Filed: Electronically 01-05-2012:11:00:17 PM Joey Orduna Hastings Clerk of The Court Transaction # 2683734

Document Code:
Zach Coughlin, Esq.

NV Bar No: 9473
1422 E. 9
th
St. #2
Reno, NV 89501
Tele: 775-229-6737
Fax: 949-667-7402
Pro per Appellant
IN THE SECOND JUDICIAL DISTRICT COURT OF THE
STATE OF NEVADA IN AND FOR
THE COUNTY OF WASHOE
ZACHARY BARKER COUGHLIN
PlaintiII,
vs.
MATT MERLISS, MD, ; MATTHEW J.
MERLISS LIVING TRUST;
DeIendant.
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CASE NO:
DEPT. NO: 7
REPLY TO DEFENDANT'S AMENDED
EMERGENCY MOTION FOR
TEMPORARY RESTRAINING ORDER
OR IN1UNCTION PREVENTING
MERLISS FROM ~DISPOSING OF
TENANTS PROPERTY; OR, IN THE
ALTERNATIVE; MOTION FOR STAY
REPLY TO DEFENDANT'S AMENDED EMERGENCY MOTION FOR TEMPORARY
RESTRAINING ORDER OR IN1UNCTION PREVENTING MERLISS FROM
~DISPOSING OF TENANTS PROPERTY; OR, IN THE ALTERNATIVE; MOTION FOR
STAY
APPELANT, ZACH COUGHLIN, appearing pro se and, unlike Baker or Hill, not getting
paid $45,000 in attorney's Iees since the Iiling oI the NO CAUSE eviction notice in RJC Rev2011-
001708, hereby Iiles this Reply to Merliss's attempts to oppose appellant's "amended emergency
motion Ior temporary restraining order." Despite the complete lack oI merit oI the opposition to the
instant motion (replete with Richard G. Hill, Esq's well known tactics, which include lying regularly,
1/24 REPLY TO OPPOSITION TO AMENDED EMERGENCY MOTION FOR TEMPORARY RESTRAINING
ORDER OR INJUNCTION PREVENTING MERLISS FROM 'DISPOSING OF TENANTS PROPERTY; OR, IN
THE ALTERNATIVE; MOTION FOR STAY
F I L E D
Electronically
01-05-2012:11:00:17 PM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2683734
alleging opposing counsel is lying despite Iailing to include any speciIics with regard to how that
may be, and Hill's numerous attempts to state something as absolute Iact to the court when, in reality,
it is nothing more than what Hill wishes or thinks might kind oI be the truth, or something that Hill
would Iind a lot more convenient were it the truth and he didn't have to bother with actually having a
basis Ior asserting that it was the truth....), Merliss has Iailed to reIrain Irom disposing oI any property
leIt behind by Mr. Coughlin pending this court's ruling on the motion, especially where Baker and
Hill continue to leave Coughlin's property unlocked, outside the house, practically replete with a neon
sign asking passerbys to steal it. This Reply to the opposition is based on the points and authorities
below and all papers and pleadings on Iile herein. THERE IS one thing that is really important to
remember here, though...why is it that Richard G. Hill, Esq. and Merliss Ieel the need to go into all
these outrageous allegations in the context oI opposing a TRO or Motion For Stay? Why not just
Iocus on the relevant Iacts and law? Is it because NRS 40.385 is so very bad Ior their case? Is it
because one simply cannot use a Summary Eviction Proceeding against a commercial tenant
according to bright line black letter law in Nevada, pursuant to NRS 40.253? Is it because they know
they have to pick their poison, ie, either I am a residential tenant and my rent is under $1,000, so
under NRS 40.385, by depositing the statutorily set sum oI $250 with the Justice Court I "may" get a
stay during the pendency oI the appeal, versus, where I am deemed a "commercial tenant"....sure the
bond can be set somewhere near three times the monthly rent...but, GIVEN THE FACT THAT
BAKER AND HILL CONDUCTED WHAT (AND THEIR NEUROSURGEON CLIENT WILL
UNDERSTAND THIS, INCLUDING WHETHER OR NOT THEY GOT HIS INFORMED
CONSENT TO IT) WAS, ESSENTIALY, A 'WRONG SITE SURGERY" BY USING A NO
CAUSE EVICTION NOTICE TO EVICT A COMMERCIAL TENANT, IN DIRECT
CONTRAVENTION OF THE EXPRESS DICTATES OF THE BENCH BOOK, NRS 40.253, AND
THE ANVUI AND GLAZIER DECISIONS OF THE NEVADA SUPREME COURT, MERLISS'S
WHOLE CASE FALLS DOWN LIKE A HOUSE OF CARDS. And cue the sad, mournIul wrongIul
eviction soundtrack and ensuing litigation....Also, Mr. Hill is curiously silent with respect to the
Lease Agreement (attached herein as Exhibit 1), which, at Paragraph 10, clearly states: "Resident
further may use the premises for any commercial enterprise, but not for any purpose which
unlawful." Likewise, the Lease Agreement in this matters, at Paragraph 11 holds: "OCCUPANCY:
Occupancy oI the premises is limited to 2 adults...and shall be used Ior a residence and for other
purposes." (Emphasis added).
POINTS AND AUTHORITIES
This is an appeal Irom a summary eviction granted in the Reno Justice Court. The pertinent
Iacts Ior purposes oI this motion are as Iollows:
1. On November 13th, 2011Respondent, MATT MERLISS ("MERLISS") and his attorney
Richard G. Hill, contributed to the wrongIul arrest oI Coughlin Ior trespass, misleading the Reno
Police Department as to Hill's OIIices November 10th, 2011 correspondence to Coughlin wherein it
inIormed Coughlin it was charging Coughlin the "Iull rental value oI the property" Ior the entire
month oI November. Further Hill Iailed to inIorm the Reno Police Deparment oIIicer's Carter and
Lopez that Coughlin had both called and written Hill's oIIice numerous with respect to Coughlin's
personal property and that Coughlin had, on numerous occasions, in writing and verbally, inIormed
Hill and his associate and staII that the undersigned did not consent to service oI ANYTHING Irom
Hill or anyone with his oIIice via electronic means, especially where Hill and Baker had continually
sought to impermissibly speed up a Summary Eviction Proceeding that is already too Iast,
particularly where it is being used impermissibly against one oI Nevada's Iew remaining small
businessmen, in direct contravention oI NRS 40.253. A not so happy by product oI Merliss Baker
and Hill's attempts to prove to the Nevada legal community that, with enough money spent litigatin'
and whatnot, a landlord can get the court's to rule whichever way they need the court to rule,
regardless oI what the law actually says. Sure, Baker and Hill's "wrong site surgery" here, in
bringing a Summary Eviction Proceeding, with only a No Cause Notice oI Eviction service (ie, no
allegation oI non-payment oI rent was stood behind) has done devastating damage to not on
Coughlin's practice and liIe, but that oI his Iamily and loved ones. Besides the cataclysmic disaster
this eviction has wrought on Coughlin's Iive year relationship with his then girlIriend and co-tenant
Melissa Ulloa, is the terrible emotional toll exacted upon Coughlin's extended Iamily (including a
mother who has served the local non-proIit, Very Special Arts Nevada admirably Ior 20 years, a
Iather who has bourne untold miseries, conIidences, and late night phone calls Irom patients as a
gladiator Iamily physician in the Reno area since 1979 with a special emphasis on addiction medicine
(and which has, at times, brought him in Iairly close proximity with some individuals Iairly integral
to the operation oI justice in our community). Some oI those Coughlin's Iather's addiction medicine
emphasis was relayed to are particularly disgusted with this ridiculous god damn lying bullsh&t Hill
and Baker seek to peddle beIore this court about Iinding a "crack pipe and a bag oI weed" at the
undersigned's law oIIice". II Judge Robert Perry (who managed to be a casino change person and a
U.S. Naval Academy graduate), may he rest in peace, was around to hear the bilge and dreck that Hill
and Baker seek to paint on those so recklessly, so dubiously, and so totally devoid oI any basis in
Iact, I have to imagine, Irom personal experience with the man born oI many a Thursday night get
together, and many a lunch time meeting, that he would smack them across their god damn lily
livered Iaces). Further distress and trouble on Iamily relationships has this wrongIul eviction exacted
on the undersigned relationship with a sister who is an occupational therapist, two others' who are
educators in grade and middle school, etc., etc). Merliss, Hill, and Baker Iret and strut their hour
upon the bench, Iull oI sound and Iury, signiIying only their own avarice and greed and complete lack
oI Iidelity to the dictates oI NRCP 11. They are a pox on the legal proIession.
At the scene oI the arrest, the Iollowing words came out oI Reno Police Department Arresting
OIIicer Carter's mouth: "Richard Hill pays me a lot oI money so I arrest who he says to arrest and I
do what he tells me to do...". Both OIIicer's Carter and Lopez reIused to query Hill with respect to
the existence and import oI Hill's November 10th, 2011 written correspondence/bill to Coughlin Ior
the Iull rental value oI the property Ior November, some $900, on the arrest date oI November 13th,
2011, making even more curious the arresting oIIicers decision to conduct a Iull on custodial arrest
(rather than declare the situation "a civil matter" as the Reno Police Department does just about
anytime Coughlin calls them to seek to have them keep the peace, including a recent indicent where
the very same OIIicer Lopez showed up to the most recent property Coughlin has rented and reIused
to protect Coughlin or make an arrest even though Coughlin oIIered OIIicer Lopez audio and video
recordings oI an domestic relationship assault and battery against Coughlin, even where Coughlin's
tires were slashed and an illegal lockout and interruption oI essential services were perIormed against
Coughlin and Coughlin pleaded with OIIicer Lopez to do something. Somehow, the circumstances
detailed in the 4-6 911 calls by Coughlin, starting on approximately December 29th, 2011, through
January 2, 2011 did not justiIy a custodial arrest, but whatever it is that Reno Police Department
OIIicer's Carter and Lopez used Ior motivation on November 13th, 2011, did result in a custodial
arrest oI Coughlin, replete with the strip search, issuance oI jail clothes and tiny toothbrush, angry
SheriII's Deputies reIusing to provide "tier time" to Coughlin, even where is was absolutely necessary
to do so iI Coughlin were to be aIIorded an opportunity to make other arrangments Ior his law
practice's clients suIIicient to avoid prejudicing their cases....
Merliss is the owner oI the residential real property located at 121 River Rock, Reno, Nevada
(the "PROPERTY"), though Green Action Law Service's Ioreman stated that Dickson Realty Realtor
and quasi property manager Darlene Sharpe was the "lender".
2. Amongst the property Hill Merliss and Baker wrongIully applied a lien to were har drives,
including those containing sensitive client inIormation. THERE IS EVIDENCE THAT THOSE
HARD DRIVES WERE ACCESSED AND OR COPIED WHILE IN HILL AND BAKERS
POSSESSION! THAT IS AN OUTRAGE OF EPIC PROPORTIONS. Appellant, ZACHARY
BARKER COUGHLIN, Esq.'s law practice and mattress/Iurniture business "Coughlin Memory
Foam" ("COUGHLIN"), was a commercial tenant at the Property beginning in late February 2010.
Coughlin's rent pursuant to the lease was $900.00 per month (ie, under the $1,000 limit mentioned in
NRS 40.385, and thereIore a $250 bond posting should have yielded a stay, much less the RJC
keeping Coughlin's $2,275...especially where Baker "remixed" Judge SIerrazza's pronouncement oI
his ruling Irom the bench on October 26, 2011, a practice that the weasel Baker reportedly does
whenever possible. When Coughlin "last paid rent" has not been litigated at all in this case or RJC
Rev2011-001708, indeed, IT WAS A NO CAUSE EVICTION NOTICE that was served in that case,
why would a court spend any time on when rent was last paid. Hill continues to try to paint the court
in clown makeup with his rubbish allegations oI how "when rent was last paid" was this or that. Stop
it Richard, you embarass not only yourselI, but your brethren in the legal proIession in the process.
Hill lies in his typical and patented style (and Iurther, the undersigned has repeatedly, and does so
again herein, state that he has neither the time nor inclination to respond to every baseless allegation
Hill makes, as such, a blanket denial applies to anything uttered or written by Hill, his associate, his
staII, anyone Hill has every loved, anything Hill has ever touched, gazed upon, or otherwise
besmirched), in his Opposition, a state oI aIIairs which he has unseemingly passed on to his associate
Baker, when he writes that: "As discussed below, the justice court rejected all oI Coughlin's reasons
Ior not paying rent...." Pray tell, Mr. Hill, why would the Justice Court even bother looking into to
whether rent was paid or not (it didn't and no testimony was oIIered in that regard, nor was any
evidence produced as Hill and Baker were to IearIul oI the NRCP Rule 11 motion Coughlin had saIe
harbored against them) WHEN HILL AND BAKER ONLY SERVED COUGHLIN WITH A NO
CAUSE NOTICE OF SUMMARY EVICTION.
3. On October 27, 2011, not, as Hill mis-states "aIter two evidentiary hearings on the matter",
but aIter October 13th, 2011 hearing, which Judge SIerrazza then continued to a TRIAL on
November 26th, 2011 (that was inappropriately notice and did not comply with the service, notice,
and process requirements oI TRIALS-think 20 days to respond to a Notice served on November 5th,
2011, not 19 days to prepare Ior a TRIAL....-, under Nevada's JCRCP 105-110), which WAS
NOTICE IN WRITING AS A TRIAL, REFERRED TO AS A TRIAL, ETC., ETC. (even Baker has
to admit to Judge SIerrazza in open court that "the use oI the word Trial, Your Honor, was
regrettable....")...Perhaps the RJC wanted the October 26th 2011 court date to be a TRIAL, as it was
indicated to be IN WRITING AND NOTICE OF THE RJC because, pursuant to NRS 40.253(6), the
RJC and Judge SIerrazza are not permitted to take Coughlin's $2,275 as some sort oI "rent escrow
deposit required to litigate habitability issues), especially where N. JCRCP 83 requires the RJC to
publish and get approved by the N. S. Ct. any sort oI analogue to JCRLV Rule 44, which is
something even Las Vegas barely can enIorce without blushing considering the inhuman toll it exacts
upon tenants....
4. Funny thing about the Reno Justice Court: when it comes to setting a hearing within 10
days oI my Iiling Motion to Contest Personal Property Lien on November 16th, 2011, the RJC is all
"oh, we needed your permission, Mr. Coughlin, to set such a hearing, its your Iault that we couldn't
get it on within the 10 days required by statute under NRS 40.253(7-8); however, when Coughlin
went in to Iiled something on November 3, 2011 at 4:58pm, RJC Iiling oIIice ChieI Clerk Karen
Stancil didn't need no permission to serve personally on Coughlin Notice oI a Hearing to take place
on Monday, November 7, 2011. Well, actually, allegathetically, another clerk had to sneak that
Notice oI the Hearing on November 7, 2011 into a stack oI papers she slipped Coughlin when she
was pretending to be helpIul Ior a change, rather than sullen, and overly opinionated Ior someone
who cares so little oI the import oI the Whitman, Devodo, and Sullivan decisions oI the Nevada
Supreme Court with respect to court employees legislating Irom the Iiling oIIice desk and reIusing to
accept Iilings because they just aren't Ieeling it that day.... You see, somebody at the RJC Iigure out
that it probably was not legal to hold on to Coughlin last $2,275 on earth iI it was not granting him a
stay (especially where NRS 40.385 entitles Coughlin to one, Ior his posting a bond as little as $250
(instead the RJC kept Coughlin's $2,275, and iI you believe Hill, did not grant a stay) as, in Judge
SIerrazza's words, that would be "conversion". So, how again is it Mr. Hill's outrageous allegations
oI Coughlin living here or there during this or that period (somethign which Hill never bothers to
support with anything other than his own bluster, hot air, and conjecture, and apparent willingness to
to incur NRCP Rule 11 sanctions iI it means milking a willIul neurosurgeon good and dry in the
process) On November 1, 2011, Coughlin was lawIully and properly locked out oI the Property.
5. On November 13, 2011, Dr. Merliss and Mr. Hill turned their little sony video camera on
when it was convenient and, presumably, disposed oI any Iootage that was not quite so convenient. I
could say I know they did this, but then I would be a jackass like Richard Hill writing that I know
things when I can only guess as to whether they are true or not, and be Iorced to cower behind some
yellow bellied "privelege oI the participant" ability to deIame litigants with impunity (a subject I
wrote about Ior the law journal "write on competition" while part oI the early days crowd at UNLV's
Boyd School oI Law (where Hill and Baker would not have lasted a second), earning one oI two or
three "Rights oI First ReIusal" to the astonishment oI my classmates, who would somehow still
manage to be astonished when I passed the bar exam in the summer Iollowing only my second year
oI law school...yet Hill and Baker describe me to the RJC, in justiIying the need to so curtail my
access to the property, as some sort oI lawyerly Uncle Fester idiot savant crackhead...go Iigure....).
So Hill recklessly deIames the undersigned, writing in his Opposition that he "discovered Coughlin
living in the basement oI the Property. Coughlin was arrested and charged with criminal trespassing
at that time. A motion Ior order to show cause why Coughlin should not be held in contempt oI the
justice court pursuant to NRS 22.020 is currently pending in that court. It was clear that Coughlin had
not made any attempt to remove any oI his belongings Irom the Property beIore he was caught living
in the basement, although he had been living there illegally Ior two weeks...." Well, Mr. Hill, iI that
is true (and the 5th Amendment applies in a civil context, and Iurther, what would that have to do
with a Motion Ior TRO or Stay anyways?), then wouldn't your Iailure to object during that time
constitute some sort oI laches, or permission to be their, particularly where your November 10, 2011
writing alleges the "Iull rental value" oI the property was currently being charged and accrued?
Regardless, though Hill continues to maintain that he has all this prooI that Coughlin was "illegally
living there", Hill never does quite manage to produce any such prooI, that is, unless Hill believes his
own conjecture to be tantamount to incontrovertible evidence, which he probably does, as anyone
who knows Richard would likely agree.
6. Even iI Hill's allegation that "During the time Coughlin was secretly living in the basement,
Mr. Hill was sending him emails almost daily in an eIIort to get Coughlin to make some eIIort to
remove his personal property Irom the residence.." were true (which is clearly is not) Hill had been
notiIied in writing numerous, numerous times and told verbally as well that email and other
electronic means oI any correspondence, communication, Iiling, or notice was not consented to by the
undersigned. II Hill were added to a "blocked sender list" in the undersigned's email, Hill certainly
would be unable to say he was not warned in that regard. Hill cannot say the same Ior written
correspondences sent by Coughlin.
7. On December 21, 2011, during hearing on Coughlin's motion to contest Merliss' personal
property lien, Coughlin chided Hill Ior entering the court room surreptiously despite being asked to
leave by Judge SIerrazza given the anticipation that Hill would be called as a witness, and Iurther
chided Hill Ior taking such a "big chance" by reIusing to return Coughlin's client's Iiles to Coughlin,
their attorney, particularly where those clients matters were so likely to be prejudiced by Hill's
misconduct, where Hill's client stood to gain so little by Hill doing som etc, etc. In response to
Coughlin invoking his distaste Ior Hill taking such a blase approach to the homeowners rights oI
middle class citizens oI Washoe County, Hill made some sort oI grotesque hand signal and Iacial
gesture seemingly meant to connote some masturbatory reIerence illustrating Hill's complete an utter
disconnection Irom his Iellow man and those citizens who, unlike Hill, do not have a stable oI some
6-8 Porches at home. Judge SIerrazza, inexplicably, exploded at Coughlin Ior pointing this out Ior
the record. Not sure how Coughlin's doing so necessitated such an uproar out oI Judge SIerrazza
when the undersigned was merely providing some accurate play by play Ior Hill's tacky sack dance.
8. Hill went to great lengths to limit, curtail, and obstruct Coughlin any access Couglin was
provided to the Property on Thursday, December 22, 2011, and Friday, December 23, 2011,
necessitating Coughlin having delivered personally written notice to Hill's oIIice demanding Hill
remove the padlock and metal chain on the back gate and take the boards oI oI the door to the rear oI
the house and rear porch, all oI which Hill Iailed to do.
9. On December 22, 2011, Coughlin sent an email to the undersigned and Judge SIerrazza,
pointing out, again, the existence oI NRS 40.385, something Ior which Judge SIerrazza and Hill, to
this day, are seemingly blissIully unaware oI. Judge SIerrazza quickly responded by email, and
reminded Mr. Coughlin that the stay had been denied, going on to cite to yet another Rule oI the
Justice Court oI Las Vegas that the Reno Justice Court has taken to enIorcing as a secret "house rule"
applied when needed, despite the RJC's Iailing to comply with the dictates oI JCRCP 83, ie,
publishing the review, subjecting it to actual sunshine, and getting it approved by the Nevada
Supreme Court, Ior to do so would be so bothersome and greatly curtail the ability oI the RJC and its
Iiling oIIice staII to make the world a better place Ior the Richard G. Hill's oI the world, as they do
through so many applications oI those neat old secret "house rules", the ones that, despite JCRRT 2's
dictate, allow RJC Iiling oIIice staII to order citizens to come down to the Iiling oIIice within 12
hours and personally serve themselves some notice oI some summary eviction hearing that is set to
take place entirely too soon under any reasonable reading oI the statute, etc., etc....
10. Coughlin was not aIIorded any legitimate opportunity remove all oI his personal property
Irom the premises, and Hill is tirelessly seeking to apply some unlawIul rent distraint and get out oI
complying with the law related to security depoists by trumping up some allegations that " a
substantial amount oI cleanup remains to be done." Hill goes on to make more allegations Ior which
he lacks prooI:" Coughlin also Iailed to comply with the court's order that any person accompanying
him to the property must sign the liability waiver attached to the court's order." What makes you
believe such signatures were not gathered Richard? Did the ORder say they had to be deliver to Mr.
Hill? No, it dint.
11. Both on Thursday and Friday, December 22-23, 2011, counsel Ior Merliss purposeIully
Iailed remove the padlock to the back gate oI the property (a padlock which was only placed on the
gate the day beIore Coughlin was to be allowed access to the property, a padlock which was not their
on that gate Ior the preceeding 6 some odd weeks that the property went unsecured, unwatched,
unlived in, but Ior which it did have the bright neon sign oI being boarded up that screamed to the
nearby residents oI the Lakemill Lodge "hey, come and break into me and steal the possessions inside
that you can see through the windows, which are not obscured by shades or anythign, see that 62 inch
HDTV? Take it. The guitars and monitors and audio equipment and 88 key hammer weighted action
keyboard? Take it!" . Hill only showed up to remove the padlock despite numerous requests
verbally, telephonically, and in writing personally hand delivered to his oIIice (Ior which a stamp oI
"received" was obtained by Hill's clerk) with about 1 hour to go on the access to the property
hourglass.
12. While Hill alleges that "While at the property to remove the padlock, Coughlin, on more
than one occasion, screamed proIanities at Merliss' counsel, and, at one point, charged Mr. Hill and
attempted to physically intimidate him. At least the audio oI this incident was captured on tape" Hill
and Baker, who had a video camera, curiously did not manage to get that on tape. Not did they
manage to make a tape oI the "inspection" they complained oI on October 4th, 2011. Nor did they
manage to, despite videoing nearly everything else on November 13th, 2011 get any Iootage oI
anyone, RPD, Merliss, Hill anybody, announcing who they were to Coughlin or asking Coughlin to
leave the premises prior to shutting the power oII to the basement and assaulting Coughlin, then
eIIectuating a wrongIul arrest oI Coughlin, attempting to steal Coughlin's three year old Pekingnese
dog., etc., etc...
13. Hill was just Ilat out lying like a weasel in his Opposition when he wrote that:
"Nevertheless, at 5:00 p.m. on Friday, December 23,2011, counsel granted Coughlin and his agents
additional, unIettered, and unlimited access to the outside oI the property to remove any remaining
items. The only condition placed on that access was that Coughlin's helpers agreed to replace the gate
on its hinges as best they could. Coughlin and his agents Iailed to remove the remainder oI Coughin's
property Irom the yard that night, and Iailed to put the gate back on the hinges." Indeed, Hill
gleeIully stated to Coughlin that he would be there as the property at 5pm, reIused to allow any
additional access and actually took property oI Coughlin's oII the sidewalk and removed it to back
behind the gates oI the property, which, some might say constitutes larceny on Hill's part.
14. On approximately December 28, 2011 Coughlin was Iorced to move again, as the
managers oI the Silver Dollar Motor Lodge where Coughlin was paying $600 a month in rent Ior the
privilege oI having his Ieet stick to the black mold growing on the Iloor/carpet, and having the
managers inIorm him in a hostile manner that they could "enter his room anytime they Ielt like it"
and aIter the managers produced some "attachment" to a contact inIormation page that they never
presented to Coughlin that sought to claim all sort oI unconscionable rights owing to them, and aIter
seeking to verbally and physically threaten Coughlin (in addition to threaten to make Ialse accusation
against Coughlin designed to deIame Coughlin's proIessional reputation in retalitation Ior Coughlin
hand delivery a habitability notice on December 17th, 2011 upon the Silver Dollar Motor Lodge
related to the moldy carpet....) Nevada's landlord's have been sent a pretty clear message by the
court's: Do whatever the hell ya Ieel like boys, is okay? Whereupon Couglin Iound a rental on
Craiglist...sadly that did result in Couglin being chase up stairs by the landlord with a butcher kniIe,
Coughlin's tires on his vehicle being slashed, Coughlin having the locks to his rental changed at 1 am
on New Years Day, etc., etc. in retaliation Ior Couglin Iailing to agree to additional charges beyond
those bargained Ior and meeting with oIIer and acceptance on December 28, 2011. Curiously,
despite all the domestic violence committed upon Coughlin by his "roomates/landlords", the RPD did
not see Iit to make a custodial arrest like that made on Coughlin on November 13, 2011. Hill
attempts to paint the court in clown makeup so more, writing "On December 28, 2011, Mr. Hill sent
an email to Coughlin, oIIering him another opportunity to Iinish retrieving his belongings Irom the
Property. A true and correct copy oI that email is attached hereto as EXHIBIT 5. Coughlin did not
accept Mr. Hill's oIIer, or respond in any way to that email." Um, what do you call all the emails
attached in Exhibit 2 Mr. Hill? Regardless, much like their perIormance at the December 20, 2011
hearing, unattended by their neurosurgeon client, HIll and Baker, in those emails, mainly sought to
curtail their own liability with respect to the wrongIul eviction action Coughlin has previously sought
to Iile in the WDC and which he Iully intends to Iile once he can pay the Iiling Iee. In the 12/28 and
12/29 email Hill mainly seeks to get Coughlin to waive the rights he has to the security deposit oI
some $700 under the Lease Agreement and the approximately $1,000 statutory penalty no owing
considering Hill and Baker's Iailure to account Ior in writing within 30 days the state oI the security
deposit or otherwise return it.
15. On December 29, 2011, the Hill allegedly re-sent Mr. Hill's email to Coughlin. A true and
correct copy oI the undersigned's email.
16. On December 30, 2011, aIter having just barely sent it to someone who had previously
indicate to Hill in writing that he did not consent to email service oI anything, Mr. Hill revoked the
oIIer extended in his December 28, 2011 email.
17. Also problematic Ior Merliss is Paragraph 13 oI the Lease Agreement (see Exhibit 1),
which holds that: "13. UTILITIES: Resident agrees to pay Ior the Iollowing utilities: Gas x
Electricity x Oil, Light x, Heat x, Energy x, Other, Resident's responsibility Ior these begins
at the commencement oI this agreement. See attached transIer oI account Addendum (note: there is/
was no such TransIer oI Account Addendum attached to the Lease Agreement). Utilities not
payable by the Resident will be paid by the Management." Merliss's counsel clearly spent a lot oI
other people's money and time at the hearings in Reno Justice Court in this matter establishing that
Merliss had a "Standing Order" with NV Energy which resulted in the electric bill reverting to
Merliss's name upon Ulloa moving out. This created a situation that beneIited Merliss (It enable him
the "power and control" so oIten sought by domestic batterers to turn oII the electricity to Coughlin's
commercial lease property just hours beIore a bad Iaith "inspection" by Baker and the videographer
he kept in tow and a day beIore Coughlin's Tenant's Answer or AIIidavit was due), but it also cut
against his interests, as clearly, with the NV Energy bill in Merliss's name, combined with the Iact
that Merliss never attached a TransIer oI Responsibility Addendum to the Lease Agreement, in
conjunction with the strict privacy laws NV Energy Iollows, resulted in a situation where the utilities
were "not payable by the Resident" and thereIore those utilities, under the Lease Agreement that
Merliss was provided as a Iull grown man, a learned doctor, in Iact, and Ireely able to sign or not sign
aIter reviewing with his ability to read and discern, "will be paid by the Management...." Whether
that means Dickson Realty, Darlene Sharpe, or Merliss himselI must pay those utilities is a matter Ior
another day, but clearly, Coughlin is not liable Ior them.
18. Paragraph 28 oI the Lease Agreement is particularly bad Ior Merliss, especially where his
Landscaping Crew, Green Action Law Service, which can clearly be seen in videos included in the
record on appeal in this matter and Iurnished by Coughlin admitting to being controlled by Darlene
Sharpe and Merliss, citing to Sharpe's distaste Ior Coughlin's outdoor carpet, etc., etc. "28.
LIABILITY: management shall not be liable Ior any damage or injury to Resident or any other
person or to any property occurring on the premises or any part thereoI, or in common areas thereoI,
unless such liability is based on the negligent acts or omission of management, his agent, or
employee, but Resident will not agree to hold management harmless from any claims for
damages if caused by the negligent acts or omissions of the Resident or his guests."
19. Further, Paragraph 30 oI the Lease Agreement was violated in that Tenant was aIIorded
no inspection in the Resident's presence upon termination oI the tenancy: "30. TENANCY
TERMINATION:... Resident shall allow Management to inspect the premises in the Resident's
presence to verify the condition of premises and contents."
20. Further, Paragraph 32 oI the Lease Agreement provides that Merliss is/was to provide
Renter's Insurance Ior the Tenant's Property, and Merliss Iurther made mention oI this in an August
2011 email to Coughlin, wherein he mentioned querying his insurance company with respect to the
damage cause by Green Action Lawn Service to Coughlin and Coughlin's property.
21. Any weak implication by Merliss that he did not read or understand this Lease
Agreement, despite being a neurosurgeon, is Iurther undermined by Paragraph 33 oI the Lease
Agreement: "33. CONTRACT: The above agreement is accepted and agreed to, jointly and
severally. The undersigned have read the above contract and understand and agree to all the
provisions thereoI and Iurther acknowledge that they have received a copy oI said contract."
22. Further, contrary to Baker and Hill's machinations on Merliss's behalI, the Lease
Agreement did not "pooI" and terminate upon the exipiration oI 12 months Irom the entery into it,
rather Paragraph 3 oI the Lease Agreement holds that: "3. HOLDOVER: Under Nevada law this
Rental Agreement and any changes properly agreed to will remain in effect on a monthly basis aIter
the initial term..."
23. On Friday, December 23rd, in addition to several phone calls being made to the Law
OIIice oI Richard G. Hill, Esq. wherein the problems associated with and objections to Hill and
Merliss's continued practice, even during the 14 hours allotted Ior removing Coughlin's personal
property, oI keeping the back yard Ience locked up with a padlock and metal chain, in addition to
keeping the entire back entrance to the house and porch completely boarded up. Curiously, the same
contractor who charged some $1,060 Ior boarding up the property and "Iixing a leak in the basement"
Ior the receipt Ior which Hill represented to the Court was Ior the "reasonable storage, moving, and
inventorying" costs contemplated by NRS 118A.480, managed to board up the property with only
plywood and SCREWS INTO THE PLYWOOD ON THE OUTSIDE OF THE PROPERTY, THAT
IS, WHERE ANYONE WITH THE RIGHT POWER DRILL COULD UNSCREW THEM
RATHER EASILY, while also, in this outrageous overcharged Ior "securing" the property-which
arguably does not come within the purview oI "reasonable storage, moving, and inventorying
expenses", especially where the "Iull rental value" being charged Ior "storage" was some $900 per
month, which should probably entitle one to an armed guard on duty at least 8 hours a day, but should
at least include taking the window unit air conditioner held in by nothing but duct tape and lacking a
brack between the top oI the window sill and the unit, out oI the window and locking the window,
and hopeIully, leaving at least a tiny night light on....
LAW
1. ReIerence is made to NRCP 65(b), which provides in pertinent part as:
A temporary restraining order may be granted without written or oral notice
to the adverse party or that party's attorney only iI (1) it clearly appears Irom
speciIic Iacts shown by aIIidavit or by the veriIied complaint that immediate
and irreparable injury loss, or damage will result to the applicant beIore the
adverse party or that party's attorney can be heard in opposition, and (2) the
applicant's attorney certiIies to the court in writing the eIIorts, iI any, which
have been made to give the notice and the reasons supporting the claim that
notice should not. be required.
NRCP 65(b)
2. ReIerence is made to NRCP 65(c), which provides in pertinent part as Iollows:
No restraining order or preliminary injunction shall issue except upon the
giving oI security by the applicant, in such sum as the court deems
proper, Ior the payment oI such costs and damages as may be incurred or
suIIered by any party who is Iound to have been wrongIully enjoined or
restrained. NRCP 65(c) 2. ReIerence is made to NRS 33.010, which
provides in Iull as Iollows: An injunction may be granted in the Iollowing

cases: 1. When it shall appear by the complaint that the plaintiII is
entitled to the relieI demanded, and such relieI or any part thereoI
consists in restraining the commission or continuance oI the act
complained oI, either Ior a limited period or perpetually. 2. When it shall
appear by the complaint or aIIidavit that the commission or continuance
oI some act, during the litigation, would produce great or irreparable
injury to the plaintiII. 3. When it shall appear, during the litigation, that
the deIendant is doing or threatens, or is about to do, or is p'rocuring or
suIIering to be done, some act in violation oI the plaintIIIs rights
respecting the subject oI the action, and tending to render the judgment
ineIIectual.
NRS 33.010.
ANALYSIS
Based on the caption oI Mr. Coughlin's Iiling with the court, it appears that he is asking the
court to temporarily restrain Merliss Irom disposing oI the personal property Mr. Coughlin
abandoned and leIt at the Property. However, Mr. Coughlin's paper Iails to provide any analysis or
evidentiary basis Ior that request, and is Iatally deIicient Ior a number oI reasons.
Mr. Coughlin makes no citation to any authority, nor does he provide any analysis, that would
even remotely support the issuance oI a temporary restraining order or preliminary injunction. In 36
pages oI rambling, Mr. Coughlin, a licensed Nevada attorney, does not manage to even mention,
much less analyze, NRCP 65 or NRS 33.010, which are the controlling provisions oI law. The court
is leIt to speculate as to the basis Ior Mr. Coughlin's request. In Iact, there is no basis.
A. Coughlin's Request for a Temporary Restraining Order is Procedurally and Substantively
1ust Fine
Thus, there is evidence to support an exercise oI discretion by this court. Further, Coughlin
certainly can explain how he will suIIer irreparable injury in the event Merliss is allowed to comply
with Judge SIerrazza's order and dispose oI the property Coughlin chose to abandon at the house as
many irreplaceable keepsakes, heirlooms, and one oI a kind items remain there, in addition to items
that are unique and expensive. In Iact, Coughlin will suIIer irreparable injury, because money
damages are unquestionably an inadequate remedy Ior any loss oI personal property he may suIIer.
To Richard Hill, money is the only thing worth anything, but that is not the case to the undersigned.
The undersigned wants to extraordinarily sentimental caricature drawing oI himselI and Ms. Ulloa.
Throughout counsel's dealings with Baker and Hill, they consistently reIuse to Iollows Orders oI the
Court (such as Ior Hill to leave and stay out oI the court room at the December 20th, 2011 Hearing on
Motion to Contest Personal Property Lien where Hill was to be a witness, instead Hill continually
reentered the court room, and even crossed the bar to pass little post it notes to his associate, Casey
Baker, with this or that instruction to Baker written thereon. Coughlin is not entitled to any relieI
under NRCP 65 because he has an adequate legal remedy. And even iI he did not, his unclean hands
and inequitable conduct should preclude him Irom any relieI Irom this court at this time.
Coughlin has paid, and the RJC still has, the $250 bond Coughlin put up with the RJC and
notice Hill oI, despite Hill's lies to the contrary. Judge SIerrazza's order is hopelessly out oI touch
with storage costs and the community that pays him so much money to the extent it suggest the
reasonable costs oI storage at the Property is $30.00 per day. Thats a room at the Sands Ior
chris'sakes, not a storage shed. Hill and Baker again seek to get attorney's Iees in a landlord tenant
action (the record reveals numerous ridiculous attempts on their part at doign so) where there is no
basis in the law Ior doing so.
B. Coughlin Has Shown Any Basis for An Injunction to Issue
The issuance oI an injunction is controlled by NRS 33.010, but one must remember NRS
40.385 as well, and Coughlin did pled in the alterntive. Coughlin declares the Iactual assertions made
herein are made under penatly oI perjury and submits this declaration in lieu oI an aIIidavit, which
rich people like Richard HIll can have their in house notary do Ior them, but to me, is an unduly
burdensome litigation expense, particularly iI I am at the same time exposed to NRCP 11, yet cannot
get attorney's Iees as a pro se attorney litigant. That statute maybe requires that there be a complaint
or an aIIidavit on Iile, and some showing oI great or irreparable harm, or a violation oI the moving
party's rights. what is so extraordinary about the relieI request? Hill says there is tons oI clean up. I
saw I want all the property at the property and would love the chance to return the property to as
good or better shape than I leIt is, the lease agreeement allows Ior the resident to clean to carpet, etc.
via a method oI his own choossing, etc. etc ... I think Merliss just wants my expensive collection oI
imported porceline and natural stone tile (see the mosaic design in pictures on Iile in this matter)
instead oI the drab cheap linoleum he put in...however, the tile was never mortared down or
otherwise aIIixed to the property, thereIore, its mine. There is at least approx. $2K oI tile there...
As discussed above, Coughlin has veriIied this and the preceding motion and submitted this,
pled in the alterntive as a delcaration in lieu oI the aIIidavit requirement, to save on notary costs. II
Coughlin has to rent a room oII oI Craigslist Irom people to kill him iI he doesn't cough up more
dough Ior this or that aIter he moves in, then he has demonstrated a Iinancial need to waive the
xpensive notary reqs.. Further, there can be no irreparable harm where money damages are an
adequate remedy, but here they aren't.
C. Coughlin is So Entitled to A Stay
From: Casey Baker (cdbakerrichardhillaw.com)
Sent: Wed 12/14/11 1:51 PM
To: zachcoughlinhotmail.com
Cc: 'Richard Hill' (rhillrichardhillaw.com)
On December 14th, 2011, opposing counsel Baker wrote the undersigned reporting the
burglary oI Coughlin's law oIIice property: "Mr. Coughlin: The River Rock property has been
broken into. We believe the break-in occurred sometime on Monday, December 12, 2011. There
appear to be items missing, including the TV in the living room, perhaps a computer monitor, and
perhaps some stereo equipment. I can`t tell what else. The contents oI the residence appear to have
been riIled through." Somehow, and I could not begin to know how, the Reno Justice Court Iound it
reasonable to not only charge Coughlin $480 Ior "storage" Iees Ior a whopping 16 days (despite the
Iact that Coughlin put on evidence oI numerous writings and phone calls, that went unresponded to
by either Hill or Baker, with respect to Coughlin's personal property), but to do so even where, old
Casey Baker just wasn't even quite sure what they hell had been stolen oI Coughlin's property and
just what it was that still remained. Unbelievable.
D. Coughlin Asks for Extraordinary Equitable Relief, And Has Succeeded to Mitigate
His Damages or Otherwise Behave Equitably
Paragraph 2 oI the Lease Agreement, which is about all Hill clings to, really only manages to
show exactly why this case, and complex issues oI contract contructuion and intent (much less the
Iiner points oI discrimination) really do not lend themselves at all well to Summary Judgment, which
is the standard applied to Summary Eviction Proceedings, that paragraph states that ""2. TERMS:
Management does hereby rent to Tenants and Tenant hereby rents Irom management Ior residential
purposes only those certain premises described at: 121 River Rock St., Reno, NV 89503, located at:
121 River Rock St., Reno, NV 89503 Ior a period oI not less than 12 months tenancy,..." Now, the
undersigned reads that and thinks it is saying that the only property being rented is that property
located at that address, whereas Merliss wants to argue that that sentence oI the Lease Agreement
creates some construction oI the Lease wherein it is only Ior residential purposes (despite the
expressing disavowal oI such an interpretation at several other points in the same very Lease
Agreement). Also, Mr. Hill is curiously silent with respect to the Lease Agreement (attached herein
as Exhibit 1), which, at Paragraph 10, clearly states: "Resident further may use the premises for
any commercial enterprise, but not for any purpose which unlawful." Likewise, the Lease
Agreement in this matters, at Paragraph 11 holds: "OCCUPANCY: Occupancy oI the premises is
limited to 2 adults...and shall be used Ior a residence and for other purposes." (Emphasis added).
C
CONCLUSION
Coughlin's motion is procedurally and substantively just Iine in all respects. He has indeed
satisIied the threshold requirements oI NRS 40.385, and NRCP 65 and NRS 33.010. He has shown
the court solid legal amd Iactual basis Ior the relieI he purports to seek, and, in Iact, does address the
merits oI his motion . Coughlin's respectIullys asks this most honorable Court to grant his Motion
and or Request..

DATED this 5th day oI January, 2012.
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.
/s/ Zach Coughlin
Zach Coughlin
Appellant
PROOF OF SERVICE
I, Zach Coughlin, declare:
On January 5, 2012, I, Mr. Zach Coughlin served the Ioregoing REPLY TO OPPOSITION
TO AMENDED EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER OR
IN1UNCTION PREVENTING MERLISS FROM ~DISPOSING OF TENANTS PROPERTY;
OR, IN THE ALTERNATIVE; MOTION FOR STAY by Iiling and serving electronically on
registered E-Filers:
Richard G. Hill, Esq.
Casey D. Baker, Esq.
652 Forest Street
Reno, NV 89509
Attorneys Ior Matthew Merliss
/s/ Zach Coughlin
Zach Coughlin
Appellant
1
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28
INDEX TO EXHBITS
1. Commercial Lease Agreement between Zach Coughlin and Matt Merliss, in more readable
OCR scanned Iormat and original reproduction as well, back to back; eights (8) pages.
2. Collection oI emails to and Irom Zach Coughlin, Esq. and Richard Hill, Esq. and Casey
Baker, Esq. (opposing counsel representing Matt Merliss) disproving Hill's spurious
allegations; Iorty three (58) pages.

F I L E D
Electronically
01-05-2012:11:00:17 PM
Clerk of the Court
STANDARD RENTAL AGREEMENT
Meadowood West
This AGREEMENT entered into on the 20
th
day oI February, 2010 between hereinaIter reIerred to Management, and Melissa Ulloa
reIerred to as Tenant, which parties hereby agree to as Iollows:
1. SUMMARY oI initial rents charges and deposits
RECEIVED AND PAYABLE PRIOR TO OCCUPANY:
Total rent Ior the period oI March 1, 2010 to February 28, 2011: $900.00
Last months rent: blank
Cleaning Iee: $200.00
Security Deposit: (see Section 6) $500.00
Key and Re-key Deposit: blank
Other: blank
Total: $1,600
2. TERMS: Management does hereby rent to Tenants and Tenant hereby rents Irom management Ior residential purposes only thos
River Rock St., Reno, NV 89503, located at: 121 River Rock St., Reno, NV 89503 Ior a period oI not less than 12 months tenancy, comme
a total amount oI $10,800.00 at a monthly rate oI $900 payable in advance on the 1st day oI each and every month. Payments will be acce
CA 95928, during normal business hours unless otherwise agree to. Make all checks payable to Matthew Merliss (Merliss initialed here) a
3. HOLDOVER: Under Nevada law this Rental Agreement and any changes properly agreed to will remain in eIIect on a monthl
written notice to vacate must be issued by the Resident prior to vacating anytime during or aIter the initial term oI this agreement. II impro
given by Resident, Resident is liable Ior prorated rent until lawIul termination and Management may deduct this Irom the Security Deposit
other lawIul means.
4. CLEANING: Upon vacating Tenant, at Tenant's expense, shall have the carpet cleaned. Tenant will vacate home in the same co
occupied. This includes, but is not limited to, the interior, the exterior, all coverings , walls, ceilings, windows, baseboards, window coveri
parking areas, etc.
5. SECURITY DEPOSIT: THE SECURITY DEPOSIT HELD BY THE OWNER, WILL SECURE THE PERFORMANCE ON
SHALL APPLY ALL PORTIONS OF SAID DEPOSIT ON ACCOUNT OF TENANT'S OBLIGATIONS. ANY BALANCE REMAINING
RETURNED TO TENANT.
6. KEY & RE-KEY DEPOSIT: n/a The above state Key and re-key Deposit shall be reIunded in accordance with law iI al
mail box key(s), laundry room key(s), pools and tennis court key(s), other key(s) are returned the day premises are
7. COLLECTION: II Resident owes more money than has been held in his account the Management aIter issuing a proper itemi
pursue as his option any legal means oI collection.
8. RENT PAYMENTS: Rent payments are legally the responsibility oI the Resident without notice or demand and may be acted u
above. Payments oI rent beIore the due date will be gladly accepted with a discount (iI agreed to by the Management and initiated by sa
9. PENALITIES: Rent payments made aIter the 5
th
day oI the month will be subject to a penalty oI $5.00 plus $3.00 per day. Res
each partial payment oI rent. Resident shall pay $50.00 Ior any dishonored bank check made to management. Acceptance oI a check in no
there by insuIIicient Iunds in the account.
10. SUBLEASING: Resident may not assign, sublet, or transIer his interest, no any part thereoI without prior written consent oI m
unreasonably withheld. Resident Iurther may use the premises Ior any commercial enterprise, but not Ior any purpose which unlawIul.
11. OCCUPANCY: Occupancy oI the premises is limited to 2 adults 2 Children, and shall be used Ior a residence and Ior other pu
$ per day Ior each guest remaining on the premises Ior more than days.
12. MULTIPLE OCCUPANCY: It is expressly understood that this agreement is between the owner and each signatory jointly.
timely payment oI rent and perIormance oI all other provisions oI this Agreement.
PAGE 1 oI 3
signed by Merliss 2-14-10, not signed or initialed by either Ulloa or Coughlin
13. UTILITIES: Resident agrees to pay for the following utilities: Gas x Electricity x Oil___, Light x, Heat x, Energy x,
responsibility for these begins at the commencement of this agreement. See attached transfer of account Addendum (note: th
Account Addendum attached to the Lease Agreement). Utilities not payable by the Resident will be paid by the Nanagement.
14 PETS: Resident agrees that an animal, bird, pet or of any kind may be kept in, on or about the premises by the Res
separate agreement signed by Nanagement.
15. WATERBEDS, ETC.: Resident shall not keep in or about said premises waterbeds, boats, camper, trailers, mobile
without separate written agreement signed by Nanagement.
16. ALTERATIONS: Resident shall make no alterations or do any painting to the property without Nanagements app
17. BREACH OF CONTRACT: Failure of Resident to pay rent or other charges promptly when due or to comply with a
or to comply with any applicable provisions of the law of the State of Nevada, shall at the option of the Nanagement empower
upon giving proper notice as set forth in the Residential Landlord and Tenant act contained in the Nevada Revised Statues.
1S. WAIVER OF TERMS: Any failure by Nanagement after any default shall not be construed to waive any right of m
legal action theretofore given or commend.
19 WAIVER OF RIGHTS OR OBLIGATIONS: Nothing contained in this agreement shall be construed as waiving any
right or obligations under the laws of the State of Nevada.
20 TERMINATION: This Agreement and the tenancy hereby granted may be terminated by either party within 30 day
(refer to Paragraph 2), or any time thereafter by giving the other party not less than thirty (30)day prior notice in writing or as
the State of Nevada (Refer to Paragraph 1 and 9 for monetary liabilities).
21 OWNER: The principal or corporate owner(s) of the lease premises is (are): Natthew Nerliss. (note: Nerliss initiale
22 MAINTENANCE, REPAIRS, OR ALTERATIONS: Tenant acknowledges that they premises are in good order and
Tenant will as hisfher own expense, maintain the premises in a clean sanitary manner including all equipment, appliances, smo
and air conditioning and will surrender the same at termination in as good condition as received normal wear and tear excepte
otherwise redecorate or make alterations to the premises without the prior written consent of the Owner. All three prong outle
codes with respect to electrical grounding. Tenant will irrigate and maintain any surrounding grounds, including laws and shru
exclusive use. Tenant will not permit any waste upon the premises or any nuisance or act which may disturb the quiet enjoym
Owner will be responsible for the cost of any retrofitting required by governmental agencies.
23. DAMAGES TO PREMISES: !f the premise are damaged by time or through any other cause which renders the pr
will have the right to terminated this Agreement as the date on which the damage occurs.
Written notice of termination will be give to the other party within fifteen (1S) days after occurrence of such damage. Should
as the result of negligence of Tenant, or hisfher invitee, then only the Owner will have the right to terminate. Should this righ
Tenant, the rent in the current month will be prorated between the parties as of the date the damage occurred. Any prepaid r
be refunded to Tenant. !f this Agreement is not terminated, then Owner will promptly repair the premises and there will be a
the premises are repaired and ready for Tenant's occupancy. The proportionate reduction will be based on the extent which re
reasonable use of the premises.
24. POLICIES: Resident agrees to abide by any and all rules and policies including, but not limited to, rules with respe
refuse, pets, parking and use of common areas. Further, Resident does not agree to abide by all amendments and additions t
such amendments or additions. Resident at the time of execution of this Agreement acknowledges that he has notice of all exi
to the Premises (Resident initials (note NUfZC handwritten here).
25. INSPECTION: Resident agrees to grant management the right to enter the premise as all reasonable times and fo
showing to the perspective residents, buyers, loan officers or insurance agents or others with lawful business therein and for e
each month. !n accordance with NRS requirements, Nanagements agrees to give Resident twice the twenty (2+) hour notifica
26. AMENITIES: Use of washing machines or other equipment, in any, are furnished by management for the pleasur
are to be construed in a manner as as a part of the rent paid by the Resident. The swimming pool, recreational and other ser
are for the use of the Resident only, at the discretion of Nanagement. Nothing
PAGE 2 OF 3
NOTE: Signed at the bottom of the page by Nerliss only, dated 2-1+-10
ADDRESS 121 River Rock, Reno, Nv 89S03
herein shall be construed to require management, during the term of the Agreement to keep said swimming pool and other fa
Resident, and the time of manner of use, or the closing, temporarily or permanently of said pool and facilities shall be at the s
accordance with rules and regulations issued by management. Any breach of said rules and regulations shall constitute a brea
27. VEHICLES: All vehicles operated by resident must be registered with the management. Only vehicles maintained
in approved areas. Unauthorized vehicles my be towed by management at owners epxense upon on a week's notice. Resident
on the premise at any one time. There is one designated parking spot. Other cars can be parked where allowed.
2S. LIABILITY: management shall not be liable for any damage or injury to Resident or any other person or to any p
any part thereof, or in common areas thereof, unless such liability is based on the negligent acts or omission of management,
will not agree to hold management harmless from any claims for damages if caused by the negligent acts or omissions of the
29. INVENTORY: A written inventory of the premise and is contents will be attached for your inspection. Please revi
copy and the offices copy within two weeks. You will be responsible for conditions of the premises when vacating in accordan
initials: NUfZC) acknowledge receipt of inventory by Resident.
30. TENANCY TERMINATION:. Upon termination of the tenancy, the Resident shall surrender and vacate the premis
all of the Resident's property. Before Departure, the Resident shall return keys and personal property listed on the inventory t
sanitary condition, normal wear accepted. Resident shall allow Nanagement to inspect the premises in the Resident's presence
and contents.
31. TAXES: !n accordance with the Nevada Revised States, as a resident of rental property, you are entitled to know
real estate taxes. The following is a breakdown for your information:
TAX ALLOCAT!ONS $17+.86 OTHER THAN TAXES $_____ TOTAL NONTHLY RENT $_____
32. INSURANCE: !t is agreed that TENANT may obtain RENTERS !NSUANCE AS LANDLORDS or his Agent's insurance
Property.
33. CONTRACT: The above agreement is accepted and agreed to, jointly and severally. The undersigned have read t
and agree to all the provisions thereof and further acknowledge that they have received a copy of said contract.
34 NOTE: the above paragraph Heading are for reference only and do not add to or diminish the intended meaning o
35. ADDITIONAL TERMS & CONDITIONS
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
_____________________________________
Resident Signatures dated 2f21f10 Nelissa Ulloa and Zach Coughlin
Owner signature Natt Nerliss 2-2+-10
PAGE 3 OF 3
ADDRESS 121 River Rock, Reno, Nv 89S03
Inventory
121 River Rock
Reno, NV 89503
Residents Melissa Ulloa and Zach Coughlin acknowledge that the Iollowing
items are apart oI the inventory at 121 River Rock, Reno~ NV 89503.
The items will not be removed and stay will stay the property upon vacating
Stack able washer and dryer, reIrigerator, gas range oven, water-heater
Iurnace. blinds (window coverings) and all other items that are attached to
walls or Iloors or ceilings.
Residents: Melissa Ulloa and Zach Coughlin acknowledge this inventory" list by initialing page 3 item 29
Signed by Merliss 2.24.10
"''''IANU"RD RE!II'f.I&l.A(;kEEMEI\'T
Wn t
THIS em:rcd ''1tO o!'lJ'm -.2!l.- "'II)' of , '2010 b<lt"<'<een .' t.cr:oinail.er ",,"..mod fa f<$
MQltQ:lTftB(lt, 3"<1 !.- lloa f.I1d CI"IJ!lli'l her=iMftftr fIJ lI< rerun!, wbU,:l1 panio:s t.1cb}' agree lallaM; :
- " PAYABLEPRI{)!{
RECEIVIf.Il TO OCCUP'ANCY
I. SlIMMAoRV orhlililll I2l1d DCJ906io
Total (tIlit pefl(ld I'/tIm Marth 1. 1010 10 ,0 r I i
1.IIJl MllIIlh', Rullf .. " _", .. .. ................ ......... _ ......... " $_. lO
... . .. .. .......... .. S
SecurilVlkpo,' il(lee !le(1;0tl6)." .. .. .. ...... .. ,'"... .. .. ..... .. ,.. .... $_ . . . _ S
__ ., ..... _ ........ .... " ..... .. .. .. . ,, _ ................ ,.. S__ _ _ ,
900,0(1
..... ..... - ..... , ............ - .... ... " ................. - .. ..... : ... " ' .. - .. .... .. .... $._. ,
TOTAL" ... " .... ............ " ... .. ,, _ ..... ,,_ ... _ ....... .. .. ... _ ............... . . " ,. :& _ _
l, TERMS: _lll:lleby .... 11 'ICIllnr and f:"tln'l MdllI8Clnc:nl fer ptl!pOs:, nllly UlQSa et!'hlin
premllcy decrif:,.,d I!; . .... 121 Rhs;:r Rack. RCllc NV SSlSrp II
River RQ;k. RfIllD. !JCl5(1] . . _ . I 'Nc.v".u,. ror II period of mt Ie.o;s
P mtl1l!i15 oOn;tlt l.r. tluy of 20J.n,. :urll mraJ I;U:-.Qcn[ of1l.Q.aQ0..Q9_ ar ft rnontllly!'llte
mJ12 in rln me 1st My of eaen 2M eVd'y' r:.c-:nfh. ..... ill X acceptc-d ijL, ) ! 121 Ridge kjln RQ!d. -G!riro CA
during ntlllTl3! busincss hours ull],m oIberv .. iliCl 10. M.b all pDynbte to Mtrl!p _e _
au:.' PLAS MAU_
l. HoLDO'VER: Under l'o/e.'ndn hlw Ihi' 111)' cba.'&e$ properly Il!!roed ro wirt I'tInlin in c;1"" on./l monlill),
IhlJ initiollerm. A 10 dri,. .... riUtn to vucuic bo iuu.:Li by rilt pritlr tn 'l'll'oting. 1:J'I}>U!rnr durillg Ilr after !foe initi31
term ofthi .. iJ:,rumGnf. [t'lmp!'''per Roticn or nn notle ID W(;Rle is given ny .. IS liable for prol'llUd n:.nC wllil la .... flll
u.:rmlfl:lCl Ullo 1Ifld may CIlct fmrr: tht! SeC' .n'I!)' on h3rld, or I:nllen:llly :nOfleyM clue ty <Ilhtr IlI.wn., 1 I."'''''h .
n .E.4NING; l.Iron v3:.ring. Tenal1t aJ TelllUJl.', eJrpcreiB, haWl the (:Up,,1 Tenl,,1 will fum.: in lhc: IiPIlKl
Mndrrlo,. 01 lc'lV ,1"." .,.hooo 'nimHy Thb hIIl;y not limited to, Ihe .all 01Xl[' cQ\oenags, Willis,
windOW!; . bMdleDrds. eppii\lnt1:5. fjl\hltr;l\, dri'lr'CWl\)-""" par\c,"" de.
S. Sr;CtJRrn DEPOSIT: 1he =o,iTy depw;i .. Ihu uwn"r, wjl, lhe pcrt'OTmlalCe ofnlll1ll"R aolltlUians. OwmTllhiJi
.1'1)'11) 1111 potrion, said d!:poIilon ;>:cell"'" (,:bli'!8rioni. AI .. rem1r"i nl! lIro" I\lIminltiM will be to TII-It!.
6. Key &; Ot:I'OSIT= r.l3 The 2ht\./O K..y k. R&-!.:O)' Dtpos!! d>.:U I ba in a:e0d3n-:t Irrw ifa11
b Y' of . __ .... 0. 1.:ey(".I, __ [',alI; _ __ Lourrd.,. R""", ___ &; lClIlIia CoUIt Kt)'{s)
.mrer kcy(t) ,.c!urned Iht,j;ry B:"!I
' . COf. LF.CTION: 11Rbsideni owes mona), t>lX:fl h .. ltlln Ilis fhe Ms:lsgell:lcn( is5uiny- 1 propct" iternired
StIlIcm.:nl llorillg 1l/1I00irn ow&d I\lay III l'P!;r.r, iI.'1)' ler:a-I o1" collecll/YI.
IJ. HEJIlT ..... 1(['111 lin: tile; .... lmaUl nnrlct or aru1 may be atll::d
1M !III!. da:e Iltrove. Payment .,f r..."t ba(orc Ifle d,.. dBIe will he gbWly <vilh I .Q% di'ZOum (if egI-eed UI by
iI!!t\Jlcdby slIm"_ .. _ . __ -,
9. Reoll mati:: altO" ,,,,-,, i!:h da,)I manU! ..... ill !lUbjo;;l:l Loll o( S I'll,",
p/da)' . JW.ictnl PJY n.t a dlIily rollc o(Srrhi Cur ",ach pUlilll paymtr.i of rer.r. Rosidmt Sball P4)' S50.M for IIny dishlJlllnd bulk" ct,=dr
mntlo 10 nlll1-'o"YIffil. a "hock in na wily Ihll f't'!!idm; JhtHJJd \hero be! fllnd. ill th'" a:x:OI,lJll
10, SUBLZ,4,SINC: mly nOl nqgn. or l\'3mrc:r !lllr lIOy p1lI1. d-":o:.nrwjthaul priOl' INT'itti:n eon!.r.nl tit'
Md".,!; __ ""', ... tl i.eh ... ill flO[ bo wil"hol.d. R",, ;<bTT rurthc U3: (h.o fen- 11<0" <omm.:r.:t .. 1 ... b ... . "" r.....- 411;:-
",+Oieh
11. OCCUP-ANCY; prern;:II!'5 ill 10 .l.i!dulill. Ilnd Q :hildrvn llld shall he u,Gd tOr a IIrd fOr
purpl)!iQ5. Rosidc!lC: IIl'oO'i. agree !D $ ___ fet .:.xh gllC.S1. remBinin,g on tilt pre..,lsos mOJ'llI/wr _ . d' ..
12. l'tllLl' 1t'1!.l! or.,;CUJ' .... ,,(;Y: II IS Irndtr!!rood diU AgreelnGnl is bdWl:cn 0." Owner Md II:-idI joi,dly.
Eoch signoMry ""ill be. TC:i?Olllible for ofrmt ,lIId ur 1111 ofdlls Agru:mMt.
I Dt3
13. UTILITIES: RI::lId.",r ttl fur the roll!l\\'JI!.S utiHti6: Gas .;. Oi1 _ --, U&h(!. He:u.,l. Other
I"eII'lloDollbiri:,' lor lhCfo" bc:!5in. :u '1o '. ""mJllellc<!'nleo!lt Dr s ..... l!I'1AdIcrf n:
liti",ics not piQ'l!ble b)-1hc "",ill b; by the Mmu'stme
OL
. . .
U. PIITS: 'lbllli'erat that an ooi1'!L11. hird. r:r PCI of any Idud D'I:I)' be kepI m. on Ilr about iii," prcrr.I!oes by lfie or 1m
(;uesr Wl1110lJI prillr aeN!emcnl by Man;,"'ttM1t-
u. WATER8G[).!i, ETC.: RftOidcnt dl.tt not keep iu OT OlOcoU: SOl id JlT'tInISl,:S WlIll:tbL'Cl!, lIO'US. I!;amper hnrr,eo, tlf
vehicle, WtutOUI wriul!r1 ugr-e.:.:nenl by . ..
16.. AI,TEA:" TIOI\'$: mlfke no 1I1tG"a1.LOIIS tJI" do ""; pAlntl"llg II> rho prnpcny wj1llout MllIlqtmflli_ apprD\'!I [ .a.,d all
",",,'I tl"rn.,ln wHJ ' Me "",If,i"",,. .
11. OF c.OHTtucr: FalfUn: PH)' 01" othtr ch3rl:"U pranlpdy when or 10 witt. ;In),
Itrm'\ or wlldilia!U hlm'Wor :oc-i1mp)y wirll My pmyjsiOfl'l orUJe IOll>'j IJf thc: ofN'evada. 511111 at Ilrthe-
elnpo" .. n .. '1$\ tn Icndnci IIpl.n 1I!;!i(Il rorth in me Residcntlall.lUIdlold iIIld Tellant Ad: liOnt:rill:!id in the
Rel,,( ... S!a!llllll.
18. WAIVER OF TER.MS: Any flJillJl"e by 10 enfnn:e Terms or'this ABtUCnJe/ll shall nOl eonnhiutc e w:J.iver <:>fsaid
by A=-l'tanc:e ufreol hy Ltu: IIJ'I)' shAlT noL: bot eonmued III lI./I}'
Of llfi'i:o."tany I!OIjq. or It.!:al ciyaf1 or coll'll'llen.:erI.
19. ""AIVER 0; RICHT!\ OR Nn:tl i nS'conctjrjj:d In At!r<to=.:nllo'hll l! he in aoyoflhc:.
or ..... ' ;lIht "" ubligaliurl1 !lAder Ihu la",. SIOtr9
20, Thi., A,t:rumenl Wt&t her::by gBIllt4J ImniDllIe\! b,. cilhcr;larty wilhill 30 .:la),s oldle
.Jc:It"....l , .. miMI;'", due: ( ."tfi:r to P""4
o
r"ph 2 ). I:#.n;r by olb"" pMt). not las Wlln PO) dD.;,':j pr'iQr nulic:c
writil\!; or !'IS othc ....... isc alJnlMtld by rIWllft'boS orrtlc Sl:rta ofNCWIdII. ro PRI'U!""ph 'Md II formonemry l1,rtbUil!cs}
21. OWIllIo:R: l'be FKifleipttJ or ('I\IIflJer(9) n(lli e (I!.re): M.IIt1heW !W .. rliu. JJiVv1
21. ;"'II\INTENANCE.. REPAIRS. OR ALTERAnONS; feo)l'lll ilcmo'Y\'lc:dps thlllhc pt'Uni!U!s are e:-dermd repair.
uJlle" irJdieafcd. TenlUt'! wIll. UC own rr. .. b:4i:3 tl lc In II clfilll and IUlilQry lIUII1I'\er lnc:JlIdJuJj an
rl\Iltelors. P;wnt>ms: Ileall'llc .,ni.l gir condlt!Oll ir,g .at.:! will SlI!'1'onliilr (hI! snrr.e, IU terminatil)Jl.1n II.' goo4ieoll.dmon as
.. normal It'3r oxceplM. Tonl1J1, will nO! 6131111, paper Ill' othcrw!st tt:lhcorllJ.: ", r /tlclIt: IQ lhe pn!1tb.c' wilhoul tJ le
,,,,',, ..... ;1..,,' I "r II,u ()............ A t ProIljS DUller. !JlmJI aomply .... (tII "II IIppU"",lJi., QOdCJI ... Idl J'e'pec!1 10 'OPlIl!ndin,Jt. T,1'IaII;
will irrigon<:;wI mu:illltin:llflJl ground ... , incltming lawnl JlIrubhl!ry. It Ihey :&rll (N"th, <: ,,,:Ju, h 'TeNllll will flot
I>'II.sfl: upon the prClllist . or .uls.:tl1C8 0>' 111:1 .... Mcl, 1II1\.} distc.u1l (he wljoymcol ufal\y kllllni ill Uu;' buiiling. will be
fur ItJe uFnny .... !r'(Ifltli'U!' riu;m! 1I.0\ocrnmcIlLaJ
.Z3. DAMAC'lS TO PllIr':MiSlS: Iflhe are dilmigl!d by tire or thl:n 1111) ollltt' cause whicJJ renders
Lm(cl!llntablc. I)ithl.'t' JlaQ)' .... !II rib>t;t:o termirmt e Ihis .,\,greelllc:r.! &5 fhe d;Uc 1)1\ d\e daJM6C ncr.:1on. Wrirten nDliO!l ot'lllm)inat ioll
...:11 be given II) th" other IJithw tirtelll 11:".)'5 alTtr oeul"l'ente dnll.ge. shuuld 5u:lh damllJC "rdcsUu.:tIOfl OClf.:II' the
.. (II,., ""C1illl:ll':<:" ". .. tile!! oniy the ... ilI hoy!;..tlu rit,:/'rt I" u ""in..llta. Sr,owcj !hi ... J3".1:." bY
or fCIIl Inr rht will lie llClw<:c!.I !ho as crUte dal4 r'-e dnrru.ge occun,ed. ).11\1 pn;lIIid
"en! and WMc:d .... tlr b,. III TCflIIIlI. lfl1lls i:; no! lMT..inlltCd. lhen Owner wilt rmmj\IIYJiep&iT the prtlntscs
und :here prop.ort'llfItr!e mluefion Ihe al'8 rop.a:1UI.I Alld nrw.rJy rnr r18"I.I'I( ' nl" p'u:>DI1k.1lliJlI::
....... ,..;1;.. ..... /11 ... " bJt$t1J 0.1 whiCh Jcp!l.trs Imufcrtl \\W! J C'nllnn of'thl! .
.24. fQLJl.1t:S; to ;sbl,jj: 41Y ru/c,; ""lll(fma. bmt "or Iilllited tD, rulr:!! wirtl tspcdlO lIn1Je,
p:utill,g 1iIltIu:.i.: uf r.ornmoo IIIl'.l\ s. FI1/!hef, Reli\krnr dDcs nol "tfCe lOoilbide by III amendl'ItetltS aIld additioos 10
S31d ru;e;lO ufl!l1}' ., ucf1 amMdnwlt!i or rCc.ill e/ll M Ih: lime r>f Iflh,. A!lflIDfllal'll: tll ... 1 hol ;,u
I::llice Drllll un.d pefl.lli niflg Iu lII e pt"erl1i5n,
. 1l .... ""J>t:Cn.ON: Iv me rlpi co [I l ler premiSe.' dme..s illJIl rot air reaMll lihl !!
'Jhov.:ng 10 rcl(i::jMU, 1Jl&ers. J.,IBII uftil:o<ll; ur i!"ur.!i:lCC wIth therein.ad for
:u ICO:;f <:IIC'1 t"flOth. I .. wjlf, .'IIt{:1. MaJ'I .. o1Srei!S to give: Re.sidc-nllWICI! IIle 1ift:1IIy.
mur (211) hoW' tt"l(lJIr.:omenl for I'hlT .....
. 16. .. ; OFW35hi'A or Ifau),. b)' MIIfI!lgemm1 fOr the ple::.:un,; and
R:e.s'.deul4!nd In beCll1Slrue..:! In.1. lnQJlOer lilt" pUIT ut Ihe rem paid b.V Ihf RI' . id&!.nt. 'J'l,c 9VI/mnlill{,: Po;)),
m nther selVles fMlllr'l!s, If WI)" on '"'" ale for !'lIe lise orll;..:: onl)" ill dl1crcI;on afManqgem!:.ll l.
2o(j
ADDRESS ____ __ .. __ _ . IU\,c rRo<;.!(. N\' S9jOJ ___ _
ho:rdn be w N<.jwrc dorin, rhll term..,r 10 keep safd ' OIfUTlminc flOG! 2nd in a
lISt OJ.' R.l:r$id-"TIt, umJ thl: l ime ur tnenntrofusc. or lhe rr. p-.!JmtD""ly, of sail! pool Gnd 'hill! be al
It ... iDle dba>:,ion nl'Plilena;:1fIC:J\t .md i/l ",kh tht ra)e! and by fo.t.tnI(;tlT:e"lI. ... .,Y breath 01 sun. Ilnd
QIIn5lJtult If ttr eacl'l . . .
2', VKllfCUS: . .,U resident P1Qn b. ,csb:ta-ed with tile: (111)' vebich::i und
fll'j be lao l.l'J'fo-..=d &<:na. IJnuud,CIf"l.t: d fUll)' b:: by ill CllcpeMC uflll:) nO wee!;;'! DoIiee.
P< .. rit flO Ill':'" rb:m --.l- .,ehick.r, on the I ny fl"cl [me. There 0" nl',; i[llUled " .wirur 1,,""- IldI .. .r r.;n am h"
fl;lri(ed "iIer: .1I01ll"Cd.
lA. 1.I.4DIUTY: n{"ll. be li",1e nr injury Itl Rtlilk:nl. or Illy oitlc:r ptr9Oll, til' II- MY propcny,
UC'CII"ina uilihe plernilC$ or CIt\)' P_11 ar i" O: OD1nKlll MellI :.hereof, i$ bil:Sed on rho Mglpr DC':! or omI!U:J.aR of
ajj:;nt. WI R:::ii Llcr.f ... iII ",,: 1<1 hukl f(rlm t.ln.!' (jt.lirm (0' bl' tnc
nee)isOM /lCI' oromis.<-icna ofilia Ki!sifll!!II Of hi!!
?oJ. INvt NTORY: A \4Tiu.cn in..clliury or lhe tlrclniac. tUld it., .. ,;11 hi: rot )/('1111"" "lclISe: rcvil'w i!
nnd -'lzn )'OIiT COP!" lind the tDfly >1"I.l!'i.P.IWO wtt4. 'r"ou ... iil bor. ra5J)005b'e (0( Ihe COIl<li(iVfl Wt-."1II4C11;:iJ1"
II" wllfl tn/t"llched. ill1tiBl& of iJwmory by Rccident.
JO TN"'-"'CV 'l'tRfLl'N" TID." , IJpon tl;: trnillOlCiul1 tcnil/"ley, !he IIl1tTenc1u Inc" the jncrudln&
lhe of In)" lind ;!I I ofmc- flmlXlrty. tl ; roft! ttlt. ",,11m b)'S find personal prupelli"' fiso.:d Qlllhc
It> o ... ""r Ifl ':/CI" and" ,...,.it..y "l ..... a' ..... D' ""ll'lod. .\h"n .l!lfo\' filii
tho Ras/rlertt., 10' veritY condnifln III1U eunu:"' , .
31. T.<\X[!;S; In ", iUl me !\o:vadlKcviEd !>'nll1IlU., M:a of rtnw )Iou IIR O:lui()ed J.o lnn .... what plin ian 01
)O!Jr rentgClllS for ,", mak The foliDwing ;!ll brcakdnwn (OI"}'OI.II" Inmtmt:io,,;
TAX l\t,t.()(:Al JO:'ll" S_ ,,4.itl OTHrut THANT". ::<E."S 1 __ .. TOTAL MONTI/l.Y IlENT
J1. 11 i$ 'WCI1IoIi tl14[ TE::\JANT rnl)' RI! NT'"E!R5 Th,SURANC5 lIS L -\h'DLORDS ."his An-ttt\
""_?l,I<'I"'lflll" DJl'C";r of li"ENANT'S pmpuny .
.D. C'{JNl'u.. .. C'f': Th ... .. .1S1'>"1'd t6,JO<nl l}" Gnd ..... TIl .. hI,,'" _d .. .. "'W
c.J n!JVc;1 r.tKl I:"&ol'Ullnd &I, [be PfO"lsiUfl5 ' (\<:ROU( WId fllt1II1::r rhN tilly have n=CI.'l'1cd .. nfald coro:r-er.
34. NOn;: Thf PIIJlI.&f8ll" tlc-Llin! are (or retbn,nu ooly and til) DOl add &0 oTd imill ilh 1h' in,,,r.dad ntSM,1lS or /).D}.
f\'I"'gr.tph.
J:S .-.DO'"I"IONAL n ;NMS 4: CO('lDJTIONS:
- - ---- -----
------
._------ --
------..--- -.---------
---------
-. - -_.. -c::::::::.:
-- .. _--- - -----
inventory
121 River Rock
Reno. NY 89503
Reside.mts Melissa Ulloa and Zaeh Coughlin acknowledge that the followillg
items are a pan. of the inventory at '21 River Rock. NV 89503.
-fheRe items will not be remllved and stay with the property upon vacating.
Stackable and dryer. refrigerator, range/oven. water heater,
furnace. blinds (window coverings) alld all other items that are anached to
Wlllls or floors or ceilings.
Residents: Melissa Ulloa and Zach CoughJin acknowledge this inventory lis(
by initialing pagc 3 item 29.

F I L E D
Electronically
01-05-2012:11:00:17 PM
Clerk of the Court
emergency motion
Sharpe's liability and status as a necessary party to REV201-001708
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 12/13/11 3:48 PM
To: cdbaker@richardhillaw.com; sgallagher@richardhillaw.com
1 attachment
12 11 11 Emergency Ex Parte Motion Merliss v Coughlin rev2011-001708 final.pdf (8.7 MB)
Zach Coughlin, Esq.
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure
under applicable law. If you are not the intended recipient(s), you are notified that any disclosure, copying,
distribution or any action taken or omitted to be taken in reliance on the contents of this information is prohibited
and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the
sender, delete this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone
other than the named recipient(s) is not a waiver of any attorney-client, work product, or other applicable
privilege.
Sent: Wed 12/14/11 3:24 AM
To: stars@softcom.net; cdbaker@richardhillaw.com
NRS 118A.260 Disclosure of names and addresses of managers and owners; emergency telephone number;
service of process.
1. The landlord, or any person authorized to enter into a rental agreement on his or her behalf, shall disclose to
the tenant in writing at or before the commencement of the tenancy:
(a) The name and address of:
(1) The persons authorized to manage the premises;
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=63...
1 of 136 1/5/2012 3:53 PM
(2) A person within this State authorized to act for and on behalf of the landlord for the purpose of service of
process and receiving notices and demands; and
(3) The principal or corporate owner.
(b) A telephone number at which a responsible person who resides in the county or within 60 miles of where the
premises are located may be called in case of emergency.
2. The information required to be furnished by this section must be kept current, and this section is enforceable
against any successor landlord or manager of the premises.
3. A party who enters into a rental agreement on behalf of the landlord and fails to comply with this section is an
agent of the landlord for purposes of:
(a) Service of process and receiving notices and demands; and
(b) Performing the obligations of the landlord under law and under the rental agreement.
4. In any action against a landlord which involves his or her rental property, service of process upon the manager
of the property or a person described in paragraph (a) of subsection 1 shall be deemed to be service upon the
landlord. The obligations of the landlord devolve upon the persons authorized to enter into a rental agreement
on his or her behalf.
5. This section does not limit or remove the liability of an undisclosed landlord.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
ZachCoughlin@hotmail.com
Nevada Bar No: 9473
2 of 136 1/5/2012 3:53 PM
Zach Coughlin has shared a folder with you.
privilege.
Sent: Wed 12/14/11 11:06 PM
To: cdbaker@richardhillaw.com
Please see fax of 12/ 14/ 2011 relating to this matter Zach Coughlin, Esq. 817 N. Virginia St. #2 Reno, NV
89501 Tel: please only communicate in writing Fax: 949 667 7402 Licensed in Nevada, NV Bar No: 9473
merliss v Coughlin
photo video
evidence
View photos Download all
You are invited to view Zach's album. This album has
125 files.
3 of 136 1/5/2012 3:53 PM
Zach Coughlin has shared a folder with you.
Casey Baker, Esq., Richard G. Hill, Esq., Dr. Matthew J. Merliss, MD neurologist Chico California landlord
tenant evictions nevada legal services VIDEO0126.avi
Coughlin explaining faults of Green Action Lawn Service conversion destruction to property VIDEO0077.avi
COUGHLIN FORCED TO PUT CARPET BACK EMERGENCY CONVERSION DESTRUCTION TO PROPERTY
GREEN ACTION LAWN SERVICE VIDEO0075.avi
EXPLAINING CARPET PROBLEMS TO MERLISS VIDEO0074.avi
green action merliss coughlin discussing problems VIDEO0076 g.avi
Share your files with
4 of 136 1/5/2012 3:53 PM
RJC Rev201-001708 Emergency Ex Parte Motion
Sent: Wed 12/14/11 11:11 PM
Please see fax and email of 12/14/2011 to follow for RJC Rev2011-001708
Zach has 7 files to share with you on SkyDrive. To view them, click the links below.
101311 merliss v coughlin1.mp3
101311merliss v coughlin2.mp3
102511coughlin1.mp3
102511coughlin2.mp3
102511coughlin3.mp3
102511coughlin4.mp3
102511coughlin5.mp3
Download all
Share your files with
Sent: Wed 12/14/11 11:42 PM
To: dclifton@washoecounty.us; cdbaker@richardhillaw.com; psferrazza@washoecounty.us;
kstancil@washoecounty.us; stuttle@washoecounty.us; Zach Coughlin (zachcoughlin@hotmail.com);
rjcweb@washoecounty.us
1 attachment
12 14 11 Fax to Chief Justice of the Peace Judge Clifton and 12 14 11 Motion attached.pdf (8.9 MB)
Please find a courtesy copy of the fax with 12/14/2011 Motion/Case Appeal
Statement attached in pdf format.
Sincerely,
Zach Coughlin, Esq.
5 of 136 1/5/2012 3:53 PM
your full rental value estimate
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Mon 12/19/11 6:16 AM
To: cdbaker@richardhillaw.com; Richard Hill (rhill@richardhillaw.com)
2 attachments
252 Mill St, Reno, NV 89501 which includes 121 River Rock St. - Zillow.pdf (62.0 KB) , 12 19 11 fax to
Casey Baker including Zillow rental estimate sheet.pdf (121.4 KB)
Is way too high. Its not based on any Lease Agreement....I don't agree you get to rewrite
NRS to avoid moving things, and the lower cost of a storage shed...but even if you do win
on that point, see the attached evidence suggesting the rental value for BOTH properties on
252 Mill St. (its one plot that contains both house, Dr. Merliss bought them for $545K total
in 2006, now they are worth $155K TOGETHER. The zillow estimate for rent is $652 a
month for both properties all TOGETHER. You are goign to go into court alleging a fair
market value of $900, and I strongly consider moving for sanctions for misconduct
6 of 136 1/5/2012 3:53 PM
committed in the presence of the court under NRS 7.085.

If I can pay your demanded "storage fees" today, can I access my property?
If I can pay both your demanded "storage fees" and the "securing" expenses of $1060, can I
access my property?
If I can pay all "storage fees" or "securing expenses", but cannot afford to make a showing
in accordance with your other demands, are you refusing to allow me to access and retrieve
my property?
If I can pay all your demands, and make all showings, but refuse to start moving my
property but removing everythign on the outside of the house first, are you refusing to allow
me to access and retrieve my property?

Please note, despite your written promises to and written statements in pleadings on file
with the court that you were allowing me to, you have continued to fail to provide me
access to the client files connected to my law practice.

What say you of the offset for the over $3,000 of property burglared due to your negligent
"storing"?

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
7 of 136 1/5/2012 3:53 PM
partial inventory
privilege.
Sent: Thu 12/22/11 11:01 AM
To: psferrazza@washoecounty.us; cdbaker@richardhillaw.com
Dear Judge Sferrazza,
I respectfully submit to you that the inventorying of stolen, lost, or damaged personal property i simply not
possible by 11 am given the interference conducted by Baker and Hill, their removing a ladder to the attic (that
belonged to me, no less) from the property, their keeping the property boarded up, the incredibly strewn
about/burglarized appearance and state of the entire property, etc, etc. It is simply not possible to provide a
complete accounting or no exactly how accurate any accounting might be at this time.
Personal Property, including that used in the commercial business run out of 121 River Rock St. Reno, NV
62hm15
Toshiba 62HM15A Projection TV (62HM15A)
expensive suits missing, expensive fixtures and kitchen appliances missing. 32 inch lcd television computer
monitor, other computer monitor/s lcd/led
Several vintage and expensive high end audio recievers
several guitars, several high end professional audio recording microphones, all expensive, music equipment
several high end memory foam mattress, broken wooden memory foam mattress platform, partially missing,
wooden shutter on porch,
jewelry
watches
several hard drives, both external and internal
several HDTV's and computer monitors,
audio interfaces, sound and video cards,
computer RAM sticks, guitar amplifiers, family heirlooms, mementos and keepsakes, obviously its ridiculous and
damn near impossible to rush into a this property and deliver you a perfect inventory of all that is missing or
damaged within an hour or so.....
expensive electric shavers, multiple high end car audio amplifiers, family heirlooms, audio and video tapes
missing, my intellectual property and creative media missing, etc. ,etc.
8 of 136 1/5/2012 3:53 PM
inventory continued
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Thu 12/22/11 12:09 PM
Dear Judge Sferrazza and Mr. Baker,
Additionally some rare book are missing, family photographs/keepsakes/heirlooms/media, I believe the hammer
weighted action Casio 88 key PX 330 is the model number, I believe, I will have to check.......Further, this is all
moot at this point as I have filed a Supersedeas Bond of $250, and according to NRS 40.385, I automatically get a
stay of eviction and am entitled to return to the property and continue in possession. The statute sets the
Supersedeas Bond (which yields a stay) at $250 if rent is under $1000, unless the Court wishes to rule that
I am a commercial tenant. However, if the court does rule that I am a commercial tenant, the No Cause
Eviction Notice in this case, under NRS 40.253 makes a Summary Eviction Proceeding impermissible, as
Summary Eviction Proceedings are not allowed against commercial tenants where only a No Cause Eviction
9 of 136 1/5/2012 3:53 PM
Notice is filed. Its one or the other, but Mr. Hill and Baker cannot have it both ways. Further, the Courts Order of
December 21, 2011 is just that, and Order, its not an agreement, its not a settlement, etc, etc. and the audio
record clearly reflects that.
NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of premises to pay rent during
stay. Upon an appeal from an order entered pursuant to NRS 40.253:
1. Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with the trial
court a bond in the amount of $250 to cover the expected costs on appeal. In an action concerning a lease of
commercial property or any other property for which the monthly rent exceeds $1,000, the court may, upon its
own motion or that of a party, and upon a showing of good cause, order an additional bond to be posted to
cover the expected costs on appeal. A surety upon the bond submits to the jurisdiction of the appellate court
and irrevocably appoints the clerk of that court as the surety's agent upon whom papers affecting the surety's
liability upon the bond may be served. Liability of a surety may be enforced, or the bond may be released, on
motion in the appellate court without independent action.
2. A tenant who retains possession of the premises that are the subject of the appeal during the pendency of the
appeal shall pay to the landlord rent in the amount provided in the underlying contract between the tenant and
the landlord as it becomes due. If the tenant fails to pay such rent, the landlord may initiate new proceedings for
a summary eviction by serving the tenant with a new notice pursuant to NRS 40.253.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
10 of 136 1/5/2012 3:53 PM
RE: inventory continued
privilege.
Sent: Fri 12/23/11 2:33 AM
5 attachments
IMG_20110522_163658 missing items Onkyo receiver tuner Sony subwoofer Technic speaker.jpg (750.3
KB) , IMG_20110818_205455 Toshiba 62hm15a hdtv.jpg (1075.7 KB) , Line 6 Spider III 15 15W 1x8 Guitar
Combo Amp and more Guitar Amplifiers at GuitarCenter_com.htm (146.2 KB) , receipt for purchase of
lamp for Toshiba 62HM15A $87.pdf (31.7 KB) , IMG_20110818_203900 hdtv 52 inch in back
bedroom.jpg (234.7 KB)
I am writing to further supplement and clarify the inventory of items missing. Mr. Baker and Mr. Hill, please
know YOU ARE PLACED ON A LITIGATION HOLD NOTICE REQUIRING YOU TO RETAIN AND PRODUCE ALL
PHOTOGRAPHIC/VIDEO/AUDIO EVIDENCE YOU OR YOUR AGENTS HAVE COMPILED TO THIS DATE AND IN THE
FUTURE, ESPECIALLY WITH RESPECT TO PERSONAL PROPERTY ON THE PREMISES, INCLUDING ANY EVIDENCE
WHICH REFLECTS UPON WHAT WAS STOLEN OR DAMAGED INCIDENT TO THE BURGLARY OF APPROXIMATELY
DECEMBER 12TH, 2011 (INCLUDING THE POLICE REPORTS YOU SHOULD HAVE MADE). I reserve the right to
update this inventory if any of these items are found, or if others are discovered lost or damaged
I hereby reserve the right to amend this inventory should any of these items turn up under some of the "rifled"
through, the use Casey Baker, Esq.'s expression property, that was completely strewn about the premises. But I
doubt they will.
Amongst the items that were missing upon what was obviously an upsetting emotional hurried inventory (you
can imagine going into your home and seeing it look like it been subject to an extensive burglary), were:
http://www.zzounds.com/item--CASPX330 That is the 88 key keyboard, with hammer weighted action, Casio
Previa PX-330 that sat atop the desk in the front office is missing, very obviously
http://www.musiciansfriend.com/accessories/lr-baggs-dual-source-system That LR Baggs Dual Source blend
system was put into the Charvel acoustic "cutaway" guitar that is missing, which was in the front office, and was
in excellent condition, in addition to having the expensive after market LR Baggs dual source system added to it:
http://en.allexperts.com/q/Guitar-General-649/Charvel-jackson-guitar.htm-Drive/13055863
http://www.hdtvsolutions.com/Toshiba-62HM15A-reviews.htm I had just purchased a new lamp for that
television. Please see attached receipt for that lamp and attached picture of that Toshiba 62 inch television.
http://www.guitarcenter.com/Line-6-Spider-III-15-15W-1x8-Guitar-Combo-Amp-482276-i1979323.gc That is a
Line 6 Spyder III guitar amplifier that is missing
http://reviews.cnet.com/projection-tvs/samsung-hl-p5685w-56/4505-6484_7-31008492.html?tag=subnav I did
not see this Samsung HLP5685W hdtv dlp at the property. I want to verify tomorrow that it is for sure gone (Yes,
its a large television, but it the top had been temporarily removed from its pedestal.
Additionally, amongst the items that were "rifled" through incident to the burglary was an AKG C300B
microphone that is heavily scratched up and is obviously damaged:
11 of 136 1/5/2012 3:53 PM
http://www.sweetwater.com/store/detail/C3000B/?utm_source=Google&utm_medium=PPC&
utm_campaign=livesound&utm_term=akg_c_3000_b&adpos=1t1&gclid=CJ6S_4rkl60CFQ5lhwodV2YG4w
missing speaker as well technic sb-2840
Sony power subwoofer (see picture attached of Onkyo Receiver stacked audio system)
I believe a 1000W Sony Xplod Car Audio 12 inch subwoofer, new in box was taken as well, it retailed for, I believe,
about $75 after taxes: http://www.walmart.com/ip/Sony-Xplod-XS-GTX120LW-12-Car-Subwoofer/12016333
A Sony audio receiver appears to be damaged, I will provide the model number later.
http://www.amazon.com/Philips-32PFL3505D-F7-32-Inch-Black/dp/B003IT6Z40 That is the model of the
manufacture in 2010 Phillips 32 inch lcd television/computer monitor that was utilized in a dual screen display
setup at the lawyer's desk in the commercial law office at 121 River Rock St. Mr. Baker correctly identified it as
missing after the break in, as he did the 62HM15A Toshiba HDTV in the living room, and the various audio
receivers, etc. in Mr. Bakers attached December 14th, email (attached and admitted into evidence along with the
reply from zachcoughlin@hotmail.com at the hearing on December 21, 2011). In his December 14, 2011 writing
Mr. Baker wrote: "The River Rock property has been broken into. We believe the break-in occurred sometime on
Monday, December 12, 2011. There appear to be items missing, including the TV in the living room, perhaps a
computer monitor, and perhaps some stereo equipment. I cant tell what else. The contents of the residence
appear to
have been rifled through."
http://www.americanmusical.com/Item--i-SHU-BETA58A-LIST I believe that microphone is missing, it is a Shure
Beta 58A Dynamic Microphone. I reserve the right to update this inventory if it is found.
A foam mattress, size full is missing. The wooden platform for it is oddly part in the flower bed and part
seemingly used to secure a window in some fashion, estimated value $800
Two, (2), of these http://www.amazon.com/Keurig-B60-Special-Single-Cup-Home-Brewing/dp/B000AQSMPO
$165 Kuerig B60 Coffee Machines appear to be missing
http://www.walmart.com/ip/Western-Digital-WDBAAU0020HBK-NESN-Elements-Desktop-Hard-Drive/13055863
Two, (2) of those Western Digital Elements 2TB external hard drives $190.
As for damaged items, the Sony hdtv 52 inch television in the back bedroom is not turning on, please see
attached picture (a clearer picture and model number will be forthcoming).
Strangely, its appears that, even where the contractor (whose bill for $1,060 included a notation of "fixing leak in
the basement") boarded up the back porch, he apparently did not do it very well, as the window to the back
door, inside the porch, appears to have been smashed.
I believe there are more things missing or damaged but this is not a task that can be done extremely quickly, and
I reserve the right to supplement this inventory as more missing or damaged items become apparent. I would
like some additional time at the property due to Richard Hill's interference on Thursday and Hill's contractor
having taken my ladder, which I was relying on for accessing and inventorying the attic. Further, I wish to leave
this property in very, very good shape for Dr. Merliss. I have respect for Dr. Merliss as I do for this Court, Mr.
Baker, and Mr. Hill, for whatever it is worth. Admittedly this litigation has gotten a bit scrappy, and we have all
been challenged by a Landlord Tenant Statute that is not always entirely clear and does not have the benefit of a
great deal of intermediate level appellate court case law to guide litigants through the ambiguities encountered
throughout this case. I want to leave this property in as good as shape as possible for Dr. Merliss, and believe
Hill and Baker are intent on limiting my opportunity to do that as much as they possibly can because they want
to pursue some theories of recovery based upon leaving property at the location, etc., etc., and have their
contractors do their typically inflated billing for work that, as here, ultimately is not very effective, as this
"securing" of the property, especially where a window unit air conditioner held in place by nothing but duct tape
and lacking even a simple jam rod atop the sliding window, was left in place on a side of the house exposed to a
sidewalk near the Lakemill Lodge. Or, Hill and Baker may just be legitimately fearful that I may do something to
harm their client's interest at the property and merely zealously advocating on Dr. Merliss's behalf. I feel like an
additional 8-16 hours at the property may yield a lot of benefit to the overall appearance and state of the
property.
12 of 136 1/5/2012 3:53 PM
I realize a stay was denied, however, I believe NRS 40.385 may be akin to the automatic stays attendant to
bankruptcies.
Sincerely and Respectfully,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
From: zachcoughlin@hotmail.com
Subject: inventory continued
Date: Thu, 22 Dec 2011 12:09:18 -0800
Additionally some rare book are missing, family photographs/keepsakes/heirlooms/media, I believe the hammer
weighted action Casio 88 key PX 330 is the model number, I believe, I will have to check.......Further, this is all
moot at this point as I have filed a Supersedeas Bond of $250, and according to NRS 40.385, I automatically get a
stay of eviction and am entitled to return to the property and continue in possession. The statute sets the
Supersedeas Bond (which yields a stay) at $250 if rent is under $1000, unless the Court wishes to rule that
13 of 136 1/5/2012 3:53 PM
I am a commercial tenant. However, if the court does rule that I am a commercial tenant, the No Cause
Eviction Notice in this case, under NRS 40.253 makes a Summary Eviction Proceeding impermissible, as
Summary Eviction Proceedings are not allowed against commercial tenants where only a No Cause Eviction
Notice is filed. Its one or the other, but Mr. Hill and Baker cannot have it both ways. Further, the Courts Order of
December 21, 2011 is just that, and Order, its not an agreement, its not a settlement, etc, etc. and the audio
record clearly reflects that.
NRS 40.385 Stay of execution upon appeal; duty of tenant who retains possession of premises to pay rent during
stay. Upon an appeal from an order entered pursuant to NRS 40.253:
1. Except as otherwise provided in this subsection, a stay of execution may be obtained by filing with the trial
court a bond in the amount of $250 to cover the expected costs on appeal. In an action concerning a lease of
commercial property or any other property for which the monthly rent exceeds $1,000, the court may, upon its
own motion or that of a party, and upon a showing of good cause, order an additional bond to be posted to
cover the expected costs on appeal. A surety upon the bond submits to the jurisdiction of the appellate court
and irrevocably appoints the clerk of that court as the surety's agent upon whom papers affecting the surety's
liability upon the bond may be served. Liability of a surety may be enforced, or the bond may be released, on
motion in the appellate court without independent action.
2. A tenant who retains possession of the premises that are the subject of the appeal during the pendency of the
appeal shall pay to the landlord rent in the amount provided in the underlying contract between the tenant and
the landlord as it becomes due. If the tenant fails to pay such rent, the landlord may initiate new proceedings for
a summary eviction by serving the tenant with a new notice pursuant to NRS 40.253.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
14 of 136 1/5/2012 3:53 PM
interference with my right to get my property
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FOLLOW GUITAR CENTER:
Sent: Sat 12/24/11 1:44 AM
To: Richard Hill (rhill@richardhillaw.com); cdbaker@richardhillaw.com; psferrazza@washoecounty.us
38 of 136 1/5/2012 3:53 PM
Some of my property remains on the premises. I want access to it, some of it,
I believe even involves both my law practice and my mattress business, and
reserve my rights to sue for damages, even the consequential/punitive kind in
the Schiff case where a seafood distributor in Nevada was awared as damages
the entire value of his business, which went under as a result of a Landlord's
nefarious deeds. My rights under the Court's Order of December 21, 2011
where interferred with. To wit, Richard Hill's contractor, for some strange
reason, removed a ladder I own from the property, preventing my access to
the attic. Further, the entire back porch remained boarded up during the
entirety of my access to the property this Thursday and Friday, that prevented
me from both removing my property and in returning Dr. Merliss's property
to the state I would have liked to leave it in. Additionally, despite not having
a chained padlock on the back fence for the vast majority of the time the
property was unoccupied, even where refusing to let me so secure the
property, all of the sudden, a chain link padlocked is secured to the
backyard/porch gate when it comes time for me to be allowed to access the
property and remove my belongs. Neither Hill or Baker responded to my
calls and written, hand delivered requests for them to remove the lock from
the back gate until it was far too late to avoid interfering with my rights under
the Order, nor did either of them ever have the door the house on the back
porch be put in an accessible state, as it remained boarded up.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
39 of 136 1/5/2012 3:53 PM
invenotry of missing personal property continued: sony DCR-DVD610
with 8gb duo memory card
privilege.
Sent: Sun 12/25/11 5:22 PM

There is a very sentimental hand drawn picture/caricture of my former girlfriend and
cotenant of 5 years Melissa Ulloa and myself that I believe I forgot to grab on my hurried
way out near 5:00pm on Friday. It was resting above the crown modling atop the area
attaching the dining room to the kitchen, where dishes were stored, in the dining room area,
it is a picture of her and I (she has glasses on in it) and I would very much like the
opportunity to retrieve it. It would have been one of the first things grabbed, but I wanted
to place it some place where it would not get bent or damaged and decided it would be
safest to bring it in my uhaul's cab near the end of this moving ordeal, but I am afraid I did
not get a chance to grab it before Richard Hill showed up with Casey Baker in tow and
video cameras. How it was at all fair to expect me to enter my former home and law office,
which has been completely turned upside down by a burglary that was able to occure due to
Baker and Hill's negligence, then demand that I ignore that extremely emotionally upsetting
occurance and immediately conduvct some crack inventory of items damaged or stolen, all
in less than an hour (after accounting for the travel time to get to somewhere to send the
Court and Baker an email inventory and the time that Richard Hill remained on the property
after 9 am on Thursday) is not at all clear to me.

40 of 136 1/5/2012 3:53 PM
In addition to the items previously disclosed as missing or damaged is the following, which
is missing:
http://www.amazon.com/Sony-DCR-DVD610-Handycam-Camcorder-Optical/dp/tech-data/B00123Q8YQ
/ref=de_a_smtd
That is a Sony DCR-DVD610. It had a somewhat expensive media card in it, which
sentimental and work related media on it that is irreplaceable. The card itself (and
this camera had one inside and one taped to it) cost money too:
http://www.amazon.com/SanDisk-16GB-Memory-Stick-PRO/dp/B00488CN1O/ref=sr_1_12?s=electronics&
ie=UTF8&qid=1324862012&sr=1-12

I believe one of the microphones previously indicated as missing has been found, a Shure
SM58a, however, I have not been able to test whether it is damaged or not, yet).

Two of these are missing as well: http://www.amazon.com/SanDisk-Cruzer-Flash-Drive-SDCZ36-032G-
A11/dp/B001T9CTS2/ref=sr_1_2?s=electronics&ie=UTF8&qid=1324862190&sr=1-2 at a current price of
$27 per on amazon, however, media and files were on those that is irreplaceable and
valuable to me.

The mold that I wrote to Merliss of on May 14, 2011 is in a very large clear bag on the
property. The original carpet, the 100% nylon brown shag, slumlord 101 carept is on the
property as well and should be retained should Dr. Merliss want it. That carpet became
moldy and had a poor smell when Merliss' handyman twice flooded (on two separate
occasions) the washing machine in the kitchen). I would like my car seats and other items
that are still on the property for which Richard Hill and Casey Baker's interference
preveneted me from having adequate time and access to remove such.

Additionally, while I have not conducted a complete review of all my hard drives, the
desktops hard drive indicates file on it were modified on at least two occasions while in Hill
and Baker's custody, both on December 6th, and December 14th, 2011. This is completely
unacceptable.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
41 of 136 1/5/2012 3:53 PM
Nevada Bar No: 9473
privilege.

To: rhill@richardhillaw.com; cdbaker@richardhillaw.com; psferrazza@washoecounty.us
Subject: interference with my right to get my property
Date: Sat, 24 Dec 2011 01:44:51 -0800
42 of 136 1/5/2012 3:53 PM
Inventory continued: screen is cracked on my 17 inch dell laptop
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
43 of 136 1/5/2012 3:53 PM
inventory continued
Sent: Mon 12/26/11 3:27 PM
Dell Studio 1737 Screen is cracked. The screen was an upgraded screen that
is 1920 by 1080 LED/LCD screen. I fired up the laptop and the screen is
shattered in appearance an is not usable.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Tue 12/27/11 2:47 PM
Among the items either stolen, missing, damaged, etc are the following:
44 of 136 1/5/2012 3:53 PM
4 1997 (approx) VW Jetta alloy wheels with performance racing tires (14 inches 4 x100
bolt pattern)
my collection of leather 8-14 way electric car seats: (3 lexus LS400 tan leather 14 way car
seats, 2 silver, 1 black 1991 ish BMW 735iL front bucket car seats), Subura, half purple
suede, half black leather Legacy sport car seat, Toyota avalon cloth driver power seat, 1995
Lexus sport coupe front bucket black leather power seat, lexus LS400 unique back seat tan
leather built into a loveseat/couch, all my cream high density carpet, approx 900 square feet
of it, my Sony 52 inch television, black velvet chairs (2), a number of other office chairs
and furniture, etc., various kitchen appliances and utensils and cleaning supplies, etc.,
various expensive accordion style cloth windows shade/blinds by levolor and other
expensive makers, approximately 15 light switch "dimmers", 900 square feet of green
woolen outdoor carpet, black Ikea office desk with glass top, approxmiatley $1,500 worth
of rare and exotic natural stone tile, porcleain, and ceramic tile, full size woode bed frame,
queen size wood bed platform, a number of extension cords, a great deal of tools, including
power tools, power recipro saw, power drill, a number of leather Lexus and BMW back car
seats incident to unique furniture creations of Coughlin Memory Foam. A BMW black
leather back seat built into a love seats, Lexus es300 silver leath back seat, LS 400 back
seats top and botton, tinted front driver and passenger glass windows for Lexus ls400 (4
total) and 2 total for corolla 1999 (also tinted), another wooden queen size bed platform,
Red stainless steel glass top patio table (large), several hibachi style grills, a huge collection
of tools and screw, nuts bolts, rope, many automobile expenisve electrical items, includign
5 auto climate controls units from Acura Legend, Lexus LS400 and ES300 and BMW's,
large collection of premium automobile speakers (approximately 25 speakers ranging from
tweeters to subwoofers), large collection of premium BMW/Lexus automobile amplifiers.
Approximately 1,000 square feet of both carpeting and plywood. The landlord should not
simply get to have his previously dirt floor basement be both vapored barriered with 10 mil
plastic sheeting and quality carpeting. I want the vapor barriers and the carpeting. It was
my hard work that got that material and all the plywood in the attic, Merliss should not
simply be given it by this Court with the help of an uneccesarily narrow in time frame
opportunity to retrieve my property (particularly where the court required i pay basically
my last $500 for the lien, for property which no certainty was provided by Baker or Hill
that it had not already BEEN STOLEN!) only to require an impossible accounting of
damage and stolen inventory of personal property (it takes time to fire up electronics and
see if they are broken etc....). I do not, and have not given anyone the right to take away
any of this property, it is my, I sweated and work hard to collect it, I could care less if
BAKER AND HILL HAVE SAID IN COURT THAT THEY THINK IT IS JUNK. HOW
WOULD YOU LIKE IT IF I SAID YOUR COLLECTINO OF 8 PORCHES WAS JUNK
MR. HILL? WHETHER YOU THINK IT IS JUNK OR NOT, IT IS MINE, I PAID THE
LIEN, AND YOUR INTEFERENCE IN REMAINING ON THE PROPERTY DURING
THE TIME THE ORDER ALLOWED ME ACCESS TOO, PUTTING A PADLOCK ON
THE BACK GATE AND ONLY REMOVING IT WITH APPROXIMATELY 3 HOURS
LEFT IN THE 16 I WAS ALLOTED TO BOTH MOVE AND CONDUCT THIS
"EMERGENCY" INVENTORY) AND IN KEEPING THE ENTIRE BACK DOOR TO
45 of 136 1/5/2012 3:53 PM
THE HOUSE AND BACK PORCH BOARD UP ENTIRELY AND INACCESIBLE,
PREVENTED ME FROM HAVING AN APPROPRIATE OPPORTUNITY TO REMOVE
MY PROPERTY. THIS INVENTORY STILL NEEDS TO BE SUPPLEMENTED. 4
ACURA LEGEND AND HOND ACCORD ALLOY WHEELS (15 INCHES) WITH TIRE
WITH APPROX 50% USABLE TREAD ON THEM. THIS IS NOT JUNK, ITS WHAT
YOU DO WHEN THE ECONOMY SUCKS AND YOU DONT' GO AROUND ASKING
THE GOVERMENT FOR A HANDOUT EVERY 5 SECONDS, LIKE I WAS TAUGHT
ABOUT NATIVE AMERICANS IN SCHOOL, YOU USE EVERYTHING YOU HAVE
AND WASTE NOTHING.

I WANT ALL OF MY PROPERTY PLEASE. IT WOULD BE RECKLESS TO THROW
AWAY MY PROPERTY ON SOME BASELESS AND UNFOUNDED ACCUSATION
THAT I WOULD SOMEHOW DAMAGE THE PREMISES. HILL AND BAKER
SHOULD NOT BE ALLOWED TO LEAD THEIR CLIENT INTO MORE AND MORE
LIABILITY IN SOME IMPRUDENT ATTEMPT TO BILL UP SOME LARGE
"DAMAGES" CAUSES OF ACTION FOR PROPERTY LEFT ON THE PREMISES OR
DISPOSAL COSTS. HILL AND BAKER HAVE AN ESTABLISHED PATTERN OF
HIRING "CONTRACTORS" TO SECURE THE PREMISES, ONLY TO LEAVE A
WINDOW UNIT AIR CONDITIONER IN A WINDOW, UNSECURED BY ANYTHING
MORE THAN DUCT TAPE, AND THEREFORE, CAUSE BY THEIR OWN
NEGLIGENCE AND THAT OF THE CONTRACTORS, THE THEFT OFF
APPROXIMATELY $7,500 IN TANGIBLE, NON SENTIMENTAL ITEMS, AND
UNTOLD AMOUNTS IN DAMAGE TO SENTIMENTAL ITEMS.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
46 of 136 1/5/2012 3:53 PM
I believe these emails should be part of the file, same as faxes from Baker
are included in the file
privilege.
Sent: Tue 12/27/11 2:53 PM
To: kstancil@washoecounty.us; cdbaker@richardhillaw.com; rjcweb@washoecounty.us;
stuttle@washoecounty.us
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FW: Disposal of Personal Property at River Rock
12/04/11
Zach Coughlin
To stuttle@washoecounty.us, kstancil@washoecounty.us, cdbaker@richardhillaw.com
From:Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Sun 12/04/11 1:40 AM
To: stuttle@washoecounty.us; kstancil@washoecounty.us; cdbaker@richardhillaw.com
1 attachment
LT Coughlin (disp of pers ppty - with encl)(12-2-11).pdf (86.4 KB)
I know what was said during the telephone conversation, believe me, I know
verbatim what was said...there was a condition placed on getting my hearing
for a motion to return personal property. I showed up to the first hearing, saw
47 of 136 1/5/2012 3:53 PM
JCRCP 84 emergency correspondence due to Judge Sferrazza's absence
privilege.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
118 of 136 1/5/2012 3:53 PM
Sent: Tue 12/27/11 7:03 PM
To: jschroeder@washoecounty.us; kstancil@washoecounty.us; psferrazza@washoecounty.us;
stuttle@washoecounty.us; cdbaker@richardhillaw.com
1 attachment
12_21_11_Order_resolving_Motion_to_Contest_PErsonal_Property_lien.pdf (2.4 MB)
Dear Chief Judge Schroeder, Judge Sferrazza, and Mr. Hill and Mr. Baker,

I am emailing this correspondence in addition to the more traditional faxing approach due
to the large number of hyperlinks it contains, and the ease wtih which one can access those
links when one receives the correspondence in an email format (simply clicking on the links
versus typing them in from a fax). Earlier in this case I had written Judge Clifton in this
case during a time when Judge Sferrazza was to be unavailable during a particular time
frame, under the belief that it was appropriate to do so under JCRCP Rule 84, in light of an
indication I do have a strong recollection fo seeing but which cannot find on the website
now, which indicated that the Chief Justice of the Peace was Judge Clifton, and further,
Casey Baker, Esq.'s October 17th, 2011 letter seeking an Emergency Order granting the
inspection of my law office was addressed to Justice of the Peace Clifton, causing me to
further confuse whom I should write to under JCRCP 84. I apologize for my mistake as it
now seems very clear that Chief Judge Schroeder is the "Chief Justice of the Peace"
mentioned in JCRCP 84 and to whom I should appropriately direct this inquiry. I take this
step of writing pursuant to Nevada's JCRCP 84 in light of the Reno Justice Court's filing
office's indication to me today that Judge Sferrazza was away this week, and while a
mention of Senior Judge Dannan was made, in an abundance of caution, I revert to the
dictates of JCRCP 84. I feel there is an exigent need to pursue this means of
correspondence given the thousands of dollars of property of mine that Mr. Hill and Mr.
Baker have indicated they will, essentially, throw away, with the intention of suing me for
thousands of dollars in "disposal" costs, which to me, seems like an unlawful rent distraint,
disallowed by NRS 40.520. Judge Sferrazza was implored to enter an Order as narrowly
curtailing my opportunity to retrieve my property, even after paying, essentially, my last
$480 dollars to Dr. Merliss, a California neurosurgeon graduate of Beverly Hills High
School, despite the fact that it had not been made clear at all, nor had any real inventory
been provided to me indicating what personatly was there prior to and after the December
12th, 2011 burglary. Mr. Baker and Mr. Hill apparently argued that my "bad faith" in
defending against a Summary Eviction Proceeding based upon a No Cause Eviction Notice
against a commercial tenant such as myself, dictated that my opportunity to retrieve my
personalty be reduced to something akin to a scene from a television game show where a
constestant is allowed into a plexiglass closet/vacuum chamber type apparatus and allowed
to grab as many dollars as they can within the few minutes afforded them. I was also
supposed to conduct a thorough inventory and accounting during my minutes in the
plexiglass chamber and email such to Judge Sferrazza. I would like an opportunity to
retrieve my belongings without a padlock and chain being place on the back gate
119 of 136 1/5/2012 3:53 PM
immediately before my visits to the property and without the back door being completely
boarded up.

http://www.co.washoe.nv.us/rjc/chiefjudge.htm :"Chief Judge The Chief Judge for 2011 is Judge Jack
Schroeder .
The duties of the Chief Judge include: administrative responsibilities, sitting for judges who are out of the office
due to sickness, vacations or schooling, verified citation trials and other hearings as necessary. "

JCRCP RULE 84. CHIEF JUSTICES OF THE PEACE

(b) Responsibilities. The chief justice of the peace in a township shall:

(3) Hear or reassign emergency matters when the assigned justice is absent or otherwise
unavailable.

(4) Designate another justice to perform the duties of chief justice of the peace when the
chief justice of the peace is absent.

Judge Sferrazza issued a ruling following the hearing on my November 16th, 2011 Motion to Contest
Personal Property Lien after the hearing held on December 20th, 2011. The Order (please find it
attached to this correspondence) allowed me access to the property, upon paying Mr. Hill and Mr.
Baker's client, Matt Merliss, MD, $480 for "storage costs" of my personal property for the period
between November 1st thorugh November 16, 2011. I was granted the time period between Thursday,
December 22nd, 2011 from 9am to 11 am to conduct an inventory of all of my personal property on the
premises and by 11 am on 12/22/11 send an email from a wifi location near the property to both Mr.
Baker and Judge Sferrazza describing all the property that was either stolen (Mr. Baker wrote me on
December 14th, 2011 reporting that the boarded up property containing so many of my possessions and
client files was burglarized and "rifled through", with a number of items of personalty missing,
including a 62 inch HDTV Digital Light Projection (DLP) television set that retailed for over $2,300 in
late 2007 (a Toshiba 62HM15A):
http://www.hdtvsolutions.com/Toshiba-62HM15A-reviews.htm

Please consider the value of my luxury automobile leather power seat collection, which is
an offshoot of my business, Coughlin Memory Foam which had at least one type of address
with the Nevada Department of Taxation listing the 121 River Rock St. 89501 address...Just
120 of 136 1/5/2012 3:53 PM
imagine a nice 14 way power seat (front to back, side to side, 4 way lumbar, head rest up
back, 4 way bottom seat tilt, heated, aftermarket massage modification built in, etc., etc),
put on a wheel base....how player wouuld that be at your desk, Mr. Hill? I know you would
probably go with something from the Porsche line given your affinity for that fine make.
Your Honor, I imagine those long hours on the bench could be made much more
comfortable with something, say, from an Cadillac Escalade in judicial robe black. Of
course, I am jesting, and this is not meant to be taken as an offer of anything, but merely to
illustrate that I have plans for those seats, they are incident to my Coughlin Memory Foam
business, and it was my sweat equity in gathering foam, luxury automobile power seats,
wheel bases, tools, plywood, metal storage shelfs (like the white ones in the attic), all the
plywood that created the attic floor, etc., etc. One of these example luxury automobile
bucket seat to office desk chair conversions was seen at my office desk at 121 River Rock,
on a wheel basis, with a power source attached, sat a tan leather Lexus LS400 second
generation driver bucket seat, with the patented coil suspension system built into the seat
(far more advanced than the simple sinusoidal variety of springs so often used):

http://www.google.com/patents/about/3913975_SUSPENSION_SEAT.html?id=rOA4AAAAEBAJ
"The redesigned LS 400 interior received upgraded features, varying from dual-zone climate controls to rear
cupholders.
[42]
A newly patented seat cushion design, similar to the car's suspension, utilized lightweight
internal coil springs and stabilizer bars to improve comfort.
[46]
" 1995 Lexus LS 400: Improving on near
perfection". New Car Test Drive.com. 2005. http://www.nctd.com/review-
intro.cfm?Vehicle=1995_Lexus_LS%20400&ReviewID=2588. Retrieved 2006-12-01. "0-60: 7.1 sec."

I believe I had 4 Lexus LS400 bucket front seats at the property, and hopefully they remain there and I will be
allowed to access them. They are all in about the best condition you could find them in, as one might go on
many, many trips to Pick N Pull junkyards resulted in a haul of these seats, in a year, make, and model, that is
very rarely found in a junk yards, and even more rarely found in any useful condition:
http://www.picknpull.com/check_inventory.aspx?Address=89501&Lat=39.526215&Lng=-119.810633&
Make=Lexus&Model=LS+400&Distance=25000
Indeed, the link above shows there are only 2 second generation Lexus LS400 cars available within an unlimited
distance of area code 89501 from the 1995-2000 model years of that generation, one in Stockton, one in Rancho
Cordova. They are too heavy to ship economically...Plus it takes work to go figure out how to get them out of a
car in a junkyard (hint, a cordless power drill, some wires, and hard earned know how gained from looking at
wiring diagrams for the sometimes 50 wires under those seats will allow one to move them forward and
backward sufficient to get at all four of the 14mm bolts holding these seats down).

I focused on the 1995-2000 second generation era of LS400 front power leather bucket
seats as they had the newly patented suspension system and I found them uniquely superior
in comfort and performance. I am a licensed patent attorney with the USPTO, and, like a
lot of creative types and inventors, can be somewhat "outside the box", and sure, to some it
looks crazy and looks like I am a "hoarded" and that my stuff is "junk".
Those 4 LS400 seats alone could be parted out for approximately $6,000:
http://www.ebay.com
/sch/i.html?_trkparms=65%253A12%257C66%253A2%257C39%253A1%257C72%253A5952&rt=nc&
_nkw=lexus+power+seat&_sticky=1&_trksid=p3286.c0.m14&_sop=16&_sc=1
121 of 136 1/5/2012 3:53 PM

Or, I believe I could sell them, after making modifications, as premium unique office desk chairs to lawyers,
doctors, business people, etc. as well as couches/love seats in a similar vein when combined with existing
couches or love seats, and there are two such prototypes at the property still, a tan Lexus LS400 back seat
incorporated into a tan sued loveseat and a black leather 1991 BMW 735il backseat incorporated into a
wicker/wood couch that is currently on the porch and not secured enough for my tastes to guard against theft.
If one takes a look at what a very nice, motorized leather office chair can cost at fine furnitures stores, it is not at
all hard to believe I could garner over $1,000 per seat. http://www.ebay.com/itm/LEXUS-LS-400-BLACK-
LEATHER-SEAT-DRIVER-POWER-95-00-OEM-/160596876448?pt=Motors_Car_Truck_Parts_Accessories&
vxp=mtr&hash=item256451dca0

But, I beg to differ, and feel I should be given some credit for being a lifelong Nevadan
who did not move when our economy began to take on a drastic appearance, rivaled by only
Rhoad Island and Michigan, but, instead buckled down and got creative and tried to find a
way to make it happen here in Reno, Nevada, both as an attorney and an entrepreneur. I
don't know about you, but ugly metal strips separating the ugly slumlord 100% nylon
medium brown shag carpet (that carpet looks good, barely, for about a day after one buys it,
after that, it is forever matted down and lackign any resistance to staining) from the ugly
linoluem inside the property (compare the linoleum to the exotice natural stone and
porceline tile from Italy, France, Indonesia, Bali, Japan, etc. that had been puzzled pieced in
by borders, ie, not mortared down, at the property, here):

https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!452&parid=root

after walking past what is essentially a dirt yard would not seam to inspire confidence in
potential clients such that they would plunk down their hard earned money to an attorney
and entrust him with their high stakes litigations (whatever decomposed granite that was
leftover from the two story pink Victorian turn of the century house the landlord owns next
door to the property I rented had long since blown away in the wind, plus a multiple times
per year practically overnight weed problem would metastasize grotesquely, for which Dr.
Merliss himself said he paid a crew of landscapers $2,000 to weed for the property I rented
alone....plus, my dog, Jackson Pawluck-feature in the December "Animal Law" issue of
Nevada Lawyer, was constantly getting those painful goatsheads from dried out weed in his
paws, plus the dirt lawn resulted in an inordinate need for constant dusting.....enter my
ingenuity in securing over 800 square feet of very high quality high density green woolen
outdoor carpet...the result? No more paying yearly for weeding, no more constant dusting
inside, no more dogs getting goatsheads in their paws, no more stigma of having a law
office with a dirt lawn, etc., etc.)
http://www.ebay.com/itm/PORSCHE-986-996-FULL-LEATHER-SEATS-2-WAY-POWER-BLACK-
/260921596407?pt=Motors_Car_Truck_Parts_Accessories&vxp=mtr&hash=item3cc02399f7

You guys say its junk, but my seat collection could be parted out for a nice chunk of
change:
http://www.ebay.com
/sch/i.html?_trkparms=65%253A12%257C66%253A2%257C39%253A1%257C72%253A5952&rt=nc&
122 of 136 1/5/2012 3:53 PM
Re: Offer withdrawn
_nkw=porsche+power+seat&_sticky=1&_trksid=p3286.c0.m14&_sop=16&_sc=1

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
From: zachcoughlin@hotmail.com (zachcoughlin@hotmail.com)
Sent: Fri 12/30/11 7:55 AM
To: rhill@richardhillaw.com; cdbaker@richardhillaw.com (cdbaker@richardhillaw.com)
I had to move again over the last couple days 8 want my property, dispose of it at yours and your clients own
liability. I didnt get your email until late last night and i still dont consent to service of anything from you or your
firm electronically. You are on a litigation hold notice as to the moldy insulation in a clear water tight bag in the
front of the property and as to any video, photo, or other evidence you have collected. You allegation that i
burglared the property is pathetic and beneath you. Did you file a police report when the property was
123 of 136 1/5/2012 3:53 PM
ADR
burglarized on approx December 12th? You are making other people look bad.
Sent from my HTC
----- Reply message -----
From: "Richard Hill" <rhill@richardhillaw.com>
To: <zachcoughlin@hotmail.com>
Subject: Offer withdrawn
Date: Fri, Dec 30, 2011 7:07 am
Mr. Coughlin - you proved me correct, you are obviously more interested in
haggling and hassling than you are in actually getting any of the remaining
stuff at the river rock house. Further, although given adequate time, you
have not even bothered to file a motion with the district court.
THE PRIOR OFFER TO LET YOU BACK INTO THE PROPERTY IS REVOKED.
We will start the disposal process immediately.
Rgh
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To ensure compliance with requirements imposed by the IRS, we inform you
that any U.S. federal tax advice contained in this communication (including
any attachments) is not intended or written to be used, and cannot be used,
for the purpose of (i) avoiding penalties under the Internal Revenue Code or
(ii) promoting, marketing or recommending to another party any transaction
or matter addressed herein.
Sent: Fri 12/30/11 8:01 AM
Your contractor and you may face fraud charges for charging $1,060 to board up the porch with screws in
plywood facing the exterior, leaving the window unit ac in without a brace, leaving property on the yard abutting
the exterior fence, etc. I want the desk too. Rich, please don't do this to yourself, you have such a bright future
124 of 136 1/5/2012 3:53 PM
why muddy it up with your sanctionable conduct? You are better than that, I know it.
Subject: An adult conversation
Date: Wed, Dec 28, 2011 9:03 am
Mr. Coughlin - let's have a reality check.
1- your list of "stolen" items continues to spiral through fantasyland.
You know WE didn't take any of your stuff.
If you did think we took your stuff, you would have filed a police report.
2- if we don't have it, then who does??
The most likely candidate---->YOU!!
You turned breaking into that house into an art form, before you were
arrested & finally locked out.
Who, besides you, would have known that there was anything in the basement
to steal?
Who, besides you, would have known how to work the lights down in that
spider hole you were living in?
Why haven't you filed a police report?
3- Dr. Merliss is only liable for negligence in terms of dealing with any of
your property- look at the statute.
The facts that you had to kick the front door down, and then had to take the
back door apart, show that adequate protections were taken. You did not gain
entry through the window with the air conditioner - at least as far as we
know, so it is a non-issue. There isn't a judge in town who will not grant
summary judgment on that issue.
4-IF you really had the stuff you say, and IF you really didn't take it ( or
know who did), then you would be filing a police report.
That would do two things:
First, it would help your abysmal lack of credibility
Second, it would possibly trigger the cops to go look for your stuff & maybe
get it back.
5-your claims.
The only real claim you have is a malpractice claim against yourself.
Your work product is terrible, and, most of the time, you can't even get it
filed and served.
Please look at RPC 1.1(competence)
125 of 136 1/5/2012 3:53 PM
6- neither Mr. baker nor I will take your calls.
All you do is hassle & harangue.
Confine yourself to written communications.
7 - we don't want the stuff left in the house, but we don't trust you - at
all.
Your stunt last time, announcing that you were going to stay, does not
inspire us to place ANY confidence in anything you say.
If you want in, you need to do up a stipulation & order, to be approved by
judge Flanagan. Suggest that you use Sferrazza's order as a starting point.
It needs to include a waiver of your security deposit. It will need to
include signed waivers by you & your posse (and we want the ones from the
last venture - a compliance/credibility thing!!). The boards on the back
stay up ( your fault on that one!); you need to fix the back gate and, you
need to be done by 5 on Friday (12/30/11). We need to be very specific that
you aren't taking anything attached to the house, or any flooring - except
the carpet in the basement and outside. You need to list what you think you
want to take for our approval.
That means no games by you on the terms - you need to get moving & submit
something for our consideration. I will edit it, but if it is going to take
any more than about 1/2 hour of my time, it will make it cheaper to just
throw the stuff away. We do have an order that we can dispose of the
property and hold you for the cost. You should regard what you send as an
offer that we may or may not take.
We may counter.
If you send over more of your self-serving crap, the deal is off. We are not
looking to engage in the protracted haggling that you so love.
We do not have a deal until the judge signs off
Show us how good a job you can do - you know what we will want.
We think that you are more interested in the hassle and the attention than
any real progress.
Again, don't call or waste our time
Rgh
126 of 136 1/5/2012 3:53 PM
TRO
RE: ADR
Triple
Sent: Fri 12/30/11 9:04 AM
To: Richard Hill (rhill@richardhillaw.com); cdbaker@richardhillaw.com; knielsen@richardhillaw.com
1 attachment
amended emergency tro for shill, er hill 12 30 11 to fax.pdf (388.0 KB)
Rich,
I hate to see you resorting to implying an improper ability to influence a
tribunal.
Sent: Fri 12/30/11 9:07 AM
To: Richard Hill (rhill@richardhillaw.com); sgallagher@richardhillaw.com; cdbaker@richardhillaw.com
what does "demonstartes" mean? Is that some sort of ancient Lycan terminology?
From: rhill@richardhillaw.com
To: zachcoughlin@hotmail.com; cdbaker@richardhillaw.com
Subject: RE: ADR
Date: Fri, 30 Dec 2011 08:26:48 -0800
this email further demonstartes your utter lack of competence as a lawyer
Sent: Fri 12/30/11 10:37 AM
127 of 136 1/5/2012 3:53 PM
Coughlin v. Merliss
I have rarely seen a grown man employ the vaunted triple question mark or triple exclamation point with such
regularity as you, Richard...
Cc: <cdbaker@richardhillaw.com>
Subject: TRO
Date: Fri, Dec 30, 2011 9:12 am
is that what the voices are telling you???
From: Zach Coughlin [mailto:zachcoughlin@hotmail.com]
Sent: Friday, December 30, 2011 9:04 AM
To: Richard Hill; cdbaker@richardhillaw.com; knielsen@richardhillaw.com
Subject: TRO
Rich,
tribunal.
Sent: Fri 12/30/11 8:56 PM
To: Richard Hill (rhill@richardhillaw.com); cdbaker@richardhillaw.com

Dear Mr. Baker and Mr. Hill,
I appreciate your quick response. However, given that I have repeatedly told both of you in
writing that I do no consent to service of anything from anyone at your firm via email or
other electronic means, it should hardly be a surprise if I either do not receive emails like
those you recently sent wherein you attempted to get around the fact that you have violated
the NRS statute requiring you to return the $700 deposit under the Lease Agreement ($200
for a "cleaning fee" with an express reservation in the Lease Agreement that I may elect to
have the carpet cleaned myself and a $500 damage deposit, no to be used for rent as I read
the Lease Agreement, but I could be wrong) and under statute within 30 days of the lockout
or provide a specific, detailed, itemization of how the deposit monies were spent. Now, you
have subjected your client to the statutory penalties for your failure to so comply with NRS
regarding the return of a damage/security deposit. I realize that you are likely doing this
case on a flat fee now, or some contigency basis wherein any recovery you are able to chisel
128 of 136 1/5/2012 3:53 PM
out pursuant to your novel "disposal costs" DSM-IV diagnoses attempts would help offset
all the time you have spent putting Merliss and my names on old pleadings.

So, regardless of whether I had any duty to mitigate by checking for emails from opposing
counsel where I have previously provided numerous notices in writing that I do not consent
to such means for notice or transmissions of correspondence/pleadings related to these
matters, I believe what has encumbered me so much these past few days will provide
sufficient justification for any delay on my part. You see, I have a new address, as I have
found it necessary to move locations, yet again. Please note my new address for all
communications/pleadings/etc.:
1422 E. 9th St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

In addition to all the Goodwill and Office Supply store expenses your wrongful
eviction/illegal lockout/contributing to a wrongful arrest/filing a false police report, etc.
have caused me, was the need to rent an immediate replacement residence, which proved
unsuitable, necessitating another move, a move which resulted in another police report
being filed due to yet another Nevada landlord feeling able to do whatever it is the like to a
tenant, be it call him a "White N*gg#r" (you get the idea, hopefully), repeatedly assault and
battery him, etc., all because the landlord sought to add additional consideration to an
agreement after offer and acceptance were complete.

By the way, are you so sure I have not already filed a police report in relation to the
burglary of my law office that Casey Baker, Esq. reported to me in a correspondence dated
12/14/11? The property is located in very close proximity to the Lakemill Lodge, Mr. Hill,
it is hardly a surprise to anyone if it is burglarized , especially where you essentially put a
big sign in neon on the outside of the building announcing that it was not being inhabited,
while at the same time leaving many of the blinds up (by the way, the blind above the
kitchen sink is mine and I want it back, it is an expensive accordian style cloth blind that
raises and lowers or adjust from both the top and bottom, I believe the brand name is
actually "Bali".

Anyway, I don't know why you would think I suspect either you are Baker of stealing the
property. Neither of you seem to have a creative or musical bone in your bodies, so what
would you want with an $800 (approx.) Casio Previa PX-330 88 key keyboard with
hammer weighted action or a Charvel acoustic guitar with Abalone inlays and a LR Baggs
dual source aftermarket pickup (complete with a FET microphone to blend with the pickup
and or piezo source vibrations)? Now, I am not sure why you seem to indicate the stolen
items were only in the basement. Clearly, the discovery/pictures/invasion of privacy of my
law office/Fourth Amendment violations/media you produced to Reno City Attorney
Hazlett-Stevens can show that so many of the stolen items were in the front office at the
129 of 136 1/5/2012 3:53 PM
property, the Previa keyboard and 32 inch LCD Television (that was used as part of a dual
monitor desktop display at the attorney's desk along with another 32 inch LCD monitor).
What else do you see in all the pictures/videos you took that was upstair (ie, not in the
basement) at the property, and which ultimately was listed amongst the stolen or damaged
property?

Further, now it is clear you and your client want my expensive collection of imported
natural stone and porcelain tile. However, the tile is merely laid on the floor...it is not
affixed to the property, it was never mortared down, no thin set, no grout, etc., etc. It is not
yours or your clients. Sure, I understand, you and he want it, you find it exotic and
creatively done, in a pastiche/melange, however, Merliss is going to have to live with the
slumlord cutrate lino he had installed by "Antonio" rather than benefit from all the items
that I mentioned as possible avenues of settlement. You and Baker steadfastly refused to
even consider any settlement throught this matter. I am sure your client, looking back,
would prefer to have his property not have been burglarized and damaged extensively by
the 12/14/11 breaking and entering Baker wrote of, and would prefer to now own the large
swamp cooler with new premium diffuser pads and brackets for mounting to an exterior
backyard window, and would prefer to own the approximately $1,500 worth of plywood
that I collected during my stay at the property and for which is currently providing an attic
floor, but which, is not "affixed" to the property, as no nails or other methods were ever
used to so affix that plywood to the property in anyway. I am sure your client would prefer
to have whatever it is you actually charged him in fees back, in addition to all the bloated
process server costs and "contractors" work, not to mention the charges wrough by Nash
Pest Control et al for "inspections" that failed to comply with the notice requirements of the
Lease Agreement (not to mention the witness fees, etc, involved in arranging for such
individuals to testify on pointless non-sequiturs). I am sure your client would prefer to have
back the last 4 months of stress and worry your reckless pursuit of attorney's fees have
wrought on his life, and the various liabilities/lawsuits, you have now subjected him to, the
specter of which is a very, very real thing Mr. Hill, which your and Mr. Baker's malfeasance
has likely resulted in a situation where yours and Dr. Merliss's interests will diverge
significantly, requiring Dr. Merliss to, in all liklihood, retain new counsel, and pay them to
get up to speed on this matter, all of which could have been avoided had you or Mr. Baker
made any attempts at responding to my numerous settlement inquiries and proposals, all of
which appear exceedingly fair and reasonable in retrospect (just like all my repair estimates
for the various habitability issues).

So, please do let me know I can get my property out of the house at 121 River Rock St. If
you feel any damage was done to the property during the 16 hours I was accorded access to
it on December 22nd and 23rd, 2011, you certainly have not indicated so in writing.
Further, you have received nary a claim of injury/slip and fall/whatever from me or anyone
who assissted in the move, and I am indicating in writing here that I am unaware of any
such claims, other than, of course, my claims that you impeded my ability to remove my
property. All of those assisting with the move have much better things to do with their time
130 of 136 1/5/2012 3:53 PM
than fight with you or to attempt to shake you or your client down for anything, they are
simply above that, obviously.

So, please, let me know, give me a call, or email me (I am providing consent to receive
email notice from you for that limited purpose only, ie, for you to quickly communicate to
me that I may retrieve the remainder of my personalty from the property such that the same
can be done expeditiously and Dr. Merliss can all the more quickly move on towards a
fruitful station where he will be receiving rent for the property).

Additionally, the recent moving of property on 12/22 and 12/23, 2011, in combination with
yet another move to my present location approximately 5 or so days later has been, to say
the least, extremely challenging, especially considering that I have been running a law
practice to boot during that time, made all the more difficult by the fact that, unlike you, I
don't have a cast of thousands helping me make it all happen, ie, I don't have "the unknown
stuntman that makes Eastwood (you) look so fine" (though the legal research in the
pleadings your office have filed certainly leaves something to be desired). My point is, I
am continuing to express here in writing an indication that the list of stolen or damaged
property, the inventory, will likely need substantial revision. For instance, the HLP5685W
was recovered during the rushed, frenetic, chaotic move of 12/22/11 and 12/23/11, albeit in
component pieces, and with the caveat that testing to see whether or not it was damaged has
not been completed yet. Further, it appears that all jewelry and watches were ultimately
accounted for. There was the matter of the large (approximately 20 feet by 50 feet) black
mesh dropcloth/tarp that formed a very nice sunshade over the porch. That is missing. I
want my dimmers, they can cost around $30 a piece at Lowe's, etc. There are
approximately 15 of them at the property.

Further, I will again reiterate my general across the board indication that all the ridiculous,
reckless and baseless accusations you make in your various correspondences will not be
responded to and any failure to so respond on my part should not be taken as an admission
of any sort, far from it. If you want to continue to drag your client into the land of liability
for defamation, who am I to stop you.

I am not sure what exactly makes you think you know what "every Judge in town will rule"
with respect to some Summary Judgment motion you anticipate filing, however, please note
that the Rules of Professional Conduct forbid your implying an ability inappropriately
influence a tribunal.

Alas, there will be no waiver of the security/damage deposit. I won't be signing over my
firstborn to you either, Richard, nor will I be entering any stipulations wherein I agree to be
held accountable for all of yours or anyone else on earth's crimes against humanity or
waiving any claims I may have to any wrongs ever done to me by anyone at any point in
my lifetime, nor will I be agreeing to have each and every issue that I ever litigate anywhere
ever heard have jurisdiction be retained with a Judge of your choosing in a forum to your
131 of 136 1/5/2012 3:53 PM
update inventory of missing/damaged items
liking, etc., etc. or any of the other things on your "wish list" that you wasted everyone's
time with during the 6 hour hearing on 12/20/11, you triple exclamation point/triple
question mark using grown man, you.

Sincerely,

Zach Coughlin, Esq.

Zach Coughlin, Esq.
1422 E. 9th St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
132 of 136 1/5/2012 3:53 PM
Sent: Sat 12/31/11 12:42 AM
To: psferrazza@washoecounty.us; cdbaker@richardhillaw.com; kstancil@washoecounty.us;
rjcweb@washoecounty.us
1 attachment
pictures of toilet sludge Merliss rev2011-001708.pdf (18.1 MB)
Dear Judge Sferrazza and Mr. Hill and Mr. Baker,
I have an additional update to the inventory of property stolen, thanks, in
part, to all the pictures Mr. Hill had taken. The 62 inch HDTV 62HM15A
shows a combo/dubbing vcr dvd on the shelf below it:
http://www.walmart.com/ip/Sylvania-Dvd-Recorder-Vcr-Combo/11088889
That is missing/stolen.
Further, the very, very large mirror and wooden frame in that picture is mine
and I wish to have access to the property to retrieve it without Mr. Hill's
obstructive tactics, as is the case with my collection of imported and exotic
natural stone and porcelain tile as is the case with all of the white metal closet
shelf, for which there is approximately $400 worth of at the property that
belong to me, including those in the attic:
http://www.homedepot.com/Storage-Organization-Closet-Storage-Complete-Storage-Systems-Wire-Shelves-
Accessories/h_d1/N-bcf0Z5yc1v/R-202104723/h_d2/ProductDisplay?langId=-1&storeId=10051&
catalogId=10053
And attached is a collection pictures of the "toilet urine sludge" that was
involved in this matter, and which only recently was found. The HLP5685W
DLP HDTV has been located, though whether it has been damaged is unclear
at this point. Please Note, I have a new address for all future mailings, etc.
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
133 of 136 1/5/2012 3:53 PM
FW: key for back door
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may
contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it
to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking
of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable
law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message
in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work
product, or other applicable privilege.
Sent: Sat 12/31/11 1:07 AM
1 attachment
121 River Rock photos.rar (8.6 MB)
Mr. Baker,
The archive attachment is what was attached to the original 5/14/10 email.
Zach Coughlin, Esq.
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
Nevada Bar No: 9473
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may
contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it
to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking
of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable
134 of 136 1/5/2012 3:53 PM
law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message
in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work
product, or other applicable privilege.
To: magunda@aol.com
Subject: RE: key for back door
Date: Fri, 14 May 2010 14:32:49 -0700
Hello Matt,
We tried the key for the house in the back door again, and even used some graphite dust, but it still appears to
not be the right key for the door. We could take care of this in exchange for a $20 discount off one months
rent.
I am attaching some pictures of what has become, rather suddenly, quite a weed problem. I did not know whose
responsibility such a thing is normally, landlord or tenants. I reviewed the lease and don't feel it is conclusive
either way. As far as precedent there appears to be support either way. How about this, we could handle the
weed problem for a $40 discount off one month's rent?
Lastly, when we moved in, there was a number of insulation batts that had fallen from the ceiling in the
basement, and rested on the dirt ground. Some fell completely, some only partially. The portions touching the
ground became very infested with mold, The ground did not have a vapor barrier, such as 6 mil plastic sheeting.
About 8 of the 6 1/4"by 15"by 93" batts became mold infested and we don't feel comfortable having them
remain in the basement. There also appears to be a mold issue on the ceiling/underside of the floorboard in the
part of the house that seems to be near the wall separating the front bedroom from the bathroom. Strangely, I
would guess it is more under the bedroom than the bathroom. Please see the attached photos in these regards.
http://www.nextag.com/r19-insulation/products-html each of those batts are about $40. 8 x $40= $320. We
could replace and install new r19 insulation if you like in exchange for $380 off one month's rent. Additionally,
we could spray some anti-mold products on the effected ceiling parts for $50.
Of course, we are only offering ways to address these matters.
Sincerely,
Zach Coughlin
PS. the photos are attached and compressed into a .rar file. Winrar or 7Zip can be download for free from
download.com to open the archive and view these high resolution photos.
To: zachcoughlin@hotmail.com
135 of 136 1/5/2012 3:53 PM
Subject: Re: key for back door
Date: Fri, 26 Mar 2010 22:09:17 -0400
From: magunda@aol.com
zach, i thought the front door key fit the back door too. if it does not i will ask darlene to rekey the door. please get
back to me. thanks.
-----Original Message-----
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: magunda@aol.com
Sent: Fri, Mar 26, 2010 1:27 pm
Subject: RE: key for back door
Hi Matt,
Can we get a key for the back door?
From: stars@softcom.net
CC: melissa.l.ulloa@gmail.com
Subject: key for back door
Date: Mon, 22 Mar 2010 08:32:18 -0700
Melissa and Zach,

I do not have any extra keys. I would ask Matt he may know where they are. I am glad you are settling in and
enjoying your new diggs. Enjoy!

Best wishes,
Darlene Sharpe
Hotmail: Trusted email with Microsofts powerful SPAM protection. Sign up now.=
The New Busy is not the too busy. Combine all your e-mail accounts with Hotmail. Get busy.
136 of 136 1/5/2012 3:53 PM
121 River Rock
From: Casey Baker (cdbaker@richardhillaw.com)
Sent: Wed 12/14/11 1:51 PM
Cc: 'Richard Hill' (rhill@richardhillaw.com)
Mr. Coughlin:
The River Rock property has been broken into. We believe the break-in occurred sometime on Monday,
December 12, 2011. There appear to be items missing, including the TV in the living room, perhaps a computer
monitor, and perhaps some stereo equipment. I cant tell what else. The contents of the residence appear to
have been rifled through.
I am providing you with this information as a courtesy. This email does NOT constitute permission for you to go
to the River Rock property.
Casey D. Baker, Esq.
Richard G. Hill, Chartered
652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858
Email: cdbaker@richardhillaw.com
CONFIDENTIAL:ATTORNEYWORKPRODUCT;ATTORNEY-CLIENTPRIVILEGE
Thise-mailmaycontainlegallyprivilegedorconIidentialinIormation.IIyouarenottheintendedrecipient,pleasedonotread,copy,use,ordisclosethis
communicationtoanyoneotherthantheintendedrecipient.IIyouhavereceivedthismessageinerror,pleasenotiIythesenderanddeletetheemailmessageIrom
yoursystem.Thankyou.
Circular230Notice.
ToensurecompliancewithrequirementsimposedbytheIRS,weinIormyouthatanyU.S.Iederaltaxadvicecontainedinthiscommunication(includingany
attachments)isnotintendedorwrittentobeused,andcannotbeused,IorthepurposeoI(i)avoidingpenaltiesundertheInternalRevenueCodeor(ii)promoting,
marketingorrecommendingtoanotherpartyanytransactionormatteraddressedherein.
HotmailPrintMessage http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpidsc6...
1oI6 1/5/20128:39PM
RE: your full rental value estimate
Sent: Mon 12/19/11 12:04 PM
To: zachcoughlin@hotmail.com; 'Richard Hill' (rhill@richardhillaw.com)
Mr. Coughlin:
Are you merely posing hypothetical questions, or are you prepared to deal with reality and pay what you owe?
We told you that Dr. Merliss is still willing to work with you, even though he is no longer under any obligation to
do so. See my letter to you dated December 2, 2011.
What are you willing to do?
Casey Baker
From:ZachCoughlin[mailto:zachcoughlin@hotmail.com|
Sent:Nonday,December19,20116:16AN
To:cdbaker@richardhillaw.com;RichardHill
Subject:yourfullrentalvalueestimate
Iswaytoohigh.ItsnotbasedonanyLeaseAgreement....Idon'tagreeyougettorewrite
NRStoavoidmovingthings,andthelowercostoIastorageshed...buteveniIyoudowin
onthatpoint,seetheattachedevidencesuggestingtherentalvalueIorBOTHpropertieson
252MillSt.(itsoneplotthatcontainsbothhouse,Dr.MerlissboughtthemIor$545Ktotal
in2006,nowtheyareworth$155KTOGETHER.ThezillowestimateIorrentis$652a
monthIorbothpropertiesallTOGETHER.YouaregoigntogointocourtallegingaIair
marketvalueoI$900,andIstronglyconsidermovingIorsanctionsIormisconduct
committedinthepresenceoIthecourtunderNRS7.085.
IIIcanpayyourdemanded"storageIees"today,canIaccessmyproperty?
2oI6 1/5/20128:39PM
IIIcanpaybothyourdemanded"storageIees"andthe"securing"expensesoI$1060,canI
accessmyproperty?
IIIcanpayall"storageIees"or"securingexpenses",butcannotaIIordtomakeashowing
inaccordancewithyourotherdemands,areyoureIusingtoallowmetoaccessandretrieve
myproperty?
IIIcanpayallyourdemands,andmakeallshowings,butreIusetostartmovingmy
propertybutremovingeverythignontheoutsideoIthehouseIirst,areyoureIusingtoallow
metoaccessandretrievemyproperty?
Pleasenote,despiteyourwrittenpromisestoandwrittenstatementsinpleadingsonIile
withthecourtthatyouwereallowingmeto,youhavecontinuedtoIailtoprovideme
accesstotheclientIilesconnectedtomylawpractice.
WhatsayyouoItheoIIsetIortheover$3,000oIpropertyburglaredduetoyournegligent
"storing"?
Sincerely,
ZachCoughlin,Esq.
817N.virginiaSt.#2
Reno,Nv89S01
tel:77S229-6737
fax:9+96677+02
NevadaBarNo:9+73
``Notice``ThismessageandaccompanyingdocumentsarecoveredbytheelectronicCommunicationsPrivacyAct,18
U.S.C.2510-2521,andmaycontainconIidentialinIormationintendedIorthespeciIiedindividual(s)only.IIyouarenot
theintendedrecipientoranagentresponsibleIordeliveringittotheintendedrecipient,youareherebynotiIiedthatyou
havereceivedthisdocumentinerrorandthatanyreview,dissemination,copying,orthetakingoIanyactionbasedonthe
contentsoIthisinIormationisstrictlyprohibited.This message is confidential, intended only for the named
3oI6 1/5/20128:39PM
FW: An adult conversation
privilege.
Sent: Thu 12/29/11 8:03 AM
Cc: rhill@richardhillaw.com
Mr. Coughlin:
In the event you did not receive the email below because you added Mr. Hill
back on your blocked senders list, I am resending it to you.
As an attorney, I am sure you recognize that this is yet another opportunity
for you to mitigate what you claim to be your damages. I suggest you take
it.
May we please hear from you?
Casey Baker
-----Original Message-----
From: Richard Hill [mailto:rhill@richardhillaw.com]
Sent: Wednesday, December 28, 2011 9:03 AM
To: 'zachcoughlin@hotmail.com'
to steal?
4oI6 1/5/20128:39PM
First, it would help your abysmal lack of credibility Second, it would
possibly trigger the cops to go look for your stuff & maybe get it back.
5-your claims.
filed and served.
all.
We may counter.
We do not have a deal until the judge signs off Show us how good a job you
can do - you know what we will want.
any real progress.
Rgh
5oI6 1/5/20128:39PM
CONFIDENTIAL: ATTORNEY WORK PRODUCT; ATTORNEY-CLIENT PRIVILEGE This e-mail
may contain legally privileged or confidential information. If you are not
the intended recipient, please do not read, copy, use, or disclose this
communication to anyone other than the intended recipient. If you have
received this message in error, please notify the sender and delete the
email message from your system. Thank you.
-----
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2012.0.1901 / Virus Database: 2109/4708 - Release Date: 12/28/11
6oI6 1/5/20128:39PM
RE: interference with my right to get my property
From: Richard Hill (rhill@richardhillaw.com)
Sent: Sat 12/24/11 6:29 AM
your lying knows no bounds - does it?
you need to take stock of yourself.
just where do you think you will be in 5 years??

stay away from the property!
Sent: Saturday, December 24, 2011 1:45 AM
To: Richard Hill; cdbaker@richardhillaw.com; psferrazza@washoecounty.us
Subject: interference with my right to get my property
Sincerely,
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=a6...
1 of 9 1/5/2012 8:34 PM
An adult conversation
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
No virus found in this message.
Checked by AVG - www.avg.com
Version: 2012.0.1873 / Virus Database: 2109/4700 - Release Date: 12/24/11
Sent: Wed 12/28/11 9:00 AM
2 of 9 1/5/2012 8:34 PM
to steal?
get it back.
5-your claims.
filed and served.
all.
3 of 9 1/5/2012 8:34 PM
Offer withdrawn
We may counter.
any real progress.
Rgh
Sent: Fri 12/30/11 7:04 AM
Rgh
4 of 9 1/5/2012 8:34 PM
RE: Offer withdrawn
Sent: Fri 12/30/11 8:18 AM
mr coughlin - whatever "evidence" you may have had was under your control.
your case = your responsibility.
we are not obligated to rummage through the garbage you & your posse left at the property, just to try to satisfy some
wild goose chase you have invented.
we have a court order.
even if you get reversed, acting pursuant to the order is reasonable.
you should have gotten a stay - or taken our offer.
of course, that would have required real legal work in a real court

new address?? be sure to tell DMV

as for my future, which one of us do you think will have their law license longer???

rgh
From: zachcoughlin@hotmail.com [mailto:zachcoughlin@hotmail.com]
To: rhill@richardhillaw.com; cdbaker@richardhillaw.com
Subject: Re: Offer withdrawn
I had to move again over the last couple days 8 want my property, dispose of it at yours and your clients own
liability. I didnt get your email until late last night and i still dont consent to service of anything from you or your
firm electronically. You are on a litigation hold notice as to the moldy insulation in a clear water tight bag in the
front of the property and as to any video, photo, or other evidence you have collected. You allegation that i
burglared the property is pathetic and beneath you. Did you file a police report when the property was
burglarized on approx December 12th? You are making other people look bad.
Sent from my HTC
5 of 9 1/5/2012 8:34 PM
RE: ADR
Subject: Offer withdrawn
Date: Fri, Dec 30, 2011 7:07 am
Rgh
Sent: Fri 12/30/11 8:23 AM
this email further demonstartes your utter lack of competence as a lawyer
From: zachcoughlin@hotmail.com [mailto:zachcoughlin@hotmail.com]
To: rhill@richardhillaw.com; cdbaker@richardhillaw.com
Subject: ADR
Your contractor and you may face fraud charges for charging $1,060 to board up the porch with screws in
plywood facing the exterior, leaving the window unit ac in without a brace, leaving property on the yard abutting
6 of 9 1/5/2012 8:34 PM
the exterior fence, etc. I want the desk too. Rich, please don't do this to yourself, you have such a bright future
why muddy it up with your sanctionable conduct? You are better than that, I know it.
Date: Wed, Dec 28, 2011 9:03 am
to steal?
get it back.
5-your claims.
filed and served.
7 of 9 1/5/2012 8:34 PM
all.
We may counter.
any real progress.
Rgh
8 of 9 1/5/2012 8:34 PM
RE: TRO
Emergency motiom
Sent: Fri 12/30/11 9:09 AM
Cc: cdbaker@richardhillaw.com
is that what the voices are telling you???
To: Richard Hill; cdbaker@richardhillaw.com; knielsen@richardhillaw.com
Subject: TRO
Rich,
tribunal.
Sent: Thu 1/05/12 2:16 PM
1 attachment
CV11-03628-2628892.pdf (139.9 KB)
Zach - wanted to make sure you were served with this
Regards
Rgh
9 of 9 1/5/2012 8:34 PM

Filed: Electronically 01-05-2012:11:00:17 PM Joey Orduna Hastings Clerk of The Court Transaction # 2683734

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Zach Coughlin, Esq.

provides in Iull as Iollows: An injunction may be granted in the Iollowing

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