11 7 12 0204 063341 D RCA Skau's Motion For Protective Order To Quash Subpoenas and For Protective ORder RE Issuance of Subpoenas

'FILED
I JOHN J. KADUC
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Reno City Attol11ey
CREIGTON SKAU
Deputy City Attol11ey
Nevada State Bar No. 34
P.O. Box 1900
2UI2 NOV - 7 PM 1;: 20
Reno, Nevada 89505
(775) 334-2050
(775) 334-2420 Fax
Attorneys for City of Reno
IN THE JUSTICE COURT OF RENO TOWNSHIP
COUNTY OF WASHOE, STATE OF NEVADA
STATE OF NEV ADA,
Case No. RCR2011-063341
Plaintiffs, Dept. No.2
vs.
COUGHLIN, ZACHARY BARKER,
___________ -----'1
MOTION FOR PROTECTIVE ORDER TO QUASH SUBPOENAS AND FOR
PROTECTIVE ORDER REGARDING ISSUANCE OF SUBPOENAS
T
COMES NOW, City of Reno ("City"), as the employer and on behalf of Reno Police
Department Officers Ron Rosa and Thomas Alaksa, and Court Marshall Joel Harley and Reno
Emergency Communication Center employees Savannah Montgomery and Scott Weese (and
any other City employees (collectively "City employees") whose names were umeadable in
subpoenas), by and through their counsel of record, John 1. Kadlic, Reno City Attorney, and
Creig Skau, Deputy City Attol11ey, and hereby moves this Court for an order to quash the
subpoenas claimed to have been served on for these City employees in violation of Justice Court
27 Rules of Civil Procedure (JCRCP) 45 and for the entry of a protective order pursuant to the
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JCRCP 26. This Motion is based upon the attached memo of Points and Authorities, the
attached Exhibits and any additional or further evidence the Court deems just and proper.
1. Statement of Facts
The following procedural background is relevant to this matter:
A. On October 26, 2012, City of Reno Emergency Communication Center employees
(ECOMM) Suzy Rogers and Kelley Odom received emails from Zach Coughlin
containing nine (9) Subpoenas, copies of which are attached as Exhibit "I" and
incorporated herein by reference.
B. On November 2, 2012, City sent Mr. Coughlin a letter to two addresses via US Mail
infonning him, among other things, the City of Reno Police Report and City of Reno
ECOMM materials regarding Case Number RMC 201106334Jwere available for
pickup provided he submit payment to the City of Reno for $108. A copy of the
letter is attached as Exhibit "2" and incorporated herein by reference. On November
5,2012, this same letter was sent again to Mr. Coughlin by certified mail to the same
two addresses.
C. This cOlTespondence also informed Mr. Coughlin that the four (4) subpoenas he
claimed to have served regarding the appearance of the City employees Ron Rosa,
Thomas Alaksa, Savannah Montgomery and Scott Weese were ineffective because
of a failure to comply with JCRCP 45(a) and/or JCRCP 45(b). The letter indicated
'because service of the subpoenas for these four (4) individuals was ineffective, these
individuals would not be appearing on November 19, 2012. (Exhibit "2").
D. On November 1,2012, Mr. Coughlin delivered twelve (12) subpoenas and a "Notice
of ElTata and Revised Supplemental Motion For a New Trial" by sliding them
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through the security glass in the front office of the Reno Police Department at
approximately 4:50 p.m. after being told the office was closed. Three (3) subpoenas
contained in this packet are duplicates. As such, this packet appears to contain the
same ten (10) subpoenas he previously sent to Reno ECOMM employees Kelley
Odom and Suzy Rogers. A copy of this packet is attached as Exhibit "3" and
E. On November 3, 2012, Mr. Coughlin emailed another subpoena duces tecum to
both City ECOMM employees, Kelley Odom and Kariann Beechler, seeking
documents previously requested in earlier subpoenas duces tecum. These subpoenas
also contained multiple pages of requests for materials unrelated to Case RMC
RCR2011063341. A copy of these documents is attached as Exhibit "4" and
F. On November 5,2012, Deputy City Attorney Robert Bony received a telephone call
from Mr. Coughlin regarding the letter this office mailed on November 2, 2012.
Among other things, Mr. Coughlin did not indicate he would be withdrawing his
subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery and Scott Weese.
Mr. Coughlin did state to have these witnesses ready for trial.
G. On November 6, 2012, Mr. Coughlin submitted a new document entitled Subpoena
Duces Tecum containing seventeen (17) pages of blended documents regarding
matters pending before Reno Justice Court on November 19, 2012 and the State Bar
Of Nevada Northern Nevada Disciplinary Board to the Reno Police Department.
The subpoena duces tecum on the first page of the packet contains many unreadable
names. A copy of the packet is attached as Exhibit "5".
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H. On November 6, 2012 City employee Marshall Joe Harley was handed a packet of
materials from an unidentified person. The cover sheet of the packed is entitled
"Subpoena Duces Tecum" regarding Case RCR2011-063341. This document also
appears to contain names of other individuals but the handwriting is unreadable. It is
not known if the other individuals on this subpoena are City employees. A headnote
on the Subpoena indicates that if the requested documents are e-mailed to Mr.
Coughlin, personal appearance may not be required. A copy of the packet is
attached as Exhibit "6".
II. Argument:
A. Service
JCRCP 45 addresses SUbpoenas. In pertinent part it states:
(b) Service.
(1) A subpoena may be served by any person who is not a party
and is not less than 18 years of age. Service of a subpoena upon a
person named therein shall be made by delivering a copy thereof to
such person and, if the person's attendance is commanded, by
tendering to that person the fees for one day's attendance and the
mileage allowed by law. When the subpoena is issued on behalf of
the State or an, officer or agency thereof, fees and mileage need not
be tendered. Prior notice, not less than IS days, of any commanded
production of documents and things or inspection of premises
before trial shall be served on each party in the manner prescribed
by Rule 5(b).
The subpoenas Mr. Coughlin e-mailed to Kelley Odom, Kariann Beechler and Suzy
Rogers on October 26, 20]2 and November 3, 2012 and re-delivered to the Reno Police
Department on November 2, 20] 2 and November 6, 20] 2 commanding the appearance of the
many different City employees above are deficient and ineffective as they fail to comply with
personal service requirement of JCRCP 45(b). Accordingly, service was ineffective and all of
the subpoenas should be quashed.
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In addition to the failnre of personal service, 3c1l ofMr. Coughlin's subpoenas referenced
in Exhibits "1", "3", "4" and "5", also:
1. Violate JCRCP 45(a)(I)(D) in that they do not set forth the text of subdivisions (c) and
(d) of JCRCP 45.
2. Violate JCRCP 45(b)(l) which states that a "subpoena may be served by any person
who is not a party" to the proceeding. All of the subpoenas were e-mailed to City
ECOMM employees Kelley Odom, Kariann Beechler and Suzy Rogers on October 26,
2012 and November 3,2012 and/or hand delivered to the Reno Police Department on
November 2,2012 and November 6, 2012 by Mr. Coughlin, a pmiy in this matter.
3. Violate JCRCP 45(b )(1) which states that service of a subpoena commanding attendance
requires that payment for one day's attendance and the mileage allowed by law. No
witness fee or mileage fee has been submitted by Mr. Coughlin for the appearance any
named City employee.
4. Violate JCRCP 45(c) which states that a party or attorney responsible for the issuance
and service of a subpoena shall take reasonable steps to avoid imposing undue bnrden or
expense on a person subject to the subpoena. Mr. Coughlin is serving a litany of
subpoenas on many City departments and City employees regarding this case. However,
he is also serving subpoenas on City depmiments and City employees on a multitude of
other cases and proceedings that are unrelated to the instant action. These subpoenas are
unduly burdensome, duplicative, irrelevant, unintelligible, oppressive, harassing, seek
information that is irrelevant to this action and violate the applicable procedural rules.
Based on the above, the requirements of JCRCP Rule 45 have not been met and the
subpoenas for all City employees to appear on November 19,2012 must be quashed. The City
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I also moves to quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley
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Odom, Kariann Beechler and Suzy Rogers andlor submitted to the Reno Police Department
which do not relate to the City or to this matter.
B. Protective Order
In accordance with JCRCP 26, the City seeks a protective order in this matter. As
described above, Mr. Coughlin, a Nevada attorney with a suspended license, is abusing the
subpoena process granted to him by this Court. He is e-mailing multiple City employees or
dropping off the same subpoenas (some of which relate to this matter and many which relate to
a State Bar proceeding or other criminal matters) at multiple City departments. This is creating
confusion and leading to a waste of time and resources of public safety employees. As an
attorney, Mr. Coughlin should be aware of the subpoena process. This is not the first matter in
which Mr. Coughlin has abused a court procedural matter. For this Court's information, Reno
Municipal Court Judge Holmes issued a Sua Sponte Order Denying Relief Sought in Improper
Document on March 13, 2012 finding, among other things, that Mr. Coughlin failed to follow
proper legal procedure in preparing and filing motions in a matter pending before that Court and
that Mr. Coughlin blatantly abused that Court's fax filing process. As such, that Court ordered
that Mr. Coughlin be prohibited from faxing any documents to that Court. A copy of this Order
is attached as Exhibit "7".
Based on the above, pursuant to JCRCP 26(c)(2) and JCRCP 26(c)(3), City respectfully
seeks an Order from this Court requiring Mr. Coughlin to submit any subpoena he intends to
serve in this-matter to this Court for review prior to issuance and service to ensure Mr. Coughlin
is seeking relevant information regarding a specific case and is following the appropriate legal
process.
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III. CONCLUSION
2 Based on the above, it is respectfully requested that this Court issue an order:
3 1.
To quash the subpoenas for Ron Rosa, Thomas Alaksa, Savannah Montgomery,
4 Scott Weese, Joel Harley or any other City employee whose names were unreadable in the
5 subpoenas for failure to comply with JCRCP Rule 45;
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2.
To quash any other subpoenas Mr. Coughlin e-mailed to City employees Kelley
Odom, Kariann Beechler and Suzy Rogers and/or submitted to the Reno Police Depatiment
which do not relate to the City or to this matter because they failed to comply with JCRCP Rule
45.
"
J.
Grant a protective order to the City pursuant to JCRCP 26 requiring Mr.
12 Coughlin to submit any subpoena he intends to serve in this matter to this Court for review prior
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to issuance and service to ensure Mr. Coughlin's subpoenas are relevant and follow the
appropriate legal process.
AFFIRMA nON
The undersigned does hereby affirm that the preceding document filed in this court does
not contain the social security number of any person.
RESPECTFULL Y SUBMITTED this ?ttt
day of November, 2012.
JOHN 1. KADLIC
7
SKAU
Depu y City Attomey
P.O. Box 1900
Reno, NY 89505
Attorneys for City of Reno
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CERTIFICATE OF SERVICE
Pursuant to JCRCP 5 (B)(4), I certify that I am an employee of the RENO CITY
ATTORNEY'S OFFICE, and that on this date, I am serving. the foregoing document(s) on the
party(s) set forth below by:
x
Placing an original or true copy thereof in a sealed envelope placed for collection
and mailing in the United States Mail, at Reno, Nevada, postage prepaid,
following ordinary business practices.
Personal delivery.
EFlex electronic service
Facsimile (FAX).
Federal Express or other overnight delivery.
Reno/Carson Messenger Service.
addressed as follows:
Biray Dogan
Washoe County Public Defender
350 S. Center Street, 5'h Floor
Reno, NV 89520
Zach Young, Deputy DA
Washoe County DA's Office, Criminal Division
P.O. Box 30083
Reno, NY 89520
DATED this of November, 2012.

B)\ .
lEA IEHOMER
Legal Assistant
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Exhibit List
Number: Name of Document: Number of Pages:
I Subpoenas 18
2 Letter dated November 2,2011 2
3 Subpoenas 23
4 E-Mail of Subpoenas to K. Odom & K. Beechler 9
5 Subpoenas 17
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EXHIBIT "1"
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STATE OF NEVADA,
Plaintiff,
Dept. No. ___ -_--
vs.
fcvG-Wkf A ( SUBPOENA
(' Defendant. (
TO: a V\ C( h q
You are. c?DJmanded to appear Justice Court 'JI \lne South Sierra Street, Reno, Nevada
on the ---t. OJ Cl/,dayof Y\)f)VJl \lYlJ05-Y __ , S\:;.2)i1 o'clock CL.M.
to testify on tlie part of .
Failure to appear may be deemed a contempt of court and subject you to the penalty set forth in NRS 22.100
and/or NRS 50.195.
STEVE TUTI"LE
CLERK OF THE COURT
BYu'1\',\. \f\C._:';,Cu.}
Deputy Cler
AFFlDA VIT OF SERVICE
STATEOF ___ _ )
)ss.
COUNTY OF ______ ---.J)
I, received this Subpoena on the ___ day of___ ,20 , and
personally served a copy of the same UPOll _____________ on the ____ day
of __ ----_____ > 20 .
Signature of Person Making Service
Subscribed and sworn before me this
_____ dayof _________ ,,20 __
Notary Public
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STATE OFNEV ADA, Case No. Ec.. e '20//- 06 3'
5
1)
Plaintiff,
Dept. No. 2
VS.

SUBPOENA
Defendan!.
You arelcommanded to apoear before the Reno Justice CouI\at One South Sierra Street, Reno, Nevada
outhe. I C(\j.-fn_dayof f\)OV)XV\k::::Uv ,20 l2,-at ?r-?:'() o'clock
to testify on the part of --
and/or NRS 50.195.
Dated this day of __ G=-. --=t==-. .c.\ C'c'k=R--=, =-:' O'-.V ____ ._' 20_\ Y_.
STEVE TUTTLE
CLERK OF THE COURT
By lAa\..--c y\
Deputy Cler
AFFIDAVIT OF SERVICE
STATE OF _______ -')
)ss.
COuNTY OF ______
I, received this Subpoena on the ___ day of ____________ _
,20 __ , and
personally served a copy afthe same UpOI1 _______________ on the day
of ____________ ., 20 __
Signature of Per SOil Making Service
____ dayof _________ ,20 __
Notary Public
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STATE OF NEVADA,
Cal>eNo. I
Plaintiff,
Dept. No. cd-
VS.
SUBPOENA
You a; to appear befory thr. Justice Court at O. ne Sou)l; Sierra Street, Reno, Nevada
on the 01_}_ y\! ayof J 2,at(3U o'clock
to testify on the part of
and/or NRS 50.195.
20 \ J
,
STEVE TUTTLE
CLERK OF THE COURT
l uC'\. '(V-OJ'v,,"
Deputy Cle
AFFIPA VIT OF SERVICE
STATE OF _______
)ss.
COUNTY OF ___ .------J
I, received this Subpoena on the ___ day of
,20 ___ , and
personally served a copy of the same upon __________ _ on the ____ day
,20 .
____ day of ,20 __
Notary Public
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COUNTY OF WASHOE, STATE OF NEV ADA
STATE OF NEVADA,
Plaintiff,
vs.
24 L- f) vGJ-krX\\
Defendant.
5'ot1=
Case No. c Q, L 6ft-Oc;'? ..32)(
'2-
Dept. No. ______ _
SUBPOENA
We 'f5 (?
You are c.9,mmanded to appe.ar before thp.Reno Street, Reno, Nevada
on the .. LVv\}::::Jev ji . o'clockcz' .M.
to testify on the part of--, _________ c--______________ _
Failure to appear may be deemed a contempt of COUlt and subject you to the penalty set forth in NRS 22.100
andlor NRS 50.195.
Dated this
STEVE TUTTLE
CLERK OF THE COURT

Deputy Cler
STATEOF _______
)ss.
COUNTY OF ___ ... __
I, received this Subpoena on the clay of _.
__________ , and
personally served a copy of the same upon ______________ on the ____ day
of ___________ ,
____ day of _________ " 20 __ .
Notary Public
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Plaintiff,
V7 /Jl

STATE OF NEVADA, Case No.
Dept. No,_---'Z=."' .=--__ _
VS.
TO:
you co . aIlded to appear befpre,the .!Zeno Justice Court at One Sierra Street, Reno, Nevada
on thet I Y 4-1/\ day of I\J OVp VV\t::ll V at . (,:.?,::! Q o'clock C.' .. ,M.
to testify onifle part of .
and/or NRS 50.195.
1 j"V\ (\ \ I d
Dated this C>C..j day of __ "': .. "")''''Q..,y'--_____ , 20_' _
STEVE TUTTLE
CLERK OF THE COURT
By ChlJllrU .. O.U. (s.to L/1 \Y\l/L'I.."-../
Depu,y alerk
AFFIDA VIT OF SERVICE
STATE OF _______
)5S.
COUNTY OF ______ .J)
J, received this Subpoena on the ___ day of
________ , 20 , and
personally served a copy of the same upon
____ . ________ on the ____ day
of ___________ ,,20 __
____ dayof _________ ,,20 __
Notary Public
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STATE OF NEVADA, Case No, R ,C tZ. 2:A '2 .--tJC S-C;}()
Dept No, ids '
Plaintiff,
Vs, SUBPOENA
DUCES TECUM
You are commanded to deliver the above mentIOned docpments before e Reno Justig'e Court at One
South Sierra Street, on before the / iday of , & v-t:'----0 /i\_J.'' __ r
___ ----:--:-:-_at i ') G a M OIl the part of __ 7 ,', c \. C c' '- ."/( " \
Failure to deliver may be deemed a contempt of cOUl1 and subject you to the penalty set forth in NRiY22. I 00
andlor NRS 50.195.
,
'. 7 \\1 \,A.. (\.J "\
DATED this __ day oJ: V
STEVE TUTTLE
Clerk of the Court
STATE OF NEVADA, )
) SS,
County of Washoe )
I received this Subpoena on the ______ . day of
____ and personally served a copy of the same upon ____________________ _
oh this ______ day of ______________ _
Subscribed and Sworn to before me
this day of
NOTARYPUBLlC
Signature of PerSOn Making Service
reY 0412009
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IN THE mSTICE COURT OF RENO TOWNSHIP
STATE OF NEVADA,
Plaintiff,
Case No_ (2 L'V(
Dept No_--.2
?c-'-( ()3J f
Vs_ SUBPOENA
DUCES TECUM
/' I
(",--,/ C",----' ,,,--,,\---,--,l"'i---' _____ SLl-\-----'""2,"--,\C=.cL-----'-1_
Le>: -zlvPc;- DeC.', ,:' J
J - c\c
You are commanded to dehver the above mentIOned d uments beforqte Reno Juttlce:C::"rt at One
South Sierra Street, on or before the I'i 'i day of J C-' (
____ 20 on the part of 7/"---- _Le" l-l \
Failure to dehver may be deemed a contempt of court and subject you to the penalty set forlh 10 N.ds 22 100
and/or NRS 50_195_
DATED L' of
STEVE TUn-LE
Clerk of the Court
,
&JO}.../\
. Deputy Clerk 6
STATE OF NEVADA, )
) SS_
County of Washoe )
I received this Subpoena on the _______ day of __________ _
------,
____ and personally served a copy of the same upon ____________________ ,
on thIs ______ dayof ________________ -
this day of
NOT MY PUBLIC
rev 04/2009
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STATE OF NEVADA,
Case No. J2.. L {."f5
Plaintiff,
Dept. No. -;?
Vs.
'?/v:. h ") Vi II vi
"
SUBPOENA
DUCES TECUM
J
____ _
11 r-BcO,I&'j
Defendant
DATED this _._,<...._J of _. _""C)"-.-.;.M1..c'-'--'.\JL.L'-LY_ __
STEVE TUTTLE
Clerk of the Court
STATE OF NEVADA, )
) SS.
County of Washoe )
I received this Subpoena on the ____ . ___ day of
____ and personally served a copy of the same upon __________________ _
on this ______ day of _______________ _
this day of
NOTARY PUBLIC rev.o4/2009
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COUNTY OF W ASHOE, STATE OF NEVADA
STATE OF NEVADA,
Plaintiff,
Vs. SUBPOENA
DUCES TECUM
. You are commanded to deliver the above mentioned dO;:l\<nents befl1fe theRen<f Justice Court at 9ne
ITa Street, Reno, Nevada on or hefore the ! I., J'1ray of Ii I I, F.,Y-. .
'2.-<''' '. ; o'clock L"--M. on part of La.., r::; C" L'
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth in l'fRs 22.100
andlor NRS 50. I 95.
DATED this day of \ J--.
STEVE TUTTLE
Clerk of the Court
STATE OF NEVADA, )
) SS.
County of Washoe )
I received this Subpoena on the ____ _
dayof _______________ ___
____ and personally served a copy of the same upon __________________ _
on this ______ day of ______________ _
this day of
NOTARYPUBUC rev 04/2009-
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IN THE ruSTIeE COURT OF RENO TOWNSHIP
COUN1Y OF WASHOE, STATE OF NEVADA
STATE OF NEVADA,
Case No. -Ot
Plaintiff,
Dept. No. L
Vs. SUBPOENA
l'\ /' "j ;\
c. .. '. . \ L- i JiAr-\-Jc I r\
DUCES TECUM
Defendant
(",,' _____
eli",--,=? \/C n l/\CVi b i 'Y ..D'. \'\ 5.0 V c , cit) IG",,-.. lL. ,,15
4
e
J "" J V ' I 17 f
. You are commanded to deliver the above before )he e ourt at,<";ln;, J
South SIerra Street, Reno" or before the of__ '" uve {;j.// ,
'7oi'L at __ 5 () o'clock on the part of 2-",< ( \ , ' i., i
Failure to may be deemed a contempt of court and subject you to the penalty set forth in NR's 22.106
and/or NRS 50.195.
DATED this
STATE OF NEVADA, )
) SSe
County of Washoe )
, d.C) \ 'd-
STEVE-TuTfLE
Clfrk of the Court
\ n
By]::i ... .v\c\Do.....'-.\.
Deputy Clerk "
I received this Subpoena on the ______ day of _______________ ,
___ and personal1y served a copy of the same upon ___________
on this _____ day of ______________ _
this day of
NOTARY PUBLIC
rev 0412009
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EXHIBIT "2"
TRACY L. CHASE
Chief Civil Depu!y
Civil Division Deputies
ROBERT F. BONY
JACK D. CAMPBELL
GABRIELLE J. CARR
DONALD L. CHRISTENSEN
MARILYN CRAIG
SUSAN BALL ROTHE
JONATHAN SHIPMAN
CREIG SKAU
Zach Coughlin
1471 E. 9'h Street
Reno, Nevada 89512
Judge Peter Sferrazza
Reno Justice Court
PO Box 30083
RENO CITY ATTORNEY'S OFFICE
JOHN J. KADLIC
City Attorney
November 2,2012
Sent Via Certified Mail and Regular US Mail to:
AND
Zach
1422 E. 9' Street, Apt. 2
Reno, Nevada 89512
Sent Via Regular US Mail to:
DANIEL WONG
Chief Criminal Deputy
Criminal Division Depulies
JILL E. DRAKE
C. HAZLETTSTEVENS
ALISON M. ORMAAS
PAMELA G. ROBERTS
BRIAN M. SOOUOI
DUI Administrative Specialist
CORINNE O. FRIEDMAN
Victim Advocate
SUZANNE RAMOS
Mr. Zach Young, Deputy District Attorney
Washoe County District Attorney's Office
One South Sierra Street
Reno, Nevada 895203083 POBox 11130
Reno, Nevada 89520
Re: Written Objection pursuant to Reno Justice Court Rule 45 (RJCR 45) regarding E-
mailed Subpoenas to City of Reno Emergency Communications Center From Zach
Coughlin Concerning RCR2011-063341.
Dear Mr. Coughlin, Honorable Judge Sfen'azza and Mr. Young:
" .- -.- . ----. -- -- - - - -
This office represents the City of Reno (City), including .its Police Department and its
Emergency Communications Center (ECOMM) and is in receipt of copies of nine (9) subpoenas
Mr. Coughlin e-mailed to City ECOMM employees Suzy Rogers and Kelley Odom on October
26, 2012 (Copies of letter and subpoenas enclosed for your ease of reference). While the
subpoenas duces tecum are vague and overbroad, the City has tried to comply with the requests
which pertain to City departments. As such, pursuant to the subpoenas duces tecum e-mailed to
the City ECOMM addressed to the Reno Police Department Custodian of Records, Emergency
Dispatch Services (City of Reno Emergency Communications Center) and the Custodian of
Records Emergency Dispatch Services of Reno Washoe County, the City has prepared copies of
the call for service records, a CD containing an audio copy of the dispatch radio traffic and a
police report responsive to the "larceny of a cell phone at the skate plaza in fi'ont of City Hall in
Mailing: P.O. Box 1900, Reno, NV 89505-1900 Physical: I East First Street, 3'd Floor, Reno, NV 89501
Telephone: 7753342050. Facsimile: 775-334-2420
www.cityofreno.com
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2ach Coughlin
November 2, 2012
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downtown Reno" on August 20, 2011 at or about lLI8 pm to 12:00 am. August 21, 2011 (Case
No. RCR1011-063341). These materials are available for pickup by Mr. Coughlin at this office
and will be released to him upon payment to the City of $108.00 (Please see attached invoice).
Be advised that the person retrieving these materials will need to sign a receipt.
Please be advised that the City lodges objections to Mr. Coughlin's e-mailed subpoenas
commanding City employees Ron Rosa, Thomas Alaksa, Savannah Montgomery and Scott
Weese to appear on November 19, 2012 These subpoenas are deficient and ineffective as they
fail to comply with RJCR 45, including but not limited to RJCR 45(a) andlor RJCR 4S(b).
Among other things, these subpoenas:
I. Violate RJCR 45(a)(1)(D) in that they do not set forth the text of subdivisions (c) and (d)
ofRJCR 45.
2. Violate RJCR 45(b)( I) which states that a "subpoena may be served by any person who
is not a party" to the proceeding These 4 subpoenas were e-mailed to City ECOMM
employees Kelley Odom and Suzy Rogers by Mr Coughlin, a party in this matter.
3. Violate RJCR 45(b)(I) whlch states tilat "service ofa SUbpoena upon a person named
therein shall be made by delivering a copy thereof to such person". E-mailing the
subpoenas to City ECOMM employees Kelley Odom and Suzy Rogers in the hopes they
will give the subpoenas to the nallled witnesses does not comply with RJCR 45(b)(I).
4. Violate RJCR 45(b)(I) which states that service of a subpoena commanding attendance
requires that payment for one day's attendance and the mileage allowed by law. No
witness fee or mileage fee has been submitted by Mr. Coughlin for the appearance of the
4 City employees.
Based on the deficient and ineffective service of the subpoenas, City employees Ron Rosa,
Thomas Alaksa, Savannah Montgomery and Scott Weese will not be appearing on November 19,
2012 at 8:30 a.m.
The City also lodges its objections to the other materials Mr. Coughlin requested in his e-
mail dated October 26, 2012 to City ECOMM employees Kelley Odom and Suzy Rogers as
those materials do not relate to the Case No. RCR2011-063341. These written objections only
relate to e-rnailed subpoenas relating to the City. The City cannot comply with the e-mailed
subpoenas Mr. Coughlin sent to the City of Reno ECOMM concerning AT&T and the Washoe
County District Attorney's Office.
Mailing: P.O. Box J900, Reno, NY 89505-1900. Physical: J Easl First Street, 3'" Floor, Reno, NY 8950J
Telephone: 775-334-2050. Facsimile: 775-334-2420
www.cityofreno.com
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Zach Coughlin
November 2,2012
Page 3
The City is happy to participate in any hearing the Court may schedule on this matter.
Should anyone wish to discuss this matter, I may be reached at 775-334-2050.
RFB/jmh
Enclosures
Sincerely,

Robert F. Bony
Deputy City Attorney
cc: Kelly Odom - Reno Emergency Communications Center
Lynne Austin - Reno Police Department, Records Division
Mailing: P.O. Box 1900, Reno, NY 89505-1900. Physical: 1 East First Street, 3" Floor, Reno, NY 89501
Telephone: 775-334-2050. Facsimile: 775-334-2420
www.citYofreno.com
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Document Code:
Zach Coughlin
Nevada Bar No: 9473 (temporarily suspended)
1471 E. 9th St.
Reno, NV 89512
tel: and Iax: 949 667 7402
Pro Se DeIendant Denied Sixth Amendment Right to Counsel
IN THE RENO MUNICIPAL COURT
IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA
STATE OF NEVADA;
PlaintiII,
vs.
ZACHARY COUGHLIN;
DeIendant.
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Case No:11 CR 26405
Dept No: 2 Hon. Judge William Gardner
NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR,
ALTERNATIVELY, SUPPLEMENTAL MOTION TO VACATE 1UDGMENT OR CONVICTION,
OR IN THE ALTERNATIVE, MOTION FOR ARREST OF 1UDGMENT
Zach Coughlin, Iiles this on his own behalI, the above title document.
Columbus Prop. Inc. v. I S K S Realty Corp., 621 N.Y.S.2d 277 N.Y.City.Civ.,1994 Because petitioner in
summary proceeding under Real Property Actions and Proceedings Law obtains beneIit oI expedited and
simpliIied procedure which bypasses many oI usual procedural steps oI plenary action, petitioner must
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NOTICE OF ERRATA AND REVISED SUPPLEMENTAL MOTION FOR NEW TRIAL, OR, ALTERNATIVELY, SUPPLEMENTAL
MOTION TO VACATE JUDGMENT OR CONVICTION, OR IN THE ALTERNATIVE, MOTION FOR ARREST OF JUDGMENT
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prove strict compliance with all requirements Ior summary proceeding; as omission oI required act oI
service is Iatal to plenary.
FACTS
1. Earlier today, on October 28th, 2012 Coughlin submitted Ior Iiling, essentially, a duplicate oI this
Iiling which, unIortunately, upon Iurther review, contained a signature that was not close enough to the
signature line, arguably, to be eIIective. ThereIore, a correction has been made in that regard, placing the
signatures in a more appropriate setting in relation to the signature line. The only other change involves the
Iollowing paragraph, with the additional materila in bold:
On February 27th, 2012, while awaiting trial before 1udge Nash Holmes in 11 TR
26800, and in a private meeting with Reno City Attorney Allison Ormaas in one of the private
conference/meeting rooms outside the interior doors to the court room, RMC Marshal Harley
entered the room and purported to personally serve Coughlin a document in the appeal of the
eviction from Coughlin's former home law office, in CV11-03628, apparently at the direction of
Richard G. Hill, Esq., on behalf of his client Merliss (the landlord, whom all three of the appointed
defenders provided by the RMC to Coughlin refused to subpoena, apparently because it would cut
into their $7K fee from the RMC and because of an apparent desire to torpedo Coughlin's defense,
despite Merliss being a material witness. Further, it is believed OFficer Carter and Sargent Lopez
were subpoened by the City, and perhaps by Coughlin, though a continuance was denied upon their
faling to appear). Washoe County Sheriff's Deputy 1ohn Machen filed a false Affidavit of Service on
November 7th, 2011, in R1C Rev2011-001708 alleging to have "personally served" Coughlin at the
time the WCSO's Deputy Machen effectuated the lockout on November 1st, 2011 at 4:30 pm (by
which time the ORders of October 25th and October 27th, 2011 made exhibits in this Trial by the
City had become stale, invalid, perhaps void, etc. given, as admitted to, apparently, by both the
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R1C's Chief Civil Clerk/Supervisor Karen Stancil (to be clear, I mean this only to the extent that Ms.
Stancil has represented to the undersigned the "usual custom and practice" of the R1C is to fax over
Orders such as those mentioned above to the WCSO the day they are file stamped, or at the latest by
the next day...plus Baker testified, apprently to receipt of the ORder by the WCSO on October 28th,
2011...all making the WCSO's "receipt" of the Orders outside the statutorily dictate that the lockout
occur "within 24 hours" thereof under NRS 40.253. Regardless, back to RMC Marshal Harley
(whom RMC 1udge Nash Holmes, in her March 12, 2012 rendition of some Order finding Coughlin
guilty of every RPD in the book, incident to a traffic citation matter tha 1udge Nash Holmes had
transmogrified into a hearing before the NNDB, apparently (see In Re Kunstler), 1udge Nash Holmes
alleged that Marshal Harley, apparently, followed Coughlin into the bathroom during the restroom
break just prior to 1udge Nash Holmes incarcerating Coughlin, whereup Harley apparently played
peeping tom on Coughlin the bathroom stall and averred to 1udge Nash Homes that Coughlin
"dissassembled his smart phone" (Martin Crowley is laughing somewhere)...the thing is, "summary
contempt" (even "misdemeanor summary criminal contempt", ie, some law 1udge Nash Holmes
appears to have legislated on the spot, and which does not require her to comply with the dictates of
NRS 189.010-060, as she refuses to transmit the record and order the production o the transcript
(and its illegal for the RMC to force criminal indigents to pay Pam Longoni, and only Pam Longoni,
ANYTHING, up front, in some application of a civil statute related thereto. Regardless, 1udge Nash
Holmes "summary criminal contempt" Orders relies upon allegations of conduct allegedly
committed OUTSIDE the presence of the Court, so whichever Marshal went playing peepin' Tom on
Coughlin in a restroom stall needs to sign their name on an Affidavit and stand behind it like a
grown up rather than right some insipid letter to the State Bar of Nevada criticizing Coughlin's
fashion sense, then proceeding to lie and lie and lie about Coughlin whilst also demonstrating a
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distrubing extent to which the City of Reno Marshals behave as a coordinated crew of intimidators
and coerces towards the citizens of Reno attempting to access justice, and to which these Marshals
themselves obstruct justice on a regular basis. Right in line with that behavior was that
demonstrated by RMC Marshal Harley in barging into a plea bargaining session between City
Attorney Ormaas and Coughlin and undertaking the legally questionable task (but certainly an
intimidating, coercive, and inappropriate action by Harley) of "personally serving" Coughlin and
ORder to Show Cause in CV11-03628 (despite Coughlin already having been served it via his
electronic filer status, something Richard HIll and Casey Baker, ESq. knew full well) . Harley
personally served Coughlin some document, then WCSO Machen filed an Affidavit of Service on 3 8
12 saying he himself personally served Coughlin. The RMC puts peopel in jail for less than that
every single day. Then Harley got real uncomfortable with Coughlin asking him questions related to
the propriety of what Harley just did. Then Harley starts whispering in City Attorne Ormaas's ear
during the trial in 11 TR 26800, held after that on the same day, despite the RMC, apparently, in
light of 1udge Nash Holmes March 14, 2012 letter/grievance against Coughlin to the SBN indications
therein, being aware that an Order For Competency Evaluation of Coughlin was entered at 1:31pm
on 2/27/12 in RCR2012-065630, as 1udge Nash Holmes admits to communications with the WCPD
regarding Coughlin. The RMC Marshals, especially Marshal Menzel like to bark menacingly at
defendnats that they have to sign some acceptance of service or waiver of service of various
documents in some apparent effort to cost cut postage expenses of the RMC in affording others due
process. But worse than that is Marshal Harley taking it upon himself to personally serve Coughlin
documents on behalf of Richard G. HIll, Esq. especially where RPD Sargent Tarter came to testify
that day about the 3 traffic citations he issued for Hill against Coughlin, and Tarter put his feet up on
1udge Aash Holmes bench (ie, where the 1udge might set her gavel) while the RMC staff served
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Sargent Tarter bottled water. Avoding an appearance of impartiality or impropriety is a cannon or
something, some might say. This is true especially incident to a trial appearance related to 3
retaliatory traffic citations issued by the RPD after they told Coughlin to leave the sidewalk near
Hill's law Office, and where 1udge Nash Holmes told Coughlin she would "put you in jail if you say
Richard HIll's name one more time"... See some of the materials in Exhibit 1 that show Also,
there may be some clerk failure or misconduct where Michelle Purdy and or Lori Matheus appear to
have refused a filign by Coughlin on October 19th, 2011 which arguably could have functioned as a
Motion for STay in CV11-03051 - ZACH COUGHLIN VS. MATT MERLISS ET AL (D1) Filing
Date: Wednesday, October 19th, 2011 . And City Attorney allison Ormaas and Dan Wong both
told Coughlin the were not going to investigate, follow up on, notate, or in any way document the fact
that Coughlin repeated to them the exact words that RPD Officer Chris Carter said to Coughlin on
November 13th, 2011 when the following exchange occurred between Coughlin and RPD Officer
Carter after Carter subjected Coughlin to a custodial criminal trespass arrest where Hill and
Sargent Lopez both admit that nobody issued Coughlin a warning to leave the premises that day and
that the RPD did not identifiy themselves as law enforcement or issue a lawful order to leave to
Coughlin prior to landlord Merliss kicking in a "basement" door:
Coughlin: (speaking to RPD Officer Carter) Are you on Richard G. Hill's
payroll, too?
RPD Officer Chris Carter, 1r: "Yes, I am. Richard Hill pays me a lot of
money so I arrest who he says to arrest and I do what he says to do".
Officer Carter said it. I reported it. Period. Now the SBN's Patrick King has failed to subpoena
Marshal Harley or City Attorney Ormaas (maybe he is afraid they will start whispering in each
other's ears again during some hearing the SBN wants to violate Coughlin's due process rights in
holding on November 14th, 2012), and instead Pat King has listed his old friend and coworker from
the Attorney Generals Office to come testify at the hearing and also listed Marshal Coppa (instead of
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Harley?) to testify as the hearing? Hhmmmmmn......Its just wrong for a smirking and chortling
RMC Marshal Harley to be perpetuating the fraud of WCSO Machen and the Rambo charlatan
litigation tactics, attempts at intimidation, and creation of the appearance of impropriety that
Richard HIll and Casey Baker cultivate so well in everything they do. Besides, why does Hill need
to have the wCSO and RMC serving Coughlin notices of Orders to Show cause when the following is
documented: 02-08-2012 Court Proof of Electronic Service Filed by or in behalf of: Court Proof
of Electronic Service 02-08-2012 Court Ord to Show Cause Filed by or in behalf of: Court Ord to
Show Cause...02-10-2012 Court Proof of Electronic Service Filed by or in behalf of: Court Proof
of Electronic Service 02-10-2012 Defendant Notice of Entry of Ord Filed by or in behalf of:
RICHARD HILL, ESQ. Notice of Entry of Ord - Continuation (if not for some impermissible
purpose?).
All oI the allegations herein also relate to "irregularities" in the proceedings and prosecutorial
misconduct" justIying the relieI requested herein. Coughlin's ability to get this exculpatory video wherein
Sargent Lopez admits RPD OIIicer Carter and Richard Hill, Esq. and Casey Baker, Esq. lied, under oath (in
Hill's case) at the June 18th, 2012 Trial and in violation oI NRCP Rule 11 (in Baker's case in his November
21st, 2011 Opposition to Coughlin's Motion to Contest Personal Property Lien) was severaly comprimised,
to an excusable neglect extent, and to a good cause standard, by the various Iraudulent, retaliatory arrests
and incarcerations (which have seen attendant deprivations oI Coughlin's medication or medications, some
oI which are considered "pyschotropic" by the WCDC), and the Iraudulent attempts by RPD OIIicer
Warren and others to alienate Coughlin Irom his Iamily and any other type oI a support system, all in the
name oI covering up wrongIul arrests by the WCPD, and or WCSO and or wrongIul "summary contempt"
Iindings, including those in 11 TR 26800, RCR 2012-065630 ( ARgent SiIre's order to arrest Couglin on
January 14th, 2012 Ior "misue oI emergency communciations", in addition to WCSO Deputy Machen's
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Iraudulent arrest oI Coughlin on June 28th, 2012, including the Iraudulent "Sixth Amendment
representation by WCPD Jim Leslie and Biray Dogan (in RCR 2012-065630 and RCR2012-067980) in
those matters)) (iI Marshal Harley is going to Iollow Coughlin into the restroom, then peer through a
restroom stall and, as alleged by Judge Nash Holmes in her 3/12/12 Order Iollowing a hearing that
Coughlin was not appropriately noticed on by the RMC, despite it being aware oI Coughlin's then current
address at the time it mailed a 2/28/12 Order in 11 TR 26800 to Coughlin...and Judge Nash Holmes is
going to enter and Order Iinding Coughlin to be guilty oI "summary criminal contempt" (which isn't even
an actual charge under NRS), then Marshal Harley and or Judge Nash Holmes need to sign aIIidavits to the
extent those Ordes explicitly reIerence alleged conduct in a bathroom stall, ie, not, allegedly "committed in
the court's presence" under any section oI NRS 22)), then Marshal Harley needs to sign an aIIidavit, which
he has not done. And RMC Marshal Coppa should perhaps Iocus less on critiquing Coughlin's alleged
wearing oI "pajama bottoms" to the RMC Iiling oIIice coutner while checking a traIIic citation, and more
on whether he violated the Fourth Amendment and other laws incident to his conduct on February 27th,
2012 in pulling into a back room in the sally bay at the WCDC WCSP Deputy Cheung and seeking to, upon
inIormation and belieI, commit some misconduct (and the RMC Marshals coming back to the WCDC on
June 28th, 2012 and retrieving Coughlin's smart phone, phone, and micro sd card is not a "search incident
to arrest", and a warrant needs to be produced to show how the RMC and or the Marshal did not violate the
Fourth Amendment. Further, the RMC needs to answer Ior why it has Ilouted Nevada law in Iailing to
transmit the appropriate materials in response to Coughlin's Iiling, on March 7th, 2012, oI a NOtice oI
Appeal (see NRS 189.010-.050) in 11 TR 26800). Further, iI any "recording device" was "dissassembled"
during a bathroom break, then how could Coughlin's answers to Judge Nash Holmes sua sponte
interrogation, incident to improper suggestions made to her by the Reno Marshals and or City Attorney
Allison Ormass, possibly be appropriate? Further, in CR12-0376 Coughlin's rights were raped by the court
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system, and WCPD Biray Dogan and Jeremy Bosler, and Judge Elliot's incarcerating Coughlin on April
19th, 2012 until April 26th, 2012 (incident to a Iraudulent Iiled letter by Lake's Crossing oI April 18t, 2012,
signed by Dr. Bill Davis, and Dr.Farmer, though Davis disclaims and connection to that letter, amazingly)
provides a Iurther excusable neglect basis, as does the Iraudulent conduct oI the RJC and or the WCSO
(including Deputy Machen) oI June 28th, 2012 in the custodial arrest (with impermissible denial oI a phone
call, Ior now reason at all, thanks to the misconduct oI Deputy Van der Wall and "Nurse Katherine", and
Deputy Beatson, in denying Coughlin a phoen call Ior 20 hours, Ior no reason whatsoever (despite WCDC
policy and or the law requiring one within 3 hours), in addition to the Iraud oI Nevada Court Services
(partners with RMC court appointed deIender Lew Taitel, whom represented Couglin in this very matter,
11 CR 26405, despite an obvious conIlict). Also, the Iraud by Ltn. Kevin Brown, Sargent Oliver Miller,
OIIicer Alan Weaver, and Sargent Dye oI the RPD in connection with the incarceration oI Coughlin Irom
July 3rd, 2012 to July 21st, 2012 contributed to preventing Coughlin Irom (as did the Iraud by the WCDC
in reIusing to timely Iile Coughlin's court Iilings so submitted, including one's in this case and in the sister
case appeal in cv11-03628 wherein during his incarceration Coughlin was prevented Irom opposing or
otherwise addressing an outrageous $40,050 attorney's Iees award to Richard G. Hill, Esq. incident to the
appeal oI the wrongIul summary eviction in RJC Rev2011-001708 by Richard. G. HIll, ESq., and Iurther
curious is RMC Judge Gardner's 11/30/11 transIerring oI the ridiculous wrongIul arrest Ior "jaywalking" oI
Coughlin on January 12th, 2012 incident to Coguhlin's peaceIully Iilming Hill's crew loading up personalty
Irom Coughlin's Iormer home law oIIice to take to the town dump, wherein HIll lied to RPD OIIicer Alan
Hollingsworth, i na criminal violation by Hill, eventually leading to a wrongIul custodial arrest oI Coughlin
Ior jaywalking in RMC 12 CR 00696 (the case "Administrative Judge" William Gardner oI the RMC just
so happened to transIer to Judge Nash Holmes (to go along with all the work she was puttin' in Ior thr RMC
on 11 TR 26800, the triple traIIic citation incdient to Coughlin seeking the return oI his client's Iiles and
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state issued indentiIication Irom Richard G. Hill, ESq. on NOvember 125th, 2011, Iollowing Coughlin's
relesae Irom 3 days incarceration incident to the Iraudulent and wrongIul custodial arrest oI Coughlin on
NOvember 13th, 2011 in 11 CR 26405 by RPD OIIicer Carter and Sargent Lopez.. Everytime, Coughlin
has been wrongIully arrested (which is everytime Coughlin has been arrested) the WCDC has
impermissibly withheld Coughlin's medications Irom him while the WCDA's OIIice and REno City
attorney and or the RMC and RJC have sought to violate NRS 178.405 and NRS 5.010 in plowing ahead
with Trials and settings during the pendency oI an Order Ior Competency Evaluation (including the one's
detailed in Coughlin's previous Iiling in this regard). Add to that the Iraud oI Northwinds in RJC reve2012-
001048, the Iraud oI GAyle Kern and WNM's Sue King in the Coughlin v. Park Terrace Town Homes
HOA in the RJC and that oI JeII Nichols in Couglhin v NIchols (another landlrod tenant matter in the RJC)
and its excusable neglect any extent to which Coughlin did not previously produce this excuplatory video,
particularly where it was wrongIully withheld Irom his under an unlawIul rent distraint or other
impermissilbe action by a landlord, and how that is excusable neglect is obvious, no matter what RMC
Judge Howard's lack oI appreciation oI what being a tenant subjected to Iraud by a landlord may have
revealed in 11 CR 22176 or the misconduct oI Pam Roberts, Esq., City attorney in that matter (and all the
Iallout oI the decisions and action by those two therein).
1.1 January 13th, 2012 RPD Sargent Marcia Lopez and OIIicer Travis Warren and OIIicer Avila
respond to a call Ior help regarding a domestic disturbance Irom Zach Coughlin relating to the attacks by
his housemates, Christopher "Erin" Allaback and Laura Foreshee Ior which Coughlin ultimately received
two Orders oI Protection in FV12-00187 and FV12-00188. Sargent Lopez subjected Coughlin to a
custodial arrest Ior criminal trespass in Reno Municipal Court case 11 CR 26405, on November 13th, 2011
(which resulted in Coughlin being convicted Ior criminal trespass Iollowing the June 18th, 2012 Trial
wherein Richard Hill testiIied as Iollows:
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The admission by Sargent Lopez was captured on a high 8mm video camera that Coughlin bought
Irom a thriIt store Ior Iive dollars aIter his then housemate ruined his digital smart phone video recorder by
throwing hot coIIee on it an Coughlin. Coughlin then transIerred the tape Irom that high 8mm to a digital
version by Iilming a television with a digital video camera later obtained, while it was playing that high
8mm tape. The Iile was name "0201 cropped Carter Lopez 26405.wmv, and the Iollowing represents and
accurate transcription thereoI, in relevant part:
Coughlin: Sargent Lopez are you going to arrest Nevada court services
Ior trespass?
Lopez: I'm not going to arrest them Ior trespass.
Coughlin: but you arrested me Ior trespass.
Lopez: because you were squatting in the property.
Coughlin: why do you say that you have any evidence oI that? (5
seconds oI silence is Sargent Lopez's response) did you announce that
you were Reno PD prior to kicking the door in?
Lopez: I didn't kick the door in.
Coughlin: did you announce that you are Reno PD prior to anybody
kicking the door in?
Lopez: I didn't have to,
Coughlin: so nobody announced that they were Reno PD?
Lopez: because the guy who kicked it in had to kick in his own door
because you were squatting in his place.
Coughlin: so you are admitting that you guys didn't announce that you
were Reno PD.
Lopez: you are wearing my patience thin, Sir, okay. I am trying to
come here to help you, and I bring a specialized oIIicer (motioning to
RPD OIIicer Travis Warren, whom has been described as some sort oI
RPD OIIicer with some specialty in "mental health" related areas).
Coughlin: that's interesting, you admit that you and OIIicer Carter
never announced that you are Reno PD, and that you never asked me to
leave, did you, prior to the door being kicked in?
OIIicer Travis Warren: She didn't have to do anything like that.
Coughlin: you didn't have to! That's great, but that means you didn't
either.
Warren: hold on Zach. You asked us to come here because you needed
help now you are being conIrontational.
Coughlin: no I'm not, no not. Anybody who asked you a question is
conIrontational, I guess, huh?
Warren: Zach, let's try to stay on topic.
Coughlin: On topic? I'm not on the topic you want me to be on.
Warren: Zach the topic that I'm interested in...
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Coughlin: Is the one that covers your ass!
Warren: No, it's not.
Coughlin: Yes, it is."
...
Coughlin: So, Sargent Lopez you have admitted that you did not ask
me to leave and you did not announce that you are Reno PD either you
or your partner either oI those things when you arrested me Ior
trespass. Are you been arrest Nevada Court Services Ior the trespass
that there is video evidence oI on YouTube right now? Are you can a
do that, Sargent? Sargent, are you?
Warren: Zach, that's not the topic were on.
Coughlin: Are you going to do that, Sargent? Sargent, are you?
Lopez: are you going to Iill out your statement?
Coughlin: sure. Are you going to do that?
Lopez: I am not going to arrest Nevada Court Services.
Coughlin: Why, are they your buddies?
Lopez: because they did their job.
Coughlin: wait a did their job by going behind my back Ience and
banging on my windows Ior 45 minutes three times a time a day?
Interesting...
Lopez: Zach, we need you to Iill out the paper.
Coughlin: Interesting how it works down there at the Reno PD. You
know, there is a lots oI documentary Iilmmakers out there these days,
Sargent Lopez? Do you have anything you would like to say?
Lopez: Zach, you need to Iinish your statement.
Warren: Zach, you call us here to help you, and now your are...
Coughlin: well apparently not because you arrest me Ior trespass when
you either didn't tell me to leave Ior announced that you were the PD
(police Department) and then you have video evidence oI Nevada
Court Services doing trespassing harassing banging on windows Ior 40
min. at a clip three times a day, behind a back gate is obviously
trespassing, and you are seeing you are not going to do anything...
Lopez: have you had your day in court on that yet?
Coughlin:That is coming up.
...
Warren: Zach, we really need to stay on topic, okay?
Coughlin: What is the topic? Nevada Court Services? The buddies oI
Sargent Lopez?
Warren: No...
...
Coughlin: are you guys going to do anything on this call because the
last time you didn't run anybody's priors and iI you had it would have
been interesting what you would have Iound, what did you say? Is that
proper procedure children somebody's priors?
Lopez: The priors Ior who?
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Coughlin: because you guys didn't do that... Well who would I be
talking about?
Lopez:(smirking) YourselI, maybe? The priors Ior yourselI?
Coughlin: Oh, is that a...do you think you are Iunny?
Lopez: I think it is Iunny, yeah. I think everything is Iunny, actually. I
am amused by a lot oI stuII.
Coughlin: Really? Do you think it's Iunny when your partner says that
Richard Hill pays him a lot oI money to arrest whom he says to?
Lopez: I am pretty sure he didn't...
Coughlin: and you were there? And you didn't Iollow up with the
questions oI whether Richard Hill had given me a bill Ior rent that
month and yet you still arrested me Ior trespass?
Lopez: 5 min. Zach.
Coughlin: I think that's Iunny, that you think it's Iunny.
Lopez: 4 min. Zach
...
Lopez:, did the management give you an eviction notice?
Coughlin: what are you getting involved in civil matters now? You are
going above and beyond, Sargent Lopez, getting involved in civil
matters...
Lopez: Zach did they give you an eviction notice or not?
Coughlin: wow you are working oI the storm over there aren't you
Lopez: Yes or no:
Warren: you could say no comment, Zach.
Coughlin: thank you, counselor. I appreciate your advice. Now, what
criminal matter were you investigating here?
Lopez: I am asking you a question.
Coughlin: About a what? A civil matter?
Lopez: Zach, did you get an eviction notice Irom these guys (Sargent
Lopez is reIerring to Western Nevada Management posting a John Doe
30 day eviction notice, allegedly, on the door oI the 1422 E. 9th St. #2
town home that WNM (which, like NCS, commits the unauthorized
practice oI landlord tenant law) had agreed to some deal with
Coughlin's housemates (or maybe they were his sublessors? Coughlin
rented a room Irom them oII oI Craigslist, but to some extent they were
held out to be employees or partners oI WNM, and WNM did testiIy at
a February 23rd, 2012 hearing aIter Coughlin Iiled an interruption oI
essential services complaint against WNM, Gayle Kern, Esq., LTD,
and Park Terrace Townhomes that Iormer WNM manager, Robyn
Batalado received approval Irom the Park Terrace Town Homes
Homeowners Associattion to allow Coughlin's sublessors to live their
in exchange Ior some handyman work (and perhaps in light oI the
lessened insurance costs associated with not having the unit vacant
incident to some scenario where the PTTHOA bought the unit at a
Ioreclosure sale).
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Warren: We will take that as a yes or no, or a maybe, who knows? All
right, Zach? You are not going to be able to bait us into saying things?
Coughlin: Well, I've been listening to you here whether you've been
baited or not, you have said a whole lot today.
...
Coughlin:... What iI Richard Hill sent me a Bill Ior rent Ior the month oI November, should you
Iollow phone that beIore you make it trespass arrest? And what did you say to that? You say no we
are not going to that Richard Hill pays us a lot oI money, and we are going to arrest whom he says
to arrest, did you hear that Sargent Lopez?
Warren: Zach, let's stay on topic.
Coughlin: this could be your star turn... This could be your star turn.
Lopez: you need some help, brother.
Coughlin: really?
Lopez: Yeah, you do.
...(Sargent Lopez and OIIicers Warren and Avila then leave shortly
thereaIter, and Coughlin has the Iollowing exchange with his
housemate's/abusers teenage daughter):
Coughlin: look someday, you are trying to support yourselI and
someone steals your license plate, and slashes your tires, and locks you
out aIter you have given them the last money you had...
Teenage Girl's Friend: well, someday we won't be an assh*le like you
Coughlin:What is an "assh*le" about that?
Teenage Girl: you are I*cking r*tarded, you are being r*tarded, you're
making my dad not like you, you steal his knives. His steak knives, like
seriously?
Coughlin: You mean the one oI he held while chasing me up the stairs
with saying he was gonna kill me?
Teenage Girl: He didn't I*ckin' chase you up the stairs and tell you he
was gonna kill you. Why would he say that, he's not like that. And iI
he say's it, it doesn't mean he means it. You make him say that, you
I*ckin' pr*ck."
January 12th, 2012 custodial arrest Ior "pedestrian Iailing to use sidewalk where available" (aka,
jaywalking) in Iront oI Coughlin's Iormer home law oIIice at 121 River Rock St., Reno, NV 89501.
(in the video Coughlin begins Iiliming Irom the parking lot in Iron oI
his Iormer home law oIIice and walks towards the property, where
Hill's contractor Phil Stewart is already there (Ior some reason Hill kept
making a deal about how Coughlin was "already at the property" when
Stewart returned their Irom the transIer center, but that is not true,
Coughlin actually took almost 30 minutes to get to the River Rock
Property aIter the talks at the transIer center, as Coughlin had to go
retrieve his hi 8mm video camera Irom his E. 9th St. address on that
date.
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Coughlin: What would the contractor's board say about you submitting
Iraudulent bills? (said to Hill's contractor, Phil Stewart, owner and
operator oI Nevada Building Industries (NBI), whose bill Ior $1,060
Ior "securing" the property was submitted as an attachment in Hill's
Memorandum oI Costs ana in Hill's Opposition to Coughlin's Motion
to Contest Personal Property Lien under a personalty lien theory citing
to NRS 118A.460, which allows Ior reasonable costs Ior "moving,
storage, and inventorying" a tenant's personal property). Would they
be okay with that? Neck carpet right there that's Dr. Merliss's property
iI you throw it away, you are throwing away the carpet, so you are on
notice and you should tell Richard Hill, iI he tries to sue me Ior the
carpet, and you throw it away, I will sue you Ior Iraud.
...
(Coughlin is seen in the video walking a Iew Ieet oII the sidewalk in
light oI the Iact that Hill's contractor's crew have taken up the whole oI
the sidewalk (Stewart's white dumptruck is parked so as to extend Irom
the drive way out onto the street so as to completely block the
sidewalk, and beyond that, the sidewalk is dotted with various items
Stewart's crew is in the process oI moving Irom the Iormer home law
oIIice) on the southern Iacing side oI the property in Iurtherance oI
their eIIorts to load up the rest oI Coughlin's personalty and take it to
the dump (as there was apparently an incredibly urgent need to do
something with the property, despite the Iact that, to this day, over one
year later, it still remains un-rented).
Coughlin: gentlemen, you are under notice this is my property and I
want it. I believe I might have some legal recourse against you Ior
destroying my property. I could be wrong. You are certainly welcome
to listen to your boss. You know what is interesting is that I have prooI
right here that you used my own plywood to board up the property and
then you try to charge a thousand dollars Ior it and Ior Iixing a leak
that's my plywood Phil or whatever your name is, guy with a
contractor's license. (Coughlin is saying this while in the parking lot oI
the studio apartments that abuts the backyard Ience to his Iormer home
law oIIice (ie, not on the sidewalk even. One oI Stewart's laborers
walk up to Coughlin within about 8 Ieet oI him and snaps a Ilash
photo):
John Doe: What's up?. (snaps another photo oI Coughlin in the parking
lots oI the Mill Place studio apartments)
Coughlin: Hi, how are you doing? What's your name?
John Doe: John Doe.
Coughlin: John Doe, really?
Doe: Don't get mouthy, buddy.
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Coughlin: What's that?
Doe: I said don't get crowley, buddy.
Coughlin: What's "crowley"?
Doe: "Crowley" means like "Crowley Lake".
Coughlin: I don't know what you mean. Anyways Phil what do you
have to say about the Iact that you Iraudulently submitted a Bill Ior
thousand dollars Ior boarding up the property to Iix a leak yet you used
my plywood to do it, Phil?
John Doe: Hey, can you stay away Irom him (motioning to Phil
Stewart)?
Coughlin: I am on a public spot right here (actually, Coughlin is still
standing in the Mill Place studio apartment's parking lot at this time). I
am not bothering him you guys just expect people to watch you use
their own property to board up a place?
Phil Stewart: do you have a receipt Ior that?
Coughlin: yeah I do. It was submitted into evidence guy. You guys
submitted it into evidence as a bill. (Coughlin then walks out oI the
Mill Place parking lot and around Stewart's white dump truck (which
was completely blocking the sidewalk) and out a Iew Ieet into the road
on Court St west oI River Rock, where the camera's view reveals
Stewart's crew has set a couch and some other personalty on the
sidewalk, where Stewart and John Dow walk onto towards the Iront oI
the property on River Rock St. to talk with Richard G. Hill, Esq.) are
you going to ask Richard about that? I even ask Richard about the Iact
they used my own property to board up the property and charged with
thousand dollars Ior it this gotta be an easier way to make money was
and ain't that easy to be an attorney as you can see, Phil.
Stewart: you obviously need to start taking your medication.
Coughlin:(Coughlin has retreated back to the Mill Place parking lot at
this point) what did you say? Are you making some sort oI accusation
or insult about taking medication? Is that what you are doing? You
know it is Iunny because a lot oI this property could've been used to
Ieed Iamilies in need. Phil are you going to throw away the carpet and
then try to bill beIore it is that what you are going to do some pretty
sure that that would be Iraud Phil. Sir, I am putting you on notice that
carpet belongs to Dr. Merliss (a couple members oI Stewart's crew are
now seen picking up the rolled up bundles oI carpet that Coughlin,
whom has now walked around to the Iront oI the property to River
Rock St. walking just oII the sidewalk (though a large tan/brown
Silverado style pickup truck parked on the North Side oI Court Street,
that Coughlin recalls seeing a large manilla Iolder in with the notation,
in hand writing, "Sargent Bradshaw" is an obstacle Coughlin must walk
around, especially where Stewart himselI is utilizing the sidewalk, and
given John Doe's very recent request that Coughlin "stay away" Irom
Stewart, it would seem cautious oI Coughlin not to attempt to walk on
the same small patch oI sidewalk oII Court Street as Stewart and his
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laborers.) Hey, Phil? Phil? The carpet, there was also some more oI
it right around there... HopeIully you haven't thrown it away already...
HopeIully, you do not try to bill me Ior it Phil....
(Coughlin is now standing on the sidewalk on the western side oI River
Rock, parallel with the northern boundardy line oI the property, when
John Doe appears Irom around the corner oII oI Court Street and snaps
another Ilash bulb photograph at Coughlin).
Coughlin: Sir, this is a public street. This is a public street you do not
on the sidewalks are have you ever heard oI a documentary? You
know there's a lot oI guys making documentaries these days about the
bad things people do.
(up rolls RPD OIIicer Hollingsworth on his motorcycle, and RPD
dispatch chatter can be heard describing a "suspect in a larceny".
OIIicer Hollingsworth has been called to the scene by Richard G. Hill,
Esq. and Phil Stewart. Hill shows up seconds aIter Hollingsworth.
Now, neither Hill nor Stewart were charged with "misuse oI emergency
services like Coughlin was in RCR2012-065630. So in this video
Stewart talks with oIIicer Hollingsworth Ior a Iew moments until
Richard Hill arrives...)
Coughlin: hey Rich how are you doing?
Hill: Great, Zach, thank you buddy.
Coughlin: would you preIer oI psychology Mr. Hill?
Hill: I would, Zach.
Coughlin: Mr. Hill, how are you doing? Hey that is a cool "skulls"
shirt, Mr. Hill (Hill is wearing a black Ed Hardy style bowling shirt
with Ilaming red skulls on it.. Hill begins doing his Reno PD thing
with OIIicer Hollingsworth, Coughlin stands back about 12 Ieet Irom
their communique).
Hill: (to OIIicer Hollingsworth) can we get him out oI here? (and
therein, besides calling 911/RPD dispatch in the Iirst place where no
legitimate reason existed to, Hill proceeds to leverage law enIorcement
acting with color oI law to prevent opposing counsel Irom collectin
evidence Ior a wrongIul eviction damages analysis).
Hollingsworth: Iirst oI all oI gotta Iigure out iI I have legal authority to
do so.
Hill: Re: court order evicting him Irom the property, subsequently we
had him arrested Ior trespass is lost his appeal (which was totally not
true when Hill made that Ialse statement to a police oIIicer seeking to
have Coughlin arrested, on January 12th, 2012, given that the appeal
would not be decided Ior months), he's lost.... Now we have been
talking to our workers
Hollingsworth: Have you tried to get a protection order?
Hill: no but we do have an order Irom the court disposition oI the
premises (unintelligible...)
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Coughlin: what about the sidewalk bridge you on the sidewalk?
Hill: is been over to the transIer station Sargent Bradshaw I just leIt
Irom there is Sargent Bradshaw who is been on (unintelligible)... These
over here just generally being a pain in the ass
Coughlin: Ireedom oI the press, Rich. (Hill starts making some big
gesticulating motions to OIIicer Hollingsworth like a child whom is not
being given the toy he wanted Ior Christmas or Veruca Salt throwing a
Iit in Charley's Chocolate Factory). They have important things to do
rich they are busy. (Helen Stewart continued talking the Hollingsworth
by this time OIIicer Del Vecchio is showed up, it looks like OIIicer
McQuattie is there (actually, that might be then trainee OIIicer Leedy,
OIIicer Look is there now too)
OIIicer Look: hey how are you doing
Coughlin: Hi, Sir, good to see you again. I didn't catch your name last
time I recognize you Irom the the day..
Look: with oIIicer look
Coughlin nice to see you again I think I saw you the other day when
came out on a call with OIIicer Gannon, Ior a domestic disturbance a
run East-Sage
look: I honestly don't remember
Coughlin: Yeah, I think you guys are up in my bedroom...
Look: Right on Scottsdale
Coughlin: Satan E. 9th St., Park Terrace Town homes... Freedom oI the
press, Rich.
Look what you guys have going on today?
Hill: contempt oI court Mr. Coughlin!
Coughlin: well, that carpet belongs to your client, Mr. Hill iI you try to
throw it away and then build me Ior it.
Hollingsworth: (comes over to talk to Coughlin) can you turn that oII,
Sir, Ior a second stuII over here on over on the sidewalk (Coughlin
was already on the sidewalk, but Hollingworth leads them Iurther
North along the River Rock side walk's western side). Okay so what's
the deal today why are we here?
Coughlin: I don't know, sir.
Hollingsworth did used to live here?
Coughlin: I preIer to just keep my privacy as a private citizen. But I
mean you no disrespect Sir.
Hollingsworth no problem, I can respect that here's the deal you
understand here in the sidewalk no problem you on it student run tape
no problem but you can't interIere with them doing their job and they're
probably enough apply Ior temporary station order against you in
which he/she can be within 100 yards oI there or them. (Hill gets into
his $100,000 Porsche Carrera where he goes oII the Reno Justice Court
and gets a TPO signed by Judge Schroeder within 40 minutes oI the
application being stamped in. Behind Hill's Porsche is OIIicer Look's
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patrol car and the patrol car being utilized by OIIicer Leedy and his
training, tenured OIIicer, OIIicer Del Vecchio. These vehicles are in
addition to the motorcycle ridden by OIIicer Hollingsworth. Richard
Hill's wiIe/legal assistant Sheri Hill is parked in the lot on the east side
oI River Rock in her maroon Lexus SUV. Contractor Stewart is seen
jaywalking across River Rock to the lot where Sheri Hill is parked, but
he is not arrested.). All they are trying to do is get their business or
taking care oI
Coughlin: I'm trying to take care oI my business, too.
Hollingsworth: okay is there something we can help you with?
Coughlin: I don't believe so, sir. I called the police recently I told them
somebody threatened my liIe the the day that in six see Iit to arrest
anybody so apparently Richard Hill is a national treasure.
Hollingsworth: Okay, well, I don't know who that is, all I know is I'm
here today and you are here with the camera and you're not breaking
any laws that I can see but they're gonna try to get it to where you are
violating a temporary protection order
Coughlin I understand it threatening abuse oI process and malicious
prosecution
Hollingsworth: so it would be helpIul iI maybe you could Iind
something else to do this aIternoon because I have been listening on the
radio and we've had two or three calls Ior service Ior you already today
and would like to be evidence oI do some other work today, no one I
mean
Coughlin okay well I hear what you're saying
Hollingsworth is basically a second help you with
Coughlin: iI you wouldn't mind telling me your last name
Hollingsworth: Hollingsworth
Coughlin thank you, Sir, Goodbye OIIicer Look, good to see you
again, Sir.(Coughlin then proceeds to walk back towards the mill place
parking lot Western Lane along court street he does not walk in the
street but rather uses the sidewalk which is now cleared oI Stewart's
laborers and any oI the personalty they are seeking to take to the dump
however the white dump truck belong to Stewart is still blocking the
sidewalk. Coughlin Fox all the way back to the area in the Mill's Place
parking lot immediately to the west oI the Ienced, gated backyard to his
Iormer home law oIIice, and can view OIIicer Hollingsworth pull away
on his motorcycle heading north on River Rock. Footage oI contractor
Stewart's white dump truck reveals how extremely implausible Stewart
sworn testimony was at the February 23, 2012 Order to Show Cause
hearing (which Hill had Coughlin personally served Notice oI by
WCSO Deputy Machen (by way oI RMC Marshal Harley) incident to
Coughlin arriving and waiting at the RMC Ior the traIIic citation Trial
in 11 TR 26800 stemming Irom the three traIIic citations RPD Sargent
John Tarter had issued to Coughlin incident to the November 15
incident at Hill's law oIIice where Coughlin ventured upon being
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released Irom three days incarceration Iollowing the November 13,
2011 criminal trespass rests at Coughlin's Iormer law oIIice Coughlin
went to Hill's oIIice to retrieve his keys state issued drivers license and
or identiIication his wallet and his client's Iiles, which Hill reIused to
release. It took until November 22nd, 2011 beIore Hill turned over
Coughlin's wallet and driver's license to Coughlin. It took until
December 22nd, 2011 beIore Hill turned over Coughlin's client's Iiles,
causing Coughlin to incur great expense in arranging Ior alternatives.
Coughlin starts to make his way back towards the Iront oI the property
and decides to walk along the edge oI the parked Tan Brown pickup
truck instead oI venture near it be laborers working Ior Stewart who are
now utilizing the sidewalk on the north side oI court street once again.
Coughlin notices the large manila envelope and the dashboard oI the
track with a large. Written note indicating Sargent Bradshaw on the
outside oI oI the Iolder. Coughlin then crosses the street in a straight
continuation Irom the northern sidewalk on Court St. to the parking lot
on the east side oI River Rock, just as any pedestrian would (except
Contractor Stewart actually just walked out in the middle oI the road
when he crossed River Rock earlier, rather than in a straight
continuation oI the sidewalks. Coughlin notices Contractor Stewart
milling about on the west sidewalk oI River Rock just north oI his
Iormer law oIIice. This group includes Stewart, Del Vecchio, Leedy,
and Look, whom are now joined by Sargent SiIre. OIIicer
Hollingsworth has leIt to do some real police work by this time. Sheri
Hill is still watching on Irom her maroon Lexus SUV in the parking
lot).
Coughlin: (talking vaguely in the direction oI Contractor Stewart who
is approximately 30 Ieet away) you might when I try to make sure you
don't throw away that carpet over there because I will dispute it iI you
guys try to bill me Ior it. (Coughlin then positions himselI to get a shot
oI the interior oI the Iormer home law oIIice where a he sees a very
sentimental item to him that he Iorgot to grab at the last second during
the mad rush to move his property out to whatever extent possible by
the 5 PM deadline December 23 this item is a 5" x 16" caricature oI his
Iormer domestic partner oI the preceding Iour and a halI years Irom a
relationship that ended in late May 2011 and himselI done during the
early stages oI their relationship. This was amongst Coughlin's most
treasured possessions and was only leIt atop a crown molding during
the move with the idea that it would be the last thing Coughlin would
grab, and thereIore he would be able to place it in a saIe place on his U-
Hauls dash board or somewhere else where it would be saIe. However,
the chaos incident to Richard Hill's showing up in demanding everyone
be oII the property by exactly 5 PM under the threat oI arrest caused
Coughlin to overlooked grabbing this treasured sentimental item. This
caricature is visible in the video)
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Coughlin: that is that sentimental picture that I told them about oI
Melissa and I. the caricature... And I believe the dolphin windchime
mobile, one oI the last things my grandmother gave me beIore she died
is in there...oh, and look at that there is $150 appliance. (to Contractor
Stewart). Sir I season sentimental heirloom keepsakes in their that I
guess you are just going to throw it away you don't care, the last thing
my grandmother gave me beIore she died very sentimental thing (at
this point Contractor Stewart turns to the camera an makes a revolting
gesture). Sir when you put a padlock on the back Ience? (Hill's placing
a padlock on the back Ience only just about the time that it was
Coughlin's right to remove his property resulted in Coughlin's progress
in moving all his personalty being severely impeded.).
...
(At this point in the video Coughlin returns to the parking lot oI Mill's
Place, private property, behind the Ienced back yard oI his Iormer
home law oIIice. Like a couple oI goons approaching, OIIicer's Leedy
and OIIicer Look venture into that private property, the Mill's Place
parking lot:
OIIicer Leedy: Mr. Coughlin could talk to Ior second?
Coughlin: I mean neither conIirming that that's my name, Sir, but you
are the law under asking to speak to somebody so.
(at this point OIIicer Look approaches Coughlin very rapidly and
immediately grabs Coughlin's wrist, Couglin holding his video camera,
which is, obviously, still Iilming, as OIIicer Leedy and OIIicer Look
immediately jump straight to applying excessive Iorce to Coughlin's
wrists. OIIicer Look jumps at Coughlin Irom Coughlin's leIt side and
OIIicer Leedy sneeks around behind Coughlin and grabs Coughlin's
camera out oI his right hand and turns it oII)
OIIicer Look: video camera down, put your camera down.
Coughlin:Whoa! Whoa! Why are you touching me! (OIIicer Look is
captured on video breaking back Coughlin's leIt wrist and wrenching
Coughlin's leIt arm behind his back, prior to any sort oI attempt to
peaceably approach Coughlin, a license attorney, whatsoever, but then
accidentally turns it back on a second later, a Iact to which he is
unaware. OIIicer Leedy places both oI his hands on Coughlin's right
side and right arm and wrist in a display oI excessive use oI Iorce.)
OIIicer Leedy: We don't want your camera....
Coughlin why are you touching me this is not their properties, Sir?
(the camera goes black Ior a moment)
Coughlin: Owww!. You are breaking my wrist!! Oww! Owww!!
Help!!! Help!!! My wrist hurts, somebody call 911. Owww!!
Owww!!! Somebody help!!! Somebody help!!! Sir, there is no need to
break my wrist like that, Sir. Oww!!!. Oww!!!Why are you
handcuIIing me, Sir?
OIIicer Leedy: You are being placed under arrest.
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Coughlin: For what? For what?
Sargent Paul SiIre: They'll explain everything to you in a little bit (but,
actually, Coughlin would not be told what he was charged with Ior
over an hour and a halI, and in the intervening period while he was
handcuIIed and placed in the OIIicer Leedy's patrol car, with tenured
training OIIicer Del Vecchio (whom had handcuIIed Coughlin, and
placed him in the back oI his patrol car on night in July 2011 incident
to Del Vecchio drawing his weapon, or appearing to, on both Coughlin
(whom was walking his bike at the time) and another bicyclist in Iront
oI Coughlin's Iormer home law oIIice at approximately 10 pm at night,
all because OIIicer Del Vecchio Ielt the light on Coughlin's bike was
"not up to code").
Sargent SiIre: I am going to shut your camera oII so the battery will not
run down.(OIIicer Del Vecchio can be seen in the video at this point
walking around in his acid wash jeans).
Coughlin: I don't wan't it shut oII, Sir. You are obstructing justice iI
you shut it oII! (Sargent Paul SiIre then shuts oII the video camera
whereupon OIIicer's Look and trainee OIIicer Leedy continuing
applying the wrongIul use oI excessive Iorce to Coughlin's arms and
wrists as they pin him Iace down to the concrete with a smug,
nauseating CaliIornian transplant name Sargent Paul SiIre (whom
incident to another wrongIul detention oI Coughlin on March 29th,
2012 told Coughlin he doesn't like Nevada or Reno, but the job he has
pays him so much, and he has so little chance oI Iinding such an
arrangement in any local more to his liking, that he essentially has a
pair oI "golden handcuIIs" tying him to Northern Nevada, which he
detests, beIore going on to tell Coughlin about how he lead his little
league team in both home runs and strike outs, then proceeding to
ramble on unconvincingly about how he was "trying to get you the help
you need", in a tone that was more suggestive oI a veiled threat to
Coughlin, the import oI which was clear, ie, that Coughlin better not
complain anymore about the RPD's police misconduct, such as
Coughlin did in his written complaints to the RPD on September 7th,
2011 and January 8th, 2012 wherein Coughlin complained oI the police
misconduct by RPD OIIicers Nick Duralde and Ron Rosa during the
wrongIul arrest oI Coughlin on August 20th, 2011in RCR2011-063341
(written complaint submitted to the RPD on September 7th, 2011 and
supplemental on January 8th, 2012, at which time a written complaint
against Nevada Court Services, RPD OIIicer Chris Carter, Jr., and
Sargent Marcia Lopez incident to their police misconduct during the
November 13th, 2011 wrongIul arrest oI Coughlin in RMC 11 CR
26405. Sargent SiIre would again order Coughlin arrested less than
48 hours later in RCR2012-065630 Ior "misue oI emergency
communications services". In between these two arrests RPD OIIicer
Duralde would get a chance to retaliate against Coughlin incident to
pulling Coughlin over in his car in the early morning hours oI January
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13th, 2012, aIter Coughlin bailed himselI out oI jail and use a
combination oI a cab ride and walking to get to his car in 20 degree
whether on a very windy night. Coughlin instantly recognized SiIreon
January 14th, 2012 Irom seeing him on January 12th, 2012 as on both
days Iact that SiIre was wearing a short sleeves uniIorm shirt
emphasizing his tribal armband tatoos, and body builder biceps.
...
See attached in Exhibit 1 the videos Irom all oI these varius wrongIul
arrests by local law enIorcemtn oI Coughlin
While it may be expendient Ior some in local law enIorcement
to discredit Coughlin or have him "committed", it does not make it
legal, and it does not vitiate the import oI law enIorcement misconduct
in all oI the wrongIul arrests oI Coughlin since August 19th, 2011.
Coughlin was just inIormed by his mother that this same OIIicer Travis Warren, along with another
RPD OIIicer and "two social worker types" met with Coughlin's mother, Very Special Arts oI Nevada
(VSAN) Program Director Mary Barker, and Coughlin's Iather, Dr. Timothy D. Coughlin, MD, oI Reno
Family Physicians at Dr. Coughlin's medical oIIice in an purported attempt to have Coughlin "committed"
sometime in approximately February 2012. Such a meeting is conveniently and suspiciously close in time
to the video transcribed above wherein Sargent Lopez essentially admits that she and OIIicer Carter lacked
probable cause Ior a criminal trespass arrest oI Coughlin (and, upon inIormation and belieI, the RPD was
served a subpoena by Coughlin requiring Carter and Lopez's presence at Trial, though neither managed to
show up, despite the City Attorney's having previously subpoenaed at least one oI them Ior that purpose as
well...It seems to City Attorney's OIIice got wind oI how terribly Iraudulent OIIicer Carter's probable cause
sheet was (and Carter did tell Coughlin, in the "Zach's arrest 010.mp4" video that Carter would put his
name on the "arrest sheet iI you have any problem with that" in response to Coughlin mentioning to OIIicer
Carter that the police did need to have probable cause to make such an arrest. Further troubling is the Iact
that RPD Sargent SiIre had Coughlin arrested just over 24 hours aIter Sargent Lopez put her Ioot in her
mouth her, bringing 5 other RPD OIIicers with him on January 14h, 2012 to respond to a 911 call by
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Coughlin reporting the disappearance oI his Pekingese dog, Jackson Pawluck, and the menacing statements
connected thereto by the house mates against whom Coughlin would eventually be awarded two diIIerent
TPO's.
Just about 12 hours prior to Sargent Lopez and OIIicer Warren and OIIicer Avila arriving at
Coughlin's E. 9th St. rental in response to a call by Coughlin reporting a domestic dispute (two oI
Coughlin's tires had been slashed and his license plate had turned up missing), just aIter Coughlin spent his
last $160 bailing himselI out oI jail incident to the January 12th, 2012 "jaywalking" arrest ordered by RPD
Sargent Paul SiIre, Coughlin was pulled over while driving home his vehicle aIter making his way to it
Irom the Washoe County Detention Center (which had seen Iit to release Coughlin exactly a couple
minutes aIter the last RTC bus had leIt Ior the night (on a night where the temperature was a balmy 25
degrees, with a considerable wind chill on top oI that) by the same RPD OIIicer Nick Duralde (whose wiIe
is an emergency communications dispatcher, Jessica Duralde, which complicates matters considering that
the petty larceny oI an iPhone case, RCR2011-063341 stemming Irom Duralde's wrongIul August 20th,
2011 arrest oI Coughlin has involved an inquiry wherein Duralde's basis Ior alleging he was justiIied in
conducting a Terry Stop "weapons check pat down" and or a search incident to arrest was largely premised
upon some purported "inIormation he received Irom dispatch" oI a "disturbance or possible Iight", despite
the Iact that none oI the discovery, 911 logs, dispatch reports, etc. propounded to Coughlin mention a
"possible Iight", but they do mention a "disturbance" and "possible larceny oI a cell phone" and the "RP
(reporting party) screaming at the accused". DDA Young may need to answer Ior just where this whole
notion oI Duralde being dispatched mention oI a "possible Iight" comes Irom exactly, other than the
prosecutors wish list oI things he wishes there was documentation oI to support his hopes oI proving
Coughlin's Fourth Amendment rights were not violated by an OIIicer eager to show up the lawyer in Iront
oI some teen-agers and early twenty-somethings. To be Iair, those youths did a Iair amount oI lying that
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night in their Iraudulent attempts to cover up the conduct oI Cory Goble, which may be tantamount to
having abandoned (and iI Goble did not abandon it, then anyone whom claimed it in response to the "man
holding a six-pack" oIIering it up and threatening to "throw it in the river iI someone doesn't claim it right
away", arguably "saved" the iPhone Irom being destroyed in connection with Goble's alleged negligence or
abandonment oI it, and thereby, the iPhone was no longer Goble's, iI it was, indeed, his to begin with
(which is unclear given Goble's contradictory statements in that regard where he alleges that he himselI
bought it three years previously, according to Duralde in his Supplemental Declaration incident to his arrest
report, in comparison to Goble's testimony on the August 29th, 2012 Trial date in RCR2011-063341,
wherein Goble alleges his brother bought it Ior him three years previously, not that WCPD Jim Leslie
would undertake any investigation or issue a subpoena to clariIy such a thing, mind you) his three year old
iPhone 3G (Goble's Iriend testiIied that Goble set it down on the concrete ground at around 11:00 pm or so
on a Saturday evening in the downtown Reno skate plaza in Iront oI City Hall (and Goble's statements in
his Witness Statement, that he was "skateboarding 15 Ieet away Irom the phone" conIlicting sharply with
both Goble's statements on the audio tape oI his 911 calls (wherein he admits to having been at his Jeep at
the relevant time, which was, apparently, according to Goble's Iriend Nathaniel Zarate's testimony, parked
on the west side oI the skate plaza, on Virginia Street, whereas some still unidentiIied "man holding a six-
pack" whom Zarate alleges picked up the phone oII the ground and held it aloIt (and Zarate's Iriend Nicole
Watson admitted on a video Iilmed by Coughlin upon his being released Irom 7 days in WCDC, where this
liIelong resident oI Reno, an attorney, whose entire immediate Iamily lives here, who had no criminal
record previous convictions aside Irom a January 2003 "dry" reckless driving conviction, was denied an OR
release by a retaliatory WCDC staII Ior 7 days, and where Coughlin's bail was impermissibly inIlated by
Duralde's Iraudulent overcharging as Ielony grand larceny Ior the purported theIt oI an item that was three
years old and on worth "between $250 and $300" when it was bought new three years previously. The
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RMC impermissibly violated NRS 5.011 when Judge Gardner held Coughlin's arraignment in 11 CR 22716
on October 10th, 2012 during the pendency oI the Order Ior Competency Evaluation oI Coughlin in
RCR2011-063341. So, OIIicer Duralde and Iive other RPD OIIicers just happened to be hanging around
Coughlin's car when he Iinally made his way to it upon his release Irom jail in the early morning hours oI
January 13th, 2012. Coughlin had previously Iiled a written complaint against RPD OIIicer Duralde and
OIIicer Ron Rosa on September 7th, 2011 and January 8th, 2012, making such a large show oI Iorce
incident to that pull over (Ior a license plate that just so happened to all the sudden turn up missing", and
the main suspects would be the RPD, or Coughlin's then house mates, or, Iinally, some stranger). A video
oI the wrongIul arrest was taken by Coughlin, and here is the transcript (oI the video Coughlin took oI the
August 20th, 2011 petty larceny arrest in RCR2011-063341):
RETALIATORY ARREST: "Let him do his job or we will call the Nevada Bar and tell them how you cooperated with
our investigation. How's that runnin' for ya?" and "Now, your're under arrest ofr larceny. Now we can search you
incident to arrest. How's that?"
On the video/audio recording oI the arrest ( VID20110820232801) the Iile name oI which represent an accurate time
stamping oI the time at which the video Iile began recording on 8/20/11 at 11:28:01 pm incident to the petty larceny charge
Coughlin is currently Iacing in RCR2011-063341)
(3 second mark)
Coughlin: I am scared oI you young kids...you have nothing to lose, oI course I'm scared oI you...please
don't hurt me...you have clearly scared me"
(at approximately the 22 second mark RPD OIIicer Duralde arrives on the scene)
Austin Lichty: We saw it light up in his pocket. He won't give it back.
Robert Dawson: He won't give us the phone he stole.
(27 second mark)
Zarate: I saw the whole thing.
(28 second mark)
Duralde: Do you have the phone?...Is it in your pocket?"
Coughlin: What?
Colton Templeton: The iPhone!
Lichty: Don't play dumb, just give it to us!
Duralde: The iPhone.
(41 second)
Coughlin: Don't I have a right not to answer an OIIicer when he inquires as to what is in my pockets?
Unless this is a Terry Stop, but I don't think this is a reasonable cause to do a pat down...
Duralde: It is a reasonable cause to do one.
Coughlin: Perhaps, you might be right.
(54 second mark)
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Templeton: And iI he calls it and it lights up in his pocket, will that prove it?
Duralde: Set your bike down on the ground, and move over there Ior a pat down.
(1:00 minute mark)
Coughlin: This dog likes to run away, OIIicer, can I tie it to something?
Duralde: Tie it to your bike.
Coughlin: Okay.
Austin Lichty: Corey, We can call it. Let's call it.
(1:02 mark).
Duralde: Dude, I am going to be real with you right now, the kid will probably be Iine iI you give him
the phone back, if not, we are going to get it out of your pocket and you are going to go to jail .
(From the 1:08 mark to the 1:28 mark Coughlin ties his dog to his bike and moves several Ieet south
towards the Siena in response to D's direction.)
Templeton: You want to go to jail over a iPhone that's not yours?
Lichty: You have a touch screen phone
Goble: Seriously, I don't get it, you just said iPhones are played out...
(1:28 mark)
Duralde: Face that way, other hand on the back oI your head...this hand on the back oI your head, there
you go...
(1:32 mark)
Coughlin: Can, I say one thing OIIicer? I'm a lawyer.
(1:36 mark)
Duralde (startled): Okay! (strange slipping/click sound emitted on video oI arrest at this point)
Coughlin: You just touched my junk! OIIicer, I don't appreciate you touching my penis. I am a lawyer,
and you haven't even asked me a question yet and you are handcuIIing me. I don't see how this is a Terry
Stop. I wish you would tell me why you are proceeding like this.
(2:00 minute mark)
Alaksa: You are a suspect in a larceny oI a phone. You have been identiIied by a victim as a suspect in a
larceny oI a phone. We are conducting an investigational stop. We checked you Ior weapons to make
sure that you do not have any weapons,.
Zach: Those young men assaulted me, I do not see them being handcuIIed.
(2:35 mark)
Duralde: Dude, you are the one who is accused oI the Irickin' crime.
Coughlin: I am accusing them oI assaulting me.
Duralde: Okay, and I am saying that is unIounded how are you injured.
Coughlin: Uh, assault isn't injury, its apprehension oI imminent bodily harm.
Duralde: Okay, so what did they do?
Coughlin: They grabbed me, they pushed me, they reached into my pocket, and they pulled my dog Irom
me,
Duralde: II they touched you its not assault.
Coughlin: ...As a gang oI skaters, twenty oI them backed me up into oncoming traIIic.
(3:05 mark)
Duralde: Citizen's arrest. They wouldn't have been coming aIter you iI you hadn't stolen the kids phone.
Coughlin: OIIicer, let me tone this down a little bit, okay. I have respect Ior you.
Duralde: What is your name?
Coughlin: Zachary Coughlin, Nevada Bar number 9473.
Duralde: I don't care what your bar number is, what is that? How does that bare on this?
Coughlin: Well, maybe it bares towards...okay, you seem to not respect or be willing to hear anything an
attorney says, yet a group oI skaters you believe wholeheartedly.
Duralde: Do you have the phone?
Coughlin: I'm not an...well, let me think about that....Do I have the phone? Do I have a right not to
answer your question?
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(3:41 mark)
Duralde: 1ust don't talk anymore.
Coughlin: Okay.
(3:45)
Coughlin: Do you have a right to search my pockets right now?
Duralde: What is your last name, how do you spell it?
(3:55 mark)
Coughlin: Am I under arrest?
Duralde: Dude, you are detained Ior a crime we have every right to identiIy you.
Coughlin: So, I think its under the Hiibel case where the guy reIused to give the police oIIicer his name?
Rosa: Its called 171.123, Terry Stop. You can provide your name or be arrested Ior obstruction.
Coughlin: You know what I'm talking about.
RPD OIIicer Rosa: Yeah, I know what your are talking about.
Coughlin: Search incident to arrest.
RPD OIIicer Rosa: That's not what your being...you are being detained, dude.
Duralde: You are not under arrest.
Coughlin: Okay.
(4:15 mark)
RPD OIIicer Rosa: Provide your name or go to jail for obstruction, and we will call the Nevada Bar
and let them know how you cooperated with our investigation, how is that runnin' for ya? We are
tired, and we are busy tonight, we have got better things to do tonight than be out here and debate the law
with you. Give the man your name and let him do his job. Is there anything wrong with that?
Coughlin: Well, can I ask you a question?
RPD OIIicer Rosa: No! You can't, just provide your name and inIormation or go to jail. Those are your
options, we are done discussing the law.
(4:40 mark)
Coughlin: Am I under arrest?
RPD OIIicer Rosa: How many times do I have to tell you, your are being detained.
(4:42 mark, dispatch radio traIIic can be heard in the background Irom the OIIicer's radio saying "3994",
the State Iailed to produce any dispatch recordings despite being served with a subpoena and despite the
Iact that such radio traIIic is recorded under RPD policies).
RPD OIIicer Alaksa: A decision has not been made
(4:46 mark, oII in the distance)
Skater voice, likely Templeton's: It will either light up or vibrate.
Coughlin: Okay, Can I just ask a question?
RPD OIIicer Rosa: What is your question.
Coughlin: I have total respect Ior you, believe me, I do.
(4:51 mark oII in distance)
Goble: He might have switched it over and or flipped it over.
(4:52 mark)
RPD OIIicer Rosa: Well then give the man your name, show him a little respect.
(4:54 mark)
Goble: He might have flipped it over to the right if it isn't in there then.
Licthy: Yeah, that is what he did.
(4:58 mark)
Coughlin: Can you ask these kids to back oII so we can tone down this situation..
RPD OIIicer Alaksa: You guys can you leave us along! Back oII! I said I would help you out. Okay,
allow me to do my job, okay?
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(5:02 mark, radio dispatch traIIic remains audible)
(5:07 mark)
Duralde: Now, you are under arrest Ior larceny. Now, we can search you incident to arrest. How's that?
Coughlin: Well, I mean, I wish you had asked me some questions prior to arresting me, I mean, it might
look better Ior you.
Duralde: Stand up!
(5:39 mark)
RPD OIIicer Alaksa: Who do you live with, Sir.
Coughlin: At this point OIIicer, though I respect you, iI you guys want to play so hardcore with me, you
know...
RPD OIIicer Alaksa: I want to try to help you with your dog and your bike, who can take care oI your
dog?
Coughlin: I live alone.
(5:52 mark, RPD OIIicer Duralde removes Coughlin's HTC G2 smartphone Irom Coughlin's right side
short's pocket, looks at the screen light up aIter touching it, and presses the red recording button to stop
the video recording).
The RPD and or Reno City Attorney's OIIice misconduct justiIies a tolling oI any deadline to Iile a
Motion Ior New Trial, or Arrest Judgment, or any other deadline given the many instances oI such
wrongIul conduct, including the Iollowing January 14th, 2012 arrest oI Coughlin in RJC RCR2012-065630
Ior "misuse oI emergency services" (and add to that the repeated Iraud by the pre-trial services staII at the
WCDC in lying and comitteing misconduct incident to their retaliatory dealings with Coughlin). Here is a
transcript, in relevant part, oI at least some oI the video and or audio recordings oI the momenets prior to
the arrest in RCR2012-065630 (and ECOMM and DDA Young and the RPD/State's misconduct in reIusing
to turn over excuplatory recordings and materials in that matter Iurther provides a good cause, tolling,
excusable neglect basis Ior granting the relieI requested herein).
TRANSCRIPT OF RECORDING OF RPD INTERACTIONS, IN PART, OF COUGHLIN
INCIDENT TO CUSTODIAL ARREST FOR MISUSE OF EMERGENCY SERVICES INCIDETN
TO CUSTODIAL ARREST OF COUGHLIN ON 1ANUARY 14TH, 2012 IN RCR2012-065630:
RPD OFFICER SCHAUR: how are you doing over here?
Coughlin: not so good.
Schaur: What's wrong.
Coughlin: My dog is gone.
Schaur: What kind oI dog do you have?
Coughlin: Pekingese.
Schaur: Peningese? I didn't see a Pekingese when we were comin' in here...do you have a tracker on it or
somethin' on it, one oI those little scanners?
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Coughlin: Like a microchip? You have six cops here? Why? I recognize this guy over here (reIercing
RPD Sargent Paul SiIre, whom admits to having ordered Coughlin be subjected to a custodial arrest Ior
"jaywalkign" which obstructed justice incident to Coughlin collecting evidence Ior a wrongIul eviction
lawsuit stemming Irom RJC Rev2011-001708.) You arrested me Ior jaywalking the other day.
RPD Sargent Paul SiIre: No, I didn't arrest you Ior jaywalking but I was on the scene.
Coughlin: what was your name?
Sargent SiIre: Here's the deal...what do you need today?
Coughlin: My dog is gone, threatening statements and smirks were made by the two women or girls in here
and the man...
...
SiIre: You are not injured or anything?
Coughlin: No, sir.
SiIre: are these your roomates?
Coughlin: she wasn't she moved in aIterwards, it's my understanding she is supposed to be living with her
mother. Can I go in there an here what they are saying (motioning to the RPD interviewing Laura Foreshee
and Stephanie Allaback).
SiIre: No, you have to stay here, we have to Iigure out iI you even have a domestic relationship.
Coughlin: So, you didn't arrest me the other day?
SiIre: No, I was on the scene, though.
Coughlin: So, who did arrest me?
SiIre: its on the paperwork.
Coughlin: Who did arrest me? OIIicer Leedy, the trainee, or OIIicer Del Vecchio, the observer?
SiIre: OIIicer Leedy, the trainee,.
Coughlin: So Leedy was the trainee but he was making the arrest?
SiIre, Yeah, but he was still sworn personnel. How long have you been livin' here, man?
Coughlin: why wouldnt' you tell me what the arrest was Ior?
SiIre: Yeah, they told you.
Coughlin: What was it?
SiIre: Pedestrian in a roadway.
Coughlin: is that normally necessitate a custodial arrest?
SiIre: It can be.
Coughlin: Why did it need to be a custodial arrest, Sir?
SiIre: That one, because I said it was?
Coughlin: Why did you make that choice?
SiIre: Because we had several incidents involving you yesterday, or, uh, Thursday.
Coughlin: And just because they involvea me, it necessitated a custodial arrest?
SiIre: Yeah, you didn't qualiIy Ior a citation?
Coughlin: Why was that?
Sargent SiIre: I just told you, we had several incidents involving you...
Coughlin: But, what iI I was the victim in each incident?
RPD Sargent SiIre: then you shouldn't keep putting yourselI in that situation.
Coughlin: Oh, okay. (Coughlin previously worked as a domestic violence attorney/advocate at Washoe
Legal Services and is well Iamilar with the "blaming the victim" methoaology employed here by RPD
Sargent SiIre)/
Sargent SiIre: That is why you got served with the TPO (temporary protection Order Iiled by Richard G.
HIll, Esq., incident to his abuse oI process and successIul attempts to obstruct justice in
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The cases wherein Coughlin was a victim oI opposing party and or law enIorcement misconduct
justiIying the relieI sought herein, include, but are not limited to
REV 2012-001082 Northwind Apts. Vs Zach Coughlin
REV 2012-001083 Northwind Apts. Vs Zach Coughlin
REV 2012-075658 Zach Coughlin vs JeII Nichols
RJC 2012-076746 Zach Coughlin vs Northwind Apts.
REV 2012-00374 Park Terrace Townhomes vs Zach Coughlin
REV 2012-074408 Zach Coughlin vs Park Terrace Townhomes
REV 2012-001048 Northwind Apts vs Zach Coughlin
RJC RCP2012-000287 Milan Krebs (Northwinds maintenance man) v. Zach Coughlin (another TPO the
RPD Iraudulently induced a landlord to procure against Coughlin, thanks to RPD OIIicer Alan Weaver,
Sargent Oliver Miller, and Ltn. Kevin Brown).
REV 2011-001492 Matt Merliss vs Zach Coughlin
REV 2011-001708 Matthew Merliss vs Zachary Coughlin
RJC 2012-078432 Zachary Barker Coughlin vs Superior Mini (in this matter, on approximately September
22nd, 2012, besides RPD OIIicer Weaver calling up Coughlin's mother an attempt to coerce her into
assisting him and the RPD In violating Soldal v. Cook County, the RPD and OIIicer Weaver and Sargent
Oliver Miller also attempted to induce Superior's Matt Grant to Iile another Iraudulent "distrubing the
peace" charge against Coughlin shortly aIter Weaver swaggeringly, and in a smug manner, threatened to
Iraudulently arrest Coughlin again Ior another "Iailure to secure a load" citation and conduct another
impermissible "search incident to arrest" or "inventorying" oI Coughlin's vehicle. RPD Sargent Dye and
OIIicer Weaver had also violated criminal laws in attempting to dissuade Couglin Irom testiIying at to their
misconduct in RMC 12 CR 12420 on September 5th, 2012 (SArgent Dye tracked Coughlin down while he
was deliverying materials incident to his part time job, shortly aIter midnight on September 5th, 2012 to
attempt to intimidate Coughlin in a Scolari's desolate parking lot, and OIIicer Weaver made menacing
gesticulations to Coughlin in court while they waited Ior the 12 CR 12420 case to be called, wherein Reno
City Attorney committed proIessional misconduct in violating RPC 3.8 in amending the criminal complaint
in that matter to charge Coughlin with trespassing, and RMC "deIenders" Keith Loomis, Esq. and Henry
Sotelo both violated NRS 178.405 and NRS 5.010 at various times by Iailing to abide by the stay required
therein and in obtaining orders allowing their withdrawal (oI course, the kept their monthly, princely $7K
"side gig" payment Irom the RMC, which Ior all purposes seems to be made in exchange Ior their selling
their criminal indigent client's down the river and or subjecting them to impromptu cross examination
demanding answers to which they are not entitled, especially in Loomis's case, and otherwise withholding
Irom criminal indigent deIendant's the Iew inviolable rights they have, including, the right to counsel under
the Sixth Amendment, the right to subpoena or call witnesses, and the decision on whether or not to testiIy.
Storage. Loomis also committed Iraud in assisting in having Coughlin incarcerated wrongIully Ior nearly
20 days in July 2012, including his Iailure to Iorward to the RMC the prooI oI insurance Coughlin provided
Loomis (which had already been provided to charlatan police oIIicer's Weaver and Dye anyways), and in
coercing wrongIully Irom Coughlin some purported consent to view Coughlin's HIPAA protected medical
records (something WCDC social worker Jan Guidetti also sought to do on behalI oI RMC Judge Nash
Holmes)
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Coughlin also took a video oI the January 12th, 2012 "jaywalking" arrest in RMC 12 CR 00696,
and Coughlin also took a video oI at least part oI the January 14th, 2012 arrest Ior "misuse oI emergency
services" (a gross misdemeanor) in RCR2012-065630. Both arrests were ordered by Sargent SiIre, as
admitted by SiIre himselI in the video Coughlin took oI at least part oI the January 14t, 2012 arrest. And,
curiously, the RPD, ECOMM, and DDA YOung, despite having been loaded up with visible cameras and
audio recorders (amongst the various 6 oIIicers dispatched in response to Coughlin's 911 call oI that night)
have so Iar Iailed to propound (despite WCPD Dogan purporting to have made such requests and or served
the appropriate subpoenas...though everything with Dogan has been rather "murky", with his supervisor
Jim Leslie hovering around the case exacting a similar toll upon Coughlin's deIense as that Leslie has done
to two other cases wherein he purports to be "deIending" Coughlin (in RCR2011-063341, the iPhone petty
larceny case, which Coughlin Iinally managed to get Leslie booted Irom on October 22nd, 2012, leaving
Coughlin little time to prepare Ior the November 19th, 2012 resumption oI that Trial, particularly where
Leslie has still Iailed to comply with an Order in that matter requiring him to digitally transmit various
materials Irom Coughlin's Iile to Coughlin; and in RCR2012-067980, the "Ialse statement to a public
oIIicer" retaliatory prosecution that DDA Young is bringing against Coughlin incident to a wrongIul arrest
by ol' WCSO Deputy Machen on June 28th, 2012, stemming Irom a Summary Eviction Order that Judge
Schroeder oI the RJC managed to sign despite numerous written correspondences to the RJC and the
Sparks Justice Court providing a "heads up" that the 5 day unlawIul detainer served by ol' Northwind
Apartments Associates, LLC (a corporation, and thereIore, not entitled to appear without an attorney under
NRCP 11, nor entitled to utilize an entity committing the unauthorized practice oI law, though they did, in
hiring "eviction consulting and process services" Iirm Nevada Court Services, in RJC REV2012-001048,
whose licensed process service Robert Wray (or maybe it is Ryan Wray?) Iiled a Iraudulent declaration oI
service alleging he personally served Coughin on June 14th, 2012 a 5 day unlawIul detainer notice incident
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to Wray and Northwind's Manager Duane Jakob attempting to break into Coughlin's rental #29 at
Northwind's Apartments on that date, a rental with no windows whose door was closed and locked, though
Wray alleges to have "personally served" the notice (and thereby cut short by 3 days the amount oI time the
tenant had to Iile a Tenant's AIIidavit...though Coughlin did submit just that to the court listed as having
jurisdiction on the Nevada Court Services prepared June 14th, 2012 5 day notice (which "mistakenly" listed
Sparks Justice Court" as the Iorum to Iile such a Tenant's Answer or AIIidavit), Sparks Justice Court, on
June 26th, 2012 (and the SJC Iaxed as much over to the RJC on June 28th, 2012). Deputy Machen
arrested Coughlin on June 28th, 2012, alleging it did
OIIicer Warren To be Iair, OIIicer Travis Warren did a rather proIessional and admirable job
recently in coordinating, with RPD OIIicer Wilson, a "civil standby" oI sorts at Northwind Apartments, on
or about October 10th, 2012 when Coughlin went there to retrieve what remained oI his personalty aIter he
was unable to remove it all Irom his three diIIerent rentals at Northwinds on during the 16 hours allotted on
August 13th-14th, 2012. A Northwind's apartment maintenance man was able to assist his employer in
subverting the civil eviction process along with some inspiration and coaxing by Reno Police Department
oIIicer Alan Weaver and Sargent Dye by obtaining a temporary order protection against Coughlin on July
5, 2012 in RJC RCP2012-000287 (Milan Krebs v. Zach Coughlin). OIIicer Weaver and Sargent Dye had
arrested Coughlin on July 3, 2012 (in RMC 12CR12420, which has now seen granted two diIIerent Motion
to Withdraw by Coughlin's court appointed Counsel in that matter: Keith Loomis, Esq. (and Loomis scored
a similar Order allowing him to depart Irom his purported Sixth Amendment IulIillment aIter continuing to
do little while unIailingly collecting his "side gig" $7K a month as a contracted court appointed counsel Ior
the RMC, gotta pay Ior that new white BMW somehow, right, Keith) and Henry Sotelo, Esq. (also pulling
in a princely "side gig" as one oI the RMC's many, many McGeorge School oI Law alumni Iormer
prosecutors turned court appointed prosecutor's helpers, er, indigent criminal deIendant herders, er, deIense
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counsel, to go along with the various McGeorge School oI Law alumni sitting judges at the RMC (some, oI
whom, like RMC Judge Kenneth Howard, have been close personal Iriends with Loomis since their days
playing on the law school basketball team back at McGeorge; Judge Howard, McGeorge 1981, another
judge at the RMC, McGeorge, 1985, Judge Nash Holmes, McGeorge 1977, court appointed deIender
Iormer prosecutor Keith Loomis, McGeorge 1982; court appointed deIender Iormer prosecutor Henry
Sotelo, McGeorge 1987; Loomis has been busy puttin' in work Ior the RMC oI late with respect to
Coughlin, managing to torpedo Coughlin's deIense in the criminal trespass matter beIore Judge William
Gardner in 11 CR 26405 by Ilat out reIusing to subpoena either Sargent Lopez or OIIicer Carter, or
landlord Merliss, despite all three being the only other eye witnesses to the events to the November 13th,
2011 arrest scene (besides the seemingly conveniently edited videos Hill and Merliss Iilmed, which Hill
seemingly never bothered to view as they expressly contradict his sworn testimony at the June 18th, 2012
Trial in that matter) incident to pulling him over Ior a minor traIIic violation and alleged in plastic tub had
Iallen oII his vehicle wherein they charged him with Iailure to secure load and Iailure to maintain prooI oI
insurance, despite the Iact that Coughlin provided prooI oI his vehicles and should current insurance in the
Iorm oI a PDF high-resolution image oI his insurance card on his 5 inch smart phone screen to which
oIIicer Weaver declared that the prooI needed to be on actual paper at which point oIIicer Weaver arrested
Coughlin Ior disturbing the peace incident to some alleged statement by Coughlin that morning at
Northwind apartments wherein Milan Krebs asserts Coughlin said something all along the lines oI "don't
mess with my locks again or else you'll be sorry" (which Coughlin did not even say, though Coughlin did
arrive at his rental at Northwind's on that July 3rd, 2012 morning to Iind "someone" had placed some sort
oI glue in the key slot oI the lock on his rental's door), though Krebs's statements in his application Ior an
order oI protection compared to those he makes in his witness statement incident to the July 3 arrest oI
Coughlin contains some glaring inconsistencies particularly with respect to the protection order going into
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some alleged propensity oI Coughlin to carry around large butcher knives where is the witness statement in
connection with the July 3 disturbing the peace arrest Iails to mention such a minor detail. Krebs also
makes an allegation that Coughlin burglarized his truck despite the Iact that Coughlin has a video oI the
incident Krebs reIers to wearing Krebs admits under oI at the extension hearing on his application Ior a
temporary protection order that he was not present during incident wherein his coworker Luke idea and his
manager Dwayne Jakob indicated him that they caught Coughlin attempting to burglarized his truck.
Coughlin also has a video oI the incident wherein Krebs alleges Coughlin was Iollowing him Ior 5 minutes
and screaming out threats and inciting in the violence. Also may be critical oI Coughlin's propensity to Iilm
things one might ask himselI where Coughlin would be had he not all these exculpatory videos proving the
perjury oI various individuals including OIIicer Weaver, Northwind's Apartment's Associates, LLC (part oI
the monolithic ACG-AMPI, Inc., doing business in ten states operating enormous apartment complexes that
are known Ior cheating it's tenants out oI their damage deposits by asserting especially spurious rationale in
support Ior Iailing to so return such deposits) Manager Dwayne Jakob (who lied under oath at the July 31st,
2012 Hearing related to various Motions Coughlin Iiled in connection with a wrongIul arrest oI June 28th,
2012, wherein the Washoe County SheriII's OIIice's Deputy Machen (the same deputy whose Iraudulent
aIIidavit oI service Iiled November 7, 2011 asserted that it personally served Coughlin the lockout order on
November 1, 2011 incident the eviction Irom Coughlin's Iormer home law oIIice despite the Iact. Mansions
supervisor Washoe County SheriII's oIIice civil division supervisor Liz digital admits and had February
2012 e-mail to Coughlin that matching merely posted. Summary eviction order on the door to Coughlin's
Iormer law oIIice when no one was home and proceeded to then eIIectuate a lockout, and thereby Iailed to
comply with the dictates oI NRS 40.400 (which incorporate the Nevada Rules oI Civil Procedure into
landlord tenant summary eviction proceedings and unlawIul detainer actions under NRS 40. Arrested
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Coughlin (and, yes, that arrest was captured on video tape as well, and is providing another basis Ior DDA
Zach Young to Iurther hone his retaliatory prosecution chops) an idea
1.When Coughlin was in the quasi-"basement" (it isn't a room Iit Ior habitation or use under the Housing
Code (only one exit, ceiling are about 5 Ieet high in most places, Iloor was dirt when Coughlin Iirst rented
it, but he Iixed it up very nicely over time and it certainly looked like someone could have been living in
there well prior to the eviction, but Judge Gardner ruled all that stuII about "using it as a residence" was
irrelevant, except Ior the Iact he mentioned it in his Order and Hazlett let it creep into his closing
arguments....) there was not any voices calling to him (certainly the videos Iilmed by Hill and Merliss,
propounded to the City and the court appointed deIenders who reIused to subpoena Merliss despite Hill's
and the RPD's obvious motive and bias...show that neither Hill nor Merliss, as conIirmed by Hill's Trial
testimony, made any verbal incantations to Coughlin, but rather, retreated upstairs to wait Ior the RPD...)
prior to what was ultimately revealed to be the RPD arriving. As shown with a lot more indicia oI
reliability than Hill's lie Iilled June 18th, 2012 sworn testimony at trial, in his November 21st, 2011
Declaration, Hill Iails to assert that the RPD "identiIied themselves as law enIorcement" and issued a
lawIul order to emerge Irom the basement (which is not necessarily lawIul, even iI they identiIy themselves
as law enIorcement, iI they were not given the authority to issue it by someone having such authority, and
its not clearl that either Merliss or Hill did...). Regardless, the RPD deIinitely DID NOT "identiIy
themselves as law enIorcement" prior to Merliss kicking the door down. Rather, it is telling that in HIll's
November 21st, 2011 Declaration he merely mentions the RPD attempting to (see this dissected in glorious
detail in the attached Bar grievance) "coax Coughlin to emerge Irom the basement". And the RPD did just
that. Only, they didn't identiIy themselves as law enIorcement at any time prior to the door being kicked
down. So, iI you are Coughlin, and you have a real strong claim oI right deIense to any allegation oI
trespass, then just hearing some random voices "coaxing" him to talk to them like they are therapists or
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some other crap like that is not tantamount to a "lawIul order to emerge Irom the basement" or warning to
leave the premises else be cited or arrested Ior criminal trespass. (Hill told Coughlin he was billing him the
same $900 a month as when Coughlin was there under a lease allowing Ior "Iull use an occupancy"; any
eviction order was void Ior lack oI jurisdiction, Coughlin was entitled to a stay Coughlin had yet to receive
back Irom the RJC the "rent escrow" $2,275 that Judge SIerrazza, on October 27t, 2011, announced would
be held onto by the RJC as Coughlin's "bond on appeal" (meaning the supersedeas bond, as appeal bond's
are set statutorily at $250 in such matters and supersedeas bond's are the ones teh RJC typically makes in an
amount worth "three month's rent" (ie, the RJC can't keep the money Ior the stay, and call it that, and deny
the stay...its like calling it a summary eviction hearing, but ruling on more than possession, then ruling
Coughlin established a genuine issue oI material Iact and noticing the October 27th, 2011 date as a "Trial"
in writing (Baker says on the record in that case "the use oI the term "Trial" was unIortunate, Your
Honor....", then ordering an impermissible rent escrow deposit...not giving the 20 days to respond to a
Complaint called Ior by JCRCP 109....basically giving HIll and Merliss all the beneIits oI the quick and
easy summary eviction proceeding (Coughlin was precluded Irom making counterclaims or bringing in
third party deIendants like Dickson Realty or NV Energy or Green Action Lawn Service, etc), and
Coughlin none oI the procedural protections oI a plenary unlawIul detainer, while also attempting to aIIor
HIll and Merliss the beneIits oI a plenary unlawIul detainer (awarding back rent, attorney's Iees, landlord
was able to bring a summary eviction proceeding against a commercial tenant based only on a No Cause
Notice, verboten under NRS 40.253...). Further, and this is shown on the videos Hill and Merliss Iilmed,
the RPD at no time gave Coughlin a warning to leave where Coughlin could have heeded it and leIt, or
otherwise been issue a citation in lieu oI a custodial arrest. The RPD wanted to make the big rich landlord
and attorney happy here, and neither the RPD (which was mad at Coughlin Ior Iiling a police misconduct
complaint incident to the wrongIul August 20th, 2011 arrest oI Coughlin that ain't lookin' good Ior the State
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now that Coughlin got WCPD Jim Leslie booted Irom the case in RCR2011-063341) nor Hill or Merliss
were going to be satisIied with just issuing Coughlin a "warning" to leave the premises, as they Iigure
Coughlin would just heed any such warning....The RPD and Merliss/HIll were all jacked up on revenge
powder and wanted Coughlin arrested. Dr. Merliss is practically Irothing at the mouth (demanding "more
eye contact!" Irom Coughlin in the video "Zach's arrest 0010" just beIore Dr. Merliss commits a crime in
lying to the RPD in response to Coughlin's querying those there as to who warned him against trespassing
and when, whereupon Dr. Merliss lies in order to get Coughlin arrested, and Hill co-signs it:
Richard G. Hill, Esq. (opposing counsel in the civil eviction case Irom which this criminal trespass trial
stems) testiIied, under oath, that the Reno Police Department identiIied themselves as law enIorcement and
issued a lawIul order to leave prior to the RPD entering the door that Hill's client Merliss kicked down
after such identiIication and issuance oI a lawIul order or warning to leave the premises was issued by the
RPD. Additionally, beyond the impermissible extent to which RMC D2 Judicial Assistant Lisa Wagner
Iailed to Iile Coughlin's June 28th, 2012 Notice oI Appeal (Iax Iiling allowable under RMC Rules, any
Order by Judge Gardner to the contrary spoke to pre-trial Motions only), the Washoe County Detention
Center impermissibly reIused to timely Iile Coughin's additional Notice oI Appeal in a timely Iashion while
Coughlin was wrongIully incarcerated incident to a wrongIul arrest by the RPD, buttressed upon an
impermissible bail increase (supported in Judge Gardner's rationale by a "public health and saIety"
rationale not providing a basis Ior bail under Nevada Law), at an unnoticed impromptu bail hearing on July
5th, 2012 wherein the RMC and court appointed deIender Keith Loomis, Esq. coerced Irom Coughlin an
impermissible invasion oI Coughlin's medical records under extremely coercive circumstances made worse
by the Iraud committed upon the court by RPD Sargent Dye and OIIicer Weaver (the arrest in that matter
12 CR 12420 was pretextual and Iraudulent, and compounded by Sargent Oliver Miller and OIIicer Weaver
subsequent misconduct incident to another Soldal v. Cook County violation on their part involving
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Coughlin and Superior Mini Storage in an RJC eviction matter stemming Irom police misconduct by Miller
and Weaver on or about September 22nd, 2012.
There was an Order For Competency Evaluation by Judge CliIton in RCR2012-065630 entered
February 27th, 2012, and the Order in CR12--0376 adjudging Coughlin competent and remanding
jurisdiction back to the lower court was not entered until May 9th, 2012, yet Loomis and Hazlett-Stevens
persisted in seeking to ramrod the criminal trespass case in RMC 11 CR 26405 through...and both were
well aware oI the February 27th, 2012 Order Ior Competency Evaluation and the import oI NRS 178.405,
requiring the suspension oI all proceedings during the pendency oI such an Order, made applicabel via
NRS 5.010 and the various rationale set Iorth in the attached materials. Further, the RMC Iailed to Iile the
timely Notice oI Appeal I submitted Ior Iiling on June 28th, 2012, and which was served by delivering to
the City Attorney's OIIice on June 27th, 2012 (timely within 10 days under NRS 189.010) resulting in the
dismissal oI the appeal. The Iraud oI the WCSO, RPD, City Attorney and others prevented Coughlin Irom
having an appropriate chance to Iile as complete and thorough a Motion Ior New Trial as he intended,
including a wrongIul arrest on June 28th, 2012, the WCDC denying Coughlin even a phone call Ior no
reason Ior 20 hours, until aIter the RMC had closed on Friday, June 29th, 2012, and then another wrongIul
arrest on July 3rd, 2012 by the RPD, with an impermissible bail increase by the same Judge William
Gardner whom should have recused himselI Irom the June 18th, 2012 Trial in 11 CR 26405 in the RMC,
violating oI most provision Iound in the NRS related to bail.
CONCLUSION
Please grant this Motion Ior New Trial or Vacate the Judgement oI Conviction or Motion to Arrest
the Judgement (and return Coughlin's money, including the $310 the RMC kept, which made it twice the
usual Iine Ior Iirst oIIesnse criminal trespass) and or reinstate Coughlin's appeal and apprise D10 in CR12-
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1262 oI Coughlin's timely Iiling a notice oI appeal on June 28th, 2012 and timely serving the City
Attorney. DeIendant/Appelant Coughlin hereby respectIully requests all Orders, Convictions, Judgments,
Contempt Findings, etc, be amended, set aside, etc.
AFFIRMATION Pursuant to NRS 239B.030
The undersigned does hereby aIIirm that the preceding document does not contain
the social security number oI any person. And I declare the bit about RPD OIIier Travis Warren and others
is true to the best oI my knowledge under NRS 53.045 and that the videos and transcripts are, to the best oI
my knowledge, accurate and true. The rest? Well, one, tape dont lie. Two, iI Hazlett don't have to sign a
declaration in putting in all his unsworn hearsay pajama-centric tacky testimony, I shouldn't have ta. But
to the extent that I am Iorced to? Yeah, that stuII is sworn to as well.
DATED this October 28th, 2012
/s/ Zach Coughlin
Zach Coughlin
DeIendant
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PROOF OF SERVICE
I, Zach Coughlin, declare:
On this date, I, Mr. Zach Coughlin served the Ioregoing document by emailing and or Iaxing and
or placing in the USPS mail, AND PERSONALLY DELIVERING TO THE OFFICE OF THE RENO
CITY ATTORNEY a true copy thereoI to:
CHRISTOPHER HAZLETT-STEVENS, ESQ.
JOHN KADLLC ESQ.
hazlett-stevenscreno.gov
kadlicjreno.gov
Company: Reno City Attorney's OIIice - Criminal Divison
P.O. Box 1900 Reno , NV 89505
Phone Number: 775-334-2050 Fax number: 775-334-2420
courtesy copies Iiled with the RMC either by Iax Iiling, emailing and or paper Iiling
DATED THIS October 28th, 2012
BY:
-----------------------------
Zach Coughlin
Pro Se DeIendant Denied Sixth Amendment Right To Counsel and
Subpoenas
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IINDEX TO EXHIBITS
1. Exhibit 1: RELEVANT MATERIALS AND VIDEOS on a CD, including the newly uncovered
exculpatory videos oI wrongIul arrests oI Coughlin detailed in the above Iiling, including, but not limited
to, the Iollowing videos, which can also be Iound at the Iollowing link:
rpd sargent lopez i have a question Ior you 11 cr 26405 00696 26800.wmv (13.6 MB)
VID20110820232801 oIIicer duralde and rosa 8 20 11 arrest.Ilv (9.5 MB),
SAM0189mpeg4 rpd hill siIre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4 (12.2 MB)
SAM0190mpeg4 rpd hill siIre jaywalking 11 cr 26405 11 tr 26800 rmc.mp4 (10.0 MB)
20120605204307 cory goble Ilicks cigarette at coughlin hits coughlin's leIt shoulder RCR2011-
063341.mp4 (5.6 MB)
and one hundred and ninety Iives (195 pages) oI exhibit 1's paper/pdI materials.
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EXHIBIT 1
EXHIBIT 1
- 42/42 -
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STATE OF NEVADA, Case No. R-c f2 '/,>/2 S-(; ;(J
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Plaintiff,
Dept. No.---L::)
Vs.
SUBPOENA
DUCES TECUM
You are commanded to deliver the above mentioned before e Reno Justicfe at One
Sou,h Sierra Street, on or before thS. / I: . !day of_ ,(; vV ,. {A.......<._.'
______ at _ .... '} (..' M. on the part of ,', c '\ L. C c-. "I( (/ \
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth in NR 22.100
andlor NRS 50.195.
DATED this _,.0('_' ""_ day of_1'; 0j Il \eM V , ?\)\Y
STATE OF NEVADA, )
) SS.
County of Washoe )
STEVE TUTTLE .-:c--------
Clerk of the Court
I received this Subpoena on the __ ....... ____ day of _______________
and personally served a copy of the same upon ___ ._."
on this ______ day of
this ' day of
-------,-_.
NOTARY PUBLIC rev 0412009
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IN THB mSTICE COURT OF RENO TOWNSHIP
COUNTY OF WASHOE, STATE OF NEY ADA
STATEOFNEYADA,
Plaintiff,
Case No. lLL L
. .--,
..
SUBPOENA
DUCES TECUM
Defendant
_f::-"C-L)JL-{: V=_ _____ _
\'0 \ \ 'A--" ! i en V s;
. You are commanded to deliver the ab ve mentioned documents befor,e the Reno Court at One
South Sierra Street, Reno, On or before the day of ,.f (, 0!--'c_,(
at ':s)C)
Failure.to deliver may be deemed a contempt of court and subject you to the 22.100
and/or NRS 50.195.
l\\,
DATED thiS __ --'-I ' __ day of
STEVE WTTLE .
Clerk of tbe Court
STATE OF NEVADA, )
) SS.
County of Washoe )
I received this Subpoena on the _______ day of
____ and personally served a copy of the same upon __ _
on thls ______ day of _______________ .
this day of
NOTARY PUBLIC
rev 04/2009
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STATE OF NEVADA,
Case No.
Plaintiff,
Dept. No. L
Vs. SUBPOENA
DUCES TECUM
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Defendant
TO:
6
c 121/'\( LA t\ 19\"\ s:.ov V 1;- t-' S c, '6 7l&1SAe
J .) (7
You are commanded to deliver the above me._ before e iustlC ourt at/?ne J
South Sierra Street, Reno, evada on or before the J . ,h of. uvt!
:7 [:/\''1. ,at '50 o'clock 0\....VLM: on thepartof 2.cc. ( \ ,"} (f--
Failure to deliver may be deemed a contempt of court and subject you to the penalty set forth 10 N1fs" 22.100
and/or NRS 50 195.
DATED this
STEVE -YUTfLE
Clerk of the Court
STATE OF NEVADA, )
) 5S.
County of Washoe )
1 received this Subpoena on the ________ day of
____ and personally served a copy of the same upon _________ _
onthis __ _
this day of
NOTARY PUBLIC
rev 04/2009
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STATE OF NEVADA,
Plaintiff,
.--/
..
SUBPOENA
DUCES TECUM
Defendant
/
__ D"",. _____ _
,', ,)" ,\, ]: y}>C 0 J);' 'l
. You are commanded to deliver the ab ve mentIOned documents Reno lyst''?,e Court at One
South Slerra Street, Reno, on or before the .I '[ day of .Y (- 0 '-'c .. -7
at X ')C' 7/;: C/:JC), '97-AJ] Ii..-
Failure to deliver may be deemed a contempt of court and subject you to the penally ;;ol forth 22.100
and/or NRS 50.195.
STEVE 'fUTILE
- Clerk of the Court
STATE OF NEVADA, )
) SS.
County of Washoe )
I received this Subpoena on the
____ day of
_____ and personally served a copy of the same upon ____________________ _
on this _____ dayof ________ .
this day of
NOTARY PUBLIC
rev 04/2009
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STATE OF NEVADA,
Vs.
Plaintiff,
/. _\ '\ //1 /; \ '1
( e,-/Ii\ V
'-
TO:
c-'v 5-( u c1
SUBPOENA
DUCES TECUM
0'2"'</ })\ v'\ (L q)
P -0c
c
/-:'.",\J\
+
You are commanded to deliver the above mentioned before e Reno.Justi,/e C.9.urt at One
South Sierra Street, on or before /'i-Iilily of .C- V\---'----' ,
_,---_--c-:-:-_.at ) u __ M. on the part of 7 "'. C '\ LC c- .-,il I.'
Failure to deliver may be deemed a contempt of cmUi and subject you to the penalty set forth in NR1221 00
and/or NRS 50.195.
STATE OF NEVADA, )
) SS.
County of Washoe )
STEVE TDYfLE
Cle"'rk""o"'rcctlC'le-C=-o-u-r'-------
r- "
nrt()CU;\ GJ-\Ot\wVvv
epuly Clerk d
1 received this Subpoena on the ____ dayof ________ _
____ and personally served a copy of the same upon
Oil this _____ day of ________ . ___ _
this _______ d.ayof
-------,-_.
NOTARY PUBLIC reY 04/2009
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COUNTY OF WASHOE, STATE OF NEV ADA
STATE OF NEVADA,
vs.

Plaintiff,
Defendant.
Case No. e.C rz '20/! - 06 3'5z()
Dept. No. 2
SUBPOENA
You are,commanded to apoear before the Reno Justice COllrt,at One South Sierra Street, Reno, Nevada
on the_ J Of'i-fn_dayof f\JOV-.ZYv\!c:l..P..v ,20 Si'-?:O o'clock G-.M.
to testify on the part
Failure to appear may be deemed a contempt of court and subject YOli to the penalty set forth in NRS 22.100
and/or NRS 50.195.
) \'-\.h
Dated this day of
20 \y
---' -_.
STEVE TUTTLE
CLERK OF THE COURT

Deputy Cler
AFFIDA VlT OF SERVICE
STATEOF ________
)ss.
_____
I, received this Subpoena on the ___ day of _________________ " and
personalJy served a copy of the same upon
on the ____ day
of ____________ , 20 __
____ dayof _________ ,,20 __
Notary Public
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STATE OF NEVADA,
Plaintiff,
Dept. No.
VS.
23& V\ &v &J U A ( SUBPOENA
Defendant. (
TO Va V\ q h 5<l utg1l.fi/kif)
You are to appear b,for<;-the Reno Justice Court LJ;e South Sierra Street, Reno, Nevada
on the........--f-0 r-dayof r\)DY.Q.VY1JQJ..Y __ ,20 , o'clock Cl_.M.
to testify on the part of
and/or NRS 50.195.
STEVE TUTILE
CLERK OF THE COURT
By
Deputy Cler
STA TE OF ______ -...-.J
)ss.
COUNTY OF __ . ___ ---')
I, received tillS Subpoena on the ___ day of ________ _ . __ ._,20 __ , and
personally served a copy of the same upon ______________ on the __ _ day
of
_____ ,20 __
Subscribed and sworn betore me this
____ day of _________ " 20 __
Notary Public
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STATE OF NEVADA,
Plaintiff,
2-
Dept. No .. _____ _
vs.
24 LH SUBPOENA
Defendant.
Td
1
) 5c 0 ___
You are mmanded to appear before thr.Reno cor. ZOne South Street, Reno, Nevada
on the iHJ:::':aayof_/\JDVl.xv\DeV _,20 at 55'- ,:,c, o'clocke( .M.
to testify on the part _
andlor NRS 50.195.
Dated this "-V _____ , 20_1
STATE OF ______ --.1)
)ss.
COUNTYOF _______
STEVE TUT':LE
CLERK OFf HE COURT

Deputy C1er
AFFJDA VIT OF SERVICE
J, received this Subpoena on the day ____ __ 20 ____ . and
personally served a copy oflhe same upon on the _ ... ___ day
of
___ of __ _____________ , 20 __ _
Notary Public
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TN THE JUSTICE COURT OF RENO TOWNSHIP
STATE OF NEVADA,
Plaintiff,
Dept. No.
VS.
24c-H-- SUBPOENA
TO RlIll 1U"lcs-ALM{5 It
You I com!':'jmded to appear befory thy Reno J.ustice Court at One South Sierra Street, Reno, Nevada
on the CJ_J_hl __ ,20 / /;=?ll) o'clock C\..M.
to testifY on the part of
andlor NRS 50.195.
Dated this
20 \ d- , .
. ---
STEVE TUTTLQ
CLERK OF THE COURT
By \.D. l \()'L" YV'\AA..,,-

Deputy Clelk
AFFIDA VIT OF SERVICE
STATE OF

)ss.
COUNTYOF _________ )
I, received this Subpoena on the ___ day of __ . ___________________ , 20 , and
personally a copy of the same upon _____ .. ________________ on the ____ day
of ____________ __
,20 __
____ day 0[ _________ , 20 __ -
Notary Public
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STATE OF NEVADA,
Case No. (2 CVI ?c--d-c) ()}.J {
Plaintiff,

Vs. SUBPOENA
DUCES TECUM
/"" f
_. ----,C,"=" ___ _
t='J L v J
J
You are commanded to deliver the above befoft:}-ij1e Reno JU$tice
,
at One
South SIerra Street, Reno, Nevada on or before the 1'1 " day of J 1,,-, f
at 6')0 \
may be deemed a contempt of court and subject you to the penalty set forth m l\Tf{s 22 100
and:or NRS 50.195.
"
DATED this __ =--j_' L- ' '_day of __ __ .
STEVE TUHLE
Clerk of the Court
STATE OF NEVADA, )
) SS.
County of Washoe )
I received this Subpoena on the ____ _ day of
____ and personally served a copy of the same upon _______ _
on this ______ dayof _______________ .
Subscribed and Sworn to before me .
this day of
NOTARY PUBLIC rev 04/2009 '
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STATE OF NEVADA,
Vs.
---7
.. __<,:A
0-
TO &_
Plaintiff,
Case No. {'-Z.I:-?Cil-CC.rsJ!
DepeNo ..
SUBPOENA
DUCES TECUM
. You are commanded to deliver the above mentioned bef9[e the. Ren<;i Justice Court at 9ne
South I ITa Street, Reno, on or before the I Lr l'i1'lry of Iii !- ,,->----. t .
-;::'" . , -- 'K ... ' o'clock c"--..M on the part of -Z:""J c;: C" - -- ...
Failure to deliver may be deelned a contempt of court and subject you to the penalty set forth in c RS 22.100
andlor NRS 50.195.
DATED this
STEVE TlJITLE
Citifk of the Court

Deputy Clerkj
STATE OF NEVADA, )
) SS.
County of Washoe )
I received this Subpoena on the ___ ---c ___ day of _____ _
____ and personally served a copy of the same upon _______ _
on this ______ day of ________________ .
this day of
NOTARY PUBLIC rev 0412009
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Plaintiff,
KeiZ 2v/-Vb?09!
STATE OF NEVADA,
Case No.
Dept. __
vs. 2zc h SUBPOENA
'D UC5
&--0,610 r I r
you JI,e co , anded to appear befPrc,lhc Reno Justice Court at One South Sierra Street, Reno, Nevada
onthe( /Y4-Vl day of I\JOV-flvvdO,lY o'ciocko ..... M.
to testify on'ifle part of
and/or NRS 50.195 .
. ; C 1"\
Dated this LX...j day of __ _____ ,
STEVE TUTTLE
CLERK OF THE COURT
By CAU0clx) (:..,..\Q LA 1'Yl.(i\.A ..
Deputy erk '
STATEOF _____ ,
COUNTY OF
.-J
)ss.
) ,

AFFIDA VlT OF SERVICE
I, received this Subpoena on the __ day of _________ , ___ 20 , and
personally served a copy of the same upon ____________ on the __ . ____ day
of ___
____ day of ________ 20 __
Notary Fublic
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EXHIBIT "4"
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Rob Bony
From:
Sent:
To:
Cc:
Subject:
Hi Rob,
Kelley Odom [OdomK@renogov]
Saturday, November 03,20128:53 PM
Rob Bony
Kariann Beechler
Fwd: FW: request for audio records
Here's one we got today.
Kelley Odom
Assistant Manager
Reno Emergency Communications
P.O. Box 1900
Reno, Nevada 89505
(775) 326-6610
Fax: 775-326-6698
Odomk@reno.gov
"Life isn't about how to survive the storm, but how to dance in the rain."
''The information transmitted in this e-mail and any attachments, including any audio/video files, is
intended only for the person(s) or entity to which it is addressed, in response to an official request
for information. This transmission may contain confidential and/or privileged material which is
protected by NRS 179(A) from further disclosure. It is intended for official use only. If you received
this message in error, please contact the sender and delete the material from the computer or any
transfer media."
-----Original Message-----
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: "EcommOps@reno.gov" <ecommops@reno.gov>, "odomk@reno.gov" <odomk@reno.gov>, "beechlerk@reno.gov"
<beechlerk@reno.gov>
Date: Sat, 3 Nov 2012 20:18:12 -0800
Subject: FW: request for audio records
Hi ECOMM,
RENO JUSTICE COURT CASE RCR20 11-063341 D2
THIS IS A SUBPOENA FOR
STATE OF NEVADA, PLAINTIFF
V.
ZACH COUGHLIN, DEFENDANT
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SUBPOENA AND SUBPOENA DUCES TECUM
ATTN: YOU MUST COMPLY IN ACCORD WITH JCRCP 45 AND OR NRCP
45
ATTN: CUSTODIAN OF RECORDS ECOMM, KELLY ODOM, CITY OF
RENO, RENO POLICE DEPARTMENT ETC.
Please just send me (preferably by email) any and all recordings or documentation
of any sort involving Zach Coughlin or Zach Cuoghlin, whether with a date of birth
of 9/27/76 or 9/1/76, or any other DOB, including for Zachary Coughlin or Zach
Caughlin or any iteration of those names, including dispatch recordings (not just
the 911 calls, by all recordings, including communications with the police officers
or other law enforcement personel), including those in any way related to incidents
or arrests on, but not limited to, the following:
August 20th, 20 II arrest at IOn. center 5t by RPD Duralde, involving Officer Rosa
and OFficer Alaksa as well with various 91l1rpd/dispatch calls including some
made by the following numbers
any call ever made from or to:
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
7752296737
or 775 338 8118
9496677402
also, my fOlmer Washoe County Public Defender Jim Leslie served Kelly adorn a subpoena for these matrials
on 10 3 12. I got Leslie removed and am now representign myself in RCR20 I 2-063341. Leslie says ECaMM
and aDaM failed to produce anything or respond in any way ... which I doubt...so please just include the
response to that subpoena in what you send me
i also want anything related to the following criminal cases:
in the Reno MUnic Court II cr 22176 (occuring at the w. 2nd sl. walmart on 9/9/1 I at around 9 pm, arrest by
RSIC,
2
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NOvember 13th, 2011 arrest In RMC II cr 26405 (arrest by reno pd at 121 RIver Rock St reno 89501 at
sometime around noon)
November 30th, 2011 arrest by reno marshals in II cr 22176
january 12th, 2012 arrest in rmc 12 cr 00696 (at 121 River Rock 8950 I as well, please include anythign related If"
to Richard G, HIll or Matt Merliss's calls to law enforcement, including anything on HHl's tpo in rcp2012- ,
000018)
january 13th pullover by rpd duralde el al of coughlin on near 252 mill st
january 14th, 2012 arrest in rcr20 12-065630
any of the 911 calls or dispatch recordings related to any incidentsor responses thereto by law enforcment in
any way connected to coughlin on or around the 1422 E. 9th St #2 address between december 1,2011 and the
present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
anything related to reno marshal rmc arrest in II tr 26800 on 2f271l2
anything on the I III 5/1 I incident resulting in II tr 26800 on st laurence involving the rpd, sargent tarter, 652
forrest sl. richard hill, etc.
rcr2012-067980 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and in fact
anything involving Zach Coughlin and any law enforcement figures at or around Northwinds Apartments at
1680 sky mountain drive and or Superior mini storage at
L Google+ page
THanks,
7795 White Fir Street Reno. NV 89523
(775) 746-4322
or at some west fourth street address or Superior MIni STorage, especially on or around september 22n,
2012 whether involving officer alan weaver or
sargent oliver miller or not, including calls for law enforcement response by matt grant (a woman) or k,
grant or marvin dye or anyone with superior mini storage
the july 3rd. 2012 arrest in nnc 12 cr 12420 AND ANYTHING AN EVERYTHING OTHER WISE
RELATED TO ZAGl COUGHLIN IN ANY WAY, DONT FORGET THE JAN 132012 STUFF
WITH SARGENT LOPEZ AND OFFICER WEAVER AND A VILA, ALL THE SARGENT SJFRE
STUFF,
ANYTHING IN CRI2-0376."ANDYTHING IN MH12-0032
I am subpoening all these materials incident to Judge Sferrazzas I Of221l2 ORder in RCR20 11-063341,
which he granted me the right
to issue these subpoenas upon you without paying up front the witness fees or other expenses (IFP)
3
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
Date: Fri, 23 Dec 201111:04:35 -0800
From: EcommOps@reno.gov
To: zachcoughlin@hotmail.com
Subject: request for audio records
Mr. Coughlin,
Your request for audio records has been received. However, I do not have sufficient information to process it.
Can you tell me the date and time this occurred, along with the location so I will be able to locate the call.
Thanks,
Ella Mae
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,
Rob Bony
From:
Sent:
To:
Kelley Odom [OdomK@reno.gov]
Saturday, November 03,20129:51 PM
Rob Bony
Cc: Kariann Beechler
Subject: Fwd: FW: request for audio records
And another one ...... he's named Reno Direct on this one.
Kelley Odom
Assistant Manager
Reno Emergency Communications
P.O. Box 1900
Reno, Nevada 89505
(775) 326-6610
Fax: 775-326-6698
Odomk@reno.gov
"Life isn't about how to survive the storm, but how to dance in the rain."
"The information transmitted in this e-mail andanyattachments.includinganyaudio/videofiles.is
intended only for the person(s) or entity to which it is addressed, in response to an official request
for information. This transmission may contain confidential and/or privileged material which is
protected by NRS 179(A) from further disclosure. It is intended for official use only. If you received
this message in error, please contact the sender and delete the material from the computer or any
transfer media."
-----Origina! Message-----
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: "ecomrnops@reno.gov" <ecommops@reno.gov>, "odomk@reno.gov" <odomk@reno.gov>, "beechlerk@reno.gov"
<beechlerk@reno.gov>, "ZYOUNG@DA.WASHOECOUNTY.US" <zyoung@da.washoecounty.us>, "kadlicj@reno.gov"
<kadlicj@reno.gov>, "WONGD@RENO.GOV" <wongd@reno.gov>, "Istuchell@washoecounty.us" <Istuchell@washoecounty.us>,
"renodirect@reno.gov" <renodirect@reno.gov>
Date: Sat, 3 Nov 2012 21 :30:08 -0800
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
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Zach has 2 files to share with you on SkyDrive. To view them, click the links below.
121 S' rmc subpoena 063341 TO ECOMM ODOM AND OTHERS.pdf
121 i 0204 ECOMM SUBPOENA. pdf
Download all
From: zachcoughlin@hotmaiLcom
To: ecommops@reno.gov; odomk@reno.gov; beechlerk@reno.gov
Date: Sat, 3 Nov 2012 20:18:12 -0800
Hi ECOMM,
RENO JUSTICE COURT CASE RCR2011063341 02
THIS IS A SUBPOENA FOR
STATE OF NEVADA, PLAINTIFF
V.
ZACH COUGHLIN, DEFENDANT
AnN: YOU MUST COMPLY IN ACCORD WITH JCRCP 45 AND OR NRCP 45
AnN: CUSTODIAN OF RECORDS ECOMM, KELLY ODOM, CITY OF RENO, RENO
POLICE DEPARTMENT ETC.
Please just send me (preferably by email) any and all recordings or documentation
of any sort involving Zach Coughlin or Zach Cuoghlin, whether with a date of birth
of9/27176 or 9/1176, or any other DOB, including for Zachary Coughlin or Zach
Caughlin or any iteration of those names, including dispatch recordings (not just the
911 calls, by all recordings, including communications with the police officers or
other law enforcement personel), including those in any way related to incidents or
arrests on, but not limited to, the following:
August 20th, 2011 arrest at IOn. center st by RPD Duralde, involving Officer Rosa
2
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II
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and OFficer Alaksa as well with various 91llrpd/dispatch calls including some
made by the following numbers
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
7752296737
or 7753388118
< font color="#OOOOoO">949 667 7402
also, my fOlmer Washoe County Public Defender Jim Leslie served Kelly Odom a subpoena for these matrials
on 103 12. I got Leslie removed and am now representign myself in RCR2012-063341. Leslie says ECOMM
and ODOM failed to produce anything or respond in any way ... which I doubt. .. so please just include the
response to that subpoena in what you send me
in the Reno MUnic Court II cr 22176 (oecuring at the w. 2nd sl. walmart on 9/9111 at around 9 pm, arrest by
RSIC,
NOvember 13th, 20 II arrest in RMC II cr 26405 (aITest by reno pd 'It 121 River Rock St. reno 8950 I at
sometime around noon)
November 30th, 2011 arrest by reno marshals in I I cr 22176
january 12th, 2012 arrest in rmc 12 cr 00696 (at 121 River Rock 8950 I as well, please include anythign related
to Richard G. HIli or Matt Merliss's calls to law enforcement, including anything on Hili's tpo in rcp2012-
000018)
january 13th pullover by rpd duralde el al of coughlin on near 252 mill sl.
january 14th, 2012 arrest in rcr2012-065630
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law enforcment in
any way connected to coughlin on or around the 1422 E. 9th SI. #2 address between december I, 20 II and the
present, including any calls by Christopher "Erin" ervin Allaback or Laure Foreshee or Laura Petrone
anything related to reno marshal rmc an-est in II tr 26800 on 2/27112
anything on the 11115111 incident resulting in II tr 26800 on st laurence involving the rpd, sargent tarter, 652
forrest s1. richard hill, etc_
rcr2012-067980 (anything on the june 26th, 2012 aITest by wcso deputy machen and bowman, and in fact
anything involving Zach Coughlin and any law enforcement figures at or around Northwinds Apartments at
1680 sky mountain drive and or Superior mini storage at
1. Google+ page
3
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THanks,
(
7795 White Fir Street Reno, NV 89523
(775) 746-4322
or at some west fourth street address or Superior MIni STorage, especially on or around september 22n
2012 whether involving officer alan weaver or
sargent oliver miller or not, including calls for law enforcement response by matt grant (a woman) or k
grant or marvin dye or anyone with superior mini storage
the july 3rd, 2012 arrest in mlC 12 cr 12420 AND ANYTHING AN EVERYTHING OTHER WISE
RELATED TO ZACI-I COUGHLIN IN ANY WAY, DONT FORGET THE JAN 132012 STUFF
WITH SARGENT LOPEZ AND OFFICER WEAVER AND AVILA, ALL THE SARGENT SIFRE
STUFF,
ANYTHING IN CRI2-0376.ANDYTHING IN MH12-0032
I am subpoening all these materials incident to Judge Sferrazzas 10/22112 ORder in RCR20 11-063341,
which he granted me the right
to issue these subpoenas upon you without paying up front the witness fees or other expenses (lFP)
Zach Coughlin
1471 E. 9th St-
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmaiLcom
Date: Fri, 23 Dec 201111:04:35 -0800
From: EcommOps@reno.gov
To: zachcoughlin@hotmaiLcom
Subject: request for audio records
Mr. Coughlin,
Your request for audio records has been received. However, I do not have sufficient information to process it.
Can you tell me the date and time this occurred, along with the location so I will be able to locate the call.
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Thanks,
Ella Mae
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EXHIBIT "5"
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No, RCR J J -()63J4 J
Dcp! No 2
SUBPOENA DUCES TECUi>1
IN HIE JUSTICE COURT OF RENO TOWNSHIP
THE STATE OF "11' VADA, Plainriff,
f) '
r""- v 5 1 A VC' J &&'ZL vC-P 5'1 jffjt; ,o("J "IL fj ffi",} iJ'4- [J '(0-"'" I/iF<.(j--ff-
I FROVf ZACH COVGHLIN, ESQ. IAttornevtempb'ri>ri1tfI' u ended'in Nevada self ,
PURSUANT TO NRS 174315 WE COMMAND YOU TO APPEAR BEFORE ;Z ,
, . !Ie; f-l'\ Ij5 rCLv-J .
DeparilTICllf " 5 f .
Reno JUsUce Court .
One South SitTr:l Strel2L Reno. Nevada
On NOVEMBER 19TH. 2012 to [cstity for the above-named Oc.ie-ndant
AT 8:30 AM IN 02, BEFORE HONORABLE JUDGE SFERRAZZA
ANY PERSON "AILI.NG TO APPEAR \-1/\ Y BE HELD IN CONTEMPT OF COURT
,,\CCURDING TU NRS 22100 THE PEN,'ILTY FOR CONTEMPT Of COUR'r IS A
fiNE L'P TO $'IIO,\ND/OR 25 DA YS !;VfPIUSONjyfENT.
Daled 11/6/12
Zach Coughlin, Esq_
1471 e sL
reno, 89512
Bv Zach Cough] in
1471 E. 9th St_
Reno, NY 89512
(suspended attorney)
If you have any qUestiOIlS l
regarding 'your appeamncc, please ,
COntact: Zach Coughlin at
949 667 7402
tel and Eax- 949 667 y402 ZachCoughlin@hotmail.com
) SS_
11/6/12
Sigmullf . of Attorney attorney) Date --------
SUBPOENA DUCES TECUM; ITEMS TO BE PRODUCED: Copy of any and all cell
phone fcCorJS (incoming and (lwgoing cajjs), texI messages {()[ cell number (775)527-
9440 lor ti,e J<1tes (> f 8120/20 1 I and 8/21120 I I.
you may have to appear if you provide these materials to a repre:,entutivc <.J::UWx
or to Zach Coughlin on or November 17th, 2012
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CASE NUMBER: ng12-0204 ng-0435 ng-0434
STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,
PETITION
V.
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
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)
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ng12-0204 ng-0435 ng-0434 motion to
biIurcate 10 15 12
YOU ARE COMMANDED to appear before the State Bar of Nevada and Northern Nevada
DiscipIinary Board at the State Bar of Nevada's Northern Office, 9456 DoubIe R BouIevard
Reno, NV 89521, State of Nevada, Washoe County, on the date of November 14th, 2012, at 9
am to testify on the part of Zachar Barker CoughIin. FaiIure by any person without adequate
excuse to obey a subpoena served upon that person may be deemed a contempt of the court
from which the subpoena issued. [Nevada RuIes of CiviI Procedure, RuIe 45(e)]
PLEASE NOTE THAT THIS MAY NOT BE A LAWFUL COMMAND, AND THEREFORE YOU MAY
OR MAY NOT BE ENTITLED TO IGNORE. I AM NOT PROVIDING YOU LEGAL ADVICE. IT
MAY BE TOO LATE TOO LATE FOR THIS SUBPOENA TO BE SERVED ON YOU IN A TIMELY
MANNER REQUIRING YOUR COMPLIANCE WITH IT...FURTHER, WHILE BAR CONSEL HAS
MADE INDICATION THAT DESPITE COUGHLIN BEING SUSPENDED HE MAY "ISSUE"
SUBPOENAS, AND THE SBN MAY HAVE FURTHER INDICATED COUGHLIN WOULD NOT
NEED TO PAY WITNESS FEES AT ALL, OR AT LEAST UP FRONT, THE EXIGENCIES OF
HAVING BOTH THE NOVEMBER 14T, 2012 scr 105 HEARING WITH THE sbn (EVEN WHERE
THE NOTICE AND DUE PROCESS PROVISIONS AND TIME PERIODS OF SCR 105 ETC ARE
ARGUABLY NOT BEING FOLLOWED) AND THE PETTY LARCENY TRIAL ON NOVEMBER
19TH, 2012 IN RCR2011-063341 HAVE MADE IT DIFFICULT TO ASCERTAIN THE EXACT
REQUIREMENTS ATTENDANT TO A DOCUMENT SUCH AS THIS. AS SUCH, PLEASE
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CONSULT YOUR OWN ATTORNEY REGARDING WHETHER OR NOT THIS DOCUMENT
CARRIES AND WEIGHT OR LAWFUL COMMAND OR DISPLAY OF AUTHORITY
To: Alison M. Ormaas, Pam Roberts, Christopher Hazlett-Stevens, Brian Sooudi Company: Reno
City Attorney Address: One East First Street, 3rd Floor P.O. Box 1900 Reno , NV 89505 Phone
Number: ~-- Fax number: 775-334-4226 Email: ormaasa@reno.gov, hazlett-stevensc@reno.gov,
robertsp@reno.gov, sooudib@reno.gov
Joel Harley, and Scott Coppa and Townsend, and Marshal Court Marshal RMC; custodian of
records city of reno Marshals Division, and Chief Justin Roper
roperj@reno.gov
renomarshal@reno.gov
harleyj@reno.gov
1 South Sierra Street Reno, NV 89502 (775) 326-5125
Chief Marshal Justin Roper (334.1254, Fax 334.1260, roperj@reno.gov).
Pam Longoni, RMC exculsive transcriptionist demanding down payment from criminal defendant
appelants in violation of nevada law, Donna Ballard
plongoni@charter.net c/o Reno Muncipal Court
1 South Sierra Street Reno, NV 89502 fax 775 334 3824 ballardd@reno.gov
Reno mUnicipal Court custodian of records, and Marilyn Tognoni, and the "clerk of court for
Department 3" referenced in SBN's Pat King's corrspondence to Coughlin alleging some reports of
the clothing Coughlin wore to the filing office counter at the RMc in March 2012, and any submission
by the Reno Marshals, Lisa Wagner, Administrative Judge William Gardner
1 South Sierra Street Reno, NV 89502 (775) 326-5125, renomunicrecords@reno.gov,
christensend@reno.gov, fax: 775 334 2420; 775 334 3824
Northwinds Apartments Associate LLC
Manage Duane Jakob, lOU cADA mLAN kREBS
1680 Sky Mountain Dr
Reno NV 89523
fax: 775 747 9202
NEvada Courts Services
Nevada Court Services
475 So. Arlington Suite 1A
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
Email: nevcs@nevcs.com
JOel Durden, R. Wray, Jeff Chandler, Jennifer Chandler, Cedonio, and Nevada Court SErvices
Custodian of REcords and "Staff Attorney" Jeff Chandler
Richard G. Hll, Esq. and Custodian of Records for Law Office of Richard G. Hll, Esq.
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Richard G. Hill Company: ~ Address: 652 Forest St. ~ Reno , NV 89509 Phone Number: 775-348-
0888 Fax number: 775-348-0858 Email: rhill@richardhillaw.com
Casey D. Baker Custodian of Records for Baker & Baker Law Offices, PLLC Address: 432 W. Main
St., 2nd Flr. P.O. Box 25 Danville , KY 40423 Phone Number: 859-238-2233 Fax number: 859-439-
0028 Email: cbaker@centralkylegal.com Website:
WCSO Custodian of Records and Liz Stuchell, and Roxy Silva, and Deputy John Machen, Patricia
Beckman, Debi Cummings, Jason Hodge, Deputy Beatson, Madeline C. JOnes, Deputy Van Der
Wall, Nurse Katherine, Deputy Michael R. Hoekstra, WCDC Medical/Nursing Staff Custodian of
Records
Washoe County Sheriff's Office Location:911 Parr Blvd., Reno, NV 89512Main Phone:775-328-
3001Email:sheriffweb@washoecounty.us
fax 775 3286308
Roberto Puentes Company: ~ Address: 416 Ridge St. ~ Reno , NV 89501 Phone Number: 775-786-
7676 Fax number: 775-786-8720 Email: PUENTESLAW@AOL.COM
Keith Lloyd Loomis Company: ~ Address: 9468 Double R Blvd. Suite A Reno , NV 89521 Phone
Number: 775-853-7222 Fax number: 775-853-0860 Email: '
bdogan@washoecounty.us
Biray Dogan, Jim Leslie,and Joe Goodnight, and Evo Novak
Company: Washoe County Public Defender's Office Address: P.O. Box 30083 ~ Reno , NV 89509
Phone Number: 775-337-4868 Fax number: 775-337-4856 Email:jleslie@washoecounty.us,
BDOGAN@WASHOECOUNTY.US, JGOODNGHT@WASHOECOUNTY.US
Mary Margaret Kandaras Company: Washoe County District Attorney Address: One S. Sierra St.
P.O. Box 30083 Reno , NV 89520 Phone Number: 775-337-5700 Fax number: 775-337-5732 Email:
mkandaras@da.washoecounty.us
cTY OF RENO/RENO POLCE DEPARTMENT:
Deputy Chief Mike Whan (334.3849, Fax 334.3890, whanm@reno.gov ) Lieutenant Keith Brown
(334-3845, Fax 334-3890, brownk@reno.gov, rOBERT bONY BONYR@RENO.GOV
PLEASE PROVDE THE VDEO FOOTAGE OF THE EVENTS LEADNG UP TO AND THE
ARREST THAT STARTED ALL THS ON AUGUST 20TH, 2011, FROM BETWEEN
APPROXMATELY 11:10 PM TO 12:30 AM ON aUGUST 21ST, 2011...A LTGATON HOLD
NOTCE OF SORTS WAS CERTANLY PROVDED, AT LEAST TO THE RPD, AND ARGUABLY
TO THE CTY OF RENO AND CTY ATTORNEY'S OFFCE AND THE SGN N THE SKATE PLACE
AT 10 N. CENTER ST NDCATES THE RPD S VDEO MONTORNG WTH "DOWNTOWN
PROPERTES" AND THER CLEARLY ARE VDEO CAMERAS PLACE ATOP CTY HALL, WHCH
OVERLOOKS THE SCENE OF THE ARREST, ALL OF THS SHOULD HAVE BEEN
PROPOUNDED ALREADY in rcr2011-063341
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Zachary N. Young Company: Washoe County DA Office Address: 1 South Sierra P.O. Box 30083
Reno , NV 89520 Phone Number: 775-328-3200 Fax number: 775-325-6703 Email:
Zyoung@da.washoecounty.us
please be ready to testify regarding you participation in the clandestine status conference o 2/27/12
and the 1:31pm file stamped ORder for Competency Evaluation in RCR2012-065630,any
communications with or to anyone with regard thereto, your alleged multiple violations of nrs 178.405
Patrick O. King Company: State Bar of Nevada Address: 9456 Double R Blvd. Suite B Reno , NV
89521 Phone Number: 775-329-4100 Fax number: 775-329-0522
please produce any materials related to Zachary Barker Couglin in any way, shape or form, and be
present and ready to testify fully regarding the RMC Marshal peering through Coughlin's bathroom
stall (not exactly in the "immediate presence of the court", now is it, sufficient for a "summary
criminal contempt" conviction....cited on the record by Judge Nash Holmes on 3/12/12 in 11 tr 26800
by the Marshal and the violations of the courthouse sanctuary doctrine by Marshal Harley on behalf
of Deputy Machen, on behalf of Richard Hll to serve in front of ORmaas the ORder to Show Cause
in the appeal of the richard g. hill eviction matter in cv11-03628, as well as any and all information or
documentation related to the "receipt" by the wcso of any and all Orders of any sort (or any
correspondence whatsoever) in connection with RJC rev2011-001708, rcj rev2012-001048, rcr2012-
067980 and any other materials related to Coughlin and Northwinds Apartments Associates and or
Superior Mni STorage and all materials detailing the practices and policies of the wCSO with
respect to maintaining documentation or transferring documentation concerning or providing proof of
when the wcso FRST received or came to have "receipt" of any sort of Orders related to an eviction
vis a vis nrs 40.253 or otherwise, including the name of the locksmiths doing any and all lockouts of
coughlin, and media gathered by the wcso, anything related to the booking into evidence of the
materials retrieved by the RMC's Marshals after the period in which those Marshals could have
lawfully conducted an search incident to arrest, and therefore violative of the fourth amendment
where no warrant or other basis for so retrieving such materials has been admitted to.
Speciality Courts Administrator Shiela Leslie, Mental Health Court for SEcond Judicial District Court
Custodian of Records fax 775 325-6617.
Rene Biondo 775 325-6605 and sabel Meadows 775 325-6650
75 Court Street
Reno, NV 89501
(775)328-3110
shiela.leslie@washoecourts.us, rene.biondo@washoecourts.us, isabel.meadows@washoecourts.us,
joey.hastings@washoecourts.us
See you at the hearing, court from which the subpoena issued. [Nevada Justice Court Rules of Civil
Procedure, Rule 45(e)]
Dated this November 3rd 2012:
__________________________
Zachary Barker Coughlin, Esq. (Nevada law license temporarily suspended, USPTO license in tact,
and given permission to issue subpoenas by SBN Chief Bar Counsel David Clark, Esq.)
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NEVADA RULES OF CIVIL PROCEDURE, RULE 45(c) AND 45(d)
(c) PROTECTION OF PERSONS SUBJECT TO SUBPOENA.
(1) A party or an attorney responsible Ior the issuance and service oI a subpoena shall take reasonable steps to avoid
imposing undue burden or expense on a person subject to that subpoena. The court on behalI oI which the subpoena was
issued shall enIorce this duty and impose upon the party or attorney in breach oI this duty an appropriate sanction, which
may include, but is not limited to, lost earnings and a reasonable attorney's Iee.
(2)(A) A person commanded to produce and permit inspection and copying oI designated books, papers, documents or
tangible things, or inspection oI premises need not appear in person at the place oI production or inspection unless
commanded to appear Ior deposition, hearing or trial.
(B) Subject to paragraph (d)(2) oI this rule, a person commanded to produce and permit inspection and copying may,
within 14 days aIter service oI the subpoena or beIore the time speciIied Ior compliance iI such time is less than 14 days
aIter service, serve upon the party or attorney designated in the subpoena written objection to inspection or copying oI any
or all oI the designated materials or oI the premises. II objection is made, the party serving the subpoena shall not be
entitled to inspect and copy the materials or inspect the premises except pursuant to an order oI the court by which the
subpoena was issued. II objection has been made, the party serving the subpoena may, upon notice to the person
commanded to produce, move at any time Ior an order to compel the production. Such an order to compel production shall
protect any person who is not a party or an oIIicer oI a party Irom signiIicant expense resulting Irom the inspection and
copying commanded.
(3)(A) On timely motion, the court by which a subpoena was issued shall quash or modiIy the subpoena iI it
(i) Iails to allow reasonable time Ior compliance;
(ii) requires a person who is not a party or an oIIicer oI a party to travel to a place more than 100 miles Irom the place
where that person resides, is employed or regularly transacts business in person, except that such a person may in order to
attend trial be commanded to travel Irom any such place within the state in which the trial is held, or
(iii) requires disclosure oI privileged or other protected matter and no exception or waiver applies, or
(iv) subjects a person to undue burden.
(B) II a subpoena
(i) requires disclosure oI a trade secret or other conIidential research, development, or commercial inIormation, or
(ii) requires disclosure oI an unretained expert's opinion or inIormation not describing speciIic events or occurrences in
dispute and resulting Irom the expert's study made not at the request oI any party, the court may, to protect a person
subject to or aIIected by the subpoena, quash or modiIy the subpoena or, iI the party in whose behalI the subpoena is
issued shows a substantial need Ior the testimony or material that cannot be otherwise met without undue hardship and
assures that the person to whom the subpoena is addressed will be reasonably compensated, the court may order
appearance or production only upon speciIied conditions.
(d) DUTIES IN RESPONDING TO SUBPOENA.(1) A person responding to a subpoena to produce documents shall
produce them as they are kept in the usual course oI business or shall organize and label them to correspond with the
categories in the demand. (2) When inIormation subject to a subpoena is withheld on a claim that it is privileged or subject
to protection as trial preparation materials, the claim shall be made expressly and shall be supported by a description oI
the nature oI the documents, communications, or things not produced that is suIIicient to enable the demanding party to
contest the claim.
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STATE BAR OF NEVADA
PETITION
V.
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
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biIurcate 10 15 12
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roperj@reno.gov
harleyj@reno.gov
Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
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Records
fax 775 3286308
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75 Court Street
Reno, NV 89501
(775)328-3110
__________________________
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copying commanded.
(B) II a subpoena
contest the claim.
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STATE BAR OF NEVADA
PETITION
V.
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
.
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)
biIurcate 10 15 12
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roperj@reno.gov
harleyj@reno.gov
Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
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Records
fax 775 3286308
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75 Court Street
Reno, NV 89501
(775)328-3110
__________________________
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copying commanded.
(B) II a subpoena
contest the claim.
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STATE BAR OF NEVADA
PETITION
V.
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
.
)
)
)
)
)
)
biIurcate 10 15 12
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roperj@reno.gov
harleyj@reno.gov
Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
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copying commanded.
(B) II a subpoena
contest the claim.
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STATE BAR OF NEVADA
PETITION
V.
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
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biIurcate 10 15 12
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roperj@reno.gov
harleyj@reno.gov
Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
- 2/6 -
No. RCR 11-063341
Dept. No.2
(
SCBPOENA OtJCESmCuM
IN THE JUSTICE COURT OF RENO TOWNSH!P
COUNTY Of WASHOE, STATE OF NEVADA
THE STATE OF NEVADA, Plaintiff,
vs.
ZACHARY BARKER COUGHLIN. Dekndant.
TO PD YV/rckr urq I
FRo.:v!: ZACH COUGHLIN, ESQ. (Attorney temporarily suspended in Nevada sel,f represented)
PURSUANT TO NRS 174.315 WE COMMAND YOU TO \PPEAR BEFORE
Depanment "2
Reno Justice Court
One Soul11 Sierra Street, Reno. Ncvilda
On NOVEMBER 19TH, 2012 to [('stifY for the DC.Jt'llda!l!
AT 8: 30 AM IN D2, BEFORE HONORABLE JUDGE SFERR.':\ZZA
/\\,Y PEIZSO", FAlLING TO APPEAR rv/,\ Y B[ HU,f) IN CON rr'i\Wr OF COURT
ACCORLlfNG TO NRS niOO THE PEN .. \LTY fOR COCilE,,/I'1 OF COURT IS A
FINE UP TO $500 AND/OR 25 DA YS IMPRlSON,\.IENT
Daled: 11/6/12
Zach Coughlin, Esq.
1471 e. 9th st.
reno, 89512
By Zach Coughlin
1471 E. 9th st-
Reno, NV 89512
(suspended au_orney) If you have any questions
regarding your please
conl,lC{: Zach Coughl in at
949 667 7402
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tel and fax: 949 667 ?402
) 55.
COUNTY OF IV ;\SflO[ )
ZachCoughlin@hotmail ,com S--f!V V I c'0
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I hC'CbY:::f6' rhat 111'" __ , JI the loc,,"on 01 _
__ ill II \lIe v, IJ!vvEl t (lj\ ddl\ el lng il LOP) 1..)[ till": Subpoena to
0': by comp1Ylng ''lth the lD NRS 174.345
Subpoel'" or malllDg It Dt
V
I /
11/6/12
Signatur .of Attorney attorney} Date:
._---- \
SUBPOENA DUCES TECUM: ITEMS TO BE PRODUCED: Copy of any and all cell
phone records (incoming and outgoing call;.;), texll11e-ssages-fo[ ('eU number (775)527-
9440 lor ihe dates of 8/20/20 II and 8
1
21/20 II,
you may have to 3ppeaf if you provide I.hese mareriwf) tQ J oii:Wx
or to Zach Coughlin Onor November 17th, 2012
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zach coughlin
1471 e. 9th st
reno, nv 89501
ZachCoughlinhotmail.com (please email materials iI possible, doing so may result in agreement
that your attendance on November 19th, 2012 at 830am will not be required.
tel and Iax:949 667 7402
RENO 1USTICE COURT
STATE OF NEVADA COUNTY OF WASHOE
STATE OF NEVADA
PLAINTIFF
V.
ZACH COUGHLIN,
DEFENDANT
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rcr2011-063341
Department 2
SUBPOENA AND SUBPOENA DUCES TECUM and Notice of Witnesses and REquest for
Reciprocal Discovery and NOtice of Witness defense intends to call at resumption of
Trial;Notice of Availability of Discovery and identification of new witness in compliance with
any continuing duty to so identify NRS 174.245 Disclosure by defendant of evidence relating to
defense; limitations. 174.295 Continuing duty to disclose; failure to comply; sanctions
request for NRS 174.235 Disclosure by prosecuting attorney of evidence relating to
prosecution.
To:YOU ARE COMMANDED to appear before the the HonorabIe Judge Peter J. Sferrazza at
the Reno Justice Court in Department 2 at 1 S. Sierra St. Reno, NV 89502 on November 19th,
2012 at 8:30 am to testify on the part of Zachary Barker CoughIin. FaiIure by any person
without adequate excuse to obey a subpoena served upon that person may be deemed a
contempt of the Court.
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NRS 174.315 ssuance of subpoena by prosecuting attorney or attorney for defendant; promise to
appear;
Anyone wishing to issue Zach CoughIin a promise to appear, pIease emaiI it to him at:
zachcoughIin@hotmaiI.com or fax to 949 667 7402
NRS 174.345 Service of subpoena.
2. Except as otherwise provided in NRS 174.315, a subpoena to attend a misdemeanor
triaI may be served by maiIing the subpoena to the person to be served by registered or
certified maiI, return receipt requested from that person, in a seaIed postpaid enveIope,
addressed to the person's Iast known address, not Iess than 10 days before the triaI which
the subpoena commands the person to attend.
3. f a subpoena is served by mail, a certificate of the mailing must be filed with the court within 2
days after the subpoena is mailed
roperj@reno.gov
harleyj@reno.gov
by the Reno Marshals, Lisa Wagner, Administrative Judge William Gardner, Judge Dorothy Nash
Holmes, Judge Kenneth Howard, Cassandra Jackson, Lisa Wagner, Veronica Lopez
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Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
JOel Durden, Ryan Wray, Jeff Chandler, Jennifer Chandler, Cedonio, and Nevada Court SErvices
Custodian of REcords and "Staff Attorney" Lewis Taitel, Esq.
Records
jmachen@washoecounty.us, lstuchell@washoecounty.us, rsilva@washoecounty.us
Washoe County Sheriff's Office Location:911 Parr Blvd., Reno, NV 89512Main Phone:775-328-3001
Email:sheriffweb@washoecounty.us
fax 775 3286308
911 Parr Blvd Reno, NV 89512 Forensic Science Division at (775) 328-2830. The fax number is:
(775) 328-2831.
and please do be sure to give me your views on proper service, there, WCSO Civil Division...
Number: 775-853-7222 Fax number: 775-853-0860 Email: keithloomis@earthlink.net
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775-334-2121 Police Department: 455 E. Second Street, Reno, NV 89502 Directions Email:
askrpd@reno.gov
Officer Nicholas Duralde duralden@reno.gov
Ron Rosa rosar@reno.gov
Thomas Alaksa alaksat@reno.gov
Sargent Marcia Lopea lopezm@reno.gov
officer travis warren warrent@reno.gov
officer chris carter carterc@reno.gov
sargent paul sifre sifrep@reno.gov
officer jason schaur schaurj@reno.gov
officer alan hollingsworth hollingswortha@reno.gov
officer travis look lookt@reno.gov
officer wesley leedy leedyw@reno.gov
officer alan weaver weavera@reno.gov
rpd sargent brian dye dyeb@reno.gov
sargent oliver miller millero@reno.gov
lietn keith brown brownk@reno.gov
sargent kim bradshaw bradshawk@reno.gov
PLEASE BE SURE TO NCLUDE ALL ECOMM DSPATCH RECORDNGS (NCLUDNG
THE CONTENTS OF COMMUNCATONS BETWEEN DSPATCH AND THE OFFCERS. PLEASE
NCLUDE THE VDEO OF THE SKATE PLAZE AT 10 N. CENTER ST. ADN NEAR FRST AND
VRGNA, NCLUDNG THE CAMERAS ATOP CTY HALL, CONSDERNG THE SGN N THE
SKATE PLAZA THAT NDCATES THE RPD S VDEO RECORDNG THE AREA, AND THE
LTGATON HOLD NOTCE THE CTY OF RENO AND RPD WERE PLACED ON SHORTLY
AFTER THE ARREST OF AUGUST 20TH, 2011 N RCR2011-063341. SHOULDN'T BE TOO
HARD TO SHOW WHETHER OR NOT THOSE SKATERBOARDS WERE TELLNG THE TRUTH.
SURE MAKES A LOT OF SENSE TO BET ON THE 18 YEAR OLD SKATEBOARDERS VERACTY
VERSUS THE 35 YEAR OLD ATTORNEY'S THOUGH....No reasons at all to take a more cautious
approach than was taken, probably....
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please produce any materials related to Zachary Barker Coughlin in any way, shape or form, and be
75 Court Street
Reno, NV 89501
(775)328-3110
Ella Mae Carthen, Kelley Odom, Kariann Beechler, ECOMM
Operations
COR Emergency Communications
Supervisor line (775) 334-2399
Office line (775) 326-6613
carthene@reno.gov, odomk@reno.gov, beechlerk@reno.gov
ecommops@reno.gov
ECOMM CUSTODAN OF RECORDS AND KELLY ODOM AND KARANN BEECHLER AND RENO
DRECT AND CTY OF RENO, WASHOE COUNTY SHERFF'S OFFCE, WASHOE COUNTY
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DSTRCT ATTORNEY'S OFFCE, RENO MUNCPAL COURT, CTY OF RENO, RENO DRECT,
SECOND JUDCAL DSTRCT COURT, RENO JUSTCE COURT, CUSTODANS OF RECORD.
YOU ARE COMMANDED to appear before the the Honorable Peter J. Sferrazza in Department 2 of
the RJC on November 19th, 2012 at 8:30 am to testify on the part of Zachary Barker Coughlin.
Failure by any person without adequate excuse to obey a subpoena served upon that person may be
deemed a contempt of the court from which the subpoena issued. [Nevada Rules of Civil Procedure,
Rule 45(e)] , please be sure the materials you provide included, but are not limited to:
Please just send me (preferably by email) any and all recordings or documentation of any sort
involving Zach Coughlin or Zach Cuoghlin, whether with a date of birth of 9/27/76 or 9/1/76, or any
other DOB, including for Zachary Coughlin or Zach Caughlin or any iteration of those names,
including dispatch recordings (not just the 911 calls, by all recordings, including communications with
the police officers or other law enforcement personel), including those in any way related to incidents
August 20th, 2011 arrest at 10 n. center st by RPD Duralde, involving Officer Rosa and OFficer
Alaksa as well with various 911/rpd/dispatch calls including some made by the following numbers
7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
also, my former Washoe County Public Defender Jim Leslie served Kelly Odom a subpoena for
these matrials on 10 3 12. got Leslie removed and am now representign myself in RCR2012-
063341. Leslie says ECOMM and ODOM failed to produce anything or respond in any way...which
doubt...so please just include the response to that subpoena in what you send me
rcr2011-063341 (petty larceny arrest near 10 n. center st on August 20th, 2011 by rpd officer nick
duralde (your dispatcher JEssica Durald'es husband) with assistance by rpd thomas alaksa and ron
rosa (please include anything about th 1994 lawsuit agains rosa as an officer in second judicial
district court)
in the Reno MUnic Court 11 cr 22176 (occuring at the w. 2nd st. walmart on 9/9/11 at around 9 pm,
arrest by RSC,
NOvember 13th, 2011 arrest in RMC 11 cr 26405 (arrest by reno pd at 121 River Rock St. reno
89501 at sometime around noon)
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November 30th, 2011 arrest by reno marshals in 11 cr 22176
january 12th, 2012 arrest in rmc 12 cr 00696 (at 121 River Rock 89501 as well, please include
anythign related to Richard G. Hll or Matt Merliss's calls to law enforcement, including anything on
Hll's tpo in rcp2012-000018)
january 13th pullover by rpd duralde el al of coughlin on near 252 mill st.
any of the 911 calls or dispatch recordings related to any incidents or responses thereto by law
enforcment in any way connected to coughlin on or around the 1422 E. 9th St. #2 address between
december 1, 2011 and the present, including any calls by Christopher "Erin" ervin Allaback or Laure
Foreshee or Laura Petrone
anythign related to cr12-0376 remanding to custody on April 19th and including anything related to
incarceration at wcdc between 4/19/12 and 4/29/12
anything related to reno marshal rmc arrest in 11 tr 26800 on 2/27/12
anything on the 11/15/11 incident resulting in 11 tr 26800 on st laurence involving the rpd, sargent
tarter, 652 forrest st. richard hill, etc.
rcr2012-067980 (anything on the june 26th, 2012 arrest by wcso deputy machen and bowman, and
in fact anything involving Zach Coughlin and any law enforcement figures at or around Northwinds
Apartments at 1680 sky mountain drive and or Superior mini storage at
Google+ page
(775) 746-4322
or at some west fourth street address or Superior Mni STorage, especially on or around september
22nd 2012 whether involving officer alan weaver or
sargent oliver miller or not, including calls for law enforcement response by matt grant (a woman) or
ken grant or marvin dye or anyone with superior mini storage
the july 3rd, 2012 arrest in rmc 12 cr 12420 AND ANYTHNG AN EVERYTHNG OTHERWSE
RELATED TO ZACH COUGHLN N ANY WAY, DONT FORGET THE JAN 13 2012 STUFF
WTH SARGENT LOPEZ AND OFFCER WEAVER AND AVLA, ALL THE SARGENT SFRE
STUFF,
ANYTHNG N CR12-0376...ANYTHNG N MH12-0032
am subpoening all these materials incident to Judge Sferrazzas 10/22/12 ORder in RCR2011-
063341, in which he granted me the right
to issue these subpoenas upon you without paying up front the witness fees or other expenses (FP)
Dated this 5th day of November, 2012:
__________________________
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NRS 174.345 Service oI subpoena. 1. Except as otherwise provided in NRS
174.315 and subsection 2, a subpoena may be served by a peace oIIicer or by any other person who is
not a party and who is not less than 18 years oI age. Except as otherwise provided in NRS 289.027,
service oI a subpoena must be made by delivering a copy thereoI to the person named. 2. Except as
otherwise provided in NRS 174.315, a subpoena to attend a misdemeanor trial may be served by
mailing the subpoena to the person to be served by registered or certiIied mail, return receipt
requested Irom that person, in a sealed postpaid envelope, addressed to the person`s last known
address, not less than 10 days beIore the trial which the subpoena commands the person to attend. 3.
II a subpoena is served by mail, a certiIicate oI the mailing must be Iiled with the court within 2 days
aIter the subpoena is mailed.
DISCOVERY AND INSPECTION NRS 174.233 Disclosure by deIendant oI intent to claim
alibi; deIendant to disclose list oI alibi witnesses; prosecuting attorney to disclose list oI rebuttal
witnesses; continuing duty to disclose; sanctions. NRS 174.234 Reciprocal disclosure oI lists
oI witnesses and inIormation relating to expert testimony; continuing duty to disclose; protective
orders; sanctions. NRS 174.235 Disclosure by prosecuting attorney oI evidence relating to
prosecution; limitations. NRS 174.245 Disclosure by deIendant oI evidence relating to
deIense; limitations. NRS 174.275 Protective orders. NRS 174.285 Time limits. NRS
174.295 Continuing duty to disclose; Iailure to comply; sanctions. SUBPOENA NRS 174.305
Subpoena Ior attendance oI witnesses; Iorm; issuance. NRS 174.315 Issuance oI subpoena by
prosecuting attorney or attorney Ior deIendant; promise to appear; inIorming witness oI general nature
oI grand jury`s inquiry. NRS 174.325 Production oI prisoner as witness. NRS 174.335
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Subpoena Ior production oI documentary evidence and oI objects. NRS 174.345 Service oI
subpoena. NRS 174.365 Place oI service. NRS 174.375 Subpoena Ior taking
depositions; place oI examination. NRS 174.385 Contempt.
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SUBPOENA NRS 174.305 Subpoena Ior attendance oI witnesses; Iorm; issuance. Except as provided in NRS 172.195
and 174.315: 1. A subpoena must be issued by the clerk under the seal oI the court. It must state the name oI the court and
the title, iI any, oI the proceeding, and must command each person to whom it is directed to attend and give testimony at
the time and place speciIied therein. The clerk shall issue a subpoena, signed and sealed but otherwise in blank, to a party
requesting it, who shall Iill in the blanks beIore it is served. 2. A subpoena must be issued by a justice oI the peace in a
proceeding beIore the justice oI the peace under the seal oI the court. (Added to NRS by 1967, 1420; A 1967, 1367; 1987,
124) NRS 174.315 Issuance oI subpoena by prosecuting attorney or attorney Ior deIendant; promise to appear; inIorming
witness oI general nature oI grand jury`s inquiry. 1. The prosecuting attorney may issue subpoenas subscribed by the
prosecuting attorney Ior witnesses within the State, in support oI the prosecution or whom the grand jury may direct to
appear beIore it, upon any investigation pending beIore the grand jury. 2. The prosecuting attorney or the attorney Ior the
deIendant may issue subpoenas subscribed by the issuer Ior: (a) Witnesses within the State to appear beIore the court at
which an indictment, inIormation or criminal complaint is to be tried. (b) Witnesses already subpoenaed who are required
to reappear in any Justice Court at any time the court is to reconvene in the same case within 60 days, and the time may be
extended beyond 60 days upon good cause being shown Ior its extension. 3. Witnesses, whether within or outside oI the
State, may accept delivery oI a subpoena in lieu oI service, by a written or oral promise to appear given by the witness.
Any person who accepts an oral promise to appear shall: (a) IdentiIy himselI or herselI to the witness by name and
occupation; (b) Make a written notation oI the date when the oral promise to appear was given and the inIormation given
by the person making the oral promise to appear identiIying the person as the witness subpoenaed; and (c) Execute a
certiIicate oI service containing the inIormation set Iorth in paragraphs (a) and (b). 4. The prosecuting attorney shall orally
inIorm any witness subpoenaed as provided in subsection 1 oI the general nature oI the grand jury`s inquiry beIore the
witness testiIies. Such a statement must be included in the transcript oI the proceedings. (Added to NRS by 1967, 1368; A
1979, 130; 1985, 573; 1989, 685; 1991, 302; 1993, 118) NRS 174.325 Production oI prisoner as witness. 1. When it is
necessary to have a person imprisoned in the state prison brought beIore any district court, or a person imprisoned in the
county jail brought beIore a district court sitting in another county, an order Ior that purpose may be made by the district
court or district judge, at chambers, and executed by the sheriII oI the county when it is made. The order can only be made
upon motion oI a party upon aIIidavit showing the nature oI the action or proceeding, the testimony expected Irom the
witness, and its materiality. 2. When a person required as a witness beIore a district court is imprisoned, the judge thereoI
may order the sheriII to bring the prisoner beIore the court at the expense oI the State or, in the judge`s discretion, at the
expense oI the deIendant. (Added to NRS by 1967, 1420) NRS 174.335 Subpoena Ior production oI documentary
evidence and oI objects. 1. Except as otherwise provided in NRS 172.139, a subpoena may also command the person to
whom it is directed to produce the books, papers, documents or other objects designated therein. 2. The court on motion
made promptly may quash or modiIy the subpoena iI compliance would be unreasonable or oppressive. 3. The court may
direct that books, papers, documents or objects designated in the subpoena be produced beIore the court at a time beIore
the trial or beIore the time when they are to be oIIered in evidence and may, upon their production, permit the books,
papers, documents or objects or portions thereoI to be inspected by the parties and their attorneys. (Added to NRS by
1967, 1421; A 1985, 1030) NRS 174.345 Service oI subpoena. 1. Except as otherwise provided in NRS 174.315 and
subsection 2, a subpoena may be served by a peace oIIicer or by any other person who is not a party and who is not less
than 18 years oI age. Except as otherwise provided in NRS 289.027, service oI a subpoena must be made by delivering a
copy thereoI to the person named. 2. Except as otherwise provided in NRS 174.315, a subpoena to attend a misdemeanor
trial may be served by mailing the subpoena to the person to be served by registered or certiIied mail, return receipt
requested Irom that person, in a sealed postpaid envelope, addressed to the person`s last known address, not less than 10
days beIore the trial which the subpoena commands the person to attend. 3. II a subpoena is served by mail, a certiIicate oI
the mailing must be Iiled with the court within 2 days aIter the subpoena is mailed. (Added to NRS by 1967, 1421; A
1977, 638; 1989, 685; 2007, 2816) NRS 174.365 Place oI service. A subpoena requiring the attendance oI a witness at a
hearing or trial may be served at any place within the State oI Nevada. (Added to NRS by 1967, 1421) NRS 174.375
Subpoena Ior taking depositions; place oI examination. 1. An order to take a deposition authorizes the issuance by the
clerk oI the court Ior the county in which the deposition is to be taken oI subpoenas Ior the persons named or described
therein. 2. A resident oI this state may be required to attend an examination only in the county wherein the resident resides
or is employed or transacts business in person. A nonresident oI this state may be required to attend only in the county
where the nonresident is served with a subpoena or within 40 miles Irom the place oI service or at such other place as is
Iixed by the court. (Added to NRS by 1967, 1421) NRS 174.385 Contempt. Failure by any person without adequate
excuse to obey a subpoena oI a court or a prosecuting attorney served upon the person or, in the case oI a subpoena issued
by a prosecuting attorney, delivered to the person and accepted, shall be deemed a contempt oI the court Irom which the
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subpoena issued or, in the case oI a subpoena issued by a prosecuting attorney, oI the court in which the investigation is
pending or the indictment, inIormation or complaint is to be tried. (Added to NRS by 1967, 1421; A 1979, 130; 1995,
1082)
NEVADA RULES OF CIVIL PROCEDURE, RULE 45(c) AND 45(d) and see also JCRCP 45
copying commanded.
(B) II a subpoena
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contest the claim.
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zach coughlin
1471 e. 9th st
reno, nv 89501
tel and Iax:949 667 7402
RENO 1USTICE COURT
STATE OF NEVADA
PLAINTIFF
V.
ZACH COUGHLIN,
DEFENDANT
.
)
)
)
)
)
)
rcr2011-063341
Department 2
prosecution.
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appear;
roperj@reno.gov
harleyj@reno.gov
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Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
Records
fax 775 3286308
(775) 328-2831.
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askrpd@reno.gov
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75 Court Street
Reno, NV 89501
(775)328-3110
Operations
Office line (775) 326-6613
ecommops@reno.gov
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7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
district court)
arrest by RSC,
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Google+ page
(775) 746-4322
STUFF,
__________________________
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1082)
copying commanded.
(B) II a subpoena
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contest the claim.
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zach coughlin
1471 e. 9th st
reno, nv 89501
tel and Iax:949 667 7402
RENO 1USTICE COURT
STATE OF NEVADA
PLAINTIFF
V.
ZACH COUGHLIN,
DEFENDANT
.
)
)
)
)
)
)
rcr2011-063341
Department 2
prosecution.
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appear;
roperj@reno.gov
harleyj@reno.gov
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Reno NV 89523
fax: 775 747 9202
Reno, Nevada 89501
(775) 348-7560
(Toll Free) 800-570-5583
Fax: (775) 348-7977
Records
fax 775 3286308
(775) 328-2831.
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askrpd@reno.gov
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75 Court Street
Reno, NV 89501
(775)328-3110
Operations
Office line (775) 326-6613
ecommops@reno.gov
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7753786673
7758153680
7752338593
7752303726
7753043004
7752330367
775 229 6737
or 775 338 8118
949 667 7402
district court)
arrest by RSC,
- 6/12 -
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Google+ page
(775) 746-4322
STUFF,
__________________________
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1082)
copying commanded.
(B) II a subpoena
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contest the claim.
- 12/12 -
EXHIBIT "6"
I.
y;)U may
I! i
Dept \ks
Snfl'OENA DUCES TEeL"\>!
(
[Hi: JUSTICE C()URT OF RENO TO\VNS! HP
(Of. :;\TY OF \,\,/\51 fOE, STXIT UF \.lEVADi\
'/;;.
!/ ... BAR.K!:R CUL!C1iLJ0J.
-\-
i{C:ilLl JiuiL" . .' (\)t!:i
(jilt:: S1.itllh Si":')"f;i R .... nu. \"'('''':Fh
':X):lJ ,0; Ii i 'K) ", iJ
'. 1 t.od I
ill':
,',j!;}!"';;-,;
\" i-'ftZS
i
J,\ !' ..:\lLL<(,i l () '\I'Pi:_I.F Y Ui_: Hf:U) 1:-': CU;".{"IT1'-.---lP'! or CO('RT
,\CCORDii'\; TO un 'j i if"' FOR CO>; i"l::\'IV! OF (()L'RT LS .'1
13\ Z8ch Cl)uqh.L_l:
J:j71 2:. 9::-.JJ s:-
Re:)o, NV 89::i12
) S.',
.;:1 .il. ir"ynu bF'C qU('::';i.iOilS
:':g;',rding ':P1X;U','iI1l':'C, pk;I.')c
(.piltitC[ ..:<,::)-. C,-")uqhJ J J) c-tt
pilL'Ht ,j;1(z.1l1ling and \:'lli:-;.i. lC'X! lne::::';,IU,;S fc'f '..'c]! D lU,-; hcr (-: 75)52. 7,
lJJ.-f(j f(!r rhe j ;mJ 8,.::'!.__-201 i
have to ::'IT tC: :H, rhl.'sc, m:W:TWj;.; ,1 ,.-:jJn::;;;n(i.!;.!I"C ("!;t.\'9..t:-
XX
II
d
II
I
zach coughlin
1471 e. 91h Sl
reno, nv 8950 I
, 7.achCol!!.'.hlin({}; h'Jlmai!.col1l (pk'{iSC email so may result in agreement
/1 I November 191h, ]012 at x30am ',viil no! be required.
lei and lax :l)4() 067 !402
" II
"/
i
l
' rA n :.OF AtM
)I.AINTIFF
ltvl
::
i ' COUCIILI
:iJITFNI):\NI
RENO .JUSTICE COURT
SJ ,c..TE OF 1\ D!\ COll\!lY 01 W ASIIOr:
I
I
I
I
i
I
I
i
I
'I
Ii
IBP()iN"\...i\N-i-) __ fFTlj\1 .!lllt ;""oti c!: HJ Witncs)_t's and H:Eq!lcst for I
! OiSCH\ cry and N'<Hi{'c...9.L \\',rncss ddt'!!sc ttl C2J !
i I Iria 1;!'i!)licl'_ of ;\ y,) ilabi!it\ Wic! \\ ihlfsS in. :\' iill :
I du.h_..1o SH 71-24::> HI L'\ tOI
" , defens iimihtllons . COHlimnng dll! y i n lailure 10 {'flnlp!y; S:!IH:lions I
" fm- NRS 174.235 l,i"tloslIn: hy pros"l.' ul ing atlonl ey oft' vidcru:t r..:i;!ting 10
,I p' Hsccuiwn. .
II !
It .
" II To to .. Peter Sfecrazza at
i,' the .. G..t)urt in alJ S.;>len" St. 89.;0;02 19t1],
i 201? .. 8:}O ar(LJo the parLor Zi\cJ:la.ry by
II w. Ith.Q!J
t
. a mi:!Y be a
I contemot of the Court
1, --'-
ii' TI-!i'\.LIHI.MAX"LQT!.iE .. ,.At\m TH!;REFQRE YPUMAY I
) I! 0 . R !V. _. JA ....Y...NOT E?_!; .. ENJr.f. .. T9 IG.NQR .. A. M .N .... . .lQ.:UiQ_y.Qu ..... IT . i
. MAY BE TOO LATE TOO LATE FOR THIS SUBPOENA TO BE SERVED ON YOU IN A TIMELY i
>': ! I - I
. J . I !
.'( I ,
? II ARGI)ABl"Y N.QT THi:.pETJY LARCENY
I
' 2.912 tN_ M.t\OE IT DIFFIGUl T.IP E:.BT AIN THE __ EXACT
:.: ;: I REQUIREMENTS ATTENDANT TO A DOCUMENT SUCH AS THIS. AS SUCH PLEASE
I
f----- ,. "/j
I
,I B-1:;'; f c::\ Ii
, i
"-'
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MADE 9ND9CA89ON 8HA8 DESP98E COU;H79N 1E9N; SUSPENDED HE MAY =9SSUE=
SU1POENAS& AND 8HE S1N MAY HA'E 3UR8HER 9ND9CA8ED COU;H79N :OU7D NO8
NEED 8O PAY :98NESS 3EES A8 A77& OR A8 7EAS8 UP 3RON8& 8HE E>9;ENC9ES O3
HA'9N; 1O8H 8HE NO'EM1ER %?8& $+%$ "r %+* HEAR9N; :98H 8HE bn @E'EN :HERE
8HE NO89CE AND DUE PROCESS PRO'9S9ONS AND 89ME PER9ODS O3 SCR %+* E8C ARE
AR;UA17Y NO8 1E9N; 3O77O:EDA AND 8HE PE88Y 7ARCENY 8R9A7 ON NO'EM1ER
%)8H& $+%$ 9N RCR$+%%B+C..?% HA'E MADE 98 D9339CU78 8O ASCER8A9N 8HE E>AC8
RE<U9REMEN8S A88ENDAN8 8O A DOCUMEN8 SUCH AS 8H9S. AS SUCH& P7EASE
CONSU78 YOUR O:N A88ORNEY RE;ARD9N; :HE8HER OR NO8 8H9S DOCUMEN8
CARR9ES AND :E9;H8 OR 7A:3U7 COMMAND OR D9SP7AY O3 AU8HOR98Y
NRS 174.315 Issuance of subpoena by prosecuting attorney or attorney for defendant pro#!e to
appearD
An/one 4!h!ng to !ue 0a"h Coughl!n a pro#!e to appear& pleae e#a!l !t to h!# at-
za"h"oughl!nEhot#a!l."o# or fa6 to )?) CCF F?+$
NRS 174.345 Ser!ice of subpoena.
$. E6"ept a other4!e pro,!ded !n NRS %F?..%*& a ubpoena to attend a #!de#eanor
tr!al #a/ be er,ed b/ #a!l!ng the ubpoena to the peron to be er,ed b/ reg!tered or
"ert!f!ed #a!l& return re"e!pt re5ueted fro# that peron& !n a ealed potpa!d en,elope&
addreed to the peronG lat 2no4n addre& not le than %+ da/ before the tr!al 4h!"h
the ubpoena "o##and the peron to attend.
3. If a subpoena is ser!ed by "ai#$ a certificate of the "ai#ing "ust be fi#ed %ith the court %ithin &
days after the subpoena is "ai#ed
To: '#ison (. )r"aas$ *a" Roberts$ Christopher +a,#ett-Ste!ens$ .rian Sooudi Co"pany: Reno
City 'ttorney 'ddress: )ne /ast 0irst Street$ 3rd 0#oor *.). .o1 1233 Reno $ N4 52535 *hone
Nu"ber: 6-- 0a1 nu"ber: 775-334-4&&7 /"ai#: or"aasa8reno.go!$ ha,#ett-ste!ensc8reno.go!$
robertsp8reno.go!$ sooudib8reno.go!
9oe# +ar#ey$ and Scott Coppa and To%nsend$ and (arsha# Court (arsha# R(C custodian of
records city of reno (arsha#s :i!ision$ and Chief 9ustin Roper
roper;8reno.go!
reno"arsha#8reno.go!
har#ey;8reno.go!
1 South Sierra Street Reno$ N4 5253& <775= 3&7-51&5
Chief (arsha# 9ustin Roper <334.1&54$ 0a1 334.1&73$ roper;8reno.go!=.
*a" >ongoni$ R(C e1cu#si!e transcriptionist de"anding do%n pay"ent fro" cri"ina# defendant
appe#ants in !io#ation of ne!ada #a%$ :onna .a##ard
p#ongoni8charter.net c?o Reno (uncipa# Court
1 South Sierra Street Reno$ N4 5253& fa1 775 334 35&4 ba##ardd8reno.go!
Reno "@nicipa# Court custodian of records$ and (ari#yn Tognoni$ and the Ac#erB of court for
:epart"ent 3A referenced in S.NCs *at DingCs corrspondence to Cough#in a##eging so"e reports of
the c#othing Cough#in %ore to the fi#ing office counter at the R(c in (arch &31&$ and any sub"ission
- %D1% -
,4A80/$. .$3 ,4A80/$. 34C/, -/C4@
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by the Reno (arsha#s$ >isa Eagner$ 'd"inistrati!e 9udge Ei##ia" Fardner$ 9udge :orothy Nash
+o#"es$ 9udge Denneth +o%ard$ Cassandra 9acBson$ >isa Eagner$ 4eronica >ope,
1 South Sierra Street Reno$ N4 5253& <775= 3&7-51&5$ reno"unicrecords8reno.go!$
christensend8reno.go!$ fa1: 775 334 &4&3 775 334 35&4
North%inds 'part"ents 'ssociate >>C
(anage :uane 9aBob$ #)@ c':I' "I>'N BR/.S
1753 SBy (ountain :r
Reno N4 525&3
fa1: 775 747 2&3&
N/!ada Courts Ser!ices
Ne!ada Court Ser!ices
475 So. 'r#ington Suite 1'
Reno$ Ne!ada 52531
<775= 345-7573
<To## 0ree= 533-573-5553
0a1: <775= 345-7277
/"ai#: ne!cs8ne!cs.co"
9)e# :urden$ Ryan Eray$ 9eff Chand#er$ 9ennifer Chand#er$ Cedonio$ and Ne!ada Court S/r!ices
Custodian of R/cords and AStaff 'ttorneyA >e%is Taite#$ /sG.
Richard F. +I##$ /sG. and Custodian of Records for >a% )ffice of Richard F. +I##$ /sG.
Richard F. +i## Co"pany: 6 'ddress: 75& 0orest St. 6 Reno $ N4 52532 *hone Nu"ber: 775-345-
3555 0a1 nu"ber: 775-345-3555 /"ai#: rhi##8richardhi##a%.co"
Casey :. .aBer Custodian of Records for .aBer H .aBer >a% )ffices$ *>>C 'ddress: 43& E. (ain
St.$ &nd 0#r. *.). .o1 &5 :an!i##e $ DI 434&3 *hone Nu"ber: 552-&35-&&33 0a1 nu"ber: 552-432-
33&5 /"ai#: cbaBer8centra#By#ega#.co" Eebsite:
ECS) Custodian of Records and >i, Stuche##$ and Ro1y Si#!a$ and :eputy 9ohn (achen$ *atricia
.ecB"an$ :ebi Cu""ings$ 9ason +odge$ :eputy .eatson$ (ade#ine C. 9)nes$ :eputy 4an :er
Ea##$ Nurse Datherine$ :eputy (ichae# R. +oeBstra$ EC:C (edica#?Nursing Staff Custodian of
Records
;"achen8%ashoecounty.us$ #stuche##8%ashoecounty.us$ rsi#!a8%ashoecounty.us
Eashoe County SheriffJs )ffice >ocation:211 *arr .#!d.$ Reno$ N4 5251&(ain *hone:775-3&5-3331
/"ai#:sheriff%eb8%ashoecounty.us
fa1 775 3&57335
211 *arr .#!d Reno$ N4 5251& 0orensic Science :i!ision at <775= 3&5-&533. The fa1 nu"ber is:
<775= 3&5-&531.
and p#ease do be sure to gi!e "e your !ie%s on proper ser!ice$ there$ ECS) Ci!i# :i!ision...
Roberto *uentes Co"pany: 6 'ddress: 417 Ridge St. 6 Reno $ N4 52531 *hone Nu"ber: 775-757-
7777 0a1 nu"ber: 775-757-57&3 /"ai#: *@/NT/S>'E8')>.C)(
Deith >#oyd >oo"is Co"pany: 6 'ddress: 2475 :oub#e R .#!d. Suite ' Reno $ N4 525&1 *hone
Nu"ber: 775-553-7&&& 0a1 nu"ber: 775-553-3573 /"ai#: Beith#oo"is8earth#inB.net
- &D1% -
,4A80/$. .$3 ,4A80/$. 34C/, -/C4@
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bdogan8%ashoecounty.us
.iray :ogan$ 9i" >es#ie$and 9oe Foodnight$ and /!o No!aB
Co"pany: Eashoe County *ub#ic :efenderCs )ffice 'ddress: *.). .o1 33353 6 Reno $ N4 52532
*hone Nu"ber: 775-337-4575 0a1 nu"ber: 775-337-4557 /"ai#:;#es#ie8%ashoecounty.us$
.:)F'N8E'S+)/C)@NTI.@S$ 9F)):NIF+T8E'S+)/C)@NTI.@S
(ary (argaret Dandaras Co"pany: Eashoe County :istrict 'ttorney 'ddress: )ne S. Sierra St.
*.). .o1 33353 Reno $ N4 525&3 *hone Nu"ber: 775-337-5733 0a1 nu"ber: 775-337-573& /"ai#:
"Bandaras8da.%ashoecounty.us
cITI )0 R/N)?R/N) *)>IC/ :/*'RT(/NT:
775-334-&1&1 *o#ice :epart"ent: 455 /. Second Street$ Reno$ N4 5253& :irections /"ai#:
asBrpd8reno.go!
:eputy Chief (iBe Ehan <334.3542$ 0a1 334.3523$ %han"8reno.go! = >ieutenant Deith .ro%n
<334-3545$ 0a1 334-3523$ bro%nB8reno.go!$ r)./RT b)NI .)NIR8R/N).F)4
*>/'S/ *R)4I:/ T+/ 4I:/) 0))T'F/ )0 T+/ /4/NTS >/':INF @* T) 'N: T+/
'RR/ST T+'T ST'RT/: '>> T+IS )N '@F@ST &3T+$ &311$ 0R)( ./TE//N
'**R)KI('T/>I 11:13 *( T) 1&:33 '( )N a@F@ST &1ST$ &311...' >ITIF'TI)N +)>:
N)TIC/ )0 S)RTS E'S C/RT'IN>I *R)4I:/:$ 'T >/'ST T) T+/ R*:$ 'N: 'RF@'.>I
T) T+/ CITI )0 R/N) 'N: CITI 'TT)RN/ICS )00IC/ 'N: T+/ SIFN IN T+/ SD'T/ *>'C/
'T 13 N. C/NT/R ST IN:IC'T/S T+/ R*: IS 4I:/) ()NIT)RINF EIT+ A:)ENT)EN
*R)*/RTI/SA 'N: T+/IR C>/'R>I 'R/ 4I:/) C'(/R'S *>'C/ 'T)* CITI +'>>$ E+IC+
)4/R>))DS T+/ SC/N/ )0 T+/ 'RR/ST$ '>> )0 T+IS S+)@>: +'4/ .//N
*R)*)@N:/: '>R/':I in rcr&311-373341
)fficer Nicho#as :ura#de dura#den8reno.go!
Ron Rosa rosar8reno.go!
Tho"as '#aBsa a#aBsat8reno.go!
Sargent (arcia >opea #ope,"8reno.go!
officer tra!is %arren %arrent8reno.go!
officer chris carter carterc8reno.go!
sargent pau# sifre sifrep8reno.go!
officer ;ason schaur schaur;8reno.go!
officer a#an ho##ings%orth ho##ings%ortha8reno.go!
officer tra!is #ooB #ooBt8reno.go!
officer %es#ey #eedy #eedy%8reno.go!
officer a#an %ea!er %ea!era8reno.go!
rpd sargent brian dye dyeb8reno.go!
sargent o#i!er "i##er "i##ero8reno.go!
#ietn Beith bro%n bro%nB8reno.go!
sargent Bi" bradsha% bradsha%B8reno.go!
*>/'S/ ./ S@R/ T) INC>@:/ '>> /C)(( :IS*'TC+ R/C)R:INFS <INC>@:INF
T+/ C)NT/NTS )0 C)((@NIC'TI)NS ./TE//N :IS*'TC+ 'N: T+/ )00IC/RS. *>/'S/
INC>@:/ T+/ 4I:/) )0 T+/ SD'T/ *>'L/ 'T 13 N. C/NT/R ST. ':N N/'R 0IRST 'N:
4IRFINI'$ INC>@:INF T+/ C'(/R'S 'T)* CITI +'>>$ C)NS:I/RINF T+/ SIFN IN T+/
SD'T/ *>'L' T+'T IN:IC'T/S T+/ R*: IS 4I:/) R/C)R:INF T+/ 'R/'$ 'N: T+/
>ITIF'TI)N +)>: N)TIC/ T+/ CITI )0 R/N) 'N: R*: E/R/ *>'C/: )N S+)RT>I
'0T/R T+/ 'RR/ST )0 '@F@ST &3T+$ &311 IN RCR&311-373341. S+)@>:NCT ./ T))
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+'R: T) S+)E E+/T+/R )R N)T T+)S/ SD'T/R.)'R:S E/R/ T/>>INF T+/ TR@T+.
S@R/ ('D/S ' >)T )0 S/NS/ T) ./T )N T+/ 15 I/'R )>: SD'T/.)'R:/RS 4/R'CITI
4/RS@S T+/ 35 I/'R )>: 'TT)RN/ICS T+)@F+....No reasons at a## to taBe a "ore cautious
approach than %as taBen$ probab#y....
Lachary N. Ioung Co"pany: Eashoe County :' )ffice 'ddress: 1 South Sierra *.). .o1 33353
Reno $ N4 525&3 *hone Nu"ber: 775-3&5-3&33 0a1 nu"ber: 775-3&5-7733 /"ai#:
Lyoung8da.%ashoecounty.us
p#ease be ready to testify regarding you participation in the c#andestine status conference o &?&7?1&
and the 1:31p" fi#e sta"ped )Rder for Co"petency /!a#uation in RCR&31&-375733$any
co""unications %ith or to anyone %ith regard thereto$ your a##eged "u#tip#e !io#ations of nrs 175.435
*atricB ). Ding Co"pany: State .ar of Ne!ada 'ddress: 2457 :oub#e R .#!d. Suite . Reno $ N4
525&1 *hone Nu"ber: 775-3&2-4133 0a1 nu"ber: 775-3&2-35&&
p#ease produce any "ateria#s re#ated to Lachary .arBer Cough#in in any %ay$ shape or for"$ and be
present and ready to testify fu##y regarding the R(C (arsha# peering through Cough#inCs bathroo"
sta## <not e1act#y in the Ai""ediate presence of the courtA$ no% is it$ sufficient for a Asu""ary
cri"ina# conte"ptA con!iction....cited on the record by 9udge Nash +o#"es on 3?1&?1& in 11 tr &7533
by the (arsha# and the !io#ations of the courthouse sanctuary doctrine by (arsha# +ar#ey on beha#f
of :eputy (achen$ on beha#f of Richard +I## to ser!e in front of )R"aas the )Rder to Sho% Cause
in the appea# of the richard g. hi## e!iction "atter in c!11-337&5$ as %e## as any and a## infor"ation or
docu"entation re#ated to the AreceiptA by the %cso of any and a## )rders of any sort <or any
correspondence %hatsoe!er= in connection %ith R9C re!&311-331735$ rc; re!&31&-331345$ rcr&31&-
377253 and any other "ateria#s re#ated to Cough#in and North%inds 'part"ents 'ssociates and or
Superior (Ini STorage and a## "ateria#s detai#ing the practices and po#icies of the %CS) %ith
respect to "aintaining docu"entation or transferring docu"entation concerning or pro!iding proof of
%hen the %cso 0IRST recei!ed or ca"e to ha!e AreceiptA of any sort of )rders re#ated to an e!iction
!is a !is nrs 43.&53 or other%ise$ inc#uding the na"e of the #ocBs"iths doing any and a## #ocBouts of
cough#in$ and "edia gathered by the %cso$ anything re#ated to the booBing into e!idence of the
"ateria#s retrie!ed by the R(CCs (arsha#s after the period in %hich those (arsha#s cou#d ha!e
#a%fu##y conducted an search incident to arrest$ and therefore !io#ati!e of the fourth a"end"ent
%here no %arrant or other basis for so retrie!ing such "ateria#s has been ad"itted to.
Specia#ity Courts 'd"inistrator Shie#a >es#ie$ (enta# +ea#th Court for S/cond 9udicia# :istrict Court
Custodian of Records fa1 775 3&5-7717.
Rene .iondo 775 3&5-7735 and Isabe# (eado%s 775 3&5-7753
75 Court Street
Reno$ N4 52531
<775=3&5-3113
shie#a.#es#ie8%ashoecourts.us$ rene.biondo8%ashoecourts.us$ isabe#."eado%s8%ashoecourts.us$
;oey.hastings8%ashoecourts.us
/##a (ae Carthen$ De##ey )do"$ Dariann .eech#er$ /C)((
)perations
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C)R /"ergency Co""unications
Super!isor #ine <775= 334-&322
)ffice #ine <775= 3&7-7713
carthene8reno.go!$ odo"B8reno.go!$ beech#erB8reno.go!
eco""ops8reno.go!
/C)(( C@ST):I'N )0 R/C)R:S 'N: D/>>I ):)( 'N: D'RI'NN .//C+>/R 'N: R/N)
:IR/CT 'N: CITI )0 R/N)$ E'S+)/ C)@NTI S+/RI00CS )00IC/$ E'S+)/ C)@NTI
:ISTRICT 'TT)RN/ICS )00IC/$ R/N) (@NICI*'> C)@RT$ CITI )0 R/N)$ R/N) :IR/CT$
S/C)N: 9@:ICI'> :ISTRICT C)@RT$ R/N) 9@STIC/ C)@RT$ C@ST):I'NS )0 R/C)R:.
I)@ 'R/ C)(('N:/: to appear before the the +onorab#e *eter 9. Sferra,,a in :epart"ent & of
the R9C on No!e"ber 12th$ &31& at 5:33 a" to testify on the part of Lachary .arBer Cough#in.
0ai#ure by any person %ithout adeGuate e1cuse to obey a subpoena ser!ed upon that person "ay be
dee"ed a conte"pt of the court fro" %hich the subpoena issued. MNe!ada Ru#es of Ci!i# *rocedure$
Ru#e 45<e=N $ p#ease be sure the "ateria#s you pro!ide inc#uded$ but are not #i"ited to:
*#ease ;ust send "e <preferab#y by e"ai#= any and a## recordings or docu"entation of any sort
in!o#!ing Lach Cough#in or Lach Cuogh#in$ %hether %ith a date of birth of 2?&7?77 or 2?1?77$ or any
other :).$ inc#uding for Lachary Cough#in or Lach Caugh#in or any iteration of those na"es$
inc#uding dispatch recordings <not ;ust the 211 ca##s$ by a## recordings$ inc#uding co""unications %ith
the po#ice officers or other #a% enforce"ent persone#=$ inc#uding those in any %ay re#ated to incidents
or arrests on$ but not #i"ited to$ the fo##o%ing:
'ugust &3th$ &311 arrest at 13 n. center st by R*: :ura#de$ in!o#!ing )fficer Rosa and )0ficer
'#aBsa as %e## %ith !arious 211?rpd?dispatch ca##s inc#uding so"e "ade by the fo##o%ing nu"bers
any ca## e!er "ade fro" or to:
7753757773
7755153753
775&335523
775&3337&7
7753343334
775&333377
775 &&2 7737
or 775 335 5115
242 777 743&
a#so$ "y for"er Eashoe County *ub#ic :efender 9i" >es#ie ser!ed De##y )do" a subpoena for
these "atria#s on 13 3 1&. I got >es#ie re"o!ed and a" no% representign "yse#f in RCR&31&-
373341. >es#ie says /C)(( and ):)( fai#ed to produce anything or respond in any %ay...%hich I
doubt...so p#ease ;ust inc#ude the response to that subpoena in %hat you send "e
i a#so %ant anything re#ated to the fo##o%ing cri"ina# cases:
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rcr&311-373341 <petty #arceny arrest near 13 n. center st on 'ugust &3th$ &311 by rpd officer nicB
dura#de <your dispatcher 9/ssica :ura#dCes husband= %ith assistance by rpd tho"as a#aBsa and ron
rosa <p#ease inc#ude anything about th 1224 #a%suit agains rosa as an officer in second ;udicia#
district court=
in the Reno (@nic Court 11 cr &&177 <occuring at the %. &nd st. %a#"art on 2?2?11 at around 2 p"$
arrest by RSIC$
N)!e"ber 13th$ &311 arrest in R(C 11 cr &7435 <arrest by reno pd at 1&1 Ri!er RocB St. reno
52531 at so"eti"e around noon=
No!e"ber 33th$ &311 arrest by reno "arsha#s in 11 cr &&177
;anuary 1&th$ &31& arrest in r"c 1& cr 33727 <at 1&1 Ri!er RocB 52531 as %e##$ p#ease inc#ude
anythign re#ated to Richard F. +I## or (att (er#issCs ca##s to #a% enforce"ent$ inc#uding anything on
+I##Cs tpo in rcp&31&-333315=
;anuary 13th pu##o!er by rpd dura#de e# a# of cough#in on near &5& "i## st.
;anuary 14th$ &31& arrest in rcr&31&-375733
any of the 211 ca##s or dispatch recordings re#ated to any incidents or responses thereto by #a%
enforc"ent in any %ay connected to cough#in on or around the 14&& /. 2th St. O& address bet%een
dece"ber 1$ &311 and the present$ inc#uding any ca##s by Christopher A/rinA er!in '##abacB or >aure
0oreshee or >aura *etrone
anythign re#ated to cr1&-3377 re"anding to custody on 'pri# 12th and inc#uding anything re#ated to
incarceration at %cdc bet%een 4?12?1& and 4?&2?1&
anything re#ated to reno "arsha# r"c arrest in 11 tr &7533 on &?&7?1&
anything on the 11?15?11 incident resu#ting in 11 tr &7533 on st #aurence in!o#!ing the rpd$ sargent
tarter$ 75& forrest st. richard hi##$ etc.
rcr&31&-377253 <anything on the ;une &7th$ &31& arrest by %cso deputy "achen and bo%"an$ and
in fact anything in!o#!ing Lach Cough#in and any #a% enforce"ent figures at or around North%inds
'part"ents at 1753 sBy "ountain dri!e and or Superior "ini storage at
Foog#eP page
7725 Ehite 0ir Street Reno$ N4 525&3
<775= 747-43&&
or at so"e %est fourth street address or Superior (Ini STorage$ especia##y on or around septe"ber
&&nd &31& %hether in!o#!ing officer a#an %ea!er or
sargent o#i!er "i##er or not$ inc#uding ca##s for #a% enforce"ent response by "att grant <a %o"an= or
Ben grant or "ar!in dye or anyone %ith superior "ini storage
the ;u#y 3rd$ &31& arrest in r"c 1& cr 1&4&3 'N: 'NIT+INF 'N /4/RIT+INF )T+/REIS/
R/>'T/: T) L'C+ C)@F+>IN IN 'NI E'I$ :)NT 0)RF/T T+/ 9'N 13 &31& ST@00
EIT+ S'RF/NT >)*/L 'N: )00IC/R E/'4/R 'N: '4I>'$ '>> T+/ S'RF/NT SI0R/
ST@00$
'NIT+INF IN CR1&-3377...'NIT+INF IN (+1&-333&
I a" subpoening a## these "ateria#s incident to 9udge Sferra,,as 13?&&?1& )Rder in RCR&311-
373341$ in %hich he granted "e the right
to issue these subpoenas upon you %ithout paying up front the %itness fees or other e1penses <I0*=
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:ated this 5th day of No!e"ber$ &31&:
QQQQQQQQQQQQQQQQQQQQQQQQQQ
Lachary .arBer Cough#in$ /sG. <Ne!ada #a% #icense te"porari#y suspended$ @S*T) #icense in tact$
and gi!en per"ission to issue subpoenas by S.N Chief .ar Counse# :a!id C#arB$ /sG.=
$?, 174.&45 ,ervice o su!poena. 1. /)cept as other'ise provi"e" in $?,
174.&15 an" su!section %, a su!poena ma# !e serve" !# a peace oicer or !# an# other person 'ho is
not a part# an" 'ho is not less than 18 #ears o age. /)cept as other'ise provi"e" in $?, %89.0%7,
service o a su!poena must !e ma"e !# "elivering a cop# thereo to the person name". %. /)cept as
other'ise provi"e" in $?, 174.&15, a su!poena to atten" a mis"emeanor trial ma# !e serve" !#
mailing the su!poena to the person to !e serve" !# registere" or certiie" mail, return receipt
re(ueste" rom that person, in a seale" postpai" envelope, a""resse" to the personEs last Cno'n
a""ress, not less than 10 "a#s !eore the trial 'hich the su!poena comman"s the person to atten". &.
: a su!poena is serve" !# mail, a certiicate o the mailing must !e ile" 'ith the court 'ithin % "a#s
ater the su!poena is maile".
3:,C02/?5 .$3 :$,8/C-:0$ $?, 174.%&& 3isclosure !# "een"ant o intent to claim
ali!i> "een"ant to "isclose list o ali!i 'itnesses> prosecuting attorne# to "isclose list o re!uttal
'itnesses> continuing "ut# to "isclose> sanctions. $?, 174.%&4 ?eciprocal "isclosure o lists
o 'itnesses an" inormation relating to e)pert testimon#> continuing "ut# to "isclose> protective
or"ers> sanctions. $?, 174.%&5 3isclosure !# prosecuting attorne# o evi"ence relating to
prosecution> limitations. $?, 174.%45 3isclosure !# "een"ant o evi"ence relating to
"eense> limitations. $?, 174.%75 8rotective or"ers. $?, 174.%85 -ime limits. $?,
174.%95 Continuing "ut# to "isclose> ailure to compl#> sanctions. ,4A80/$. $?, 174.&05
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,u!poena or atten"ance o 'itnesses> orm> issuance. $?, 174.&15 :ssuance o su!poena !#
prosecuting attorne# or attorne# or "een"ant> promise to appear> inorming 'itness o general nature
o gran" Fur#Es in(uir#. $?, 174.&%5 8ro"uction o prisoner as 'itness. $?, 174.&&5
,u!poena or pro"uction o "ocumentar# evi"ence an" o o!Fects. $?, 174.&45 ,ervice o
su!poena. $?, 174.&+5 8lace o service. $?, 174.&75 ,u!poena or taCing
"epositions> place o e)amination. $?, 174.&85 Contempt.
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,4A80/$. $?, 174.&05 ,u!poena or atten"ance o 'itnesses> orm> issuance. /)cept as provi"e" in $?, 17%.195
an" 174.&15* 1. . su!poena must !e issue" !# the clerC un"er the seal o the court. :t must state the name o the court an"
the title, i an#, o the procee"ing, an" must comman" each person to 'hom it is "irecte" to atten" an" give testimon# at
the time an" place speciie" therein. -he clerC shall issue a su!poena, signe" an" seale" !ut other'ise in !lanC, to a part#
re(uesting it, 'ho shall ill in the !lanCs !eore it is serve". %. . su!poena must !e issue" !# a Fustice o the peace in a
procee"ing !eore the Fustice o the peace un"er the seal o the court. (.""e" to $?, !# 19+7, 14%0> . 19+7, 1&+7> 1987,
1%4< $?, 174.&15 :ssuance o su!poena !# prosecuting attorne# or attorne# or "een"ant> promise to appear> inorming
'itness o general nature o gran" Fur#Es in(uir#. 1. -he prosecuting attorne# ma# issue su!poenas su!scri!e" !# the
prosecuting attorne# or 'itnesses 'ithin the ,tate, in support o the prosecution or 'hom the gran" Fur# ma# "irect to
appear !eore it, upon an# investigation pen"ing !eore the gran" Fur#. %. -he prosecuting attorne# or the attorne# or the
"een"ant ma# issue su!poenas su!scri!e" !# the issuer or* (a< 6itnesses 'ithin the ,tate to appear !eore the court at
'hich an in"ictment, inormation or criminal complaint is to !e trie". (!< 6itnesses alrea"# su!poenae" 'ho are re(uire"
to reappear in an# Gustice Court at an# time the court is to reconvene in the same case 'ithin +0 "a#s, an" the time ma# !e
e)ten"e" !e#on" +0 "a#s upon goo" cause !eing sho'n or its e)tension. &. 6itnesses, 'hether 'ithin or outsi"e o the
,tate, ma# accept "eliver# o a su!poena in lieu o service, !# a 'ritten or oral promise to appear given !# the 'itness.
.n# person 'ho accepts an oral promise to appear shall* (a< :"enti# himsel or hersel to the 'itness !# name an"
occupation> (!< @aCe a 'ritten notation o the "ate 'hen the oral promise to appear 'as given an" the inormation given
!# the person maCing the oral promise to appear i"enti#ing the person as the 'itness su!poenae"> an" (c< /)ecute a
certiicate o service containing the inormation set orth in paragraphs (a< an" (!<. 4. -he prosecuting attorne# shall orall#
inorm an# 'itness su!poenae" as provi"e" in su!section 1 o the general nature o the gran" Fur#Es in(uir# !eore the
'itness testiies. ,uch a statement must !e inclu"e" in the transcript o the procee"ings. (.""e" to $?, !# 19+7, 1&+8> .
1979, 1&0> 1985, 57&> 1989, +85> 1991, &0%> 199&, 118< $?, 174.&%5 8ro"uction o prisoner as 'itness. 1. 6hen it is
necessar# to have a person imprisone" in the state prison !rought !eore an# "istrict court, or a person imprisone" in the
count# Fail !rought !eore a "istrict court sitting in another count#, an or"er or that purpose ma# !e ma"e !# the "istrict
court or "istrict Fu"ge, at cham!ers, an" e)ecute" !# the sheri o the count# 'hen it is ma"e. -he or"er can onl# !e ma"e
upon motion o a part# upon ai"avit sho'ing the nature o the action or procee"ing, the testimon# e)pecte" rom the
'itness, an" its materialit#. %. 6hen a person re(uire" as a 'itness !eore a "istrict court is imprisone", the Fu"ge thereo
ma# or"er the sheri to !ring the prisoner !eore the court at the e)pense o the ,tate or, in the Fu"geEs "iscretion, at the
e)pense o the "een"ant. (.""e" to $?, !# 19+7, 14%0< $?, 174.&&5 ,u!poena or pro"uction o "ocumentar#
evi"ence an" o o!Fects. 1. /)cept as other'ise provi"e" in $?, 17%.1&9, a su!poena ma# also comman" the person to
'hom it is "irecte" to pro"uce the !ooCs, papers, "ocuments or other o!Fects "esignate" therein. %. -he court on motion
ma"e promptl# ma# (uash or mo"i# the su!poena i compliance 'oul" !e unreasona!le or oppressive. &. -he court ma#
"irect that !ooCs, papers, "ocuments or o!Fects "esignate" in the su!poena !e pro"uce" !eore the court at a time !eore
the trial or !eore the time 'hen the# are to !e oere" in evi"ence an" ma#, upon their pro"uction, permit the !ooCs,
papers, "ocuments or o!Fects or portions thereo to !e inspecte" !# the parties an" their attorne#s. (.""e" to $?, !#
19+7, 14%1> . 1985, 10&0< $?, 174.&45 ,ervice o su!poena. 1. /)cept as other'ise provi"e" in $?, 174.&15 an"
su!section %, a su!poena ma# !e serve" !# a peace oicer or !# an# other person 'ho is not a part# an" 'ho is not less
than 18 #ears o age. /)cept as other'ise provi"e" in $?, %89.0%7, service o a su!poena must !e ma"e !# "elivering a
cop# thereo to the person name". %. /)cept as other'ise provi"e" in $?, 174.&15, a su!poena to atten" a mis"emeanor
trial ma# !e serve" !# mailing the su!poena to the person to !e serve" !# registere" or certiie" mail, return receipt
re(ueste" rom that person, in a seale" postpai" envelope, a""resse" to the personEs last Cno'n a""ress, not less than 10
"a#s !eore the trial 'hich the su!poena comman"s the person to atten". &. : a su!poena is serve" !# mail, a certiicate o
the mailing must !e ile" 'ith the court 'ithin % "a#s ater the su!poena is maile". (.""e" to $?, !# 19+7, 14%1> .
1977, +&8> 1989, +85> %007, %81+< $?, 174.&+5 8lace o service. . su!poena re(uiring the atten"ance o a 'itness at a
hearing or trial ma# !e serve" at an# place 'ithin the ,tate o $eva"a. (.""e" to $?, !# 19+7, 14%1< $?, 174.&75
,u!poena or taCing "epositions> place o e)amination. 1. .n or"er to taCe a "eposition authorizes the issuance !# the
clerC o the court or the count# in 'hich the "eposition is to !e taCen o su!poenas or the persons name" or "escri!e"
therein. %. . resi"ent o this state ma# !e re(uire" to atten" an e)amination onl# in the count# 'herein the resi"ent resi"es
or is emplo#e" or transacts !usiness in person. . nonresi"ent o this state ma# !e re(uire" to atten" onl# in the count#
'here the nonresi"ent is serve" 'ith a su!poena or 'ithin 40 miles rom the place o service or at such other place as is
i)e" !# the court. (.""e" to $?, !# 19+7, 14%1< $?, 174.&85 Contempt. 1ailure !# an# person 'ithout a"e(uate
e)cuse to o!e# a su!poena o a court or a prosecuting attorne# serve" upon the person or, in the case o a su!poena issue"
!# a prosecuting attorne#, "elivere" to the person an" accepte", shall !e "eeme" a contempt o the court rom 'hich the
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su!poena issue" or, in the case o a su!poena issue" !# a prosecuting attorne#, o the court in 'hich the investigation is
pen"ing or the in"ictment, inormation or complaint is to !e trie". (.""e" to $?, !# 19+7, 14%1> . 1979, 1&0> 1995,
108%<
$/2.3. ?49/, 01 C:2:9 8?0C/34?/, ?49/ 45(c< .$3 45("< an" see also GC?C8 45
(c< 8?0-/C-:0$ 01 8/?,0$, ,4AG/C- -0 ,4A80/$..
(1< . part# or an attorne# responsi!le or the issuance an" service o a su!poena shall taCe reasona!le steps to avoi"
imposing un"ue !ur"en or e)pense on a person su!Fect to that su!poena. -he court on !ehal o 'hich the su!poena 'as
issue" shall enorce this "ut# an" impose upon the part# or attorne# in !reach o this "ut# an appropriate sanction, 'hich
ma# inclu"e, !ut is not limite" to, lost earnings an" a reasona!le attorne#Hs ee.
(%<(.< . person comman"e" to pro"uce an" permit inspection an" cop#ing o "esignate" !ooCs, papers, "ocuments or
tangi!le things, or inspection o premises nee" not appear in person at the place o pro"uction or inspection unless
comman"e" to appear or "eposition, hearing or trial.
(A< ,u!Fect to paragraph ("<(%< o this rule, a person comman"e" to pro"uce an" permit inspection an" cop#ing ma#,
'ithin 14 "a#s ater service o the su!poena or !eore the time speciie" or compliance i such time is less than 14 "a#s
ater service, serve upon the part# or attorne# "esignate" in the su!poena 'ritten o!Fection to inspection or cop#ing o an#
or all o the "esignate" materials or o the premises. : o!Fection is ma"e, the part# serving the su!poena shall not !e
entitle" to inspect an" cop# the materials or inspect the premises e)cept pursuant to an or"er o the court !# 'hich the
su!poena 'as issue". : o!Fection has !een ma"e, the part# serving the su!poena ma#, upon notice to the person
comman"e" to pro"uce, move at an# time or an or"er to compel the pro"uction. ,uch an or"er to compel pro"uction shall
protect an# person 'ho is not a part# or an oicer o a part# rom signiicant e)pense resulting rom the inspection an"
cop#ing comman"e".
(&<(.< 0n timel# motion, the court !# 'hich a su!poena 'as issue" shall (uash or mo"i# the su!poena i it
(i< ails to allo' reasona!le time or compliance>
(ii< re(uires a person 'ho is not a part# or an oicer o a part# to travel to a place more than 100 miles rom the place
'here that person resi"es, is emplo#e" or regularl# transacts !usiness in person, e)cept that such a person ma# in or"er to
atten" trial !e comman"e" to travel rom an# such place 'ithin the state in 'hich the trial is hel", or
(iii< re(uires "isclosure o privilege" or other protecte" matter an" no e)ception or 'aiver applies, or
(iv< su!Fects a person to un"ue !ur"en.
(A< : a su!poena
(i< re(uires "isclosure o a tra"e secret or other coni"ential research, "evelopment, or commercial inormation, or
(ii< re(uires "isclosure o an unretaine" e)pertHs opinion or inormation not "escri!ing speciic events or occurrences in
"ispute an" resulting rom the e)pertHs stu"# ma"e not at the re(uest o an# part#, the court ma#, to protect a person
su!Fect to or aecte" !# the su!poena, (uash or mo"i# the su!poena or, i the part# in 'hose !ehal the su!poena is
issue" sho's a su!stantial nee" or the testimon# or material that cannot !e other'ise met 'ithout un"ue har"ship an"
assures that the person to 'hom the su!poena is a""resse" 'ill !e reasona!l# compensate", the court ma# or"er
appearance or pro"uction onl# upon speciie" con"itions.
- 11D1% -
,4A80/$. .$3 ,4A80/$. 34C/, -/C4@
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("< 34-:/, :$ ?/,80$3:$; -0 ,4A80/$..(1< . person respon"ing to a su!poena to pro"uce "ocuments shall
pro"uce them as the# are Cept in the usual course o !usiness or shall organize an" la!el them to correspon" 'ith the
categories in the "eman". (%< 6hen inormation su!Fect to a su!poena is 'ithhel" on a claim that it is privilege" or su!Fect
to protection as trial preparation materials, the claim shall !e ma"e e)pressl# an" shall !e supporte" !# a "escription o
the nature o the "ocuments, communications, or things not pro"uce" that is suicient to ena!le the "eman"ing part# to
contest the claim.
- 1%D1% -
,4A80/$. .$3 ,4A80/$. 34C/, -/C4@
(
EXHIBIT /17/1
RENO
.cMUNICIl'Al COURT
P.O. L900
Rfno. NV &9505
(702) :04.2290
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IN THE MUNICIPAL COURT OF THE CITY OF RENO
COUNTY OF WASHOE, STATE OF, NEVADA
FILeD
CITY OF RENO,
Plaintiff,
RENO MUNICIPAL COURT
Case No. II 3
Dept. 3 MAR 1 3 2012
vs.
TIME .
BY Cl .
ZACHARY BARKER COUGHLIN,
Defendant.
DOROTHY HOlMeS, JuoGi
SUA SPONTE ORDER DENYING IYn,IEF SOUGHT IN IMPROPER DOCUMENT
On March 9, 2012, at 12:38 p.m., defendant Zachary Barker Coughlin, an attorney and
self-represented litigant in the instant traffic citation case, began fax-filing a 2lS-page
document to the Reno Municipal Court purporting to seek various and sundry types of relief
from this court on a "Boulevard Stop" traffic citation matter. He labeled his document "Motion
to Return Cell Phones; Motion to Set Aside Summary Contempt Order; and Notice of Appeal
of Summary Contempt Order." Said document was filed by the Clerk of the Court, on Monday
March 12,.2012, after causing much disruption to the court's operations.
The court herein issues this Order sua sponte to prevent the plaintiff, Reno City
Attorney, from devoting any additional time or resources to this document, and to relieve the
plaintiff from any burden of attempting to respond to said document. Likewise, the court staff
is relieved of any obligation to further deal with this aberrant document.
The court finds that the defendant has failed to follow proper legal procedure in
preparing and filing his motions and purported Notice of Appeal. The court also finds that Mr.
Coughlin has blatantly abused the court's fax-filing process offered for the convenience of
parties appearing in this court. As with his previous, mostly incoherent document, this
document filed by Mr. Coughlin appears to be a recitation of family grievances, lyrics to rock
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RENO
MUNICIPAl.. COURT
P.O. Box 1900
Rctn.NVg9S(l5
(702) 334_2190
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IS
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songs, disjointed legal ramblings, citations and argument in another case with another judge in
a different department of Reno Municipal Court, and, is, thus, even more irrelevant to the
instant case than the 224-page document previously filed by Mr. Coughlin.
IT IS ORDERED that any and all relief sought by the defendant Zachary Barker
Coughlin in the above-described document is denied.
IT IS FURTHER ORDERED that Zachary Barker Coughlin shall refrain from, and is
hereby barred and prohibited from faxing any documents to Reno Municipal Court.
IT IS ALSO ORDERED that if Zachary Barker Coughlin wishes to file documents in
Reno Municipal Court on any matter assigned to Department 3, he must present signed
originals only, in appropriate legal form and format, limited to no more than 15 pages in length,
and before they are filed, the clerk of the court shall present them to this court for review in
chambers, and this court will make a precfiling determination ifthey can be filed by the clerk.
IT IS SO ORDERED
Dated this 13th day of March, 2012.
~ /1 / ~
/' 1/4:/-/{ r:r 7"-"2 ""7-<0>
The Hon. Do thy Nash Holmes
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Reno Municipal Judge
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Reno Municipal Court
Dorothy Nash Holmes,
Judge
:P.O. Box 1900
Reno, NV 89505
(77S) 334382Z
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Pursuant to NRCP S(b), I eaFtlfy that I am an employee of the Reno Municipal
Court, Reno, Nevada, that I am v ~ r the age of 18 years and not a party to the above
action, and that on this date, servea a true and correct copy of the attached document
to the following as set forth b\'1low:
Allison Ormaas
Deputy City Attorney
PO Box 1900
Reno NV 89505
Zachary Barker Coughlin, &51'1.
1422 E. 9
th
Street #2
Reno NV 89512
X Placing said document in a SealEild envelope and placed for collecting and
mailing by Unites States mail In Rano, Navada, postage prepaid following ordinary
business practices.
Washoe County Jail
Court Services
Facsimile (FFAX)
Electronic Mail (Emall)
Inner.officemail following ordinary business practices
Personal Delivery.
DATED: March 13,2012.
artment Three
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11 7 12 0204 063341 D RCA Skau's Motion For Protective Order To Quash Subpoenas and For Protective ORder RE Issuance of Subpoenas

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