordinarily deemed essential to fair criminal trials, decisions of the
Supreme Court (Cooke v. United States, 1925, 267 U.S. 517, 45 S.Ct. 390, 69 L.Ed. 767; In Re
Oliver, 1948, 333 U.S. 257, 68 S.Ct. 499, 92 L.Ed. 682; Harris v. United States, 1965, 382
U.S. 162, 86 S.Ct. 352, 15 L.Ed.2d 240; Johnson v. Mississippi, 1971, 403 U.S. 212, 91 S.Ct.
1778, 29 L.Ed.2d 423) and Several courts of appeals,(United States v. Meyer, 1972, 149
U.S.App.D.C. 212, 462 F.2d 827 (collecting cases); United States v. Willett, 4th Cir. 1970,
432 F.2d 202; United States v. Peterson, 10th Cir. 1972, 456 F.2d 1135; United States v.
Marshall, 9th Cir. 1971, 451 F.2d 372. But see In Re Niblack, D.C.Cir.1973, 476 F.2d 930,
and In Re Gates, D.C.Cir. 1973, 478 F.2d 998, discussed at note 7, infra) ave severely
constricted the scope of the summary contempt power.
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One constraint on the use of Rule 42(a) is a requirement that there be 'need for immediate
penal vindication of the dignity of the court'. Cooke v. United States, supra, 267 U.S. at 536,
45 S.Ct. at 395. The defendants in Cooke had written and delivered an insolent letter to a
district court judge who had just presided over several cases in which the defendants had an
interest, and who was about to preside over other such cases. The Supreme Court, reversing
summary contempt convictions, carefully distinguished obstructive contempts in open court
from other forms of contempt. Disturbance, violence, or disrespectful behavior may be dealt
with summarily, if committed in open court, because of the need to vindicate the court's
authority on the spot. 'When the contempt is not in open court, however, there is no such right
or reason in dispensing with' normal plenary procedure. 267 U.S. at 536, 45 S.Ct. at 395.
The Court has preserved the distinction it articulated in Cooke. In Re Oliver, supra note 2,
reversed the contempt conviction of a witness who appeared before a judge sitting as a oneman grand jury in Michigan. The judge-grand jury found the witness in contempt for giving
evasive answers to his questions. The inquiry had occurred in chambers, with few people
present. Quoting from Cooke, the Court made clear that summary contempt power can
constitutionally reach 'only such conduct as created 'an open threat to the orderly procedure of
the court and such a flagrant defiance of the person and presence of the judge before the
public' that, if 'not instantly suppressed and punished, demoralization of the court's authority
will follow.' (Cooke) (267 U.S.) at 536 (45 S.Ct. 390).' 333 U.S. at 275, 68 S.Ct. 508.
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Two more recent cases, Harris v. United States, supra note 2, 382 U.S. at 165, 86 S.Ct. 352,
and Johnson v. Mississippi, supra note 2, 403 U.S. at 214, 91 S.Ct. 1778, reaffirmed, with
reliance on Cooke, the view that need of immediate action to restore order to an ongoing court
proceeding is a prerequisite, both constitutionally and under Rule 42(a), to use of the summary
contempt power.
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Federal law, 18 U.S.C. 401, confers upon a court the authority to punish by
imprisonment "misbehavior of any person in its presence or so near thereto as to
obstruct the administration of justice," id. 401(1), and "disobedience or resistance to its
lawful writ, process, order, rule, decree, or command," id. 401(3). A finding of direct
contempt is appropriate only if the criminal contempt occurred in the presence of the
judge and "the judge saw or heard the contemptuous conduct and so certifies."
Fed.R.Crim.P. 42(b). Contempt in the presence of the court "must be punished on the
spot to maintain the court's authority." The use of the summary contempt power is
proper only for "charges of misconduct, in open court, in the presence of the judge,
which disturbs the court's business, where all of the essential elements of the misconduct
are under the eye of the court, are actually observed by the court, and where immediate
punishment is essential to prevent `demoralization of the court's authority' before the
public." Pounders v. Watson,521 U.S. 982, 988, 117 S.Ct. 2359, 138 L.Ed.2d 976 (1977)
(per curiam) (quoting In re Oliver,333 U.S. 257, 275, 68 S.Ct. 499, 92 L.Ed. 682
(1948)).As we have recognized, however, the contempt power may be abused. We have
held the summary contempt exception to the normal due process requirements, such as a
hearing, counsel, and the opportunity to call witnesses, "includes only charges of
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misconduct, in open court, in the presence of the judge, which disturbs the court's
business, where all of the essential elements of the misconduct are under the eye of the
court, are actually observed by the court, and where immediate punishment is essential
to prevent `demoralization of the court's authority' before the public." In re Oliver,333
U.S. 257, 275 (1948) (quoting Cooke, supra, at 536). We have stressed the importance of
confining summary contempt orders to misconduct occurring in court. Where
misconduct occurs in open court, the affront to the court's dignity is more widely
observed, justifying summary vindication. See In re Green,369 U.S. 689, 692 (1962)
(relying on due process cases); Harris v. United States,382 U.S. 162, 164 (1965) (defining
boundary between summary and ordinary contempt under Fed. Rule Crim. Proc. 42).
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It is true that courts have long exercised a power summarily to punish certain conduct
committed in open court without notice, testimony or hearing. Ex parte Terry, 128 U.S.
289, 9 S.Ct. 77, 32 L.Ed. 405, was such a case. There Terry committed assault on the
marshal who was at the moment removing a heckler from the courtroom. The 'violence
and misconduct' of both the heckler and the marshal's assailant occurred within the
'personal view' of the judge, 'under his own eye,' and actually interrupted the trial of a
cause then under way
That the holding in the Terry case is not to be considered as an unlimited abandonment
of the basic due process procedural safeguards, even in contempt cases, was spelled out
with emphatic language in Cooke v. United States, 267 U.S. 517, 45 S.Ct. 390, 69 L.Ed.
767, a contempt case arising in a federal district court. There it was pointed out that for a
court to exercise the extraordinary but narrowly limited power to punish for contempt
without adequate notice and opportunity to be heard, the court-disturbing misconduct
must not only occur in the court's immediate presence, but that the judge must
have personal knowledge of it acquired by his own observation of the contemptuous
condut . This Court said that knowledge acquired from the testimony of others, or even
from the confession of the accused, would not justify conviction without a trial in which
there was an opportunity for defense. Furthermore, the Court explained the Terry rule
as reaching only such conduct as created 'an open threat to the orderly procedure of the
court and such a flagrant defiance of the person and presence of the judge before the
public' that, if 'not instantly suppressed and punished, demoralization of the court's
authority will follow.' Id., at page 536 of 267 U.S., at pages 394, 395 of 45 S.Ct.
..."'For the purposes contemplated by the provision of the constitution, the presence
of the officers of the courtmen whom, it is safe to say, were under the influence
of the courtmade the trial no more public than if they too had been excluded.'
People v. Hartman, 103 Cal. 242, 244, 37 P. 153, 154, 42 Am.St.Rep. 108." The RMC
regularly clears the court of members of the public (as is did in 11 cr 22176, the walmart
case) and or holds Coughlin's criminal case until the very end of the last stacked docket
of the day and or locks to courts doors, so that Coughlin's Trials cannot be said to occur
in the presence of anyone other than the jUdge, the prosecutor, coughlin, and whatever
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witness is testying, and an Administrative Assistant or Judicial Assistant (to the exten
they too are are not considered "officers of the Court" and not subject to the
exclusionary rule. So the idea that these summary conempts were necessary "preserve
the dignity of the court" in front of "the public". see alston Sutton 683 f. supp at 684, in
re spencer 985 so. 2d 300, 260 f.3d at 227, in re scott 1978 wl 26483 at 3, 477 ne 2d at 260,
matter of daniels 530 a. 3d at 1273.
... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin violated in
both 11 cr 22176 and 11 tr 26800, also orders no sufficiently detailed or capable of being
known how to comply with, not sufficient warning, violat Houston v Eighth Judicial District
(Nev.).
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See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt"
occur " in the "immediate presence" of the Court. Maybe Marshal Harley and some other
Marshal have misled Judge Nash HOlmes, or maybe something worse is going on here....but
what Judge Nash HOlmes said on the recording is entirely misleading an inaccurate, if not an
outright lie (again, maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but
regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary
where she not only purports to issue a "summary criminal contempt" conviction against an
attorney, but also where Judge Nash Holmes appears to try to transmogrify what she sees as "a
simple traffic citation trial" into a full blown SCR 105 disciplinary hearing where she is both
Bar Counsel and the Panel...That Marshal needs to sign an affidavit, under NRS 22.020 and
Judge Nash HOlmes ought to have to put something on the record, under oath, in response to
Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash HOlmes phone in her
testimony, and it probably won't even be sworn testimony, but rather just some musings by
Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence"
all sorts of things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel
has also filed Motion to Quash the Subpoenas Coughlin attempted to have served on Marshal
Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge William Gardner, Judge Gardners
Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal Coughlin
faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal
was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin
appeal of the 11 cr 22176 conviction resulting in this Court's 6/7/12 temporary suspension
Order in cr11-2064, which was denied based upon a civil preparation of transcript down
payment rule, in that criminal appeal, where the RMC has a thing in place with this Pam
Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the trial
for some time, insisting only Longoni would be allowed to transcribe it, and that the
transcript's preparation would absolutely not start until a down payment was made. Plus, even
where Coughlin caved to the payment demands..Longoni repeatedly hung up the phone on him
and otherwise ignored his communications (there may be an issue of the email Longoni
holding out to the public issuing a "bounceback"...but she needs to sign an affidavit as to
whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed
his request to the number the RMC held out for her on her behalf too...
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In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and
perhaps, NG12-0435, depending upon whom you ask and what King means by "Clerk of
Court"...because in King's 3/23/12 email to Coughlin he apparently identifies Ms. Marilyn
Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't it be Second Judicial
District Court Clerk of Court Joey Orduna Hastings that would need to send Family Court
Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King
now apparent contention that the NG12-0435 "ghost grievance" consisting of Judge L.
Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court Orduna
Hastings? Do you have anything to say about this? Judge Nash Holme's 3/14/12 grievance to
bar counsel reads:
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"
Re: Zachary Barker Coughlin, Nevada Bar No. 9473
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Dear Mr. Clark:
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This letter constitutes a formal complaint of attorney misconduct and/or disability against
Zachary Barker Coughlin. The accompanying box of materials demonstrates some of the
problems with the practice of this attorney being experienced by myself and the other three
judges in Reno Municipal Court. My two most recent Orders in what should be a simple traffic
citation case are self-explanatory and are included, together with copies of massive documents
Me. Coughlin has faxfiled to our court in this case. Audio recordings of two of my hearings in
this matter are also included. He failed to appear for the second one this past Monday.
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I have another traffic case pending trial with him that was re-assigned to me based on our
Department I judge being out for surgery. We have multiple addresses for Mr. Coughlin and
can't seem to locate him between cases very easily. We are setting that case for trial and
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attempting to serve him at the most recent address we have (1422 E. 9 St. #2 Reno NY
89512), although I heard today he may be living in his vehicle somewhere. We do have an
address for his mother, however, as she recently posted part of a fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on
appeal to the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a
matter currently pending in his court with Mr. Coughlin as the defendant. I have enclosed
some copies of documents from those matters, in chronological order, simply because they
appear to demonstrate that he is quickly decompensating in his mental status. Our staff also
made you some audio tapes of Coughlin in the him and him and him and him and him and him
and him him and I will him and him and him and him and him in Departments 2 and 4 so you
can hear for yourself how this attorney acts in court. You can see his behavior in my traffic
citation case does not appear to be an isolated incident.
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It is my understanding that Reno Justice Court also has a matter pending on this attorney. My
Judicial Assistant was contacted by the Washoe Public Defender in February when I had Mr.
Coughlin jailed for Contempt of Court and they stated that they represent him in a Gross
Misdemeanor matter in RJC. I have no other information on that.
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You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal
Court in your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious
litigant in our court, antagonizing the staff and even our pro temp judges on the most simple
traffic and misdemeanor matters. I do think this is a case of some urgency, and I apologize for
taking two days to get this package to you; our IT person was ill and could not make the copies
of the audios of Mr. Coughlin's hearings until today, and I felt it was important that the audios
be included in the materials to be considered by the State Bar. On February 27, 2012, Mr.
Coughlin told me he was actively practicing law and had appointments with clients. [ do not
know if that was true, but if so, he could be causing serious harm to the practice of law in
Northern Nevada and could be jeopardizing someone's freedom or property interests. "
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it is instructive to consider judge William Gardner's comments on the record at the trial in the
criminal trespass matter from Coughlin's former home office again it is judge William Gardner who is
the brother of Judge Linda Gardner whose April 2009 sanction order was cited by Washoe legal
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services and named party in this matter at this sole reason for firing Coughlin additionally Washoe
15 legal services now employs as part of the ECR program with Thodore who was at one time Coughlin
said on this criminal trespass matter until apparently Joe figured out the Calder was doing his
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business partners Nevada court services table is a court-appointed attorney by the defendant defense
attorney by the Reno municcourt
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at the 19 minutes mark of the audio of the 6/18/12 trial in the criminal trespass matter 11 cr
26405:
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Judge Gardner: finally the it leaves the issue of recusal although you have not raised in the
caption of the pleading news.with in the party their about page do we about address this issue
before and I've denied that motion to recuse there is nothing raised in any of the pleadings that
causes me to be busy in this case other than a fair detached observer of the facts of that will be
denied for
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Coughlin Your Honor just interject that not just prefaced that by saying Nevada doctors did
your announced any judge Your Honor and completely fair so let's give me a lot of confidence
the corridor but I do believe there might be a judicial candor something this is where judge has
litigants before him who have a case involving a family member of the judge and some other
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sphere and I think that Mike and mandatory recusal auto but I did find and follow mandamus
action adventure sister attended court in 2009 I was fired from a job as if surveillance attorney
for Washoe legal services was told I was fired because of her because of conduct by neither
resulted in her order distilleries and starts marshaling services I did follow mandamus petition
response to that. Judge of the Supreme Court father wasn't worthy of more reviewer require
and responsiveness and and now there's this grievance for the court and I call it not be flipped
by: p.m. macula conception grievance because nobody can tell me who filed it or how the can
grievance but that order one 2009 sanction may require me to pay personally $1000 in
attorney's fees under NRS him .085 as a consequence of my advocacy is a domestic violence
attorney after number of bus client a battered woman tenant or alimony incident to a 20 year
marriage when I was ordered to slaughter my pocket that is now grievance it upon information
believed that it can grievance with the State Bar because your sister judge Linda Gardner did
the order to you whereupon you indicated that you get judge Nash Holmes whereupon judge
Nash and skipped for counsel along with a number of other materials that I've not been privy
to despite my attempts to secure them from the filing officer the court or from door counsel I
have made numerous attempts to get these recordings at antenna materials as are not directed
at
Judge W. Gardner: thank you Mr. Coughlin let me just tell you this that case goes back to the
Family Court of no real knowledge except that I have read the Order it is unrelated and
irrelevant to this case. I have not really discuss the merits of this case with my sister who is a
judge in the Family Court there would've been no reason to discuss that case and even if that
would've happened it would have not, uh, um, there really is no nexus between her being a
judge hearing the case for Europe attorney and and my been a judge some three years later on
a case where you are a defendant in, so the motion to recuse is denied and I think that
identifies the issues that you faced in the motion you filed June 5, 2012 it looks like now we
are ready to go to trial is that correct, Mr. Hazlett-Stevens?"
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Hazlett-Stevens that's correct Your Honor: I'll call Richard Hill to the stand "
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Judge W. Gardner curiously defines and limits to an overly narrow extent, Coughlin'
appearance before him, even where Coughlin had been forced to represent himself in violation
of the Sixth Amendment given the utterly fraudulent "court appointed representation" by Keith
Loomis, Esq. as "a case where you are a defendant in".
Then (and this also goes to the overly narrow limiting of the conflict analysis to seeing
Coughlin only as "a defendnat before me in a criminal case" that Judge W. Gardner made
above) at the 23:20 minute mark, despite judge William Gardner admitting to being where
previously of the fact that Coughlin's law license had been suspended by this court on June 7,
2012 judge Gardner notes:
Judge GArdner: excuse me Mr. Hazlett Stevens let me just enter one more thing for the record
on that recusal analysis Mr. Coughlin limits the wording of this case to the date I have put the
criminal complaint alleges on number of November 13, 2011 in the city of Reno at 121 River
Rock St. the defendant was found in the property after being evicted on November 1, 2011
Billy other information I heard about the cases been whatever was raised in the pleadings filed
by either you or Mr. Hazlett-Stevens, so that being the case, go ahead and proceed with your
examination of Richard Hill"
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Interesting how the complaint pleads being evicted as tantamount to a criminal trespass
warning, and Hazlett-STevens impermissibly sought to invoke State v. nichols in the broadest
of senses (criminal trespass? civil trespass? was notice appropritately served in Nichols?
doesn't matter apparently, and Judge Gardner indicates he doesn't care what service rules apply
to evictions, as he will decide that based upon the facts as developed a trial, refusing to allow
Coughlin to make legal argument in that regard.
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in that audio fo the trial, very shortly therafter at the 24:02 mark:
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"Coughlin: I'm sorry I don't mean minaret to Mr. Hazel Stevens but if I can just quickly
interject her honor with respect what you just said to the extent that I am required to broach the
topic of any discussions you had with judge Nash Holmes with respect to these matters
Gardner: I can tell you that judge Nash owns I have not discussed this with anybody. We have
not. F their have been no discussions between me and the judge about your case to protect
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And, darn, forgot this, but there actually was a Pam Longoni prepared transcript in the appeal
of the criminal trespass conviction (but as cr12-1018 may suggest, it can be a good idea to
double check Ms. Longoni's transcriptions for the RMC, she is held out as their "exclusive"
transcriptionist, and documentation is provided to appellants that ther transcript's preparation
will not even begin until a substantial down payment is made (and probably won't, i need to
check this...but probably won't be forward to dist court until full payment is made, all in
violationf of NRS 189.030...despite whatever civil statute Judge Elliot cited in denying
Coughlin's appeal of the walmart thing udnerlying coughlin's current suspension of 6/7/12...in
cr11-2064...)
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but, it is really interesting to note How Judge W. Gardner, nuetral arbiter of fact, recounts the
record in that trespass case in Longoni's transcript, especially iwth regard to the import of NRS
178.405 in the context of nrs 5.010 especially and considering the communications between
city atty Hazlett-Stevens, Hon. W. Gardner and then court appointed defense counsel Keith
Loomis in a clandestine status conference the morning of trial (totally unbeknownst to
Loomis's attorney client Coughlin, on 4/10/12)...
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while alternately citing to Coughlin's being removed from mental healt court by Judge Breen,
MD as a basis for denying a motions on 6 18 12, only to then rule as irrelevant any argument
Coughlin made to the basis for that removal (which is all pointless now, as the 5/7/12 ORder
by Judge Sferrazza transferring that iPhone case to Mental Health Court was violative of NRS
178.405 in that the order resolving the 2/27/12 ORder for Competency Evaluation in cr120376 did not even get signed and entered, with a file stamp until 5/9/12...so the whole mch
deal is void.. but check out Hon Gardners characterization of the trial setting vis a vis the 6 18
12 trial and other key dates, skillfully dealt with, yes indeed with respect to the pendecy of an
Order for Competency Evaluation during key times, Coughlin interlineations will be in bold
and in parentheses...:
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"Hon. Judge Gardner: On November 13th, 2011, Mr. Coughlin was arrested
by the Reno Police Department and charged with one count of trespassing.
On November 14'h, 2011, Mr. Coughlin was arraigned and pled not guilty.
Trial was then set for December 13th, 20 11.
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On November 23'd, 2011, a Motion to Continue was filed by
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the City Attorney, a Hill motion is what I'll call it, based on an absent
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witness. I believe it was Mr. Hill, not related to the Hill motion.
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MR. HAZLETT-STEVENS: That's the original motion, yes.
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THE COURT: That was not opposed by Defendant's counsel at

the time (that would have been RMC court appoint counsel Lew Taitel,
whose business partners NEvada court Services Coughlin was suing at
the time incident to their work for Richard G. Hill and Casey Baker).
And on November 28th, I entered an order continuing the trial the first time.
The trial was then reset for January 30th, 2012. On January 3,d, 2012, a
Motion to Continue was filed by Mr. Puentes, your attorney at the time. The
City Attorney did not object.
On January 18th, I -well, prior to that, before the ruling on that motion, on
January 18th, Mr. Puentes filed a Motion to Withdraw as your attorney.
On February 2nd, 2012, I scheduled a (inaudible) hearing on the Motion to
Withdraw. The motion was granted, and Mr. Loomis was appointed.
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On February 13th, 2012, you filed, Mr. Coughlin, a Motion to Vacate, a

Motion for Reconsideration for Recusal.
On February 22nd, 2012, an Opposition to the Motion was filed by the City
Attorney.
Trial, then at that point, was ultimately reset for April 10th, 2012.
(that trial setting is file stamped 3/7/12 in that RMC case 11 cr 26405,
which, curiously is avoide throughout this recitation of the "docket",
which is awfully tough to get a copy of from the RMC. Now Coughlin's
11/14/12 Disciplinary Hearing before the Panel and SBN involves three
grievances. ng12-0204, filed by Richard HIll, ng12-0434, filed by RMC
Judge Nash Holmes, in relation to finding Coughlin in "summary
criminal contempt" despite cooke and in re oliver and the whole "every
essential element occured within the immediate presence" etc., etc. and
despite some real slippery shadowy reconting as rendered stuff about a
restroom break, o affidavits signed by any Ct. Marshals at to whatever it
was they said to Judge Nash Holme and whatever remixing of the order
of bathroom breaks and search incidents to arrest, and going back to the
jail the next day to retrieve the attorney's smart phone and data card
may have actually occurred...but the talkign point is this: ON 2/27/12 IN
RCR2012-065630 ANOTHER ORDER FOR COMPETENCY
EVALUATION WAS ENTERED AS TO COUGHLIN. A couple hours
later, after Judge Nash HOlmes was finally found by her staff, the traffic
citation trial in connection with RPD citing Couglin at Hill's law office
for 3 minor traffic ciolations 11 tr 26800 was held, despite Judge Nash
Holmes admission in her grievance to bar counsel on 3/14/12, which
became ng12-0434....the third grievance, strangely stamped as received in
the sBN 3/15/12 with the "5" in the "15" looking a little under the
weather, is ng12-0435, and like a baby left on a doorstep after someone
rings the doorbell and runs away...its pretty murky just how that "three
year old Order in a completely unrelated case" as HOn. W. Garner
characterizes it, which he admits to passing from his sister to the other
RMC Judges shorlty before judge Nash HOlmes submitted her "box of
materials" to the SBN along with her grievance against Coughlin (whose
filings, to her, represent the singularly most disturbing pieces of legal
work she has seen in her 35 years in this business".. because Coughlin
can be a real Kunstler)
On March 5th, 2012, Mr. Coughlin, you filed a motion actually captioned in
the District Court, but it made itself -it did make itself appropriate to our file.
On March 21'" you filed another Motion -the City filed a (Page -6- (of
Longoni's transcript)
Motion to strike your motion based on no service on the City Attorney.
On January 20th, 2012 (must be referring to the ORder that says "filed in
error" and has a new file stampe of 2/20/12, one of several instances of
such "filed in error" restampings in this case and other RMC cases, here
is seems to have little important and to be a simple scrivenor stamper
error), I entered an order, number one, denying your motion that was filed on
February 13th, 2012. On March 21st, 2012, I entered a second order denying
your Motion to Dismiss that was filed on March 5th, 2012.
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(if you are waiting for Judge W. Gardner to indicate there was an Order
SEtting for Trial this crimina trespass case on 3/7/12 (setting the first
trial date of 4/10/12...at which a curious order of things went like this...Ct
finds Coughlin question of competency regarding Coughlin...then court
grants Loomis Motion to Withdraw...huh? nrs 178.405 "stay the
proceedings', not "grant Loomis one of his many, many succesful Motion
to Withdraw in his "work" as a court appointed "defense counsel" for
the RMC)...you will be waiting a long time, becaues he never managed to
point that out....nor did he point out that the 5/8/12 stamped "Trial
Setting" (setting the 6/18/12 trial date) was also violative of nrs 178.405
vis a vis nrs 5.010 (and even without 5.010 is it) given the ORer in cr120376 wasn't signed and entered until 5/9/12...but Hon. J. Garnder does
manage to mention cr12-0376, just not the fact that all these Trial setting
and ORers granting withdraws (similar ot the one Henry Sotelo, ESq.
anothe McGeorge former prosecutor court appointed defense counsel at
the RMC got in 12 cr 12520 during the pendency of Coughlin third
Competency Evaluation ORder.)
And then on April 10th, 2012, I suspended the proceedings based on a
competency issue that had been raised in the District Court.(well, actuall it
was more than 'raise" by the 2/27/12 Order in the justice court that
Gardner's fellow RMC judge Nash HOlmes appears to reference ever so
curiosly in her 3/14/12 greivance against coughlin with the sbn) And then
at that time, at your request, Mr. Loomis was relieved as your attorney.
(request is putting is charitably...if Loomis is more of a prosecutor than
the prosecutor, is one deciding to go it along, albeit during the pendency
of a competnecy order that precludes any such violation of the attendant
stay..is that really a "request"?)
On April 26th, 2012, in District Court, Judge Elliott found you competent to
stand trial.
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(well...isn't the order finding Couglin Competent in that case cr12-0376

actually file stamped 5/9/12? doesn't the jail rip peopel off their
medications during times liek the 8 day jail stay Couglin got from apri
19th, to april 26th, 2012 when DDA Zach Young committed one of his
many numerous violationso of nrs 178.405 in seeking to have Coughlin's
bail revocked based upon some lies in a letter filed with the court by
Lakes Crossing's Bill Davis and Sally Farmer (class ic was a jail booking
area phone call between davis and Coughlin, recorded by the jail, we'll se
if the produce it. wherein DAvis claims that he "didn't write the letter"
that bares his signature as a Ph.D. and was filed on 4/17/12 in cr12-0376
and cited to extensively by d10 Judge Steven Elliot (the judge on the
associate 60317, the companion case to the instant 60302) as a basis,
along with Young's nrs 178.405 violative Motion, for ripping a license
attorney, on the spot, with no stay, away from his practice and client's,
with no opposition of any import, zeal, or skill by wcpd Biray Dogan, and
refusing to even consider the legal research Coughlin attempted to
submit to the court vis a vis whether these retaliatory competency
evaluations are "blank checks" into a criminal defendants entire
medical/mental health HIPAA protected records. Top it off, Biray
Dogan, just after an express direction not to by Coughlin, announces the
name of a medication Coughlin takes into the record, in front of 40
members of teh public and bar milling about, and Dogan's boss Jeremy
Bosler later refuses to move to strike or ameliorate in any way Dogan's
error. Oh, also the WCPD, and the RJC co-signs this in some instances,
maintains the position that defendnats don't have a right to know be
apprised of very important filings in their cases by their court appointe
counse...its, uh...not a duty to communicate with client's situation or
anything...at least when its a public defender, and dogan got an $8K raise
during one of the worst economic years in our nations history recently.)
On May 19th, 2012, Judge Elliott signed an Order finding you competent
(actually it was 5/9/12) and remanded whatever case was pending in the
Justice Court back to the Justice Court, and then I reset trial for June 18th,
2012, today's date. (WHOA! HOLD ON THER JUDGE
GARDNER...about that "and then I reset trial for June 18th, 2012"
bit...don't you mean you set trial for 6/18/12 on the record (which the
SBN admits getting, though Pat Hill, or Richard King, er, I mean Pat
King indicates he finds it hard to listen to such stuff and do much reading
or research or anything of that sort) Becuase Hon. J. Gardner set the
6/18/12 Trial on 5/8/12, and that was a violation of NRs 178.405. the fifth
or sixth he made in that criminal trespass case where he swears he was
able to be a "neutral arbiter of fact" despite all the conflicts attendnat to
the matters set forth herein.)
On May 7th, 2012, Judge Sferrazza assigned that case in the Justice Court to
the Mental Health Court. On May 24th, Judge Breen, the District Court
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Judge, and the Judge responsible for the administration -him and Judge Blake,
one of the two Judges, sent the case back to the Reno Justice Court. (at least
Judge SFerrazza lets cases go when he hands them over to the MCH,
rather then do what the RMC Judges do, which is "stay" the
proceedings, but retain jurisdiction in the RMC rather than transfer it
the the MCH...but regardless, given the ORder resolving the 2/27/12
ORder wasn't signed and entered until 5/9/12...that 5/7/12 Order by
Judge Sferrazza was void)
Then on June 5th, you filed the motion we're talking about now, including the
Motion to Continue."
(the one Hazlett-Stevens "wasn't served with", uh huh. City of Reno
Drop box that front desk security at city hall says will work for City
attorney's? that one, Hazlett-Stevens? literally every second of the 11 cr
26405 criminal trespass trial is dripping with that which really really
needs a good careful close inspection for misconduct, from the
"substance" of the 6/5/12 Motion, to the violations of the stay,the the
arguing things not in the record in closing by Hazlett-Stevens, the the
"civil eviction stuff is relevant when the prosecution needs to coopt it to
atempt to leverage a criminal trespass warning from "rendition"
(criminal law concept nrs 189.010) of an eviction order (no matter how
completely different the Order(s) may have wound up being once put
through Hill and Baker's truth factory) to all "civil eviction law is
compeltely not relevant to this criminal trespass matter...i will decide
what rules apply as to service of the eviction order by the facts as
developed through testimony at trial,...i don't want to hear you get all far
afield with legal argument about the rules applicable to civil evi tion
orders...." too bad, because you would miss the rich moments like Casey
Baker, Esq. having to admit that, despite his office biling the landlord
$60K in attorneys fees, Baker was unaware that NRS 40.400 makes
applicabe the NRCP, not the JCRCP, to summary evictions in Nevada
(and therefore NRCP 5 and NRCP 6(e), where, as there, no personal
service of eviction order)..to Hill and Bakers sworn testimony, to the
RMc filing OFfices record keeping, to the failure to stamp in the timely
notice of appeal in cr12-1262, which resulted in a dismissal of the appeal
by...wait for it...Judge Steven Elliot)
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...
COURT: Yeah, I don't know exactly what happened, Mr. Coughlin. I
appreciate that. I'm reading from Judge Breen's Order that "The Defendant be
removed from the Mental Health Program, and that you be returned to the
Reno Justice Court for all future proceedings."
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So, whatever happened over there, which I'm not privy to, and which I don't
think really is related or relevant to this case, we're going to not delay these
proceedings by sending the case over there.
Finally, that leaves the issue ofrecusal. You have, while not raised in the
caption of the pleading, it is identified in the pleadings you raised, on page
two, we've addressed this issue before in detail.
I've denied that Motion to Recuse. There's nothing raised that even (inaudible)
prevents me from hearing this case and being a fair, detached observer to the
facts oflaw, so that will be denied.
MR. COUGHLIN: Your Honor, if! could quickly enter an objection for the
record on that. THE COURT: Go ahead.
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MR. COUGHLIN: And just to preface that by saying everybody I've talked to
has indicated you're an outstanding Judge, Your Honor, and completely fair,
so that's definitely given me a lot of confidence in the Court in that regard.
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But I do believe there might be -I don't know if it's a judicial (inaudible)

(canon, Ms. Longoni, canon....that would be another instance of an
appeable issue, like in cr12-1018 being chalked up to, by the RMC's
Longoni as "inaudible") or something that says where a Judge has litigants
before him who have a case involving a family member of the Judge, in some
other sphere. I don't know if that's a mandatory recusal, but I did file a
mandatory habeas action against your sister, the Honorable Judge Linda
Gardner, in Family Court in 2009. I was fired from my job as a domestic
violence attorney from Washoe Legal Services, and I was told I was fired
because of her -because of the conduct by me that resulted in her order only.
It's the only reason I was fired, according to Washoe Legal Services.
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I did file a Mandamus Petition. It was pretty much a three judge panel, and
the Supreme Court felt it wasn't worthy of, I guess, more review or requiring
a response.
And then now there is a grievance with the State Bar. I call it -not to be flip,
but I call it kind of the immolate conception grievance because nobody can
tell me who filed it, or how it became a grievance.
But that order from 2009 sanctioned me requiring me to pay $\,000 attorney's
fees, NRS (inaudible) .085. In the context of my being a domestic violence
legal aid attorney advocating on behalf of my client, a battered woman, trying
to get her alimony incident to a 20-year marriage with two kids, wherein I
was ordered to pay $\,000 out of my pocket, that's now a grievance.
Page -16-
It's upon infonnation and belief it became a grievance with the
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State Bar because your sister, Judge Linda Gardner, gave the order to
you, whereupon I believe you indicated you gave it to Judge Nash
Holmes, whereupon Judge Nash Holmes gave it to bar counsel, along
with a number of other materials that I have not been privy to, either in
my attempts to secure them from the filing office here at the Muni Court,
or from bar counsel, Mr. Patrick Kinney (king).
I've made numerous attempts to get these recordings and these different
materials. So, just to enter that for the record, Your Honor.
THE COURT: Alright, thank you, Mr. Coughlin. And let me just tell you this.
That case goes back to the Family Court, I have no real knowledge, except I
have read the Order. It's unrelated and irrelevant to this case. I have not really
discussed the merits of this case with my sister who is a Judge in the Family
Court.
There would be no reason to discuss that case, and even if that would have
happened, we have not -there's really no nexus between her being a Judge and
having heard a case where you're an attorney on, and my being a Judge some
three years later on a case where you are a Defendant in.
So, the Motion to Recuse is denied. And I think that identifies the issues
raised in your Motion filed June 5th, 2012. It looks like now we're ready to go
to trial, is that correct, counsel?
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MR. HAZLETT -STEVENS: The City is ready, Your Honor. THE COURT:
Alright, let's go ahead and call your first witness, Mr. Hazlett-Stevens.
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MR. HAZLETT-STEVENS: The City calls Richard Hill to the

stand.
MR. COUGHLIN: And, Your Honor, I don't know if I'm supposed to intelject
this now, or not, but I believe I did subpoena some witnesses who appear
(inaudible) (uh, Pam Longoni, thats another "inaudible" on another
appealable issue, that being the failure to grant a subpoena where, if that
is the case here, Sargnet Marcia Lopez and Officer Chris Carter were
subpoened (apparently they were by the city attorney, and Coughlin
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asserted he though he did subpoena them, but indicated some ambiguity

or uncertainty in that regard...but "inaudible" doesn't quite preserve the
appealable issue).
THE COURT: Right, and we'll address that at the appropriate time.
Ultimately, Mr. Coughlin is a lawyer. B (not according the the SBN and
this Court's 6/7/12 ORder that Judge Gardner admits to haveing been
apprised of...Coughlin couldn't issue supboenas like an attorney, post
6/7/12, could he?) You know we take these -Mr. Hill, good morning.
MR. HILL: Good morning, sir.
THE COURT: We take these matters step by step by step. There's no other
way to do it, so we'll address all legal issues as they show up in the due
course, and pursuant to protocol at trial.
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So, let's swear in Mr. Hill. (Witness duly sworn). THE COURT: Have a seat,
Mr. Hill. Mr. Hazlett-Stevens, go ahead. MR. HAZLETT-STEVENS: Thank
you, Your Honor.
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RICHARD HILL
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called as a witness, having been duly sworn,
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testified as follows:
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DIRECT EXAMINA nON BY MR. HAZLETT-STEVENS: Q Good

morning, can you please state your name, and spell your last for the record?
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Page -19THE COURT: You know, Mr. Hazlett-Stevens, and Mr. -let
me make one last comment for the record.
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MR. HAZLETT-STEVENS: Please.
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THE COURT: I know that Mr. Coughlin is an attorney. Nonetheless, he's

representing himself.
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Mr. Coughlin, let me tell you what I know about this case to date. I am
looking at a Criminal Complaint that alleges that on November 13th, 2011, in
the City ofReno, at 121 River Rock Street, the Defendant was found on the
property after being evicted on November 1st, 2011.
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The only other information I know about the case is that the whatever was
raised in the pleadings filed, both by you and Mr. Hazlett-Stevens.(maybe
Loomis and Puentes didn't file anything? Oh, wait, did they attach all of
Coughlin's emails to them detail the Richard HIll Judge Nash HOlmes
nexus? Really?)
So, with that in mind, go ahead, Mr. Hazlett-Stevens. MR. HAZLETTSTEVENS: Thank you. BY MR. HAZLETT-STEVENS: Q Thank you. Can
you please state your name, and spell your last for the record?
A Richard Hill, H-I-L-L.
Q Good, Mr. Hill, I'm going to ask you MR.
COUGHLIN: I'm sorry, I don't mean to interrupt you, Mr. Hazlett-Stevens. If!
could just quickly interject, Your Honor, given what you just said, to any
extent, I'm required to broach the topic of any discussions you've had with
Judge Nash Holmes with respect to these
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matters or -
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THE COURT: I can tell you that Judge Nash Holmes and I have
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not discussed this case with anybody, we have not. There has been no
discussions between me and the Judge about your case, the trespassing, set for
today.
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MR. COUGHLIN: Or any other matters related to Richard Hill?
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THE COURT: Or any other matters. We've never discussed any matters
related to Richard Hill at all.
MR. COUGHLIN: Okay, and when you said you and your sister had never
discussed anything about me?
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THE COURT: Not related to this case.
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MR. COUGHLIN: I believe earlier you just said you never discussed
anything about me at all. MR. HAZLETT-STEVENS: Judge, you've already
ruled on this. I'm going to ask that you THE
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COURT: We have ruled. Let me tell you -let me tell you what I've discussed.
We have discussed -I have not discussed with Judge Nash Holmes and I am
advised that based on some steps she's taken, there's been a matter referred to
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the State Bar which is under, if not -I'm aware that you have been suspended
by the State Bar, and that that's subject to further review.
To the extent that Judge Holmes has had a case in her department, as has
Judge Howard, and has myself, we have had discussions, general discussions
related to the State Bar matter. (Judge W. Gardner is referring to the three
grievances forming the scr 105 Complaint set for a disciplinary hearing
on 11/14 12, consisting of one grievance by Hill, one by jUdge Nash
HOlmes stemming from a traffic citation trial where the citation was
issued by the rpd outside Hill's office after they told Coughlin to leave
(which he did, but the RPD wasn't satisfied so they pulled him over while
he was leaving) in 11 tr 26800, where, on the record, Judge Nash HOlmes
threatened Coughlin with "IF you say Richard HIll's name one more
time I am going to put you in jail for contempt, do you understand me!",
and where Holmes eventually did find Couglin guilty of "summary
criminal contempt" denied a stay to a practicing attorney askign for a
chance to make alternate arrangments for his clients, and had Coughlin
cuffed, searched, and taken the the WCDC, not that gently either...only
to have the RMC Marshal return well after an period wherein the
"incident to" part of a "search incident to arrest" could be said to be
possible, to retrieve a licensed attorney's smart phone, micro sd card, and
other items...with all the date wiped or destroyed therein prior to being
returned to then licensed attorney Coughlin some 37 days later...with a
chain of custody in between deserving a whole lotta second looks (Mary
Kandaras? anything? Deputy Hodge? Marshals Coppa or Deighton?
Deputy Cheung? How about you WCSO's Debi Cummings, Brandi
Berriman, Deputy Beatson, Deputy Van der Wall, or Patricia Beckman?
Anything? Deputy Iver? No?s)
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As related to my conversations with either my sister, which have been very

limited related to you, and certainly none related to your
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case, except you had a case over here, I've had no discussions with Judge
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Howard, Judge Holmes, Mr. Hill, Mr. Hazlett-Stevens,(well, actually the

Hon. W. Gardner did, on the record in the first attempt at a Trial in that
trespass case on 4/10/12 admit the he, City of Reno Prosecutor HazlettStevens, eSq. Coughlin' court appointed counsel Keith Loomis, Esq. did
get together in a back room that morning and hash some stuff out....but
judge Gardner would later indicate all this stuff was very "planned out"
and done "very carefully" and whatnot) or my sister regarding this
trespassing case. And that's by design that was carefully thought out so there's
been no discussions.
MR. COUGHLIN: And with the State Bar, I know earlier THE
COURT: I have had no conversations with the State Bar.
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MR. COUGHLIN: Okay, at our last hearing though you made a statement, I
believe, the disciplinary or the Bar will be meeting next week to make aTHE COURT: I was advised by Judge Holmes that the process involving you
and the State Bar was in the process where they were going to make a
decision, which ultimately apparently they did. Those were the substances of
those conversations, but none were related to this case, and I can tell you that
none have had any conversations regarding the witnesses in this case that
have never come up between any of the counsel. I'm not sure they even know
who the witnesses were quite frankly.
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MR. COUGHLIN: Okay.
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THE COURT: Okay, thank you.
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MR. COUGHLIN: Thank you, Your Honor.
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THE COURT: Okay, let's go ahead and proceed. BY MR. HAZLETTSTEVENS:

Q Thank you. Mr. Hill, I'm going to ask you to make sure you speak up and
not trail off your answers at the end. This is being recorded, so for appellate
purposes, or any other purpose, I'd like to get a good recording of this.
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Page -21Mr.
Hill, what's your occupation or profession?
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I am an attorney practicing in Reno, Nevada."
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And so on and so of.. Richard G. Hill and Casey Baker seeking to charge the
same rent as they did for "full use and occupany" as relevant to a claim of
right defense to the criminal trespass charge? Not relevant according to Judge
Gardner. RPD misconduct and Hill and Merliss's lies contributing to false
arrest and Hill's perjured sworn testimony detailed extensively in 61901, as is
Casey Baker, Esq.'s professional misconduct in doing in violation of NRCP
11 that which Hill chickened out doing in his Declarations of 11/21/11 and
1/20/12, until the necessity and exigency of his misdeeds and professional
negligence ("wrong site surger" equals using summary eviction proceeding
where only No Cause basis pled or noticed, agains commercial tenant, in
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express violation of NRs 4.0253 and even this Court's simplified instructions
in the "Landlord Tenant Handbook" (really choice how the instructions to the
forms on lockouts seem to adopt WLS's Sasser, ASsemblyman Horne and
Frierson and Segerblom's wishes as to the "within 24 hours" languagne being
interpreted to be no sooner than "within 24 hours" which, you can be sure,
aint how summary eviction order lockouts are being carried out. Ask NVB
Judge Beesley about Coughlin's ultra sheek t shirt and tie combination under
the old blased at 2:00Pm on 3/25/12 in Cadle Company v Keller ($1.6 million
dollar debt adversary proceeding) where Coughlin manage to appear (finding
a dress shirt was a problem given Coughlin used the scant 5 minutes WCSO
deputies durbina and cannizzaro accorded him at 1:30 pm ish on 3/15/12 to
grab his computers, client's files, medications, contacts, glasses and whatnot
after they broke in at gunpoint and evicted Coughlin, as they do to all citizens
of Washoe County subject to a summary eviction order. GAyle Kern, Esq.?
paging Gayle Kern...rjc rev2012-000374) But the great thing is that Casey
Baker testified on 6/18/12 that:
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A That's correct. Q So, the Findings of Facts, Conclusions of Law and
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Order of Eviction found in your favor, Mr. Merliss's favor, rather, and the
date of eviction was as of October 31" at 5:00 p.m., correct? A That's correct.
That's what we announced in Court and put on that Findings of Fact. Q And
that Order said that anyone there after that date could be removed, is that
correct?
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That was the command given to the Sheriff.
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"Shall be removed."
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Yes.
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Page -66Page
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-67Q Did you serve that document on Mr. Coughlin in any fashion? A Notice of
Entry of Order or anything like that? Or was that served by the Court on him?
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A The way it works is the Court -after the Court enters the Order, the Court
forwards it to the Sheriff. Q Okay.
A And the Sheriff goes out and enforces the order.
Q Okay, now I'm going to draw your attention to the date of November 13th,
201 1.
THE COURT: What was that date again?
MR. HAZLETT-STEVENS: November 13, 2011, Your Honor.
THE COURT: Okay, give me just a second, counsel.
MR. HAZLETT-STEVENS: Certainly, Judge.
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THE COURT: I'm making some notes here regarding some dates.
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MR. HAZLETT-STEVENS: And I'm going to withdraw that question, Your
Honor, so if you don't want to jot that note down, you don't have to at this
point.
THE COURT: Okay, I'm looking at something else, okay. Go ahead. Thank
you, counsel. BY MR. HAZLETT-STEVENS:
Q I'm going to draw your attention to the date of November 1 st, 2011. Do
you recall what you were doing that day?
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A Yes, I was actually off of work that day. I was at home.
-68Q Okay. A But I was basically on stand-by because I knew that the eviction
was going to happen. Q Okay, and did you actually eventually respond or
have to come to the area of 121 River Rock?
A Yes.
Q Why?
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A The way it works, again, I'm sorry to keep doing this.
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Q Please, please, please, you are educating us all.
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A You have to wait for the Sheriff to contact you.
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Q Okay.
A The Sheriffs Deputies are sent out with several of these
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things on the days that they do them, however, they do them every day. You
can try to shoot for a specific time, but you are at the mercy of the Sheriffs
Deputy's schedule. Some lockouts take longer than others. They try to give
you lead time.
I had spoken with the Sheriffs Deputy already, I believe, on Friday the 28th
Q Okay. A I believe. It was either that, or I contacted him on his cell phone.
But I came back in (inaudible) do the lockouts.
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THE COURT: I'm sorry?
THE WITNESS: I came back in so we could do the lockout, to meet the
Sheriffs Deputies at the property after the Sheriff calls. Q Okay, and so you
actually did go to 121 River Rock?
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A Yes.
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Q And were there Sheriffs Deputies there?
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A I got there first.
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Q Okay.
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A Along with a member of our staff.
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Q Okay.
A And then two Sheriff's Deputies arrived.
Q Okay.
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A And then we had to wait for the locksmith.
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Q Okay, when the Sheriff's Deputies arrived, did they
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have any documents in their hand? A I believe they had -yes, they had their
copies of the Findings of Fact, and Order for Summary Eviction. Q Okay, and
do you recall what the deputies, or one or both of those deputies did with the
Findings of Facts and Order of Eviction?
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A Yes":
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Now, combine that testimony with the fact that the WCSO Liz STuchell, Roxy Silve, Deputy
Machen, Maureen, etc., etc. get real uncomfortable when it comes to discussing just when they
"received" either the 10/25/11 Eviction Order and Decision of the 10/27/11 Findings of Fact,
Conclusions of Law....combined the the RJC's various statements respecting just how and when the
WCSO gets those eviction orders, and the usual custom and practices...combined with the WCSO's
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statements about the maintenance of the faxes, the fax headers, the singular copies of those faxes
being filed back with the court transmitting them along with the Deputies AFfidavit of Service (like
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th 11/7/11 one where Deputy Machen swore he "personally served" Coughlin, despite his supervisor
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Liz Stuchell having to later admit in writing that to Machen "personally served" means "taped it to
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the door when no one was home"...and you know when HIll testified on 6/18/12 about "they taped it
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to to door because you ran away" that, given Baker's testimony that HIll was not present on that
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date, 11/1/11, and Baker's failure to make any such allegation...that Hill was just doing more of the
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same tired innuendo and baseless accusation, conveniently made to disguise yet another situation
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where his reckless pursuit of fee generation clashes with the rules of professional conduct attendant
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to his privilege to practice law.
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some choice excerpts from the unofficial transcript of the rjc rev2011-001708 richard g. hill casey
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baker summary eviction proceeding on 101311 (then after the Court rule Coughlin met the Anvui
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STandard to establish a genuine issue of material fact, the case was set for "Trial" though without
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enough notice under JCRCP 109, and the court didn't let coughlin bring counterclaims, do
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discovery, etc., etc.):
Judge: Well I dont know what the third party complaints are but the issue of territory
eviction may or may not.
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Plaintiff: Your Honor under NRS 20A.510 the burden is on Mr. Coughlin to show retaliation,
he has not done that. He has not offered any proof that there is any sort of
retaliation here. The parties, the whole purpose of the 30 day notice and the
statute and then the lease is freedom of contract Your Honor. Once Mr.
Coughlin is a month to month tenant the landlord is free to terminate the lease
with 30 days notice Mr. Coughlin is free to move out with 30 days notice. If we
flip it around and Mr. Coughlin had given 30 days notice and we had come
down here tried to stop him from moving this doesnt make any sense Your
Honor. There has been no proof put forward that there is any retaliation here.
Judge: Well actually I have no proof so far that the lease is over or anything else. I dont even
have a copy of the lease.
Defendant: Your Honor the statute provides that I am to provide that today and I have
copies here.
Plaintiff: Your Honor Rule 109 speaks to a 20 day period notice prior to a hearing which I
believe is applicable in this case and has not been provided.
Defendant: Im sorry I didnt catch any of that.
Judge: He said.
Plaintiff: Rule 109 Your Honor, setting of trial and actions. Your Honor NRS 118A.510 speaks
for retaliatory conduct by the landlord against the tenant. It goes into the
extent to which notice is required and up to date to put on a defense and to
litigate those claims as afforded to [inaudible 0:05:50] turning off their power
in the middle of the five
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day notice period is unduly burdensome and it I believe is in violation of the federal statutes
and state statutes respecting the appropriate notice one must give to tenants
prior to shoving them out.
Defendant: Your Honor I have a copy of the lease here would you like to see it?
Judge: Yes please.
Defendant: I attach that to my
Judge: The section you are starting to sort of apply [inaudible 0:06:24] you are not going
under summary eviction. This is a summary eviction.
Defendant: I thought you said at the outset that this was a no cause not a summary eviction
Your Honor or Mr. Baker said that?
Judge: No cause is summary. ...
those claims as afforded to [inaudible 0:05:50] turning off their power in the middle of the
fday notice period is unduly burdensome and it I believe is in violation of the
federal statutes and state statutes respecting the appropriate notice one must give
to tenants prior to shoving them out.
Defendant: Your Honor I have a copy of the lease here would you like to see it?
Judge: Yes please.
Defendant: I attach that to my
Judge: The section you are starting to sort of apply [inaudible 0:06:24] you are not going
under summary eviction. This is a summary eviction.
Defendant: I thought you said at the outset that this was a no cause not a summary eviction
Your Honor or Mr. Baker said that?
Judge: No cause is summary. ....Defendant: I remember the hearing Your Honor and I just, I would
think there is something that when a tenant alleges a retaliatory eviction that the
summary and extremely quick nature of this process is slowed somewhat. Judge: Only
if the court finds that there is a meritorious defense, which I havent done so, I havent
even been presented any evidence to persuade me that you have any meritorious
defense whatsoever. Defendant: Are you sure Your Honor?. Judge: And I am giving
you that opportunity to proceed. So do you want to proceed or not? Defendant: Yes sir
Your Honor I have abundance of evidence in support. Judge: Come up here and take
the stand, sir. Defendant: Yes sir Your Honor may I bring my laptop with me because
it has pictures that I intend to offer and a videotape as well? Judge: Wait a second sir,
no you may not what am asking you for is to establish a prima facie case of retaliatory
eviction through your testimony and then if I determine and establish the prima facie
case then well set it over for trial. Defendant: Yes sir Your Honor. Judge: So if you
want to come up here. Go ahead sir. 11 Defendant: Defendant: I remember the hearing
Your Honor and I just, I would think there is something that when a tenant alleges a
retaliatory eviction that the summary and extremely quick nature of this process is
slowed somewhat. Judge: Only if the court finds that there is a meritorious defense,
which I havent done so, I havent even been presented any evidence to persuade me
that you have any meritorious defense whatsoever. Defendant: Are you sure Your
Honor?. Judge: And I am giving you that opportunity to proceed. So do you want to
proceed or not? Defendant: Yes sir Your Honor I have abundance of evidence in
support. Judge: Come up here and take the stand, sir. Defendant: Yes sir Your Honor
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may I bring my laptop with me because it has pictures that I intend to offer and a
videotape as well? Judge: Wait a second sir, no you may not what am asking you for is
to establish a prima facie case of retaliatory eviction through your testimony and then
if I determine and establish the prima facie case then well set it over for trial.
Defendant: Yes sir Your Honor. Judge: So if you want to come up here. Go ahead sir.
11 Defendant:.....Defendant: It does Your Honor, it says by his agents or employees he
is responsible. Judge: Yeah and [inaudible 0:48:58] that they are his agents I find they
are in independent contractor and so if you deposit the rent by Monday at 9:00 oclock
with the court in the amount of 2275 I will continue this for trial on the merits to
determine whether or not there really is a habitability issue. If the rent is not deposited
then there will be no continuance the eviction will be granted forthwith on Monday
morning at 9:00 oclock. And furthermore the court is now making any finding other
than that you have made an argument about habitability and that you are entitled to
trial on that issue if you deposit the rent. Alright but you are not entitled to trial if you
dont deposit the rent. And I have given you credit based on your allegation which is,
which I do not find was substantiated today; I simply find that you made that
allegation, that this is what you were owed. And so if you deposit the rent then we will
set this for trial and it will be the following week after that on the same court day. The
same day of the week.
THIS IS THE START OF THE TRIAL ON OCTOBER 25TH, 2011 102511 IN 1708: Judge: And
we have a trial. Okay, the next is Matthew Merliss versus Casey -- oh, I'm sorry,
versus Zachary Coughlin. Casey Baker represents the plaintiff in this matter and this
was the time set for determination on the no cause eviction and -- are the parties ready
to proceed? Plaintiff: Just one moment, Your Honor. Defendant: [INDISCERNIBLE
0:57] first. Judge: Is that this? We'll hear it. Come up. Plaintiff: I believe that would be
it, Your Honor. Judge: All right. Plaintiff: Just to make sure [INDISCERNIBLE 1:21].
Judge: Oh, you can all be seated. I'm trying to figure out where we are because when I
-- I was contacted by counsel for the plaintiff in respect to emergency request for
conference call with -- I did not have that. I was not here at the time when the request
came in, but I did grant an order short in time with respect to a motion to inspect the
property and I don't know if the property was inspected or not. Plaintiff: No, Your
Honor. The property was not inspected. Judge: And do you desire to have the
inspection before going forward with this proceeding today or no? Plaintiff: Well, my
understanding in this proceeding, Your Honor, is that this Mr. Coughlin's chance to
present -- to substantiate his legal defense that he's trying to present here. Mr.
Coughlin, after the last hearing, deposited the rent with the court as the court ordered,
so he got himself another bite at the apple. If Mr. Coughlin is going to proceed and
present evidence of what he claims are habitability issues, then I may ask the court to
adjourn so we can go inspect. But I've not seen anything of Mr. Coughlin since 29 the
last hearing, nothing has been produced, other than a couple of motions and a notice of
appeal which we do not believe is effective. Judge: Well, it may be effective, but it
doesnt stay these proceedings. Plaintiff: No, and it's not an appeal [INDISCERNIBLE
3:45] that Mr. Coughlin appealed anyways and no, it does not stay these proceedings.
You're absolutely correct, sir. I guess the way I would suggest that we proceed is, if
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Mr. Coughlin wants to proceed, and he presents anything and I think we need to go
inspect, then I would ask the court to adjourn. I don't want to waste the court's time
any more on this-- Judge: Right. Plaintiff: Than absolutely necessary. And I've never
seen this before. I don't know what this is so I can't really address it, Your Honor.
Judge: And so they do have a right to respond to this, so I'm not going to consider this
today. They'll have 10 days to respond to this. Plaintiff: Your Honor, if I may as well,
there was something shoved through my mail slot last night as well from Mr. Coughlin
bearing a file stamp of yesterday, Emergency Demand for Jury Trial and Amended
Tenant's Affidavit Answer Counter-Claim. Again, I havent had a chance to look at
this. I know it's not appropriate to have a jury trial here and the court has already ruled
that there's not been entertaining a third party claims, this is a summary eviction. But,
again, I havent had a chance to even look at this because it's [INDISCERNIBLE 3:45]
yesterday. Judge: All right. Well, you have 10 days to respond to that as well. So we'll
put those aside for the moment and -- now. So, assuming you -- what the court had
done at the last hearing I had given you credit against the rent which was owed $4,500
for the alleged habitability issues, which included a window at $150, stairs at $1,250,
weeds at $350 x 2, garbage disposal $125, mold $500, and that together was subtracted
from the $4,500. The 30 offsets totaled $2,725
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NOTE: It does not appear that Baker or Hill opposed the contentions in Coughlin's October 18th,
2011 filing in 1708 or the one from around October 24th, 2011. Those, in conjunction
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with the Tenant's Answer/AFfidavit itself of 10/5/11 clearly set forth the commercial
tenancy pled by Coughlin regarding his former home law office, and perhaps his foam
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mattress business (Coughlin Memory Foam, sole proprietorship started in 2004).
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Defendant: Yes. Yes, sir, Your Honor. Rather than having myself have another bite at the apple and
I'm responding in this situation that I've been required to, and in doing that, it's
afforded me an opportunity to 31 learn quite a bit about these proceedings. Maybe the
best place to start would be to bring up Las Vegas Justice Court Rule 44. Judge: Well,
I don't think that'd be a good spot to start at all because it doesnt apply. Defendant: If
you'll just humor me for a second, Your Honor, I'll tell you why I think that's
important. Las Vegas Justice Court Rule 44 speaks to a situation-- Plaintiff: Your
Honor, can I put my objection on the record to any discussion of Las Vegas Justice
Court Rules, please? Thank you. Judge: Well, your objection is noted, but I will allow
him to state whatever it is you're going to say. Defendant: Vegas [INDISCERNIBLE
9:29] enact 44 for a reason. Reno doesnt have 44. If it wanted to, it would have to
enact it and you get the Supreme Court to sign off on it. 44 Las Vegas 2 in the context
of a summary eviction proceeding require a deposit rent escrow. If the statute alone in
NRS 118A and NRS 40.253 in combination with the Nevada Justice Court Rules of
Civil Procedure, if just those three things alone allowed for making litigants of
summary eviction proceeding deposit monies into the rent escrow, Las Vegas would
have had no need to enact Rule 44. We dont have Rule 44 in Reno. Reno is very
different from Las Vegas. As such, I believe that the rent escrow amount should be
returned to me. It's my understanding that in a summary eviction proceeding, the

standard for summary judgment is to be applied. I apologize, Your Honor, for -- when
last you saw me on October 17th, I listened to the hearing and it seemed like I wasnt
getting to what you wanted me to get to,
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which was the most

important thing, to establish material issue of facts, to
make a prima facie case that I have a legal defense to
the -- Judge: Well, I accept that you did and that's
why we're having the trial today. 32 Defendant: And
that's -- I'm glad you bring that up. You said trial,
Your Honor. You didnt say summary eviction, you
didnt say summary execution. You said trial,
plenary-- Judge: Trial on a retaliatory nature of the
eviction. I assumed you made a prima facie case on
that as there's no trial on the issue. It is summary as to whether or
not you were given notice served, which the court finds you were, with a notice to
terminate your lease. Defendant: If I can just quickly interject for the record, Your
Honor-- Judge: Unless you had -- unless you have a lease to show that you're not there
at will at this point."
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Casey Baker's representations to the Court with respect to his view that the STandard Rental
AGreement made the lease "automatically temrinate by its terms" is further a lack of
candor to the tribunal, as the terms indicate the lease renews...
Defendant (Coughlin, the commercial tenant): Th...Your Honor, but when you say trial, it's
-- well, the most important thing, Your Honor, to get across from my
point of view, is that 40.253(6) says that when the court, as you just
indicated you did imply that there is a material issue of fact, it's a
pause-- Judge: No, I didnt imply that there was. I found that you
made a prima facie case-- Defendant: That's what I'm -- that's what I
meant to-- 33 Judge: With respect to habitability and so I set it for a
trial today on that issue. But the separate issue is whether you have
any defense, which you havent given me, to the no cause eviction,
which-- Defendant: And I do and I can speak to that briefly, Your
Honor, just-- Judge: They're two separate things. Well, you're not
under oath, sir, so you're arguing now and I didnt -- I let you have
some latitude, but the question is do you have any facts to present to
the court today? Defendant: Yes, Your Honor, but just one last
introductory matter-- Judge: Okay. Defendant: Is that 40.253(6) says
once the court has found there's a prima facie showing, the court
must pause and convert this to a full-scale unlawful detainer action
with a complaint and the 20-days notice incident to Rule 109 of the
summary eviction proceedings, so -- and we don't have that here."
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Defendant: You tell us what your order is and you said it was a trial that we were
having-- Judge: Well, I said that, but I stand corrected because I do
remember and I do have the order, so we will find the order.
Plaintiff (landlord's Casey Baker, Esq.): Your Honor, the use of the word
"trial" was unfortunate."
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A great Judge Sferrazza moment at the 12/20/11 Hearing on the MOtion to Contest Personal
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Property Lien...well a couple (one, to Coughlin: you have filed a Notice of Appeal, I am divested of
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jursidiction, so you can go an confuse the District Court with those arguments of yours now..."), but
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the best one, in response to Baker making essentially the "cherry pick" argument Hill makes in his
email below:
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"From:
Richard Hill (rhill@richardhillaw.com)
Sent: Sun 11/20/11 12:42 PM
zachcoughlin@hotmail.com
To:
Mr. Coughlin - you continue to lie.
You & I have spoken several times.
You call & rant at my secretary & then hang up before I can get on the line.
Please go back and re-read my emails to you.
You will not be allowed to cherry-pick the property & leave us with several
thousand dollars worth of clean-up.
May I suggest that a good starting point would be for you to arrange a
dumpster and throw all the crap in the backyard into it??
"
Judge Sferrazza (about any anticipated cherry picking by Coughlin): Well, I think that's what the
law is, though, so he can."
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What Judge Sferrazza so astutely points out there is the fact that, one, Hill, Baker and Merliss
can only get that which the legislature set out in 118A.460...and they need to cease their unlawful
rent distraints abolished by Nrs 118A.520 or otherwise trying to cram into nrs 118A.460,
malevolently, with utter baselessness, fraudulently, all the things they want to get out the situation
but which the lanlord did not have the foresight or bargaining power to demand be a part of the
Rental Agreement way back when.
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Futher problematic is the fact that WAshoe Legal SErvices employee Lew Taitel (well, RMC
fellow defender Keith Loomis, Esq. indicated Taitel now works for WLS incident to the ECR contract
WLS has with the WCDA's office, which arguably conflicts the WCDA out of prosecuting in a
retaliatory manner via DDA Zach Young of Coughlin in three separate criminal matters currently, all
three of which are rampant with police and prosecutorial misconduct (in RJC rcr20122-063341,
rcr2012-065630, and rcr2012-067980, and all three arrests and the officila misconduct therein is
capture in audio and video recordings...no matter, DDA Zach Young presses on headlong into his
assault on liberty, and apparently, Young is really able to do some real broken field running in the
current atmosphere). Here's the thing, though: Taitel is business partners withNevada Court
Services, which got Coughlin arrested twice between 6/28/12 and 7/3/12 (and Judge L. Gardner's
Brother Judge W. Gardner, in conjunction with RPD Officer Alan Weaver and SArgent Brian Dye
and Reno City Attorney Jill Drake) manage to get Coughlin's bail magnified a ridiculous factor of 10
for a completely fraudulent and lacking even a prima facie/probable cause basis for "distrubing the
peace" to which the rpd glommed on a "failure to secure a load on one's vehicle" and a "no proof of
insurance" (RPD Alan Weaver says the statute will not allow or a 5 inch high definition pdf of one's
current proof of insurance on a smart phone to satisfy the proof requirement...and Dye and Weaver, to
which Judge W. Gardner agreed, though there exists no "for your own health and safety" basis for
increasing bail as he did, magnified Coughli's bail from a bondable $1415 to a "straight cash homey"
$three stacks ($3,000), keeping Coughlin jail from July 3 to July 21st, 2012 (whereupon Coughlin's
old high school power forward Jared Swanson, owner of Western Art & Architecture and Big Sky
Journal plunked down the lucre to spring Couglin from the hoosegow...after weeks of Coughlin trying
to get through to someone, anyone, via the inscrutable and unfair WCDC collect calling phone
system. the WCDC denied Coughlin repeadtedly any paper to file any court filings and otherwise
impermissibly denied him access to the courts and his medication.
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(note" due to the exigencies of bar counsel and the board/panels violations of the due process
requirements of the scr's some of this filing has not been edited as closely as it would be, and some
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has been dictated to a transcription software that isn't that well trained ot Coughlin's voice.) Also, we
probably gonna be linin' up the staple holes on the allange or whatever because the cert of service
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by peters on the DowSoe Coughlin has is not for a DoWSoW, but rather for a Notice of
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hearing....Coughlin now as four envleops from the sbn with a 10/12/12 date somewhere on them and
all sorts of iteratiosn of other dates and yellow stickers and post marking etc. etc.. sothis needs more
review LITIGATION HOLD NOTICE...
Zach Coughlin submits the above titled on his own behalf and swears under penalty of perjury nrs
53.045 that he didn't receive in the us mail any October 9th, 2012 mailed or so NOtice of intent to
Take Default (and the cert. of mailing on that 10/9/12 Notice of INtent to Take Default indicates the
SBN, in that one instance apparently, curiously, departed from its stated and previously adhered to
practice of mailing every filing or notice/designation to Coughlin in two different manners (one, via
certified mailing, and two, via first clase mailing). Now...a mystery remains respecting the
DowSoE...when did Coughlin get it? Did the SBN mail out a Non certified mailing, ie, first class
version of it on 10/12/12, as Peter's cert seems to indicate? Did Couglin not get that first class
mailing of the DowSoE until substantially after the 10/12/12 mailing, and, if so, whose fault is that, if
any. Complications are present here in that Couglin filed a change of address with the USPS on or
about October 5th, 2012...and updated the SBN with his SCR sometime soon thereafter (under
somewhat of a protest given Coughlin is very frightened of local law enforcement and prosecutors at
this point, and is a domestic violence victim). Couglin feels failry certain the cert of mailing on the
10/9/12 Notice Intent Take Default indicates it was only sent via certified mailing (not even email or
faxing safety measures taken by SBN?)...And we now know that that 10/9/12 certified mailing large
manilla envelope by the SBN was rejected by the USPS (ie, the wouldn't let Coughlin claim it) in that
it only had $1.25 or so of postage on it (it need some $5 more dollars)....therefore any Order
purporting to require "a verified answer" by Couglin sometime soon departs form SCR's and the
stated practice and policies of the SBN vis a vis defaults in disciplinary cases, and attestations and
representations made by King, the SBN and Peters... or the purported Summary of Evidence and
Designation of Witnesses. Coughlin has a SoEDoW's that has a 10/12/12 proof of service signed by
Clerk Peters and the pleading itself (which is on a separate filing than the Notice of Hearing itself,
contra to the SCR 105(2)(c) mandate, to say nothing of the fact that Bar Counsel sent it rather than
the Panel (tsk, tsk). Coughlin just didn't get that DoWSoE in any 10/12/12 mailing...to the best of his
knowledge. Look, that is a BIG document to Coughlin, the DoWSoE...no way he has had it since 3
days or so after 10/12/12...The SBN is placed on A LITIGATION HOLD NOTICE TO RETAIN ANY
AND ALL MATERIALS BARING ON THE ISSUE OF JUST WHEN AND HOW THE SBN AND OR
NNDB'S PANEL TRANSMITTED ANYTHING AN VIA WHAT TYPE OF MAILING TO
COUGHLIN...AND BE SURE TO INCLUDE THAT BIG ENVELOPE THAT THE USPS WOULDN'T
LET ME TAKE THE OTHER DAY (WHICH THEY FAILED TO FIND WHEN PREVIOUSLY I
INQUIRED AS TO IT, APPARENTLY, ACCORDING TO THE COUNTER CLERK AT VASSAR
STATION), BUT WHICH, NONETHELESS, HAD "INSUFFICIENT POSTAGE" (I'M BROKE, YO, I
COULDN'T FLOAT THE SBN OR PANEL A FIVER, Y'KNOW?) BUT, WHAT IS FUNNY IS THE
ENVELOPE ATTACHED AS EXHIBIT 1, HAS A SURPRISINGLY HIGH AMOUNT OF POSTAGE
ON IT. ALSO ODD IS THE EXTENT TO WHICH THE SBN IS ABLE TO APPARENTLY AFFIX
THOSE GREEN CERTIFIED MAIL MAILINGS TO ENVELOPES, THEN PLACE THEM IN THE SBN
OUTBOX, LATE IN THE DAY, WHEN THE SBN KNOWS THE MAIL HAS ALREADY BEEN PICKED
UP...DON'T YOU HAVE TO BUY THOSE GREEN CERTIFIED MAIL THINGS AND DEPOSIT THEM
RIGHT THEN TO SIGN YOUR PROOFS OF SERVICE THUS? REGARDLESS, THE SBN OR
PANEL COULDN'T FIT $5.95 WORTH OF PAPER IN THAT LIL OL' ENVELOPE...WHIC
INDICATES TO ME THAT THE SBN PUT A VARIETY OF THINGS IN THE 10 12 12 BIG MANILLA
ENVELOPE THAT THE VASSAR STATION IS SENDING BACK TO YOU (THE SBN PROBABLY
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HAS IT TODAY, I FIGURE...) AND IN THAT BIG ENVELOPE, WOULDN'T BE SURPRISED IF
THERE IS THE DoWSoE...why doesn't the SBN copy things to Couglin via fax and email? I love fax
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and email. They are so verifiable, so certain...yet Clerk Peters admits to adding Coughlin to her
"blocked sender list"? And all SBN email addresses with the @nvbar.org gateway have a 1996 era
`ation more fitting Bill Gate's first HoTMaiL account than a big bad Bar Counsel talkin'
tough 'bout takin' 'way 'man make his livin'....And why is it that Bar Counsel for the SBN are not
electronic filers with the Nevada Supreme Court? Too much oversight? To hard to "adjust" things?
Actually, I was stumped until I found that attached envelope with the wrong postage affixed to it, an
obvious over postaging of $5.95 because I just don't think Clerk Peters or Bar Counsel King would
pull something funny there....An now I am realizing that the $5.00 part of the $5.95 is probably a
$5.00 or so charge for certified mail....But can you buy certified postage like that without having. Or
not...this is confusing...well, damn...all I know is I haven't had that DoWSoE nearly 25 days so far...Is
it possible that is do to my needing a bit of time upon moving into my new place to feel secure
enough in it to reveal my address (I am a domestic violence victim under FV12-00188, but really, I
am more afraid of local law enforcement and prosecutors than my old house mates...I have been put
in jail about 10 times this year, so...). Could be, I pretty much save all the envelopes...But, this is my
law license, my 14th Amendment property right, and the notice requirements, I AM TELLINGYOU
THIS RIGHT NOW, I GIVE YOU MY SOLEMN VOW THAT IF THIS HEARING YIELDS ANYTHING
OTHER THAN A COMPLETE AND UTTER LACK OF DISCIPLINE OF ME TO ANY EXTENT, WE
WILL BE LITIGATING THIS, AND EVEN WITHOUT ANY DISCIPLINE WE MIGHT BE LITIGATIN'
THIS...Y'ALL TAXED ME PLENTY WITH THE PETER CHRISTIANSEN, JR., MIKE SANFT,
PATRICE EICHMANN, KEVIN KELLY FIASCO IN 2002-2005 during SBN President Flanagan's
tenure, kings 3/23/12 email to Couglin regarind "Clerk of Court Department 3". Now, thIS MIGHT be
a deal where Laura and or Pat did mail the DoWSoe on time, when they said they did on 10 12 12...I
do have a copy of it (and it seems to me the SBN doesn't hardly ever email me or fax me copies of
those types of things)...But, do you have any case law regarding what the deal is if, say, Laura
doesn't have the certified tag showing I got the certified sent version of the mailing with the DowSoe?
What if Laura or Pat only sent out a certified version of something like the DowSoe...I dont' know that
I got the Notice of Hearing all that close to the 10 12 12 mailing, either. I know Pat verbally told me
of the 11/14/12 date...then we can always check the emails (PLEASE NOTE YOUR ARE ON A
LITIGATION HOLD NOTICE AS TO THOSE TO) and I got all these yellow usps sitckers "notify
send of new address" on some of these envelopes here...the SBN has some Piteny Boews deal...the
point is, to you, this might be gibberish...ITS NOT TO ME. ITS MY DUE PROCESS AND I DON'T
GET PAID WHAT THE SBN GETS PAID, i don't have a Pitney Bowes set up, when I sent things
certified mail, I have to leave them in the custody of the carrier at the time of buying the green
things...apparently not the SBN though, as on October 31, 2012 I saw at 4:45 pm two certified letters
in the outgoing mail box for me, and Laura Peters admitted the mail had gone out already that
day....So, where the certified numbers scanned by the SBN already at that point? Would "taking
them to Vassar on my way home" (nice improv, Laura) really change the fact that the mailings of that
date had a certificate of service that said one thing, whereas reality might not quite comport with
that? AND YOU ARE TRYING TO TAKE A PROPERTY RIGHT FROM ME (AGAIN!).
IT may be
the case that the State Bar of Nevada didn't put the right postage on some things it mailed Coughlin,
and given the complete beat down Coughlin has suffered this year at the hands of local law
enforcement and other officials, he couldn't afford to pay the postage for the SBN...also, the USPS
may have failed to check all the right boxes for certified mailings of different sizes for things sent to
Coughlin when Coughlin went ot retrieve certified mailings...as such, the ligitimacy of the 11/14/12
hearing is in serious doubt...as is any deadline for coughlin to file an "answer" under SCR 105,
particularly where SCR 105 is not delimited to just an "answer" but rather specifies and. A cursory
review of when first I have a scan into my scan connected desktop pc reveals at date of 10 31 12 in
a file dubbed 017.jpg (i'll email it to you because then you can see the "date created"
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file size limit
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metadata...surely Pat Hill,er, uh, Richard King, er, um Pat King knows what I am talkin' 'bout...So, out
goes my theory that it was included in Clerk Peters 10 31 11 mailings, huh. ..Well, okay, I stand by
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the parts about I haven't had any version of the DoWSoE anywhere near 30 days. Whether the SBN
can pin that on me for failing to provide physicial address? When did I give the SBN my 1471 addy?
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Didn't the SBn still have the PO Box 3961? Is it on me if I don't pick up a certified mailing righ away?
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What is the SBN has an establishe practice of mailing two versions of everything, one certified, one
not...can I rely on that? And it might be on me the lack of getting the DowSoe very soon after any
alleged 10 12 12 mailing (I don't dispute that Pat or Laura think they mailed it on that date...and that
may well have...interested to know what is in the manilla envelope baring a data of, I tink 10/12/12,
though. Look, I have a Reply brief in 60302 (my wrongful term case against WLS over being fired
over Judge L. Gardner's Arpil 2009 grievance in ng12-0435, the ghost grievance (that goes back to
just who pat means when he email me that "the clerk of court" gave him that April 2009 Order...Pat,
is that the same "Clerk of Court" emailing you from "Department 3" (which means Judge Nash
Holmes, I guess, not Judge Polaha, despite the email being from 3/23/12 and my having a hearing
before Judge Flanagan, where somewhat brightly color pants that some might try to call "pajama
bottoms" may have been worn by Richard Hill or Zach Coughlin or Casey Baker (one of the
three)..remember, Coughlin also had a Contest Property Lien that day in the RJC on the Park
Terrace 1422 deal, and Judge (the Richard G. HIll 3/23/12 Order to Show Cause hearing that RMC
Marshal Harley served me notice of on 2/27/12, but WCSO Deputy Machen filed an affidavit on
3/7/12 saying he did (I mighta spied Machen out in the hallway, but don't believe he was able to
personally eye witness Harley handing it to me, for what its worth, on 2/27/12, and Marshal Harley
seemed to be bs'ing me saying he wasn't sure which Deputy handed it to him to give to me.
Right....Machen is like 35-40 years old. Harley's probably 30. You can't tell me they don't know
each other. And yeah, maybe it was a jerk move of me to start interrogating Marshal Harley, and to
interrogate City Atttoreny Ormaas. Its was nothing compared to what Caryn Sternlicht used to do to
me at WLS daily... That woman, on several occasions, almost...almost, made me cry actual grown
man tears in the workplace. I stole all her moves. But, I am telling you, and I need to dissect the
audio of it more, to be fair, I did not lie to Judge Nash Holmes incident to her sua sponte
interrogation on 2/27/12 AFTER, the one and only bathroom break that day (which came after the
point where I notated forthe record the whisperin in each others ears by Ormaas and Harley-which
Pat King as recently as a month ago still was under the impression meant I was alleging some
paramour deal between them...which is totally not the case...I was implying the were both spooked
by or pissed at me in response to my questioning them.
call me ticky tack, but have you seen what SBN's Ethics Committee Member Joseph Garin is doing
to me in 60302? See his work in 60302 Respondent's Brief..we got dpi/scan issues, legibility issues,
remixing whether process or service thereof was preserved, ifp versus pro se, versus, court's own
proof service of process form calling for a Declaration versus Joey Detroit going all NRCP 4(g)
Affidavit requirement on me (you didn't argue that for Elcano, Joey, only WLS in your 12/20/11
Motions...no wonder I missed it, I was getting speed bagged in the Contest Personal Property Lien in
the eviction from former home law office case onthat day in rjc 2012-001708...all 6.5 hours worth of
it...Hill joking with Bailiffs about shoving things up my ass ten feet from me, in the court room, while
waiting for Judge Sferrazza to take the bench...and "Order Resolving" the Motion, filed 11/16/11, but
which HIll was able to, according to him (NNDB member, Hill, that is) get delayed 6 weeks (and
asked my court appointed defender Taitel about that Hazlett-Stevens City of Reno continuance he
granted without asking me, speedy trial right be damned in the criminal trespass case, over the same
6 week Hill vacatin. some people round these parts depend on Richard G. HIll, Esq. like the first and
15th, I mean, wow....Some people really don't like Rich...you bring his name up its spit on the ground
this and eff that mother effer that...but me? I think the guy is adorable. He's just a charming rascal,
a real prankster...you just gotta "get" his sense of humor is all. Hell, he's just as generous as can be
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with his time,always teaching younger attorneys, in one way or another, some of the tricks of the
trade.
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And from the unofficial transcript so far in 11 tr 26800 (that notice of appeal i filed on 3/7/12 requires,
under NRS 189.010-.050 for the rMC to order the transcript prepared without a down payment and
transmitted to the district court the roa within 10 days. yet the RMC, Longoni, and Judge Nash
Holmes are seeking to avoid that expense. and my law license is taken away for the alleged theft of
what? a "candy bar and some cough drops"? What do you call not preparing the transcripts or
ordering them so prepared where the law requires it?...looks like somebody been saying some real
misleading things to Judge Nash Holmes...or Judge Nash Holmes is saying some things that are,
well....I mean, what is that excerpt getting at? Is she saying the Marshal found some
"dissassembled smart phone of Coughlin's" in the restroom? I have to retract the bit about "peeping
Tom" peering through the bathroom stall, but, honestly, can you blame me for assuming that is what
she meant? Otherwise, what? Supposedly I am "dissassembling a recording device" or "smart
phone" or whatever she said right in front of the Marshal...then what, "lying" about it later? About
what? having a smart phone? A "smart phone as recording device".. Maybe this is somewhat
generational. My mom flat out refuse to have a smart phone. Got a flip phone. Its got like a .25
megapixel camera on it. What is a "recording". Is a picture a recording? What is a device? YOur
talking to a patent attorney. Well, Pat King never misses a chance to tell me I am a "former
attorney". Patty Ice. Yesterday Judge Clifton got annoyed with me for not saying "yes" to his
questioning me "well, what do you mean you don't know if you understand the amended charge, you
are an attorney, aren't you?" He wanted a simple yes. Thanks, Pat. I had to get all "well, according
to some authority I have uncovered, one is still "an attorney" even when "temporarily suspended"
however, other authority seems to suggest using the honorific "Esq." on a card could get you held in
contempt of a temporary suspension order (I have been trying to change my blog to reflect that, but
the honorific is in the URL...nonethless, I am obviously too busy keeping Pat and Laura busy to do
anything else, oh, besides keep DDA Young Company and the Reno City ATtorney's Office.
Obviously, I need to do some more research on this, BUT I AM PUTTING YOU ON NOTICE
TO DO YOUR OWN AND MAINTAIN RECORDS, deal? Regardless I think I still have an argument
to beat all given the Panel wasn't even empaneled until, what...October 30th, 2012 or
somethign...SCR 105(2)(c) says the Panel sends the DoWSoe and "at least 30 days" Notice of
Hearing, not Bar Counsel, not the SBN, and not "Clerk of Court/Investigator" Peters. Sure SCR 105
might allow for the NNDB Or Panel to adopt certain procedure rules (not talkin' SCR 119 here), but I
sure haven't been made aware of any such thing. Should I be? Wait, your're going to say that's on
me, huh? oh, i might have sent a judge on an active case somethign i shouldn't have (not sure, its a
tough call) on 3/29/12...one day before the Order denying my appeal in cv11-03628, the richard g.
hill eviction matter's appeal...but you have to ask Pat King about his 3/23/12 email to me and what
"the Clerk of Court for Department 3" means (and, honestly, at that point I still didn't know the
difference between a Bailiff, Deputy, or a Marshal....
Okay so I didn't get the big-box packages. State bars finally allowed me to steal the the detailed
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previously there refusing let me come see stuff that's new since that stuff off to the printers on or
about October 31 or November 1 probably first yeah November 1 and there is stuff they didn't set off
to the printers but regardless just as I suspected the father and particularly the portion marked form
marked on formal hearing file SPN the Zach Coughlin which is they stand starting 02701 contains is
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what I thought it would which is judge Nash Holmes is grievance with the date of three 1412 but no
indication of the materials does Nash and simply identifies as enclosures along with a letter whether
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not that included judge Linda Gartner's April 2009 section order which is curiously at the document
immediately following judge Linda Gartner's under judge Nash Holmes's two-page grievance letter
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scenes made me court judges one on page enough to understand it judge William Gardner was
cross-examined by Coughlin during hearing and had to admit that he passed his sister's order which
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he received from his sister onto his other many court judges and now after-the-fact packing left to
scramble in, with some good excuse for why there appears to be some doctored up marked as
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received 315 version of Linda Gardner's order and SBN Bar Counsel King seekts to skirt the issue
by alleging that he got Judge L. Gardner's april 2009 sanction ORder from "the Clerk of Court"third
core which noticeably packing does not identify which clerk which Cordy God from I did It from the
5 clerk of court department three to same one used in an e-mail packing on March 23 detailing what
Coughlin was apparently wearing when he went to RMC counter to check out some traffic citation
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or one of his criminal cases progress or scheduling matters... meaning King screwed up that big
ticket (neurosurgeon summarily evictions commercial tenant patent attorney appeal/litigation by
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forwarding on to Coughlin this claptrap sewing circle nonsense by RMC court clerk and a bunch of
Marshal's who need to find some other things to do with their time besides screwup actual litigations.
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But what is obvious and was to be spec it is that the file as King has had it cleansed with disinfectant
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prior to Coughlin's review of in no way details the dysfunctional codependent family atmosphere
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amongst the to judge Gardner's i.e. the brother and sister William and Linda and judge Nash
HOlmes wherein they were actually able to convince each other that this game of their and all its
attendant ghost grievancing scene was not to be completely transparent and smell funny to anyone
with half a brain looking at. The Reno Muni court in 2011 when judge Kenneth Howard was actually
Reno High huskie underneath the green white hug Hawks colors he flies (he was Hug's first student
body president but his truly formative years were spent at RHS...and we at RHS will take credit for
the accomplishments of the Hon. Judge Kenneth Howard (first African American Judge in Washoe
County), as you can take the Judge out of Reno High but you can't take the Reno High out of the
Judge...we are the oldest high school in the State no matter what some study hall in a feed shop
thinks...I'm looking at you Elko). Okay, so, After Judge Nash Holmes's two-page deal in what
packing purports to be the purports to be the formal hearing file SPN the Zachary be Coughlin based
Internet 02701 after judge Nash announces March 14, 2012 two-page letter's media fall immediately
followed by Linda Gartner's April 2009 order which is curiously marked March 15, 2012 with a five
and 15 looking hundred doctored up that's followed by judge wagons $40,000 for $2000 attorney to
section. Coughlin who else Richard Hills eviction case there is no mention of quite just where these
these documents appeared from in the state bars files or who sent them or what is just about to go
screening scene what packing hiding behind the fact that he you Richard Hill passes and the than
judge Flanagan sanction order when they go play golf together is he hiding the fact that judge Linda
Gardner sits on sit in on meetings of the many court judges when she has a particular ax to grind
even where she files a recusal order in the Bell v Greer Matter fv11-02864 Is Pat King, hiding the
fact that judge William Gardner was well aware of all of this so much so to the extent that he felt
comfortable enough to drop at the April 10, 2012 hearing in a criminal trespass matter that he was
aware of the inner workings State Bar and the screening panel and when they were in a meeting
wintered in take action yada yada yada because court judge Gardner he's been a judge for five
years despite fact that the facts don't bear that out and his performance in court would tend to
indicate something more in accord which with reality which is that he was appointed sometime in
2012 is learning on the job the enormous pink elephant in the room here is fact that all the judges
and attorneys are former prosecutors and actually most of them still are prosecutors said that some
of them where black rugs and some of Mark the State Bar and some of them are getting paid to
pretend to be defending criminal defendants is court appointed counsel for that sure is weird
bedstand number 02916 is page 1 notice of formal hearing file stamp of October 12, 2012 yet page 2
is an approved service vendors formal hearing rather designation witness summary of evidence with
the caption all of its own yet it lacks file stamp and also interesting on that is that fact that after the
signature page on page 4 they stand 02919 were packing dated 12 October 2012 there is not a
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certificate of mailing the next phase is in fact a domestic return receipt indicating that Coughlin's
former housemate or a person rents a room in The Same Pl., Coughlin rents a room from John
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Juliano 20-year-old who moved out just about that day didn't `often assigned that she the return
receipt form and didn't back Hill and retrieve this letter from the appropriate postal station and in fact
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return return it Coughlin on or about October 28 stamp October 27 call from Lisa got to Juliano on
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October 28 28 which would tend to support the contention that Coughlin makes the first appearance
as he noted earlier when he was drafted this document of such a designation witness in summary of
evidence in his scanning files on his computer is for October 30, 2012 consistent with Coughlin's
stated practice it addresses can all important documents within a day or two of getting them return
receipt requested seems to be stamp October 27 on one side and then has a sort of post marketing
October 29 on the other side on the does. His certificate of mailing and following those two items
which I guess did placed in front of certificate of mailing indicating the luckiest and mail it out on
October 12, 2012 with the U.S. Postal Service certified mail receipt of 70102780000354295470 rent
peters or someone in their handwriting is indicated notice in summary Coughlin notice in summary
unserved by mail receipt now why is it that it sold from October 12 all the way to October 27 for that
certified mailing to reach Coughlin and widening Coughlin also receive a noncertified mailing a
version of it as the State Bar had previously contended that it's been doing on every firing i.e. mailing
Coughlin a noncertified version and a certified version is currently signs of class and State Bar
Coughlin does not believe he ever received a noncertified version of that mailing but obviously more
inquiries is needed for cognitive sign affidavits and and certificate of service by pierces the
undersigned hereby certifies that Ocracoke is foregoing is formal hearing was deposit immunities
Nelligan that postage fully prepaid thereon for certified first-class mail justice following Zach Coughlin
had his older PO Box 3961 address on October 12 it believe Coughlin filed a change of address on
or about October it 2012 in accord with the notice that the PO Box he was using which is in his
mother's name was set to expire on October 5 that even after this change addresses been
implemented Coughlin is still the key still works that mailbox any checks it fairly regularly and still
occasionally finds letter stressing him therein however he has regularly been receiving other mail
addressed to him that is currently been forwarded at his new 1471 he snatches this form further
recollection is good large manila folder that Coughlin's law on approximately Monday, November 5
Vassar Street postal station addressed to him which a hacker and 10 brought out to him and
admitted that when Coughlin had appeared the previous week likely on Friday 10 either did not see
that envelope or wasn't there etc. etc. that Coughlin had appeared and requested any certified mail
that was their friend given to him and that large and all envelope bearing either in October 9 Ward 12
someone there and postmarked was not presented to Coughlin for picking up what was visited the
following Monday or so October 5 10 noted that it was postage due on it as only some $1.25 or so
had interfaced with the Negroes standing Coughlin negated that he did not have the money to I had
a the difference State Bar bars the have and the items returned State Bar graph leave the that item
was the notice of intent receipt of the fall basis of certified mail version thereof Coughlin does not
believe that she.a noncertified version than Nesbitt intent to proceed on default basis he feels pretty
strongly about that but he does need more time to check his scanned files in his records specially to
the extent that the October 24, 2004 that is now clearing the charges against and shall be deemed
admitted which would not seem to be in accordance from her roses Coughlin has filed a responsive
pleading and above-captioned matter submitted one octave on October on September 17 at a time
when he was entitled to reasonably believe they sponsor talion circumstances that State Bar was
excepting and filing electronically submitted documents not just in another the certificate of mail
certificate certificate of service by mail for the October 9 certified mailing to Coughlin does not seem
to indicate that it was standby to means i.e. bivalves certified mail and first-class mail as they be
certificate certificate of service dated October 12, 2012 affixed to the notice of formal hearing
indicates wherein on page date Sam 02922 clerk. Signs certificate of service that indicates the
undersigned hereby certifies that a trucker target foregoing notice all hearing was deposit United
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States Miller Reno Nevada postage fully prepaid thereon for certified and first-class mail addressed
the following so the State Bar has mixed in an and stands on the notice of formal hearing wherein is
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no on the notice of intent to proceed on did the fall basis word only since one type of mailing of that
very very important document I you certified type mailing where is where as and apparently every
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other mailing to Coughlin the bar and/or the one from Chairman Associates is been sent by to means
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i.e. certified mailing and first-class mail is apparent that this sudden change of approach from an
entity such as a bar is unduly prejudicial and confusing to call Coughlin's not the one who's getting
paid to do this is not well-funded by the members of the bar and is not well staffed yet here is the
state bar of Nevada throwing curve balls at Coughlin vis--vis how their communicating documents
to Hannah Heather serving them why can't the State Bar just e-mail and fax them is the excerpt
cautionary safeguard any deadlines communicated to Coughlin with respect to some purported
November 9 deadline wherein he has to file something court indicted Chairman so suture panel chair
should barrios Board Chairman it should barrios should be withdrawn in light of these procedural
notice deficiencies in a regularities set forth herein and unearthed by Coughlin Coughlin is hereby
placed in the panel on the bar on notice that it has 45 days from the and paneling of the panel within
which to hold hearing and November 14 date is an extremely suspect warning that one that State
Bar should arguably not persisted in holding and certainly should not expect be able to lawfully build
Coughlin for the cost thereof where these procedural deficiencies on the part of the State Bar so
apparent this is particularly true were State Bar of Nevada ethics committee member Joe Garin has
waged a massive lead defensive coffins wrongful termination litigation against Washoe legal services
based upon extremely specious and suspect service and service of process and efficiency of service
and according to Garang now all the sudden is you it was greatly alleging insufficiency of process
arguments in 60302 and and 60317 Coughlin seeks some order from the panel that he doesn't have
to copy five different panel members on every firing and every CD makes Byetta traditional hardcopy
means to the extent that the panel and its members of not already ascended to that and to the extent
that State Bar of Nevada Saturday synod at which not something Coughlin concedes.
RMC clerk Lori Townsend is probably related to Marshalltown sin given the estimates extent to which
local law oarsmen and judiciary seem to all hire amongst each other especially concerned RPD
officer Nick dURALDE is related to dispatch or need COM employee Jessica dURALDE but what's
interesting is all these people alleging Coughlin in this include Dormont judge Nash Holmes and
others it alleging that Coughlin filed some pleading that was to hundred pages longer samosas as
long mislead the reader to the extent that pleading was far less than that and Langton is the
attachments that wrought that page double in that case does nothing out of the ordinary for what
Richard Hill files further this can solve this guy along with Garang the upon information and belief
fights with fax settings on the process and a copy of the summons and complaint Coughlin served
and those to associate a watch legal services wrongful termination suits such that the legibility of
what Coughlin had Washoe County Sheriff's office served what Coughlin himself had private party
served even where get IFP status in an order requiring Sheriff's office so serve were not legitimate
representations done with it a sufficient degree of candor to the tribunal asked what was actually
served upon Garin or Gonzaleses client for the Gonzales attempted to extort some sort of
compliance with the order for sanctions is rendered to him and his client against Coughlin by
threatening to report Coughlin the State Bar not sure if that the licensed debt collector practice or not
Brian but I've along with the lines of what RPD officer Ron Rossa did August 20, 2012 by threatening
to for Coughlin State Bar in this is nothing new am sure most lawyers notice the first thing anybody
does but finite your lawyer start threatening to report only smelled marijuana here there early failed
to this or that you never think as people just intrinsically sense a lawyer's reputation is it worth so
much sedan that it becomes a point to extort or curry favor out of that attorney. Further respecting
old Brian Goncalves maybe Brandon solvation answer for the fact that he likes it those clients or
apparently in situ be awarded fees incident litigations were his client is not even a named party in the
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caption of the pleadings such as in one of the Washoe legal services cases where Gonsalves
persisted in seeking to appear as counsel for party that was even named, Crisis Intervention
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Services (which clearly changed its name from Tahoe Women's Services upon it being succesful in
its bid to contribute to Coughlin's firing, incident to the Haubl matter/complaints by some advocate
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seeking to practice the unauthorized practice of law (she was made because Coughlin deigned to
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mention, far, far along in the game to a client who clearly felt entirely ambiguous about going through
with a protection order against her longtime live in boyfriend (and there were confidential substance
issues involved that Coughlin wont' go into here) that, say, if the boyfriend at some point sought to
become a physician or a police officer (or something along those lines) having a TPO on his record,
maintaned in the state's central repository, may have some ill effect...its a consideration...it might not
be what the far left wants advocates to say ever...but Coughlin practice for WLS on behalf of his
clients, and Elcano himself will tell you that it was not unusual for clients (most always women) to tell
Elcano Coughlin was the only person throughout the process who the felt did not seek to imbue his
own personal narrative or ideology upon them, but rather sought to effect their wishes to the extent
they were in line with reasonable and lawful aims. So "Tahoe Women's Services" becomes
something less gender polarizing while continuing to take federal and state grant money, and
becomes "Crisis Intervention Services" though it is still associated with or runs a "women and
children only shelter". Okay, so on page 02738 there is proof that Judge Nash Holmes and the RMC
are revealing Coughlin's confidential SSN to Bar Counsel and perhaps others, even members of the
screening panel, without redactions. And the RMC is curiously vague and evasive with respect to
the extent to which criminal Complaints are filed with a copy of the police report attached, and this
became a big issue in the Wal-Mart Indian Colony arrest in 11 CR 22176, and the grievance against
Hazlett-Stevens of the City' Attorney's that Coughlin filed vis a vis the City Attorney, the RMC and the
RSIC's Police (including Sargent Avansio, who is probably related to the ECOMM dispatcher
Avansino...and just how many cops and ECOMM dispatchers should be related or married? Its like
having Judges and filing office staff married...it doesn't pass the smell test. Further update stand
02757 and that e-mail Coughlin correctly points out that King's letter of March 16, 2012 was and
correct netted indicated that it can't was sent Coughlin an e-mail and was until March 19 she said
pecking at that time demonstrated his lack section with respect what appears to be generational rift
here with as far as snail mail and service goes versus electronic filing and attacking admitted he
thought e-mails were sent from websites rather than from e-mail addresses. Well, well, well now
State Bar disciplinary board/panel how do you like your precious postage snail mail man given the
fiasco that the under postaged October 9, 2012 notice of intent to take default in the large manila
envelopehas brought your chickens home to roost wherein you issue electronic service
you castigate Coughlin's e-mailing or faxing things when you behave like the old people and that
Saturday Night Live sketch wherein they adhere rigidly to a believe that robots are trying to take
them over vis--vis your reluctance to embrace electronic filing can't remember the last time you had
an e-mail not go through because somebody prayed about the wrong amount of postage and in the
clerk at the post office station couldn't give it to the person the clerk at the postal station where the
person made a special trip just to retrieve the damn certified mailing couldn't given to the person...
How you like your snail mail now State Bar and Disciplinary Board/Panel? Well, given the fact that
Coughlin has three envelopes from the SBN with a 10/12/12 post mark (or somethign marking it,
probably more the Pitney Bowes thing...and how is it the SBN can send thing certified mail, knowing
they haven't gone out that day in the regular pickup, despite what Clerk Peters wrote on her Cert of
Service....when Coughlin does certified mail he has to deposit it in the usps or their contractors
possession upon paying for the certified mailing and buying or affixing the postage...it seems the
sBN has more of an ability to "do it their way" and somehow obtain the sheen of "certified mailing",
whether it went out that day or not.
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But regardless the State Bar of Nevada and the panel and chairman solicits have a big problem here
and that they did not appropriately serve any manner the notice of intent to proceed on a default
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basis yet a persist seeking apparently to hold Coughlin to some November 9 deadline to respond to
something twitched they did not serve Coughlin it did not even copy Coughlin by e-mail it did not
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even facts a version of it to Coughlin and in that regard and ex parte emergency order clarifying the
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nature of this alleged November 9 deadline is an order.

Him and him judge you and session order and John's friend dates top request for a trial time
Coughlin caved to his settlement demand and the one judge Gardner attempted coerce out of
Coughlin is clients to agree to which brings up another issue with the Vaxevanis TPO case where,
upon Richard Molezzo, Esq. showing up with his client, the WLS attorney Coughlin witnessed then
Family Court Master Linda Gardner's and master's curious practice of giving away cars incident to
protection order hearings were should does not any have jurisdiction to do so but prolly the less said
about that the better...
Also, and I generally really like Paul Elcano...but he is '78 McGeorge. Judge Nash Holmes is '77
McGeorge, Rick Elmore '77 McGeorge (Judge Flanagan and Coughlin former cowrker, record
setting attorneys fees sanction against "residential tenant" appealing summary eviction, stay denied,
$2,275 bond kept $42 in attorney fees for vexatious appeal? even where Hill argued manufacturing
controlled substance statue in trial court to support $20K attorney fees awared (hill and baker had to
admit they "hadn't read the statue" in citing to some arcane narrow possibility for attorney's fees
somwehere in the statute based upon tenant's manufacturing controlled substances, though...upon
second though, knowing rich and casey, they probably pled that to amp up the prejudice to Coughlin/
reputational damage, sleazy inference quotient even more than the typically do...plus, hey, hat out
for $20K for using "Forms from the n. s. ct website" to ltigiate on behalf of out of state doctor)I filed
the appeal in 60302 on 2/27/12. Judge Nash Holmes convicts me of "summary criminal contempt"
on 2/27/12 despite, apparently, being made aware of the Order for Competency Evaluation by
WCPD's Office and or Biray Dogan (and Jim Leslie better have been tellin' the truth at the Marsden
hearing, I think he was under oath there...Jim? August 28th and September 5th, in rcr2011063341..Jim's work in that case is puke worthy, seriously. Real company guy, that Jimmy Sleazy.
Got quite a protege in that Biray Dogan...The go to guy when the County absolutely needs a
conviction that is just "clean" enough to stand up on appeal, with as few appealable issues preserved
for review as possible. Jim's a great attorney, if you can just get past the pretensiou schmaltz with
so little actual acumen to help it go down...the DA should give him a raise..
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Okay, back to Elcano...let's see...McGeorge one year behind RMC J. Nash Holmes (still would like
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more info on that "conflict" or, er, wait "surgery" that required "RMC Administrative Judge"
transferring the Richard HIll induced "jaywalking" custodial arrest of Couglin in 11 cr 00696 on
1/12/12 to D3 J. Nash Holmes from Judge Dilworth....on 2/27/12! I generally like Paul, but come
one...manage the firm, don't expect Coe Swobe to come in an lean on me when your managerial
deficiencies start to add up. Don't get me wrong, I think Paul is a very smart man, and a very good
man...but he needed a fire lit...and he got rid of everybody I had issues with, or almost, so...Oh, also
Supreme Court staff attorney Matt Pincolini (who I was one year behind in high school at RHS, and I
am sorry, Matty for costing us that undefeated JV basketball season when I missed those free
throws against Sparks at the end of the game...), but Paul told Cogulin Matt couldn't deal with
Sternlicht either, and left WLS because of it. I actually like Caryn. Because the Stockholme
Syndrome finally kicked in. But back to a Basque Country, Stanford Educated Paul Elcano...sound
like anybody involved in this here deal? Panel Chair Echeverria, perhaps? I talked to my boy Frank
Gehry, and he has some things stuck in his craw about the Basque Studies Board, but you know
Frankie, if it ain't a chair or building he can rearrange how he sees fit, it confounds him. Oh, look,
then theres Sternlicht Hastings '91 and City attorney Pam Robert's Hastings '90, she of the walmart
prosecution in 11 cr 22176...the one where she put on perjured testimony by three different
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witnesses, where she had video tape proving they were lying....that Pam Roberts...the one who
agreed to a continuance (funny, the RJC doesn't require Judges approval for continuances, but ol
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Judge Howard plowed the wheels of justice along on 11/30/11, despite Coughlin not having received
or any prior continuances, even where Taitel agreed to one for Rich HIll to go on vacation (to City's
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Hazlett)...dont' recall needing too much beeing the judge for one there....Taitle's hysterical, you
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should have seen him when my mom, Ma Barker served him the subpoena the other day. Still
acting like he has no idea who I am, after all the garbage with Nevada Court Services (which has
apparently gotten rid of at least 2 of the process servers who tried to break and enter my rental at
Northwinds or my trespass a gated back yard to my law office on River Rock. (Ryan Wray and Joel
Durden). Taitel share a fax number, exact mailing address receptionist, and office space with
Nevada Court Services (Coughlin filed a grievance against them for unauthorized practice of law,
probably not included in what Hill deemed part of the "file" though, or the greivances against the
WCPD or RMC defenders (Dogan, Leslie, Goodnight, Rains, Fortier, of the WCPD and Soteo,
Loomis, Puentes, and Taitel of the RMC) or various local prosecutors (Hazlett, Ormaas, Roberts,
Young, Probably Don Wang, er, Dan Wong). But it's not as though Coughlin only has criticism for the
city of Reno prosecutors and the Reno Municipal Court it's not to say there hasn't been genuine
instances of warmth express it's not every day you walk in somewhere and they give you a
Washington generals uniform of your very own.
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also, clerk peters can serve me the complaint. king cited no authority regarding certified mailing of
the complaint being sufficient where clerk peters admits to the representations she did (and she
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didn't "remail a certified mail version of the complaint following the 9/11/12 conversations...as Pat
King decided not to follow Clerk Peters representations to Coughlin, but instead attempted to shove
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the Compalint into Coughlin's suit jacket on 9/25/12, the day King and Peters and Susich failed to
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abide the Court's 6/7/12 ORder and SCR 111(7)-(8). Furtehr, i just got Peters affidavit about that,
and we'll just see how accurate it is....all the stuff Garin and WLS argued against me in 60302 and
60317 (and the associate lower court cases) is argued via incoropration by reference here. King
preints exhiibts to his filings (some of which are sent to me lackign a file stamp, like the DowSoe) on
both sides of the paper (not okay), and the attachments are all blurry (especially the bottom of the
page) and not legible (do I need to fudge up my scanner's setting to really drive that point home? IF
so, hang on, lemme give Gonsalves and Garin a call for a point of expertise about something or
other, or at least where they are signign motions that represent the attachments to their motions, in
consideration of how they appear upon the eflex deal downsampling them (and that depends what
resolution Garin, Gonsalves, and Fuller used to scan in the actuall process and complaint their
clients received....consider this a grievance against Gonsalves and Garin at least for such filing of
Motions with attachments that they dispaly a lack of candor to the tribunal in standing behind the
assertion or implication that those attachments accurately reflect the legibility of the documents in
question...because they clearly dont'...its a joke. just compare Garin's version to Gonsalve's. they
were all printed with the same printer, same paper, same resolution (high 1200 x 1200 dpi, on a
brother 5240d or as indicate in the Reply i filed the other day in 60302..)....
24
also King is clearly misleading the Panel with respect to his "oh, we have immunity from subpoenas"
argument in citing to SCR 105. No, Pat...its talking about "immunity" from "civil actions', ie, you
being sued civilly...not immunity form a REsondnet doing anything to actually contest your
transparent, trite, compromised greivances and complaints or the manner in which King and Peters,
26
but mostly King (what is Peters supposed to do, get fired?) seek to exert an improper level of
influence and overstep his SCR 104 jursidiction at every turn.
27
conclusions
25
28
1
please grant the relief sought herein or otherwise dismiss this proceeding and or order bar counsel
follow the scr and have the board and panel do the same, especially respecting the notice of the
2
hearing, "at least 30 days notice of the hearing provide BY THE PANEL, NOT BY BAR COUNSEL,
AND THAT NOTICE NEEDS TO INCLUDE THE DowSoe (which should be filestamped itselfs, and it
3
is not). further, please issue an order bifurcating these matters (obviously,this is a ridiculously huge
4
5
6
10
11
amount of issues to cram into one snack pack junk food extra value meal "combo disiplinary
hearing". ITs a joke. The only thing wreaking of less due process here is Judge Nash HOlmes
"summary criminal contempt" order, especially when you listen to an transcribe the two proceedings
in 11 tr 26800 (it is reprehensible the extent to which the Marshals, Judge NashHolmes, and the
RMC seek to subvert the Affidavit requirement in NRS 22, and Judge Nash Holmes statements in
the audio from 3/12/12 really , really need to be dissected real closely....(she alternates between
finding "by clear and convicing" evidence that Coughlin violated this or that "copy and paste the
whole RPC" recitation of the RPC with her musing that "there certainly seems to be an issue or
possibility there" that Coughlin violated this or that RPC (duty of fairness to opposing counsel?
candor to the tribuanl? there is literally nothing in the verbally rendered order or the order reduced to
writing (any of them, the one lackign any service on 2/28/12, the one stemming from the 3/12/12
"continuation fo the trial" (where they locked the doors). Allison Ormaas needs to testify at this
Hearing, period. so does Harley, and so does Judge Nash Holmes and Judge Gardner. IF the panel
doesn't require it it is a farce.
12
Also, consider Judge Gardner's statements on the record at the 6/18/12 trial (and Coughlin moves
for ifp status or something to help him obtain a copy of the February 2012 hearing in that trespass
13
case 11 cr 26405, the one with puentes, where Judge Gardner makes statements respecting the
propriety of recusal at that time....and Coughlin wants an Order from the Panel requiring King to
14
divulge the exact contents of what jUdge Nash Holmes and the RMC or anyone connected therewith
gave him (was the April 2009 sanction order in the Joshi Case transmitted to bar counsel in any way
by anyone at all connected with the RMC?). Did bar counsel have and fail to supply to coughlin the
puentes motion to withdrawl from the trespass case 26405? why? was it provided to the panel.
16
Coughlin moves for an order requiring Bar counsel divulge was was provided to the panel (and
17
whom those materials were provided to bar counsel by).
15
18
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events and when she
asked Coughlin her questions about recording, considering when a restroom break took place an exactly what it is she
19
asked Couglin and when, and what his responses were, and when some allegations by "the Marshal" were made, what
they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio transcript reads 7 minutes into the audio record the RMC
20 provided the SBN:
21
extreme form of mental illness. during the trial I asked the defendant attorney repeatedly if he was
recording the proceedings he denied that vehemently a few times and then he quote took the fifth a few
22
other times and then he requested to be excused to go to the bathroom and the Marshal later reported to
me that while the gentleman was in the bathroom he disassembled a recording device in his pocket and
23
took the memory out of it and it was later found in that, uh, by the Marshal no one else had gone into the
bathroom and that was retrieved and it was put into his possession at the Sheriff's office and when they
24
booked him into jail for the contempt charge that was booked into evidence and I asked the Sheriff's
office to hold that into evidence. I believe he has violated Supreme Court Rule 229(2)(B) which was
25
amended by ADKT 440, August 1st, 2011...."
26
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed hearsay,
like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
27
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her statement at
the 7 minute mark that "It appears to me in this case that the defendant is suffering from some extreme form of
28
mental illness." Further, that which Judge Nash Holmes had communicated to her prior to the start of Trial on
2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have Bar Counsel assert to half baked
"can't ask the judge about her mental processes" loophole, as he has done.
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the citation
or report in 11 tr 26800 contained any mention of retaliation, given she was looking right at it and given what
she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin reporting to Ormaas
what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's responses thereto on 2/27/12, and Dan
Wong, ditto at an earlier hearing on that matter...
7
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording anything or
whether he possessed a "recording device" until AFTER the one and only restroom break Judge Nash Holmes mentions
8
on the audio record. And that sua sponte interrogation of Couglin occured IMMEDIATELY AFTER THE RESTROOM
BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW COUGHLIN TO TAKE HIS
9
YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER COUGHLIN MADE A VERBAL
PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH OTHER'S EARS BY CITY ATTORNEY
10 ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED A BIT UPSET ABOUT SOME OF THE
QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE THE TRIAL (DURING THAT PERIOD OF
11
TIME WHERE JUDGE NASH HOLME'S ASSISTANT INDICATED, ON THE RECORD IN ONE OF THE OTHER
CASES ON THAT STACKED DOCKET, THAT Judge Nash Holmes just couldn't be found, and how odd that
12
was...which is odd, considering what was going on in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012065630 and rcr2011-063341 at the time (lots of reasons for and indications that local law enforcement and prosecutors and
13
public defenders were non too happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status
conference between young and dogan that neither YOung nor Dogan wish to testify about...but which seems to have been
14
held anyways after a written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the
time Judge Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about Coughlin
15 that RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of
Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for Competency Evaluation of Coughlin in
16
rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was still smarting from
a filing by Coughlin of approximately 11/28/12, which resultd in Young promptly amending his complaint in rcr201117
063341 to add a charge that was duplicative, even where YOung failure to allege theft or possessing/receiving "from
another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8 violation, which is YOung's specialty,
18
apparently. That, and violating NRs 178.405, which YOung did by filing in rcr2011-063341 with a stamp of 2:55pm a
fugitive document of his own, an Opposition to Coughlin's or the WCPD Motion to Appear as CoCounsel on
19
2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that case despite the Order finding Coughlin competent in
cr12-0376 didn't even get signed and entered until 5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the
20 criminal trespass case. NOt much respect for nrs 178.405 (including within NRs 5.010) here in Northern nevada..
21
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of Appeal
22
3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes continues to refuse to
follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
23
24
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by the trial
judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a contempt committed in his
25 immediate presence in open court cannot be likened to the proceedings here. For we held in the Oliver case that a person
charged with contempt before a "one-man grand jury" could not be summarily tried. [349 U.S. 133, 138] The power of a
26
trial judge to punish for a contempt committed in his immediate presence in open ... In re Oliver, 333 U. S. 257. Sixth
Amendment Right to Counsel of Coughlin violated in both 11 cr 22176 and 11 tr 26800, also orders no sufficiently
27
detailed or capable of being known how to comply with, not sufficient warning, violat Houston v Eighth Judicial District
(Nev.).
28
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the "immediate
2
presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash HOlmes, or maybe
something worse is going on here....but what Judge Nash HOlmes said on the recording is entirely misleading an
3
inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe she is repeating a lie, but
regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary where she not only purports to
4
issue a "summary criminal contempt" conviction against an attorney, but also where Judge Nash Holmes appears to try to
transmogrify what she sees as "a simple traffic citation trial" into a full blown SCR 105 disciplinary hearing where she is
5 both Bar Counsel and the Panel...That Marshal needs to sign an affidavit, under NRS 22.020 and Judge Nash HOlmes
ought to have to put something on the record, under oath, in response to Coughlin's recent subpoena (and SBN Pat King
6
wishes to let Judge Nash HOlmes phone in her testimony, and it probably won't even be sworn testimony, but rather just
some musings by Judge Nash Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts of
7
things outside her jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to Quash the
Subpoenas Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge
8
William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of Appeal
Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal was dismissed
9
under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176 conviction resulting in
this Court's 6/7/12 temporary suspension Order in cr11-2064, which was denied based upon a civil preparation of
10 transcript down payment rule, in that criminal appeal, where the RMC has a thing in place with this Pam Longoni that
violates Nevada law in that it refused to give Coughlin the audio cd of the trial for some time, insisting only Longoni
11
would be allowed to transcribe it, and that the transcript's preparation would absolutely not start until a down payment was
made. Plus, even where Coughlin caved to the payment demands..Longoni repeatedly hung up the phone on him and
12
otherwise ignored his communications (there may be an issue of the email Longoni holding out to the public issuing a
"bounceback"...but she needs to sign an affidavit as to whether she put Coughlin on a blocked list, and upon information
13
and belief, Coughlin faxed his request to the number the RMC held out for her on her behalf too...
14
15
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps, NG12-0435,
16
depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12 email to Coughlin
he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't it be Second
17
Judicial District Court Clerk of Court Joey Orduna Hastings that would need to send Family Court Judge Linda Gardner's
April 2009 Order sanctioning Coughlin to the SBN's King for King now apparent contention that the NG12-0435 "ghost
18
grievance" consisting of Judge L. Gardner's April 2009 Order was not filed by the RMC Judges? Oh, Clerk of Court
Orduna Hastings? Do you have anything to say about this? Judge Nash Holme's 3/14/12 grievance to bar counsel reads:
19
20
21
22
"

Dear Mr. Clark:
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary
Barker Coughlin. The accompanying box of materials demonstrates some of the problems with the practice of
24
this attorney being experienced by myself and the other three judges in Reno Municipal Court. My two most
recent Orders in what should be a simple traffic citation case are self-explanatory and are included, together
25 with copies of massive documents Me. Coughlin has faxfiled to our court in this case. Audio recordings of
two of my hearings in this matter are also included. He failed to appear for the second one this past Monday.
23
26
27
28
I have another traffic case pending trial with him that was re-assigned to me based on our Department I
judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him
1
between cases very easily. We are setting that case for trial and attempting to serve him at the most recent
th
address we have (1422 E. 9 St. #2 Reno NY 89512), although I heard today he may be living in his vehicle
2
somewhere. We do have an address for his mother, however, as she recently posted part of a fine for him.
3
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on appeal to
the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently pending in
4
his court with Mr. Coughlin as the defendant. I have enclosed some copies of documents from those matters,
5 in chronological order, simply because they appear to demonstrate that he is quickly decompensating in his
mental status. Our staff also made you some audio tapes of Coughlin in the him and him and him and him and
6
him and him and him him and I will him and him and him and him and him in Departments 2 and 4 so you
can hear for yourself how this attorney acts in court. You can see his behavior in my traffic citation case does
7
not appear to be an isolated incident.

8
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My
Judicial Assistant was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed
10
for Contempt of Court and they stated that they represent him in a Gross Misdemeanor matter in RJC. I have
11
no other information on that.
12
13
14
15
16
17
18
19
You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court
in your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious litigant in our court,
antagonizing the staff and even our pro temp judges on the most simple traffic and misdemeanor matters. I do
think this is a case of some urgency, and I apologize for taking two days to get this package to you; our IT
person was ill and could not make the copies of the audios of Mr. Coughlin's hearings until today, and I felt it
was important that the audios be included in the materials to be considered by the State Bar. On February 27,
2012, Mr. Coughlin told me he was actively practicing law and had appointments with clients. [ do not know
if that was true, but if so, he could be causing serious harm to the practice of law in Northern Nevada and
could be jeopardizing someone's freedom or property interests. "
Appellant truly appreciates this Court's recognition of its own 6/7/12 Order Temporarily
Suspending Coughlin from the practice of law. This Court therein demonstrated the high ideals it
20
21
adheres to, recognizing (where many other local prosecutors, Courts, and court appointed defenders
22
did not) that it is not permissible to try to have it both ways with respect to matters of that sort
23
whether we want is talking about and ordered temporarily suspending one's law license pursuant to a
24
SCR 111(6) Petition or an order for competency evaluation in light of NRS 178.405 and NRS 5.010.
25
26
27
28
However, Garin's Responden'ts Brief itself argues Coughlin's "failure to cite to" the
Appendix or ROA somehow disposes of everything. yet Garin gets the benefit of all 5
volums of the roa to work with, meanwhile, coughlin is denied access thereto on multiple
occasons by this Court's electronic filing system, and only first obtaine dpartial access
5
6
thereto on Octo23, 2012...and still had not been afforded access to vol 2 until today.
Coughlin has done a great deal of research on these issues and feels he has a lot to do, if
given a bit more time. Plus the SBN/Panel ar jamming him up with a 11/14/12 "combo
10
hearing" that violates every aspect of scr 105(2)(c) and this courts 6/7/12 order ("sole
purpose" proceeding singular, scr 111(7)-(8)....elcano mcgeorge '78. rmc nash HOlmes
greivanc ng12-0435 mcgeorge '77 (see 60838 and 61426 and this matter 60302).
11
It is categorically false for Judge Nash Holmes to assert, in the audio record on 3/12/12 the order of events and when she
12
asked Coughlin her questions about recording, considering when a restroom break took place an exactly what it is she
asked Couglin and when, and what his responses were, and when some allegations by "the Marshal" were made, what
13
they consisted of, etc.. on 3/12/12 in 11 tr 26800 the audio transcript reads 7 minutes into the audio record the RMC
provided the SBN:
14
extreme form of mental illness. during the trial I asked the defendant attorney repeatedly if he was
15
recording the proceedings he denied that vehemently a few times and then he quote took the fifth a few
other times and then he requested to be excused to go to the bathroom and the Marshal later reported to
16
me that while the gentleman was in the bathroom he disassembled a recording device in his pocket and
took the memory out of it and it was later found in that, uh, by the Marshal no one else had gone into the
17
bathroom and that was retrieved and it was put into his possession at the Sheriff's office and when they
booked him into jail for the contempt charge that was booked into evidence and I asked the Sheriff's
18
office to hold that into evidence. I believe he has violated Supreme Court Rule 229(2)(B) which was
amended by ADKT 440, August 1st, 2011...."
19
20
21
22
23
24
25
26
One Coughlin did not do anything of the sort indicated by Judge Nash Holmes (by way of unattributed hearsay,
like her car sleeping allegations in her 3/14/12 letter re Coughlin to the SBN) above.
NRS 178.405 should have prevented anything said or done by Judge Nash Holmes following her statement at
the 7 minute mark that "It appears to me in this case that the defendant is suffering from some extreme form of
mental illness." Further, that which Judge Nash Holmes had communicated to her prior to the start of Trial on
2/27/12 in 11 tr 26800 needs to be testified to under oath, rather than have Bar Counsel assert to half baked
"can't ask the judge about her mental processes" loophole, as he has done.
City Attorney Ormaas sure could be made to explain her statements on the record regarding whether the citation
or report in 11 tr 26800 contained any mention of retaliation, given she was looking right at it and given what
she said in court. Also, the whispering with Marshal Harley, and the bits about Coughlin reporting to Ormaas
what RPD OFficer Carter said to Coughlin in 61901, and Ormaas's responses thereto on 2/27/12, and Dan
Wong, ditto at an earlier hearing on that matter...
27
28
5
6
10
11
12
13
14
15
16
17
Simply put, there was no questioning by Judge Nash Holmes of Coughlin as to whether he was recording
anything or whether he possessed a "recording device" until AFTER the one and only restroom break Judge Nash
Holmes mentions on the audio record. And that sua sponte interrogation of Couglin occured IMMEDIATELY
AFTER THE RESTROOM BREAK, A BREAK IN WHICH JUDGE NASH HOLMES REFUSED TO ALLOW
COUGHLIN TO TAKE HIS YELLOW LEGAL PAD WITH HIM AND WHICH OCCURED AFTER
COUGHLIN MADE A VERBAL PRESERVATION ON THE RECORD OF THE WHISPERING IN EACH
OTHER'S EARS BY CITY ATTORNEY ALLISON ORMAAS AND MARSHAL HARLEY (WHO SEEMED
A BIT UPSET ABOUT SOME OF THE QUESTIONS COUGHLIN ASKED THEM IMMEDIATELY BEFORE
THE TRIAL (DURING THAT PERIOD OF TIME WHERE JUDGE NASH HOLME'S ASSISTANT
INDICATED, ON THE RECORD IN ONE OF THE OTHER CASES ON THAT STACKED DOCKET, THAT
Judge Nash Holmes just couldn't be found, and how odd that was...which is odd, considering what was going on
in 11 cr 22176, 11 cr 26405 12 cr 00696 and 11 tr 26800, and rcr2012-065630 and rcr2011-063341 at the time
(lots of reasons for and indications that local law enforcement and prosecutors and public defenders were non too
happy with Coughlin...and consider the 2/24/12 email vacating the 2/27/12 status conference between young and
dogan that neither YOung nor Dogan wish to testify about...but which seems to have been held anyways after a
written communication of its being reset was transmitted to Coughlin by Dogan, wherein, during the time Judge
Nash Holmes couldn't be found (maybe she was at one of the group meetings amongst Judges about Coughlin that
RMC Administrative Judge William Gardner referenced on the record in 11 CR 26405? Interesting the Notice of
Appeal in 60302 was filed that same day too, 2/27/12) Dogan got his ORder for Competency Evaluation of
Coughlin in rcr2012-065630 (apparently in retaliation for Coughlin's filing of 2/21/12, and DDA Zach Young was
still smarting from a filing by Coughlin of approximately 11/28/12, which resultd in Young promptly amending
his complaint in rcr2011-063341 to add a charge that was duplicative, even where YOung failure to allege theft or
possessing/receiving "from another' under Staab makes his so charging Coughlin in that iPhone case a RPC 3.8
violation, which is YOung's specialty, apparently. That, and violating NRs 178.405, which YOung did by filing
in rcr2011-063341 with a stamp of 2:55pm a fugitive document of his own, an Opposition to Coughlin's or the
WCPD Motion to Appear as CoCounsel on 2/27/12...nevermind YOung tried to hold a TRIAL on 5/7/12 in that
case despite the Order finding Coughlin competent in cr12-0376 didn't even get signed and entered until
5/9/12...ditto the Trial seeting of 5/8/12 in RMC 11 cr 26405, the criminal trespass case. NOt much respect for
nrs 178.405 (including within NRs 5.010) here in Northern nevada..
Coughlin didn't received the 2/28/12 Contempt ORder in 11 tr 26800 until July 2012...but did file a Notice of
Appeal 3/7/12...despite "summary criminal contempt" being a final appealable order, Judge Nash HOlmes
continues to refuse to follow NRS 189.010-050 (so Coughlin has to type the transcript, yay....
18
19
20
21
22
It is true that contempt committed in a trial courtroom can under some circumstances be punished summarily by
the trial judge. See Cooke v. United States, 267 U.S. 517, 539 . But adjudication by a trial judge of a contempt
committed in his immediate presence in open court cannot be likened to the proceedings here. For we held in the
Oliver case that a person charged with contempt before a "one-man grand jury" could not be summarily tried.
[349 U.S. 133, 138] The power of a trial judge to punish for a contempt committed in his immediate presence in
open ... In re Oliver, 333 U. S. 257. Sixth Amendment Right to Counsel of Coughlin violated in both 11 cr 22176
and 11 tr 26800, also orders no sufficiently detailed or capable of being known how to comply with, not sufficient
warning, violat Houston v Eighth Judicial District (Nev.).
23
24
25
26
27
28
See, this is why In Re Oliver and Cooke require all elements of "summary criminal contempt" occur " in the
"immediate presence" of the Court. Maybe Marshal Harley and some other Marshal have misled Judge Nash
HOlmes, or maybe something worse is going on here....but what Judge Nash HOlmes said on the recording is
entirely misleading an inaccurate, if not an outright lie (again, maybe not a lie by Judge Nash Holmes, maybe she
is repeating a lie, but regardless her reliance on unattributed hearsay is distrubing an inappropriate, particulary
where she not only purports to issue a "summary criminal contempt" conviction against an attorney, but also
where Judge Nash Holmes appears to try to transmogrify what she sees as "a simple traffic citation trial" into a
full blown SCR 105 disciplinary hearing where she is both Bar Counsel and the Panel...That Marshal needs to
sign an affidavit, under NRS 22.020 and Judge Nash HOlmes ought to have to put something on the record, under
5
6
oath, in response to Coughlin's recent subpoena (and SBN Pat King wishes to let Judge Nash HOlmes phone in
her testimony, and it probably won't even be sworn testimony, but rather just some musings by Judge Nash
Holmes purporting to make "rulings" finding "by clear and convincing evidence" all sorts of things outside her
jurisdiction) on 11/14/12, on, Partick O. King, SBN Bar Counsel has also filed Motion to Quash the Subpoenas
Coughlin attempted to have served on Marshal Joel Harley, Marshal Deighton, Judge Nash HOlmes, Judge
William Gardner, Judge Gardners Administrative Assistant Lisa Wagner, who can't quite find the NOtice of
Appeal Coughlin faxed to her (allowable under the RMC Rules) on June 28th, 2012 in 11 CR 26405 (the appeal
was dismissed under an NRS 189.010 analysis by Judge Elliot, whom also got Coughlin appeal of the 11 cr 22176
conviction resulting in this Court's 6/7/12 temporary suspension Order in cr11-2064, which was denied based
upon a civil preparation of transcript down payment rule, in that criminal appeal, where the RMC has a thing in
place with this Pam Longoni that violates Nevada law in that it refused to give Coughlin the audio cd of the trial
for some time, insisting only Longoni would be allowed to transcribe it, and that the transcript's preparation
would absolutely not start until a down payment was made. Plus, even where Coughlin caved to the payment
demands..Longoni repeatedly hung up the phone on him and otherwise ignored his communications (there may be
an issue of the email Longoni holding out to the public issuing a "bounceback"...but she needs to sign an affidavit
as to whether she put Coughlin on a blocked list, and upon information and belief, Coughlin faxed his request to
the number the RMC held out for her on her behalf too...
10
11
12
13
14
15
In her March 14th, 2012 grievance against Coughlin to the SBN (now NG12-0434, and perhaps, NG12-0435,
depending upon whom you ask and what King means by "Clerk of Court"...because in King's 3/23/12 email to
Coughlin he apparently identifies Ms. Marilyn Tognoni as "Clerk of Court of Department 3"...whoever, wouldn't
it be Second Judicial District Court Clerk of Court Joey Orduna Hastings that would need to send Family Court
Judge Linda Gardner's April 2009 Order sanctioning Coughlin to the SBN's King for King now apparent
contention that the NG12-0435 "ghost grievance" consisting of Judge L. Gardner's April 2009 Order was not filed
by the RMC Judges? Oh, Clerk of Court Orduna Hastings? Do you have anything to say about this? Judge
Nash Holme's 3/14/12 grievance to bar counsel reads:
16
"
17
18
Dear Mr. Clark:
19
This letter constitutes a formal complaint of attorney misconduct and/or disability against Zachary
Barker Coughlin. The accompanying box of materials demonstrates some of the problems with the
practice of this attorney being experienced by myself and the other three judges in Reno Municipal
Court. My two most recent Orders in what should be a simple traffic citation case are self-explanatory
and are included, together with copies of massive documents Me. Coughlin has faxfiled to our court in
this case. Audio recordings of two of my hearings in this matter are also included. He failed to appear
for the second one this past Monday.
20
21
22
23
24
25
26
27
28
I have another traffic case pending trial with him that was re-assigned to me based on our Department I
judge being out for surgery. We have multiple addresses for Mr. Coughlin and can't seem to locate him
between cases very easily. We are setting that case for trial and attempting to serve him at the most
th
recent address we have (1422 E. 9 St. #2 Reno NY 89512), although I heard today he may be living in
his vehicle somewhere. We do have an address for his mother, however, as she recently posted part of a
fine for him.
Judge Ken Howard, Department 4, had a case on Mr. Coughlin late last year that is now on appeal to
the Second Judicial District Court. Judge Bill Gardner, Department 2, also has a matter currently
pending in his court with Mr. Coughlin as the defendant. I have enclosed some copies of documents
from those matters, in chronological order, simply because they appear to demonstrate that he is
quickly decompensating in his mental status. Our staff also made you some audio tapes of Coughlin in
the him and him and him and him and him and him and him him and I will him and him and him and
him and him in Departments 2 and 4 so you can hear for yourself how this attorney acts in court. You
can see his behavior in my traffic citation case does not appear to be an isolated incident.
It is my understanding that Reno Justice Court also has a matter pending on this attorney. My Judicial
Assistant was contacted by the Washoe Public Defender in February when I had Mr. Coughlin jailed
for Contempt of Court and they stated that they represent him in a Gross Misdemeanor matter in RJC. I
have no other information on that.
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You will have the full cooperation of myself, the other judges, and the staff of Reno Municipal Court in
your pursuit of this matter. Mr. Coughlin has positioned himself as a vexatious litigant in our court,
antagonizing the staff and even our pro temp judges on the most simple traffic and misdemeanor
matters. I do think this is a case of some urgency, and I apologize for taking two days to get this
package to you; our IT person was ill and could not make the copies of the audios of Mr. Coughlin's
hearings until today, and I felt it was important that the audios be included in the materials to be
considered by the State Bar. On February 27, 2012, Mr. Coughlin told me he was actively practicing
law and had appointments with clients. [ do not know if that was true, but if so, he could be causing
serious harm to the practice of law in Northern Nevada and could be jeopardizing someone's freedom
or property interests. "
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One will hear some very, very interesting things on the audio record of the 5/8/12 hearing in the
trespass matter 11 cr 26405, with Keith Loomis there...Judge W. Gardner pulling up Tiburon sheets and
taking them as giving him permission to violate NRS 178.405 (and more inquiry is need to determine if
Loomis brokered a deal with the WCPD and WCDA that did transfer jurisdiction from the RMC, which
would present yet another voidness issue beyond the violating of the nrs 178.405 stay... regardless, at
the 4 minutes mark on the audio fo that 5/8/12 hearing Couglin and Gardner again address the apparent
conflict issues, and their intersection with Competency issues especially vis a vis Judge W. Gardner's
sister passing her April 2009 order sanctiong Coughlin to him, he passing it to Judge Nash Holmes it
becoming soon thereafter a grievance all to itself with the SBN, Jduge Nash Holmes openly
questioning Coughlin's competency (yet persisting in seeking to set the "jaywalking custodial arrest
richard g. hill case" for trial, amazingly, as she admits in her 3/14/12 letter..even more amazing is Judge
W. Gardner assertin he never discussed anything richard hill related with judge nash holmes in
connection with the meetings regarding Couglin where both of Judge Nash Holme's cases invovlign
Coughlin involve Richard HIll getting Coughlin arrested for jaywalking on 1/12/13 in 11 CR 00696
(which Hon Gardner trasnferred to Judge Holmes's d3 on 2/27/12? and 11 tr 26800, the triple traffic
citation case outside Hill's office wherre coughlin went upon being release from 3 days in jail incident
ot HIll signing a fraudulent criminal trespasss complaint against Coughlin. REally, Judge Gardner?
REally? Richard HIll never came up in your discussions with Judge Nash Holmes? REally?
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it is instructive to consider judge William Gardner's comments on the record at the trial in the criminal
trespass matter from Coughlin's former home office again it is judge William Gardner who is the
brother of Judge Linda Gardner whose April 2009 sanction order was cited by Washoe legal services
and named party in this matter at this sole reason for firing Coughlin additionally Washoe legal
services now employs as part of the ECR program with the RMC's Let Taitel who was at one time
Coughlin said on this criminal trespass matter until apparently Joe figured out the Calder was doing his
business partners Nevada court services table is a court-appointed attorney by the defendant defense
attorney by the Reno municcourt.. at 9 minute mark on audio Judge Gardner persists in setting for trial
the trespass case on 6/18/12 despite admitting he had no actual, legally sufficient knowledge of any
deterimination of then pending competency evaluation order (and still need to know if he need a
remand order for jurisdiction). gardners doesn't want to follow the "adjudicatory boundaries" argument
Coughlin makes...
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at the 19 minutes mark of the audio of the 6/18/12 trial in the criminal trespass matter 11 cr 26405:
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Judge Gardner: finally the it leaves the issue of recusal although you have not raised in the caption of
the pleading news.with in the party their about page do we about address this issue before and I've
denied that motion to recuse there is nothing raised in any of the pleadings that causes me to be busy in
this case other than a fair detached observer of the facts of that will be denied for
Coughlin Your Honor just interject that not just prefaced that by saying Nevada doctors did your
announced any judge Your Honor and completely fair so let's give me a lot of confidence the corridor
but I do believe there might be a judicial candor something this is where judge has litigants before him
who have a case involving a family member of the judge and some other sphere and I think that Mike
and mandatory recusal auto but I did find and follow mandamus action adventure sister attended court
in 2009 I was fired from a job as if surveillance attorney for Washoe legal services was told I was fired
because of her because of conduct by neither resulted in her order distilleries and starts marshaling
services I did follow mandamus petition response to that. Judge of the Supreme Court father wasn't
worthy of more reviewer require and responsiveness and and now there's this grievance for the court
and I call it not be flipped by: p.m. macula conception grievance because nobody can tell me who filed
it or how the can grievance but that order one 2009 sanction may require me to pay personally $1000 in
attorney's fees under NRS him .085 as a consequence of my advocacy is a domestic violence attorney
after number of bus client a battered woman tenant or alimony incident to a 20 year marriage when I
was ordered to slaughter my pocket that is now grievance it upon information believed that it can
grievance with the State Bar because your sister judge Linda Gardner did the order to you whereupon
you indicated that you get judge Nash Holmes whereupon judge Nash and skipped for counsel along
with a number of other materials that I've not been privy to despite my attempts to secure them from
the filing officer the court or from door counsel I have made numerous attempts to get these recordings
at antenna materials as are not directed at
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Judge W. Gardner: thank you Mr. Coughlin let me just tell you this that case goes back to the Family
Court of no real knowledge except that I have read the Order it is unrelated and irrelevant to this case.
I have not really discuss the merits of this case with my sister who is a judge in the Family Court there
would've been no reason to discuss that case and even if that would've happened it would have not,
uh, um, there really is no nexus between her being a judge hearing the case for Europe attorney and and
my been a judge some three years later on a case where you are a defendant in, so the motion to recuse
is denied and I think that identifies the issues that you faced in the motion you filed June 5, 2012 it
looks like now we are ready to go to trial is that correct, Mr. Hazlett-Stevens?"
Hazlett-Stevens that's correct Your Honor: I'll call Richard Hill to the stand "
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Judge W. Gardner curiously defines and limits to an overly narrow extent, Coughlin' appearance before
him, even where Coughlin had been forced to represent himself in violation of the Sixth Amendment
given the utterly fraudulent "court appointed representation" by Keith Loomis, Esq. as "a case where
you are a defendant in".
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Then (and this also goes to the overly narrow limiting of the conflict analysis to seeing Coughlin only
as "a defendnat before me in a criminal case" that Judge W. Gardner made above) at the 23:20 minute
mark, despite judge William Gardner admitting to being where previously of the fact that Coughlin's
law license had been suspended by this court on June 7, 2012 judge Gardner notes:
Judge GArdner: excuse me Mr. Hazlett Stevens let me just enter one more thing for the record on that
recusal analysis Mr. Coughlin limits the wording of this case to the date I have put the criminal
complaint alleges on number of November 13, 2011 in the city of Reno at 121 River Rock St. the
defendant was found in the property after being evicted on November 1, 2011 Billy other information I
heard about the cases been whatever was raised in the pleadings filed by either you or Mr. HazlettStevens, so that being the case, go ahead and proceed with your examination of Richard Hill"
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Interesting how the complaint pleads being evicted as tantamount to a criminal trespass warning, and
Hazlett-STevens impermissibly sought to invoke State v. nichols in the broadest of senses (criminal
trespass? civil trespass? was notice appropritately served in Nichols? doesn't matter apparently, and
Judge Gardner indicates he doesn't care what service rules apply to evictions, as he will decide that
based upon the facts as developed a trial, refusing to allow Coughlin to make legal argument in that
regard.
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in that audio fo the trial, very shortly therafter at the 24:02 mark:
"Coughlin: I'm sorry I don't mean minaret to Mr. Hazel Stevens but if I can just quickly interject her
honor with respect what you just said to the extent that I am required to broach the topic of any
discussions you had with judge Nash Holmes with respect to these matters
Gardner: I can tell you that judge Nash owns I have not discussed this with anybody. We have not. F
their have been no discussions between me and the judge about your case to protect
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And, darn, forgot this, but there actually was a Pam Longoni prepared transcript in the appeal of the
criminal trespass conviction (but as cr12-1018 may suggest, it can be a good idea to double check Ms.
Longoni's transcriptions for the RMC, she is held out as their "exclusive" transcriptionist, and
documentation is provided to appellants that ther transcript's preparation will not even begin until a
substantial down payment is made (and probably won't, i need to check this...but probably won't be
forward to dist court until full payment is made, all in violationf of NRS 189.030...despite whatever
civil statute Judge Elliot cited in denying Coughlin's appeal of the walmart thing udnerlying coughlin's
current suspension of 6/7/12...in cr11-2064...)
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but, it is really interesting to note How Judge W. Gardner, nuetral arbiter of fact, recounts the record in
that trespass case in Longoni's transcript, especially iwth regard to the import of NRS 178.405 in the
context of nrs 5.010 especially and considering the communications between city atty Hazlett-Stevens,
Hon. W. Gardner and then court appointed defense counsel Keith Loomis in a clandestine status
conference the morning of trial (totally unbeknownst to Loomis's attorney client Coughlin, on
4/10/12)...
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while alternately citing to Coughlin's being removed from mental healt court by Judge Breen, MD as a
basis for denying a motions on 6 18 12, only to then rule as irrelevant any argument Coughlin made to
the basis for that removal (which is all pointless now, as the 5/7/12 ORder by Judge Sferrazza
transferring that iPhone case to Mental Health Court was violative of NRS 178.405 in that the order
resolving the 2/27/12 ORder for Competency Evaluation in cr12-0376 did not even get signed and
entered, with a file stamp until 5/9/12...so the whole mch deal is void.. but check out Hon Gardners
characterization of the trial setting vis a vis the 6 18 12 trial and other key dates, skillfully dealt with,
yes indeed with respect to the pendecy of an Order for Competency Evaluation during key times,
Coughlin interlineations will be in bold and in parentheses...:
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"Hon. Judge Gardner: On November 13th, 2011, Mr. Coughlin was arrested by the
Reno Police Department and charged with one count of trespassing. On November
14'h, 2011, Mr. Coughlin was arraigned and pled not guilty. Trial was then set for
December 13th, 20 11.
On November 23'd, 2011, a Motion to Continue was filed by
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the City Attorney, a Hill motion is what I'll call it, based on an absent
witness. I believe it was Mr. Hill, not related to the Hill motion.
MR. HAZLETT-STEVENS: That's the original motion, yes.
THE COURT: That was not opposed by Defendant's counsel at
the time (that would have been RMC court appoint counsel Lew Taitel, whose
business partners NEvada court Services Coughlin was suing at the time
incident to their work for Richard G. Hill and Casey Baker). And on November
28th, I entered an order continuing the trial the first time.
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The trial was then reset for January 30th, 2012. On January 3,d, 2012, a Motion to
Continue was filed by Mr. Puentes, your attorney at the time. The City Attorney did
not object.
On January 18th, I -well, prior to that, before the ruling on that motion, on January
18th, Mr. Puentes filed a Motion to Withdraw as your attorney.
On February 2nd, 2012, I scheduled a (inaudible) hearing on the Motion to
Withdraw. The motion was granted, and Mr. Loomis was appointed.
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On February 13th, 2012, you filed, Mr. Coughlin, a Motion to Vacate, a Motion
for Reconsideration for Recusal.
On February 22nd, 2012, an Opposition to the Motion was filed by the City
Attorney.
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Trial, then at that point, was ultimately reset for April 10th, 2012.
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(that trial setting is file stamped 3/7/12 in that RMC case 11 cr 26405, which,
curiously is avoide throughout this recitation of the "docket", which is awfully
tough to get a copy of from the RMC. Now Coughlin's 11/14/12 Disciplinary
Hearing before the Panel and SBN involves three grievances. ng12-0204, filed
by Richard HIll, ng12-0434, filed by RMC Judge Nash Holmes, in relation to
finding Coughlin in "summary criminal contempt" despite cooke and in re
oliver and the whole "every essential element occured within the immediate
presence" etc., etc. and despite some real slippery shadowy reconting as
rendered stuff about a restroom break, o affidavits signed by any Ct. Marshals
at to whatever it was they said to Judge Nash Holme and whatever remixing of
the order of bathroom breaks and search incidents to arrest, and going back to
the jail the next day to retrieve the attorney's smart phone and data card may
have actually occurred...but the talkign point is this: ON 2/27/12 IN RCR2012065630 ANOTHER ORDER FOR COMPETENCY EVALUATION WAS
ENTERED AS TO COUGHLIN. A couple hours later, after Judge Nash
HOlmes was finally found by her staff, the traffic citation trial in connection
with RPD citing Couglin at Hill's law office for 3 minor traffic ciolations 11 tr
26800 was held, despite Judge Nash Holmes admission in her grievance to bar
counsel on 3/14/12, which became ng12-0434....the third grievance, strangely
stamped as received in the sBN 3/15/12 with the "5" in the "15" looking a little
under the weather, is ng12-0435, and like a baby left on a doorstep after
someone rings the doorbell and runs away...its pretty murky just how that
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"three year old Order in a completely unrelated case" as HOn. W. Garner

characterizes it, which he admits to passing from his sister to the other RMC
Judges shorlty before judge Nash HOlmes submitted her "box of materials" to
the SBN along with her grievance against Coughlin (whose filings, to her,
represent the singularly most disturbing pieces of legal work she has seen in her
35 years in this business".. because Coughlin can be a real Kunstler)
On March 5th, 2012, Mr. Coughlin, you filed a motion actually captioned in the
District Court, but it made itself -it did make itself appropriate to our file.
On March 21'" you filed another Motion -the City filed a (Page -6- (of Longoni's
transcript)
Motion to strike your motion based on no service on the City Attorney.
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On January 20th, 2012 (must be referring to the ORder that says "filed in error"
and has a new file stampe of 2/20/12, one of several instances of such "filed in
error" restampings in this case and other RMC cases, here is seems to have
little important and to be a simple scrivenor stamper error), I entered an order,
number one, denying your motion that was filed on February 13th, 2012. On March
21st, 2012, I entered a second order denying your Motion to Dismiss that was filed
on March 5th, 2012.
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(if you are waiting for Judge W. Gardner to indicate there was an Order
SEtting for Trial this crimina trespass case on 3/7/12 (setting the first trial date
of 4/10/12...at which a curious order of things went like this...Ct finds Coughlin
question of competency regarding Coughlin...then court grants Loomis Motion
to Withdraw...huh? nrs 178.405 "stay the proceedings', not "grant Loomis one
of his many, many succesful Motion to Withdraw in his "work" as a court
appointed "defense counsel" for the RMC)...you will be waiting a long time,
becaues he never managed to point that out....nor did he point out that the
5/8/12 stamped "Trial Setting" (setting the 6/18/12 trial date) was also violative
of nrs 178.405 vis a vis nrs 5.010 (and even without 5.010 is it) given the ORer in
cr12-0376 wasn't signed and entered until 5/9/12...but Hon. J. Garnder does
manage to mention cr12-0376, just not the fact that all these Trial setting and
ORers granting withdraws (similar ot the one Henry Sotelo, ESq. anothe
McGeorge former prosecutor court appointed defense counsel at the RMC got
in 12 cr 12520 during the pendency of Coughlin third Competency Evaluation
ORder.)
And then on April 10th, 2012, I suspended the proceedings based on a competency
issue that had been raised in the District Court.(well, actuall it was more than
'raise" by the 2/27/12 Order in the justice court that Gardner's fellow RMC
judge Nash HOlmes appears to reference ever so curiosly in her 3/14/12
greivance against coughlin with the sbn) And then at that time, at your request,
Mr. Loomis was relieved as your attorney.(request is putting is charitably...if
Loomis is more of a prosecutor than the prosecutor, is one deciding to go it
along, albeit during the pendency of a competnecy order that precludes any
such violation of the attendant stay..is that really a "request"?)
On April 26th, 2012, in District Court, Judge Elliott found you competent to stand
trial.
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(well...isn't the order finding Couglin Competent in that case cr12-0376 actually
file stamped 5/9/12? doesn't the jail rip peopel off their medications during
times liek the 8 day jail stay Couglin got from apri 19th, to april 26th, 2012
when DDA Zach Young committed one of his many numerous violationso of nrs
178.405 in seeking to have Coughlin's bail revocked based upon some lies in a
letter filed with the court by Lakes Crossing's Bill Davis and Sally Farmer (class
ic was a jail booking area phone call between davis and Coughlin, recorded by
the jail, we'll se if the produce it. wherein DAvis claims that he "didn't write the
letter" that bares his signature as a Ph.D. and was filed on 4/17/12 in cr12-0376
and cited to extensively by d10 Judge Steven Elliot (the judge on the associate
60317, the companion case to the instant 60302) as a basis, along with Young's
nrs 178.405 violative Motion, for ripping a license attorney, on the spot, with no
stay, away from his practice and client's, with no opposition of any import, zeal,
or skill by wcpd Biray Dogan, and refusing to even consider the legal research
Coughlin attempted to submit to the court vis a vis whether these retaliatory
competency evaluations are "blank checks" into a criminal defendants entire
medical/mental health HIPAA protected records. Top it off, Biray Dogan, just
after an express direction not to by Coughlin, announces the name of a
medication Coughlin takes into the record, in front of 40 members of teh public
and bar milling about, and Dogan's boss Jeremy Bosler later refuses to move to
strike or ameliorate in any way Dogan's error. Oh, also the WCPD, and the
RJC co-signs this in some instances, maintains the position that defendnats
don't have a right to know be apprised of very important filings in their cases
by their court appointe counse...its, uh...not a duty to communicate with client's
situation or anything...at least when its a public defender, and dogan got an $8K
raise during one of the worst economic years in our nations history recently.)
On May 19th, 2012, Judge Elliott signed an Order finding you competent (actually it
was 5/9/12) and remanded whatever case was pending in the Justice Court back to
the Justice Court, and then I reset trial for June 18th, 2012, today's date. (WHOA!
HOLD ON THER JUDGE GARDNER...about that "and then I reset trial for
June 18th, 2012" bit...don't you mean you set trial for 6/18/12 on the record
(which the SBN admits getting, though Pat Hill, or Richard King, er, I mean Pat
King indicates he finds it hard to listen to such stuff and do much reading or
research or anything of that sort) Becuase Hon. J. Gardner set the 6/18/12 Trial
on 5/8/12, and that was a violation of NRs 178.405. the fifth or sixth he made in
that criminal trespass case where he swears he was able to be a "neutral arbiter
of fact" despite all the conflicts attendnat to the matters set forth herein.)
On May 7th, 2012, Judge Sferrazza assigned that case in the Justice Court to the
Mental Health Court. On May 24th, Judge Breen, the District Court Judge, and the
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Judge responsible for the administration -him and Judge Blake, one of the two
Judges, sent the case back to the Reno Justice Court. (at least Judge SFerrazza lets
cases go when he hands them over to the MCH, rather then do what the RMC
Judges do, which is "stay" the proceedings, but retain jurisdiction in the RMC
rather than transfer it the the MCH...but regardless, given the ORder resolving
the 2/27/12 ORder wasn't signed and entered until 5/9/12...that 5/7/12 Order by
Judge Sferrazza was void)
Then on June 5th, you filed the motion we're talking about now, including the
Motion to Continue."
(the one Hazlett-Stevens "wasn't served with", uh huh. City of Reno Drop box
that front desk security at city hall says will work for City attorney's? that one,
Hazlett-Stevens? literally every second of the 11 cr 26405 criminal trespass trial
is dripping with that which really really needs a good careful close inspection
for misconduct, from the "substance" of the 6/5/12 Motion, to the violations of
the stay,the the arguing things not in the record in closing by Hazlett-Stevens,
the the "civil eviction stuff is relevant when the prosecution needs to coopt it to
atempt to leverage a criminal trespass warning from "rendition" (criminal law
concept nrs 189.010) of an eviction order (no matter how completely different
the Order(s) may have wound up being once put through Hill and Baker's truth
factory) to all "civil eviction law is compeltely not relevant to this criminal
trespass matter...i will decide what rules apply as to service of the eviction order
by the facts as developed through testimony at trial,...i don't want to hear you
get all far afield with legal argument about the rules applicable to civil evi tion
orders...." too bad, because you would miss the rich moments like Casey Baker,
Esq. having to admit that, despite his office biling the landlord $60K in
attorneys fees, Baker was unaware that NRS 40.400 makes applicabe the
NRCP, not the JCRCP, to summary evictions in Nevada (and therefore NRCP 5
and NRCP 6(e), where, as there, no personal service of eviction order)..to Hill
and Bakers sworn testimony, to the RMc filing OFfices record keeping, to the
failure to stamp in the timely notice of appeal in cr12-1262, which resulted in a
dismissal of the appeal by...wait for it...Judge Steven Elliot)
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COURT: Yeah, I don't know exactly what happened, Mr. Coughlin. I appreciate that.
I'm reading from Judge Breen's Order that "The Defendant be removed from the
Mental Health Program, and that you be returned to the Reno Justice Court for all
future proceedings."
So, whatever happened over there, which I'm not privy to, and which I don't think
really is related or relevant to this case, we're going to not delay these proceedings by
sending the case over there.
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Finally, that leaves the issue ofrecusal. You have, while not raised in the caption of
the pleading, it is identified in the pleadings you raised, on page two, we've
addressed this issue before in detail.
I've denied that Motion to Recuse. There's nothing raised that even (inaudible)
prevents me from hearing this case and being a fair, detached observer to the facts
oflaw, so that will be denied.
MR. COUGHLIN: Your Honor, if! could quickly enter an objection for the record on
that. THE COURT: Go ahead.
Pa -15
MR. COUGHLIN: And just to preface that by saying everybody I've talked to has
indicated you're an outstanding Judge, Your Honor, and completely fair, so that's
definitely given me a lot of confidence in the Court in that regard.
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But I do believe there might be -I don't know if it's a judicial (inaudible) (canon, Ms.
Longoni, canon....that would be another instance of an appeable issue, like in
cr12-1018 being chalked up to, by the RMC's Longoni as "inaudible") or
something that says where a Judge has litigants before him who have a case
involving a family member of the Judge, in some other sphere. I don't know if that's
a mandatory recusal, but I did file a mandatory habeas action against your sister, the
Honorable Judge Linda Gardner, in Family Court in 2009. I was fired from my job as
a domestic violence attorney from Washoe Legal Services, and I was told I was fired
because of her -because of the conduct by me that resulted in her order only. It's the
only reason I was fired, according to Washoe Legal Services.
I did file a Mandamus Petition. It was pretty much a three judge panel, and the
Supreme Court felt it wasn't worthy of, I guess, more review or requiring a response.
And then now there is a grievance with the State Bar. I call it -not to be flip, but I
call it kind of the immolate conception grievance because nobody can tell me who
filed it, or how it became a grievance.
But that order from 2009 sanctioned me requiring me to pay $\,000 attorney's fees,
NRS (inaudible) .085. In the context of my being a domestic violence legal aid
attorney advocating on behalf of my client, a battered woman, trying to get her
alimony incident to a 20-year marriage with two kids, wherein I was ordered to pay
$\,000 out of my pocket, that's now a grievance.
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It's upon infonnation and belief it became a grievance with the
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State Bar because your sister, Judge Linda Gardner, gave the order to you,
whereupon I believe you indicated you gave it to Judge Nash Holmes,
whereupon Judge Nash Holmes gave it to bar counsel, along with a number of
other materials that I have not been privy to, either in my attempts to secure
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them from the filing office here at the Muni Court, or from bar counsel, Mr.
Patrick Kinney (king).
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I've made numerous attempts to get these recordings and these different materials.
So, just to enter that for the record, Your Honor.
THE COURT: Alright, thank you, Mr. Coughlin. And let me just tell you this. That
case goes back to the Family Court, I have no real knowledge, except I have read the
Order. It's unrelated and irrelevant to this case. I have not really discussed the merits
of this case with my sister who is a Judge in the Family Court.
There would be no reason to discuss that case, and even if that would have happened,
we have not -there's really no nexus between her being a Judge and having heard a
case where you're an attorney on, and my being a Judge some three years later on a
case where you are a Defendant in.
So, the Motion to Recuse is denied. And I think that identifies the issues raised in
your Motion filed June 5th, 2012. It looks like now we're ready to go to trial, is that
correct, counsel?
MR. HAZLETT -STEVENS: The City is ready, Your Honor. THE COURT: Alright,
let's go ahead and call your first witness, Mr. Hazlett-Stevens.
Page -17
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MR. HAZLETT-STEVENS: The City calls Richard Hill to the
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MR. COUGHLIN: And, Your Honor, I don't know if I'm supposed to intelject this
now, or not, but I believe I did subpoena some witnesses who appear (inaudible) (uh,
Pam Longoni, thats another "inaudible" on another appealable issue, that being
the failure to grant a subpoena where, if that is the case here, Sargnet Marcia
Lopez and Officer Chris Carter were subpoened (apparently they were by the
city attorney, and Coughlin asserted he though he did subpoena them, but
indicated some ambiguity or uncertainty in that regard...but "inaudible"
doesn't quite preserve the appealable issue).
THE COURT: Right, and we'll address that at the appropriate time. Ultimately, Mr.
Coughlin is a lawyer. B (not according the the SBN and this Court's 6/7/12
ORder that Judge Gardner admits to haveing been apprised of...Coughlin
couldn't issue supboenas like an attorney, post 6/7/12, could he?) You know we
take these -Mr. Hill, good morning.
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MR. HILL: Good morning, sir.
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THE COURT: We take these matters step by step by step. There's no other way to do
it, so we'll address all legal issues as they show up in the due course, and pursuant to
protocol at trial.
So, let's swear in Mr. Hill. (Witness duly sworn). THE COURT: Have a seat, Mr.
Hill. Mr. Hazlett-Stevens, go ahead. MR. HAZLETT-STEVENS: Thank you, Your
Honor.
RICHARD HILL
called as a witness, having been duly sworn,
testified as follows:
DIRECT EXAMINA nON BY MR. HAZLETT-STEVENS: Q Good morning, can
you please state your name, and spell your last for the record?
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Page -19THE COURT: You know, Mr. Hazlett-Stevens, and Mr. -let
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me make one last comment for the record.
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MR. HAZLETT-STEVENS: Please.
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THE COURT: I know that Mr. Coughlin is an attorney. Nonetheless, he's
representing himself.
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Mr. Coughlin, let me tell you what I know about this case to date. I am looking at a
Criminal Complaint that alleges that on November 13th, 2011, in the City ofReno, at
121 River Rock Street, the Defendant was found on the property after being evicted
on November 1st, 2011.
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The only other information I know about the case is that the whatever was raised in
the pleadings filed, both by you and Mr. Hazlett-Stevens.(maybe Loomis and
Puentes didn't file anything? Oh, wait, did they attach all of Coughlin's emails
to them detail the Richard HIll Judge Nash HOlmes nexus? Really?)
So, with that in mind, go ahead, Mr. Hazlett-Stevens. MR. HAZLETT-STEVENS:
Thank you. BY MR. HAZLETT-STEVENS: Q Thank you. Can you please state
your name, and spell your last for the record?
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A Richard Hill, H-I-L-L.

Q Good, Mr. Hill, I'm going to ask you MR.
COUGHLIN: I'm sorry, I don't mean to interrupt you, Mr. Hazlett-Stevens. If! could
just quickly interject, Your Honor, given what you just said, to any extent, I'm
required to broach the topic of any discussions you've had with Judge Nash Holmes
with respect to these
matters or -
THE COURT: I can tell you that Judge Nash Holmes and I have
not discussed this case with anybody, we have not. There has been no discussions
between me and the Judge about your case, the trespassing, set for today.
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MR. COUGHLIN: Or any other matters related to Richard Hill?

THE COURT: Or any other matters. We've never discussed any matters related to
Richard Hill at all.
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MR. COUGHLIN: Okay, and when you said you and your sister had never discussed
anything about me?
THE COURT: Not related to this case.
MR. COUGHLIN: I believe earlier you just said you never discussed anything about
me at all. MR. HAZLETT-STEVENS: Judge, you've already ruled on this. I'm going
to ask that you THE
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COURT: We have ruled. Let me tell you -let me tell you what I've discussed. We
have discussed -I have not discussed with Judge Nash Holmes and I am advised that
based on some steps she's taken, there's been a matter referred to the State Bar which
is under, if not -I'm aware that you have been suspended by the State Bar, and that
that's subject to further review.
To the extent that Judge Holmes has had a case in her department, as has Judge
Howard, and has myself, we have had discussions, general discussions related to the
State Bar matter. (Judge W. Gardner is referring to the three grievances forming
the scr 105 Complaint set for a disciplinary hearing on 11/14 12, consisting of
one grievance by Hill, one by jUdge Nash HOlmes stemming from a traffic
citation trial where the citation was issued by the rpd outside Hill's office after
they told Coughlin to leave (which he did, but the RPD wasn't satisfied so they
pulled him over while he was leaving) in 11 tr 26800, where, on the record,
Judge Nash HOlmes threatened Coughlin with "IF you say Richard HIll's name
one more time I am going to put you in jail for contempt, do you understand
me!", and where Holmes eventually did find Couglin guilty of "summary
criminal contempt" denied a stay to a practicing attorney askign for a chance to
make alternate arrangments for his clients, and had Coughlin cuffed, searched,
and taken the the WCDC, not that gently either...only to have the RMC
Marshal return well after an period wherein the "incident to" part of a "search
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incident to arrest" could be said to be possible, to retrieve a licensed attorney's

smart phone, micro sd card, and other items...with all the date wiped or
destroyed therein prior to being returned to then licensed attorney Coughlin
some 37 days later...with a chain of custody in between deserving a whole lotta
second looks (Mary Kandaras? anything? Deputy Hodge? Marshals Coppa or
Deighton? Deputy Cheung? How about you WCSO's Debi Cummings, Brandi
Berriman, Deputy Beatson, Deputy Van der Wall, or Patricia Beckman?
Anything? Deputy Iver? No?s)
As related to my conversations with either my sister, which have been very limited
related to you, and certainly none related to your
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case, except you had a case over here, I've had no discussions with Judge
Howard, Judge Holmes, Mr. Hill, Mr. Hazlett-Stevens,(well, actually the Hon. W.
Gardner did, on the record in the first attempt at a Trial in that trespass case on
4/10/12 admit the he, City of Reno Prosecutor Hazlett-Stevens, eSq. Coughlin'
court appointed counsel Keith Loomis, Esq. did get together in a back room
that morning and hash some stuff out....but judge Gardner would later indicate
all this stuff was very "planned out" and done "very carefully" and whatnot) or
my sister regarding this trespassing case. And that's by design that was carefully
thought out so there's been no discussions.
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MR. COUGHLIN: And with the State Bar, I know earlier THE
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COURT: I have had no conversations with the State Bar.
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MR. COUGHLIN: Okay, at our last hearing though you made a statement, I believe,
the disciplinary or the Bar will be meeting next week to make a-
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THE COURT: I was advised by Judge Holmes that the process involving you and
the State Bar was in the process where they were going to make a decision, which
ultimately apparently they did. Those were the substances of those conversations, but
none were related to this case, and I can tell you that none have had any
conversations regarding the witnesses in this case that have never come up between
any of the counsel. I'm not sure they even know who the witnesses were quite
frankly.
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MR. COUGHLIN: Okay.
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THE COURT: Okay, thank you.

MR. COUGHLIN: Thank you, Your Honor.
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THE COURT: Okay, let's go ahead and proceed. BY MR. HAZLETT-STEVENS:
Q Thank you. Mr. Hill, I'm going to ask you to make sure you speak up and not trail
off your answers at the end. This is being recorded, so for appellate purposes, or any
other purpose, I'd like to get a good recording of this.
Page -21Mr.
Hill, what's your occupation or profession?

A
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I am an attorney practicing in Reno, Nevada."

And so on and so of.. Richard G. Hill and Casey Baker seeking to charge the same
rent as they did for "full use and occupany" as relevant to a claim of right defense to
the criminal trespass charge? Not relevant according to Judge Gardner. RPD
misconduct and Hill and Merliss's lies contributing to false arrest and Hill's perjured
sworn testimony detailed extensively in 61901, as is Casey Baker, Esq.'s professional
misconduct in doing in violation of NRCP 11 that which Hill chickened out doing in
his Declarations of 11/21/11 and 1/20/12, until the necessity and exigency of his
misdeeds and professional negligence ("wrong site surger" equals using summary
eviction proceeding where only No Cause basis pled or noticed, agains commercial
tenant, in express violation of NRs 4.0253 and even this Court's simplified
instructions in the "Landlord Tenant Handbook" (really choice how the instructions
to the forms on lockouts seem to adopt WLS's Sasser, ASsemblyman Horne and
Frierson and Segerblom's wishes as to the "within 24 hours" languagne being
interpreted to be no sooner than "within 24 hours" which, you can be sure, aint how
summary eviction order lockouts are being carried out. Ask NVB Judge Beesley
about Coughlin's ultra sheek t shirt and tie combination under the old blased at
2:00Pm on 3/25/12 in Cadle Company v Keller ($1.6 million dollar debt adversary
proceeding) where Coughlin manage to appear (finding a dress shirt was a problem
given Coughlin used the scant 5 minutes WCSO deputies durbina and cannizzaro
accorded him at 1:30 pm ish on 3/15/12 to grab his computers, client's files,
medications, contacts, glasses and whatnot after they broke in at gunpoint and
evicted Coughlin, as they do to all citizens of Washoe County subject to a summary
eviction order. GAyle Kern, Esq.? paging Gayle Kern...rjc rev2012-000374) But
the great thing is that Casey Baker testified on 6/18/12 that:
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A That's correct. Q So, the Findings of Facts, Conclusions of Law and

Order of Eviction found in your favor, Mr. Merliss's favor, rather, and the date of
eviction was as of October 31" at 5:00 p.m., correct? A That's correct. That's what
we announced in Court and put on that Findings of Fact. Q And that Order said that
anyone there after that date could be removed, is that correct?
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That was the command given to the Sheriff.

"Shall be removed."
Yes.
Page -66Page
-67Q Did you serve that document on Mr. Coughlin in any fashion? A Notice of Entry
of Order or anything like that? Or was that served by the Court on him?
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A The way it works is the Court -after the Court enters the Order, the Court forwards
it to the Sheriff. Q Okay.
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A And the Sheriff goes out and enforces the order.
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Q Okay, now I'm going to draw your attention to the date of November 13th, 201 1.
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THE COURT: What was that date again?
MR. HAZLETT-STEVENS: November 13, 2011, Your Honor.
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THE COURT: Okay, give me just a second, counsel.
MR. HAZLETT-STEVENS: Certainly, Judge.
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THE COURT: I'm making some notes here regarding some dates.
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MR. HAZLETT-STEVENS: And I'm going to withdraw that question, Your Honor,
so if you don't want to jot that note down, you don't have to at this point.
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THE COURT: Okay, I'm looking at something else, okay. Go ahead. Thank you,
counsel. BY MR. HAZLETT-STEVENS:
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Q I'm going to draw your attention to the date of November 1 st, 2011. Do you recall
what you were doing that day?
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A Yes, I was actually off of work that day. I was at home.
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Q Okay. A But I was basically on stand-by because I knew that the eviction was
going to happen. Q Okay, and did you actually eventually respond or have to come
to the area of 121 River Rock?
A Yes.
Q Why?
A The way it works, again, I'm sorry to keep doing this.
Q Please, please, please, you are educating us all.
A You have to wait for the Sheriff to contact you.
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Q Okay.
A The Sheriffs Deputies are sent out with several of these
things on the days that they do them, however, they do them every day. You can try
to shoot for a specific time, but you are at the mercy of the Sheriffs Deputy's
schedule. Some lockouts take longer than others. They try to give you lead time.
I had spoken with the Sheriffs Deputy already, I believe, on Friday the 28th Q
Okay. A I believe. It was either that, or I contacted him on his cell phone. But I came
back in (inaudible) do the lockouts.
THE COURT: I'm sorry?
THE WITNESS: I came back in so we could do the lockout, to meet the Sheriffs
Deputies at the property after the Sheriff calls. Q Okay, and so you actually did go to
121 River Rock?
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A Yes.
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Q And were there Sheriffs Deputies there?
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A I got there first.
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Q Okay.
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A Along with a member of our staff.
Q Okay.
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A And then two Sheriff's Deputies arrived.
Q Okay.
A And then we had to wait for the locksmith.
Q Okay, when the Sheriff's Deputies arrived, did they
have any documents in their hand? A I believe they had -yes, they had their copies of
the Findings of Fact, and Order for Summary Eviction. Q Okay, and do you recall
what the deputies, or one or both of those deputies did with the Findings of Facts and
Order of Eviction?
A Yes":
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Now, combine that testimony with the fact that the WCSO Liz STuchell, Roxy Silve,
Deputy Machen, Maureen, etc., etc. get real uncomfortable when it comes to
discussing just when they "received" either the 10/25/11 Eviction Order and
Decision of the 10/27/11 Findings of Fact, Conclusions of Law....combined the the
RJC's various statements respecting just how and when the WCSO gets those
eviction orders, and the usual custom and practices...combined with the WCSO's
statements about the maintenance of the faxes, the fax headers, the singular copies of
those faxes being filed back with the court transmitting them along with the Deputies
AFfidavit of Service (like th 11/7/11 one where Deputy Machen swore he
"personally served" Coughlin, despite his supervisor Liz Stuchell having to later
admit in writing that to Machen "personally served" means "taped it to the door
when no one was home"...and you know when HIll testified on 6/18/12 about "they
taped it to to door because you ran away" that, given Baker's testimony that HIll was
not present on that date, 11/1/11, and Baker's failure to make any such
allegation...that Hill was just doing more of the same tired innuendo and baseless
accusation, conveniently made to disguise yet another situation where his reckless
pursuit of fee generation clashes with the rules of professional conduct attendant to
his privilege to practice law. Because if that lockout order, whichever one applies,
was done too early, or too late...it was void or invalid.. meaning it was Hill, and the
WCSO, and Dr. Merliss and RPD who were doing the trespassing. Maybe that is
why the RPD refused to kick the door in on 11/13/11, but rather insisted the landlord
do it? And Maybe why those videos of the arrest and the subsequent video taped
admission by RPD Sargent Lopez reveal so clearly the fraudulence of the trespass
arrest and prosecution.
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Then there is this interchange upon Coughlin cross examining Casey Baker: "Q Okay, are you aware
that NRS 40.2080 specifically indicates that the Nevada Rules of Civil Procedure do apply to
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summary landlord/tenant proceedings to the extent that the matters not spoken to by the statutes found
in 11 8(a) or the relevant portions of 40, are silent in those regards? A You're asking me to tell you
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what that statute says? I have no idea what that statute says (inaudible). Q Are you aware that NRS
40.2080 specifically does make NRCP applicable to these proceedings? A I'm aware that you just told
me that, but I don't know that to be the case without reading the statute. Q Okay, but earlier, you said
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that was not the case, just now, correct? A What I said was that the rules that we were operating under
in the summary eviction proceeding are the Nevada Justice Court Rules of Civil Procedure. I
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understand there is some interplay in between the rules to the extent one set does not cover
something, you can look to the other set. Page -78- But, are we talking about substitute service still? I
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don't really know what your questions were other than do I know that statute verbatim? No, I don't. Q
Okay, so you're unaware of whether or not, yes, the rules relative to substantive -constructive service
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THE COURT: Mr. Coughlin. MR. HAZLETT-STEVENS: I'm going to object. THE COURT: Let me
tell you something. We are getting way out in an area that, quite frankly, from the legal perspective,
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I'm not really interested or relevant where this is going. I think you were making some ground,
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headway, asking some of the relevant questions about the issue in this case, some notice, what was
contained in the language. Those were ripe questions for cross-examination, and you were doing a
good job asking those questions. But really, I have no interest legally, and I think it's 100% irrelevant,
which rules apply in the Justice Court. I think you are getting far, far -you are straying far from the
relevant issues which you were exploring earlier, and I'm going to sustain the objections, and direct
you to ask some questions that directly relate to the content of either the Findings of Fact, the Order
of Eviction, or what happened when you were present in Court. But I'mjust not going to allow the
questions because they're not going to affect my ruling at all. I find them just irrelevant. Page -79MR. COUGHLIN: Okay, Your Honor. And in order to ascertain whether or not service was
appropriately done, we need to know what rules apply, don't we? THE COURT: Mr. Coughlin, we
don't need to know what rules are done (sic). Service, you can ask. I'll decide what service was done
from ascertaining what facts are developed here in Court, and listen to those. I've heard some things
were left on the door by the Sheriff. I have a couple documents in evidence, and I know you were
present at a hearing. And those are the questions that I think, quite frankly, you should be zeroing in
on in terms of any questions, and then there's only so many questions ultimately that can be asked that
really are relevant before we start to wear out the welcome on cross-examination in terms of
redundant, repeat, and asked and answered questions. So, let's stay focused on that issue, and go
ahead and ask another question. MR. COUGHLIN: Yes, sir, Your Honor. It just is -I don't know if
you can call it an offer of proof, but. THE COURT: Go ahead and make an offer of proof. I'll allow
that. MR. COUGHLIN: I don't even think I know what that is, sir. My point is not to take up the
Court's time. My point is THE COURT: Mr. Coughlin, let me tell you right now. You can take all the
Court time we need as long as we're focusing on the relevant areas that we have not explored. Page
-80- To the extent we begin to rehash and go over items that we've heard before, that's a waste of
everybody's time. I don't think anybody needs to worry about me having my time wasted. I've
dedicated the entire day to have this trial conducted and heard. I will do that to the extent we're asking
questions that are new, fresh, and relevant. So, go ahead. MR. COUGHLIN: And, Your Honor, my
only point is, this is probably one of the most important issues in the whole trial, if you ask me. THE
COURT: Well, then that's MR. COUGHLIN: And that's why I'm THE COURT: And that's why I
think you should probably zero in on those issues, and you're starting to stray into areas that I don't
believe are relevant to that issue, and I'm giving you my ruling from the bench. MR. COUGHLIN:
Yes, sir, Your Honor. I'm just asking for some clarification. If! can just, for a minute, set forth why I
believe this is relevant. THE COURT: Go ahead, Mr. Coughlin. MR. COUGHLIN: It seems to -it
seems this case is premised upon the idea that an eviction notice is tantamount to a waming under A.
10.040, the trespass statute, failure to leave the premises after being warned to do so. Trespass, Reno
Muni Code. So, it seems as though the City is saying, "Your warning to leave the premises was this."
And I'm saying, "This isn't this until it's served under the law, and the law says that you have to serve
it by personally serving it, because NRCP is incorporated under 40.280." Page -81 - So, you have to
either personally hand it to the party, which I will establish later was not done, and I believe his
testimony was to the effect that no one was there. So, if you don't get that, the law says, NRCP 6 -4, 5,
and 6, it says you have to substitute service. I think some people call it constructive service, three
days for mailing. THE COURT: To the extent this witness is able to answer, why don't you ask the
witness those type of questions. I think you can MR. HAZLETT-STEVENS: And, Judge, I'm going to
interpose THE COURT: Go ahead. MR. HAZLETT -STEVENS: --my objection for lack of a better
word here. I'm not trying to prove that an eviction -that an eviction Findings of Facts and Conclusions
of Law was properly served on Defendant. That's not my obligation as a criminal prosecutor in this
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case. My obligation is to show notice that he was evicted, and ifhe was back on the property. I don't
think they're relevant what kind of service actually happened, whether it's pursuant to Nevada Rules
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of Civil Procedure, the LandlordlTenant Law, or rules applicable to the Justice Courts. So, for the
record, that's my objection. THE COURT: Thank you. Why don't you focus your inquiry on some of
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the areas you raised which you should be able to have answered in two or three questions of this
witness to the extent he's able to answer Page -82- those about what service was accomplished, and
I'll deal with those legal issues at the back end? MR. COUGHLIN : Yes, sir, Your Honor. BY MR.
COUGHLIN: Q So, your testimony is that you don't know that you ever effected substitute or
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constructive service of this that your office did prior to the lockout? Order? A Q I don't know when
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we did the Notice of Entry. You don't know when you did the Notice of Entry of Order"
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Then there is this when Coughlin cross examined Richarg G. Hill Esq. at the trespass trial:
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"MR. HAZLETT-STEVENS: Objection, relevance. THE COURT: Sustained. It's irrelevant, Mr.
Coughlin. I've addressed that issue. Mr. Hill's financial arrangement with his client is irrelevant to this
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trespassing case. I'm really not legally interested in the amount of money he billed nor received. I
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think it's irrelevant. MR. COUGHLIN: I'm not offering to prove the truth of the matter asserted in what
he billed. I'm offering it THE COURT: I'm telling you it's irrelevant. That's a hearsay issue whether it's
been offered to prove the truth, and quite frankly, I'm making a judicial determination that his
relationship with his client related to finances is irrelevant to this trespassing case. So, I'm going to
not allow any questions related to that line of inquiry. So, let's move on to our next question. Page
-45MR. COUGHLIN: Yes, sir. Page -46- BY MR. COUGHLIN: Q Was the issue of whether or not the
lease allowed for a commercial use a very important issue in that summary eviction proceeding from
which this criminal trespass (inaudible)? A Are you asking was that an important consideration in my
being able to undertake the assignment? The answer is no. As to what exactly you did or said (inaudible -both talking). Q No, I'm asking you if it was important as to whether or not it was
permissible to pursue a summary eviction proceeding if it's a commercial tenant where you are only
alleging non-payment of rent. THE COURT: Ifyou can answer that, Mr. Hill, go ahead. THE
WITNESS: I didn't hear it, and I'm not sure that I can understand it. But if you'd like to try again, 1'11
THE COURT: Go ahead and rephrase the question, Mr. Coughlin. Speak loudly and clearly and Mr.
Hill will do his best to answer that question. BY MR. COUGHLIN: Q Was it an important
consideration to your office in the course of representing Dr. Merliss whether or not the lease
agreement allowed for use of the premises for a commercial use? A No. Q You are testifYing that
your office's representation of Dr. Merliss did not include a careful consideration of whether or not
the lease allowed for a commercial use of the premises? -47- MR. HAZLETT-STEVENS: Asked and
answered, Judge. He said no. THE WITNESS: That wasn't the question. The question was whether
THE COURT: I got three things going on here, and we're making an oral record so let's try to keep it
civil to the extent we're able to. Mr. Hazlett-Stevens has raised an objection to the question. Mr.
Coughlin, do you want to respond to that? MR. COUGHLIN: Yes, sir. Mr. Hazlett-Stevens said it was
asked and answered, I believe? MR. HAZLETT-STEVENS: Yes, there was an objection asked and
answered after he said no to the previous question, asked slightly differently. THE COURT: What's
your response to Mr. Hazlett-Stevens? MR. COUGHLIN: It was seeking clarification because I was
surprised to hear no to such an important issue. MR. HAZLETT-STEVENS: Surprise doesn't
overcome. THE COURT: Okay, as a matter of clarification, so the record is clarified, ask the question
again, and Mr. Hill, let's see if we can answer that question to the best of your ability. Go ahead, Mr.
Coughlin. BY MR. COUGHLIN: Q Mr. Hill, did you just testifY that you did not feel it was an important
consideration in representing your client to determine whether or not the lease in question would
permit commercial use? A No, it's not important. We were hired to evict you, and Page Page -48that was the assignment. Q Okay, so if the law has an express dictate prohibiting the use of
summary eviction proceedings against commercial tenants where the non-payment of rent is not
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alleged or served as an eviction notice, would that present a situation where it would be an important
consideration? A Mr. Coughlin, I'm having a real tough time following your question. Q Okay. THE
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COURT: Go ahead and rephrase the question, Mr. Coughlin. THE WITNESS: You've made it in
small pieces. THE COURT: Hang on, Mr. Hill. Rephrase the question. Let me tell you, I'm giving you
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a great deal ofleeway on cross-examination in fairness to you, and we're getting into issues that
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really, really exceed the scope of the direct examination. And I'm willing to give you a great deal of
leeway, but at some point, the leeway limitation comes to an end. So, go ahead and ask one more
question related to this. Try to make it specific, and then Mr. Hill will do his best to answer that
question. MR. COUGHLIN: Yes, sir, Your Honor. Just quickly, I'm a little green on this, but he
opened the door quite a bit, too. THE COURT: Go ahead and ask a question, Mr. Coughlin. BY MR.
COUGHLIN: Q You just testified that you did not feel it was an important consideration
whether or not the lease allowed for commercial Page -49- use, correct? A Yeah, it was not
that important. Q Okay, would it become important if your entire case, or the order which you
prepared for your client was void because there is no jurisdictional basis for entering such an
order? A If your presumptions were correct, which they're not, then it would become
important. But since you're wrong, it was not important. Besides that, you didn't raise it. Q
Was the fact that the property was being used for a commercial purpose set forth in the
tenant's affidavit? A I don't know. Q You don't know? A I do not recall. Q You just testified
that it wasn't raised, so how could you do that with a straight face, and then answer you don't
recall now? THE COURT: Mr. Coughlin, he's answered the question that he doesn't recall. Your
comments become argumentative so let's We're getting into an area where I'm not going to litigate in
this Court the merits of the landlord/tenant relationship, nor the -ultimately the basis for the eviction.
Mr. Hill has testified to a limited degree what he's done, and if you have anything relevant to what he
said, go ahead and ask it. If not, I think it would be a good time to terminate your cross-examination
unless you have any other relevant questions. -50- COUGHLIN: MR. COUGHLIN: Yes, sir, and I
appreciate your frustration with the extent to which civil eviction laws is taking up criminal court
resources, and that's underscored in State v. Johnson. THE COURT: No, let me tell you, Mr.
Coughlin. You are not going to misquote what I'm saying. I'm not frustrated by that process at all. I'm
just saying that it becomes irrelevant in my Court when you hear this criminal matter, the details
which happened in the Justice Court, on a landlord/tenant matter, and I'm not frustrated one bit. MR.
Yes, sir. THE COURT: To the extent matters are relevant in the criminal case, I'm going to hear
them, but as they get to be marginally irrelevant, we begin to take up time that's not best served in
the Court. So, if you have any other direct relevant questions, go ahead, and don't try to put words in
my mouth about what I'm thinking. Thank you. MR. COUGHLIN: Yes, sir, Your Honor. I apologize.
BY MR. COUGHLIN: Q Mr. Hill, are you aware of a case called State v. Johnson, that's 2010
Westlaw 4514666 where in some of the problems associated with co-opting a police force MR.
HAZLETT -STEVENS: Judge, I'm going to object already as to relevance. THE COURT: Let him
finish the question. Go ahead, Mr. Coughlin. Go ahead and finish your question. Mr. Hazlett-Stevens,
you can object at the appropriate time. Page Page -5 1 - MR. COUGHLIN: Wherein some ofthe
problems associated with landlord co-opting a police force to do civil landlord/tenant -to a certain an
effect on civil landlordltenant disputes is discussed at length? MR. HAZLETT-STEVENS: Judge, I am
going to object as to relevance, and there's no foundation for the question in this case at all based on
direct examination. THE COURT: That objection is sustained, Mr. Coughlin. I don't think that's
relevant. MR. COUGHLIN: Yes, sir, Your Honor. I'm trying to wrap it up here with a question or two,
Your Honor. I think that's all I have. THE COURT: Thank you, Mr. Coughlin. Mr. Hazlett-Stevens, any
redirect? MR. HAZLETT-STEVENS: Nothing. No redirect, Your Honor. THE COURT: Mr. Hill, thank
you very much. You may have a seat. Thank you, sir. Alright."
27
28
5
6
And, actually, Hill quite wrong. Coughlin did plead and raise quite a number of times the fact
that he was a commercial tenant and the fact that Hill, Baker, and Merliss were pursuing only a No
Cause Eviction that neither pled nor noticed Coughlin as to any non payment of rent allegation, a
clear violation of the dicate against the use of such proceedings in NRS 40.253. Is in Coughlin's
Tenant's Affidavit, various pre-Trial Motions (including the one filed on 10/18/11 in advance of the
10/25/11 "Trial", and repeatedly through the audio of the trial, for which there exists now at least a
patial unnoficial transcript. Again, the highlight of Coughlin's cross examination of Hill:
"MR. COUGHLIN: Q You just testified that you did not feel it was an important consideration whether
or not the lease allowed for commercial Page -49- use, correct? A Yeah, it was not that important. Q
Okay, would it become important if your entire case, or the order which you prepared for your client
was void because there is no jurisdictional basis for entering such an order? A If your presumptions
were correct, which they're not, then it would become important. But since you're wrong, it was not
important. Besides that, you didn't raise it. Q Was the fact that the property was being used for a
commercial purpose set forth in the tenant's affidavit? A I don't know. Q You don't know? A I do not
recall. Q You just testified that it wasn't raised, so how could you do that with a straight face, and
then answer you don't recall now? "
10
11
Dated this November 9th 2012:
12
__________________________
Zachary Barker Coughlin, Esq. (Nevada law license temporarily suspended, USPTO license in tact,
13
and given permission to issue subpoenas by SBN Chief Bar Counsel David Clark, Esq. and firing up
that whole 11.25(c)(3) engine)
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
proof of service/certificate of mailing
i zach coughlin placed this 11 9 12 Emergency Ex Parte Motion to Dismiss or Quash or Otherwise
Challenge Sufficiency of Service and of Process, of Complaint and Notice of Intent to Take Default
and DoWSoE; and Preserving for Appeal Objection to All other Due Process Violations; and
UNDER PROTEST...RESPONSE TO COMPLAINT in the mail with postage, and or transmitted a
digital copy to all of those who have either expressly or implicitly agreed to service via digital
transmission (plus Pat "Salieri" King told me the SBN takes anything I file and provides a stamped
10
copy to all 5 member of the Panel immediately and that I could rely on that), in the mail out for
11
delivery /pickup today.
12
13
14
15
16
dated november 9th, 2012.
17
18
____________
zach coughlin
19
respondent
20
21
22
23
24
25
26
27
28
1
index to exhibits:
2
1. exhibit 1: cd with relevant materials copied via digital transmission as well
3
5
6
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FILED
,
13fU25 FII3:S
IN 1l1F. }U"'ICIl COURT OF RFNO
TOWNSIIIP
COUNTY Of W A5110E. STATE Of NEVADA
Sll" WillE
,UURI
!y'. JO:.IIC
IN TIlE ADM!N!Sl1!AnVE MATfER OF:
ZACHARY BARKER COUGHLIN
----,
--
ORDER mSHOW CAUSE

ORDER 2012-91
On Doc=bcr 26, 2{l12 ZACHAII.Y llARKER COUGHLIN (Coogblillj "'... peroooally
12
"ZACHARY BARKER COUOHLIN i, "'" oJlowed to <l1a<1 ony member ofthi. Court_
13
lhan uniformed baililJ,"
1.
,101","", "fthis Order mo.y be eomid<red """'"",pi ofCOUI1 ODd punished pu,......,I", NitS
Chap'er n by. fi.. of up to!SOO ond/(If i for up to 2S da)'> in Ibo: Wooho<l;oonty
Tho Onl<, abo infeormed Mr. Coughlin .! ...:ti,," that "I_loy
[)e"",llon t'ocility."
"
nus Coort Is "",ived reports ,,{II>< fullo"'lng violOlI_ "fOrder 2012-01:

On Jonuat)I 7, 2\113 Coughlin tei",booal thr<e .mploJ= of\he Reno Justioe Court .,
the C"",,', pIK>no n"",bet.
On }""...,. 7. 2013
Cougl'dm "'... ' " med by. ","f",toed bailiff ofthU Court IIW be
..
w no( 10 ""," OIly'''''''IOC' .,;'" ony omf>loy.., ofll>e Court 0<1> t/w) uniformed bailiff, ODd he
..
W1''''''ided the tel.".,.,.., number [0<" til< bai liO"tatiro.
On Jon""'Y 23. WIJ Couihlin oontacIe<I an employee 0Iber IiwI a unifonncd bailiffat.
numberother than tho, provided '" him .. the bailifl'. nation.
On February S, 2O11 CoUhlin OOIIt.><1ed two employees who are "'" bailiff, .. a numb<r
February 5. 2013
Zach COUl/hUn
lOJ!
".h St.
Reno. !IV ,nll
La.c ...k whn "ailed thi. Oti" I in.rc.pted 1n order to

take h' opportunity to addr how we int.nd to d.ll with r
cic.tion..
unortunat.ly. r a. now vlne.d ar. unable
to .x.rei reltrllnt or let relaonably.
Whil. I eant control
"hat you do, I haVI .... control ... to ""'" ... r pond
.u I 1ndicued. thb OrUee will .trlwt to ....<tuc. your ability to

dl....ctly COntact peopl. who wgr hr..
Thl. will apply to phon.
You ..ill have to fUe document. wah
cdlo. tuu and I_H..
the court II>d .erv. thew! by _U or couri.r.
Ttl.. OUir. will
Ippelr 1n COUrt ..h'n 10 directed by a court atter proper notic.
Me will r pond to lOtion. properly filed and
rved.
'
"III .ily ACcept what hal be

ClrCUMV.nt our Iffort, to block your
.xpect.d. "ill only wgr,en _ttlr..
1
pending .. tt.r. to I conclu.ion.
We le to
' hi. could oceur or thrOUgh your letiona
. ; "Ill be _hL
i;
torney
.nrn/kh
3/20/13
RE: please respond to my subpoenas

From: Helzer, John (jhelzer@da.washoecounty.us)
Sent: Wed 2/06/13 7:36 AM
To: 'Zach Coughlin' (zachcoughlin@hotmail.com)
Cc: Covington, Mark H. (MCovington@da.washoecounty.us)
I did not read this and will move to have your e-mails to me directed to a storage file. Since your e-mails
will not be received they will not be read or acted upon. John Helzer

Sent: Wednesday, February 06, 2013 7:25 AM
To: Watts-Vial, David; dwatts-vial@washoecounty.us
Subject: please respond to my subpoenas
Dear Mr. Watts-Vial,
I received you 11/13/12 fax citing NRCP 45 and my current temporary

suspension of my law license in Nevada (but not before the USPTO) as a basis
for your office failing to comply with my subpoenas. Please note that NRCP
45 is inapplicable as SCR 110 applies. Further, the SBN/OBC/Panel/Board
gave me express permission to issue my own subpoenas (ie, no court seal
required) in this SCR 110 context, and waived any witness or subpoena duces
tecum fees. Please consider all those materials requested as included in this
NRS 239 Open Records Request and included the fax logs between the RJC
(Judges Chambers, I guess, and Civil Division filign office) and the WCSO
Civil Division where all eviction orders are faxed for the time period between
October 25th, 2011 at 3pm to November 2nd 2011 at 3pm, with a specific
focus applied to the 121 River Rock St. address an information related to just
when the WCSO "received" the two different Eviction Orders for that same
address.
https://bay158.mail.live.com/mail/PrintMessages.aspx?cpids=012bf369-7073-11e2-9858-00237de3fb3e,m&isSafe=false&FolderID=66666666-6666-6666-6666-6
1/2
3/20/13
Sincerely,
Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
7402 ZachCoughlin@hotmail.com
https://bay158.mail.live.com/mail/PrintMessages.aspx?cpids=012bf369-7073-11e2-9858-00237de3fb3e,m&isSafe=false&FolderID=66666666-6666-6666-6666-6
2/2
DECLARATION SUPPLEMENT
Page:
13-2445
CASE#
"" '-7"
On 01-25-2013, I (Detective Yturbide) was assigned this case in reference to an original fr om cas . 13 _iC"
"' '" 100306, in which there was a violation of a Temporary Harassment Protection Order. During my
investigation I determine this separate violation had occurred after the temporary order was extended. The
original order (RCP 2012-000607) was issued on 12-20-2012 and served on 12-26-2012 at about 1458
hours on the arrestee, Zacahry Coughlin. The order (Rep 2012.0(0607) was extended on 01-04-2013 and
Zachary was served on 01-05-2013 at about 1000 hours. The extended order is valid until 01-04-2014.
In the order it states that Zachary directly or through an agent is prohibited from contacting the office of
the State Bar of Nevada located at 9456 Double R Blvd. #8 by any means including facsimile (fax).
Zachary is only allowed contact to the office through the U.S. Mail. On 01-17-2013 at about 0509 hours a
371 page fax was sent to the office with a cover page documenting it coming from "zachcoughJin". The
fax was stopped prior to completion.
Zachary was contacted at a later date and booked in to the WCSO Jail.
NFD
WHEREFORE, Declarant requcsts that a fmding be made by a magisttate that probable cause eX!lIts to hold :\aid person fOf
preliminary hearing (if cbarge is a felony or gross misdemeaDor) or for a trial (ifcharge is a ntisdemeaoor).
REVIEWED FOR PROBABLE CAUSE (PC).

PC FOUND
PC NOT FOUND
DECLARANT
ATE
="'=,,
=="" '"
:=
DEFENDANT ORDERED==
D
RELEASED , DATE;
_
___
T. YTURBI DE III
,MAGISTRATE
PAGE
1.0.#
"2-
_______
9078
GF
,M AGISTRATE
DECLARAnON SUPPLEMENT
Page:
CASE# 13-100306
On 01252013, I Detective Yturbide was assigned the original of this case in reference to a Violation of a
Temporary Harassment Order. During m y investigation J dctermined that the arrestee Zachary Coughlin
was served the temporary order o n 1226-2012 at about 1458 hours. On the date of0 )0320 13 at about
1700 hours after having been served the order which states that Zachary is prohibited, either directly or
through an agent from contacting the Nevada State Bar located at 9456 Double R Blvd. #8, did have a
male individual contact that location attempting to file documents on behalf of Zachary Coughlin. While
working at this location Laura Peters was working as a Paralegal/Investigator and did see this occur. She
also saw a vehicle that she knows is Zachary Coughlin's. She knows this is Zachary's vehicle due to
several previous contacts with him.
Zachary was contacted at a later date and arrested for the violation of the Temporary Order for Protection
Against Harassment in the Workplace. This order is documen.ted under Rep 2012-000607. It W3..'\ issued
on 12-20-2012 and valid until 01-04-2013. Zachary was also arrested in relation to a violation of this
.
same order that was extended on 01-04-2013. Reference RPD case #13-2445.
NFD
WHEREFORE, Declarant requests that a finding be made by a magistrate lhal probable cause exists 10 hold said person for
preliminary hearing (if charge is a felony or gross misdemeanor) or for a trial (if charge is a misdemeanor).
REVIEWED FOR PROBABLE CAUSE (PC).
0 PC NOT FOUND --.b.L..
DECLARANT
T. YTURBIDE III
I.D.#
9078
PC FOUND
DATE:
.
= M. AGlSTRATE
A11===
DE FEND'A"NT=''''lRD='''RE D RELEASED, DATE:
W
'Rru iED\D
PAGE
2-
_______
OF-Z-
,MAGISTRATE

3 25 13 Motion For Extension of Time To File Opening Brief 0204 62337 13-08766

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1

IN THE SUPREME COURT OF THE STATE OF NEVADA

MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF

POINTS AND AUTHORITIES

Appellate Review 533. FilingExtensions for filing. As to the consequences of an

appellant's or an appellee's failure to file a timely brief, see 536 to 538.

SCR 105(3).Review by supreme court.

The 12/14/12 FOFCOL by the Panel is just that, a Findings of Fact;

However, to whatever extent the 12/14/12 FOFCOL is deemed a decision, Coughlin

and other post-judment motions, is misconduct.

Even if this Court were to accept Respondents motion to dismiss as exceptions, we

disciplinary hearing before Judge Cavanaugh was governed by the procedure

SCR's that permits it.

documents submitted for filings.

Also, arguably, the 12/14/12 FOFCOL is not a

decision, and any Recommendation contained therein is not announced thereas in

Record on Appeal and Declaration thereto filed on 3/19/12) could arguably be

to a grueling 8 hours of trial in RCR2012-065630 on 3/19/12, in an extremely specious

prosecution of Coughlin for resisting a public officer stemming from an original

misuse of 911 emergency systemgross misdemeanor charge of 1/14/12

(interestingly, Coughlin's public defener (Notice of Dogan's assignment as attorney of

Patrick O. King, Esq.

Dated March 21, 2013

2. Exhibit 2: various other relevant materials

DECLARATION OF ZACHARY BARKER COUGHLIN:

technical malfunction resulted in my computer, the internet, eflex, or something

ought be transcribed (involving an allegation of Coughlin consuming $14.00 worth of

189.030, denied Coughlin a single continuance despite a multitude of factors weighing

Additionally, incident to the criminal trespass matter in 61901, there is a

appointed defenders, and more).

NRAP RULE30.APPENDIX TO THE BRIEFS

(1)Order and Numbering of Documents.All documents included in the

(d)Exhibits.Copies of relevant and necessary exhibits shall be clearly

Coughlin diligently attempted to obtain express indications from the Clerk of

Court/sbn/nndb/and paenl respective the applicable rules of procedure in this matter

outside of Coughlin's presence as to substantive and procedural matters?

From: tsusich@nvdetr.org To: zachcoughlin@hotmail.com CC:

could be characterized as a Motion for Reconsideration, etc., regardless, it should be in

received no response or indication from either the SNB/Panel/or Board as to whether it

was filed in or being reviewed.

NRAP RULE10.THE RECORD

Peters, and the Panel.

shotgun type of complaint, completely devoid of any sense of proportion or specifics

(12 RPC's alleged violated an unenumerated number of times..crammed ridiculously

of the Exhibits King sought admission of at the Hearing).

(b)The Appellate Court Record.

(2)Exhibits.If exhibits cannot be copied to be included in the appendix, the

(1)Exhibits.If the Supreme Court directs transmittal of exhibits, the exhibits

workplace harassment protection orders, though failing to put up the statutorily

Coughlin has been declared indigent as recently as in a 1/9/13 Order by a Second

(including the transcript of both hearings in 11 TR 26800, that resulted in NG12-0434

in violation of NRS 189.030) multiple Notices of Appeal of such final appealable

of Coughlin (and there is a multitude of videos of these various arrests of an

way...whereas the jaywalking arrest that Hill succeeded in subjecting Coughlin to on

thereof....including footage of Hill's prevarications to the police). The dates of the

Esq., suddenly appeared the morning of the 1/7/13 hearing in RCR2012-067980

I was taken in to custody on 2/12/12 RCR2012-065630 upon appearing late to

such warning issued in regard to my allegedly being late to court on 12/11/13. My

Rule 3) (whether it be in RCR2011-063341, RCR2012-065630, RCR2012-067980, the

original 12/20/12 Administrative Order 2012-01 baring a caption of only In the

Coughlin's attorney or record in AO12-01 or RCR2011-063341, though some fallout

067980 and RCR2011-063341 (presumably a Gagnon I style hearing as Coughlin has

recent deprivation of Coughlin's right to file documents in these various matters),