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retaliating against me, or afraid fo the Reno City Attorney?

From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Wed 2/22/12 3:05 AM
To: lori.matheus@washoecourts.us; joey.hastings@washoecourts.us;
joey.orduna@washoecourts.us; courtadmin@washoecourts.us; fourthestate@gmail.com;
centerforcourtadministrationaccountability@yahoo.com; eflexsupport@washoecourts.us
3 attachments
FV11-02864_2662470 J OFFEE VIOLATIONS OF WDCR 10.pdf (59.3 KB) , 1 29 2012 letter to
Clerk of Court Orduna Hastings regarding Eflex rejections with attachments 41 pages
total.pdf (957.8 KB) , CR11-2064-2690562 Reno City Attorney Index to Exhibits lack line
numbers yet not rejected under WDCR 10.pdf (229.0 KB)
Dear WDC,

I have had many, many extremely important filings rejected of late based upon the "index ot exhibits
needs to have line numbers on it", when in criminal cae filings where WDCR 18 expressly forbids the
clerk rejecting filing for form issues. Now, I notice Reno City Attorney Pam Roberts is able to file what
she wishes to, in a timely manner, without having her attempts to access justice cruely thwarted. To
wit, the attached filing by Pam Roberts, Esq. contains what I imagine she intends to be an Index to
Exhibit, but which she has title a "List of Attachments". Of course, that page lacks line numbers,
somethign for which I have had numerous filings rejected, even where time was of the essence, and, I
believe, even where so rejecting was prohibited by WDCR 18:
"Rules of Practice for the Second J udicial District Court of the State of Nevada Rule 18. Papers which do
not comply with rules Except in criminal cases and writs arising from criminal cases, filing office
personnel shall refuse to file any document or pleading which is not properly signed by all persons, or
which does not comply with these rules, Nevada Rules of Civil Procedure, the District Court Rules, or
applicable statutes. " Second J udicial District Court Rule 18, NV ST 2 DIST CT Rule 18
Further, the Affirmation is placed in a manner that does not comply with WDCR 10 (I have had my
filings rejected numerous times for just this reason:
WDCR 10(4) provides that: "4. Pursuant to NRS 239B.030(4), the Second J udicial District Court requires
that an Affirmation must be attached as the last page of each document presented for filing and before
any attached exhibits, or the Affirmation may be the last sentence before the signature line on the
document, stating that the document does not contain the social security number of any person. If the
document does contain the social security number of any person, the affirmation must indicate the
specific state or federal law requiring said number. The Affirmation form is available at the Second
J udicial District Court Filing Office and on the court's website at www.washoecourts.com. " Second
J udicial District Court Rule 10, NV ST 2 DIST CT Rule 10.


Now, I am probably going to go out of business soon, or get disbarred or both, due in large part to my
inability to get the WDC filing office or Eflex staff to allow me to access justice on behalf of my clients,
or my self (I have some pro se actions). AT that point, I will need something to do with my time, and I
imagine that will involve dissecting all the various rejections Ms. Matheus et al have rendered, and
assessing the effect such rejections had on my business, my license, and any other damages so
sustained by this deprivation, under color of law, of my fundamentals rights, due, at least in part, to a
discriminatory and retaliatory intent on the part of those making the rejections, upon information and
belief, of course. What I really want to do is just scratch out a living practicing law, and, hopefully,
from the 15 page letter I wrote Clerk of Court Orduna regarding the intricacies of WDCR 10, I have
made clear that I take seriously the spirit and intent of WDCR 10 and am making strong efforts and
stride towards praciting in the Second J udicial District in a considerate manner that is mindful of the
premium that the Court must place on judicial economy and preserving resources. Please add this
correspondence to the paper trail that has been metastasizing grotesquely (like a hanzel and gretl
breadcrumb collection) in support of my contention that retaliation and discrimination against me have
resulted in an inordinate rejection of my filings, whereas the DA and, here, the Reno City Attorney, and
others do not face such obstacles in their attempts to access justice.

As for the uneven treatment given to rejections based upon the Index to Exhibits not having line
numbers on the left side of the page, please see pages 6, 7, 8 of the attached 1 29 2012 letter to Clerk
of Court Orduna, detailing previous rejections of my filings on that basis where Reno City Attorney
Roberts attached filing was not rejected:
"
WDCR 10(6). ... All exhibits attached to pleadings or papers must be preceded by an Index of
Exhibits indicating the exhibit number, exhibit description, and the length of each exhibit (number of
pages)....
Matheus has rejected a number of extremely time sensitive filings (many of which she had
previously rejected for some other reason) based upon her position that the Index to Exhibits must be
on paper with line numbers. However, WDCR 10(6) and WDCR 10(1) make clear that an Index to
Exhibits does not come within those items to which those that rule applies, further, I have had a filings
accepted previously containing an Index to Exhibits that does not have line numbers on it.....
Reason(s) for rejection: Signature on documents must appear on the same document as the text. Lines
of pages must be numbered in the left margin or on legal pleading paper. Page 17 (Note: Page 17 is the
Index to Exhibits) is not numbered in the left margin. If you have any questions, please call Lori at
328-3114...
Reason(s) for rejection: ...The Proof of Service does not comply with WCDR 10(1) Lines of pages
must be numbered in the left margin or on legal pleading paper.

"To: Zach Barker Coughlin, Esq. zachcoughlin@hotmail.com
From: eflex@washoecourts.us
Date: 2012-01-23 18:22:36.0
Subject: Your electronic filing, Re: CV09-00710 - Other Torts: Fraud/Misrepresentation - FM -
Request for Submission, was rejected by Second Judicial District Court - State of Nevada.
Case Number: CV09-00710
Case Type: Other Torts: Fraud/Misrepresentation - FM
Document Type: Request for Submission
Reason(s) for rejection:
The document does not comply with WCDR 10(1) Lines of pages must be numbered in the
left margin or on legal pleading paper. Any questions, please call Lori at 328-3114."




"To: Zach Barker Coughlin, Esq. zachcoughlin@hotmail.com
From: eflex@washoecourts.us
Date: 2012-01-23 17:59:48.0
Subject: Your electronic filing, Re: CV11-01896 - Employment Torts (Wrongful termination) - WT -
Mtn to Set Aside Decree, was rejected by Second Judicial District Court - State of Nevada.
Case Number: CV11-01896
Case Type: Employment Torts (Wrongful termination) - WT
Document Type: Mtn to Set Aside Decree
Document Type: **Continuation
Reason(s) for rejection:...Proof of Service does not comply with WCDR 10(1) Lines of
pages must be numbered in the left margin or on legal pleading paper...."


"From: eflex@washoecourts.us
Sent: Tue 1/24/12 1:31 PM
To: zachcoughlin@hotmail.com
To: Zach Barker Coughlin, Esq. zachcoughlin@hotmail.com
From: eflex@washoecourts.us
Date: 2012-01-23 18:01:04.0
Subject: Your electronic filing, Re: CV11-01955 - Employment Torts (Wrongful termination) - WT -
Mtn for Extension of Time, was rejected by Second Judicial District Court - State of
Nevada.
Case Number: CV11-01955
Case Type: Employment Torts (Wrongful termination) - WT
Document Type: Mtn for Extension of Time
Reason(s) for rejection:
Page 14 of the document is a declaration. The declaration needs to contain the original
signature of the declarant. The Proof of Service does not comply with WCDR 10(1) Lines of
pages must be numbered in the left margin or on legal pleading paper..."

"
To: Zach Barker Coughlin, Esq. zachcoughlin@hotmail.com
From: eflex@washoecourts.us
Date: 2012-01-24 20:35:22.0
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=7eb...
Subject: Your electronic filing, Re: CV11-01896 - Employment Torts (Wrongful termination) - WT -
Mtn to Set Aside Decree, was rejected by Second Judicial District Court - State of Nevada.
Case Number: CV11-01896
Case Type: Employment Torts (Wrongful termination) - WT
Document Type: Mtn to Set Aside Decree
Document Type: **Continuation
Reason(s) for rejection:
Document does not comply with WCDR 10. Lines of pages must be numbered in the left
margin or on legal pleading paper. If you have any questions, please call Lori at 328-3114."


"From: eflex@washoecourts.us
Sent: Wed 1/25/12 12:07 PM
To: zachcoughlin@hotmail.com
To: Zach Barker Coughlin, Esq. zachcoughlin@hotmail.com
From: eflex@washoecourts.us
Date: 2012-01-24 20:11:35.0
Subject: Your electronic filing, Re: CV11-01955 - Employment Torts (Wrongful termination) - WT -
Mtn for Extension of Time, was rejected by Second Judicial District Court - State of
Nevada.
Case Number: CV11-01955
Case Type: Employment Torts (Wrongful termination) - WT
Document Type: Mtn for Extension of Time
Document Type: **Continuation
Reason(s) for rejection:
Document does not comply with WCDR 10. Lines of pages must be numbered in the left
margin or on legal pleading paper. Exhibits must be separated by a divider page and
clearly marked with the exhibit number at the top and bottom of the page. If you have
any questions, please call Lori at 328-3114"


"
To: Zach Barker Coughlin, Esq. zachcoughlin@hotmail.com
From: eflex@washoecourts.us
Date: 2012-01-26 00:50:41.0
Subject: Your electronic filing, Re: CV11-01955 - Employment Torts (Wrongful termination) - WT -
Mtn for Extension of Time, was rejected by Second Judicial District Court - State of
Nevada.
Case Number: CV11-01955
Case Type: Employment Torts (Wrongful termination) - WT
Document Type: Mtn for Extension of Time
Document Type: **Continuation
Document Type: **Continuation
Reason(s) for rejection:
Signature on documents must appear on the same document as the text. Lines of pages
must be numbered in the left margin or on legal pleading paper. Page 17 is not numbered
in the left margin. If you have any questions, please call Lori at 328-3114"




Sincerely,

Zach Coughlin, Esq., 1422 E. 9th St. #2, RENO, NV 89512, tel: 775 338 8118, fax: 949 667 7402;
ZachCoughlin@hotmail.com Nevada Bar No: 9473