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on page 1 of 3: "Resident Iurther may use the premises Ior any commercial enterprise..."
also on page 1 oI 3: "11. OCCUPANCY: Occupancy oI the premises is limited to 2 adults 2 Children, and
shall be used Ior a residence and for other purposes."
emall Lo Plll on 8/17/11: " Well, repalrlng crumbllng sLeps ls noL super cheap. MaLL seems Lo have forgoLLen
abouL Lhese wrlLLen deals enLlrely. LeLs say lL cosL $600 Lo repalr sLeps, well, where does LhaL leave MaLL's
esLlmaLe of whaL l owe? 1he sLeps have been repalred. As has Lhe garbage dlsposal and oLher lLems. 1he
wlndow ls sLlll broken, MaLL never responded Lo requesLs for Lhe cosL of noxlous weed ordlnance flne
avoldlng landscaplng Lhe prevlous season (l wouldl, for now, Lake Lhe same $3S0 l agreed Lo Lhls season,
whlch ls surely less Lhan MaLL pald Lhe crew of 4 men Lo servlce Lhe nelghborlng house for 8 hours recenLly)
wlLh [agged edges of glass exposed, and an enLryway wlLh grlp sLrlps and wooden planks LhaL are ln dlsrepalr.
l have a law offlce Lo run and cannoL boLh pay renL and be Lhe pro bono handyman for Lhe absenLee landlord
whlle he ls off Lravelllng Lo AmsLerdam and 8 angkok. l made a very reasonable offer Lo MaLL Lo flx lL."
page 3 of Coughlln's 1enanL's Answer on SepLember 6Lh, 2011 ( ln Lhe false sLarL case rev2011-001492, LhaL
!udge Sferrazza laLer boosLrapped noLlce from, so...): "I have a |aw off|ce Lo run and cannoL boLh pay renL
and be Lhe pro bono handyman for Lhe absenLee landlord whlle he ls off Lravelllng Lo AmsLerdam and
8angkok. l made a very reasonable offer Lo MaLL Lo flx lL. l made an lncredlbly reasonable offer Lo MaLL Lo
have Lhe seasonal noxlous weed ordlnance flne avoldlng weedlng Laken care of for $3S0, whlch he
enLhuslasLlcally agreed Lo, Lhen a landscaplng crew prompLly came and rlpped up a faux grass lnsLallaLlon
LhaL had cosL me a greaL deal of Llme and money Lo puL ln place, Lhen refused Lo puL LhaL personal properLy
back on my renLal properLy aL all, leavlng lL on Lhe sldewalk and ln Lhe sLreeL."
page 4 of Lhe 9/6/11 1enan'Ls Answer: "Landlord has vlolaLed n8S 118A.290 ln hls fallure Lo repalr, well afLer
14 days of wrlLLen noLlce, lLems such as a broken fronL bedroom wlndow (compleLe wlLh [agged exposed
edges of glass), fallen lnsulaLlon LhaL has appeared Lo resulLed ln Lhe creaLlon of poLenLlally Loxls mold when
lL came ln conLacL wlLh Lhe ground below, whlch lacked a vapor shleld, a LolleL wlLh a defecLlve was rlng, the
front sta|rs to 1enant's home]off|ce came to a state of d|srepa|r, repleLe wlLh crumbllng rlsers LhaL
presenLed a safeLy hazard and llablllLy lssues. Landlord agreed Lo a slgnlflcanL renL deducLlon ln exchange for
arranglng Lo have Lhe work done and paylng for Lhe work lLself, yeL now Landlord seems Lo have forgoLLen
Lhese wrlLLen correspondences, eLc."
Also on page 4:
"S7 Am. Iur. roof of Iacts 3d 127, Commerc|a| 1enant's kemed|es Where Land|ord Ia||s to keep rem|ses
|n Cond|t|on I|t or Su|tab|e for Commerc|a| Use. 2S Causes of Act|on 2d 493, Cause of Act|on for 8reach of
Imp||ed Warranty of nab|tab|||ty"
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page 11: :now where LhaL becomes Lruly abhorenL ls when lL conLrlbuLes Lo hard worklng small buslness
people belng Lhrown out of off|ces and homes they have pa|d good money to rent to Ca||forn|an |and|ords
who are consLanLly ln AmsLerdamn or 8angkok and who consLanLly seem Lo forgeL" abouL LhaL LenanL's
requesL Lo make Lhls or LhaL hablLable, such LhaL a hablLual Lendency Lo lgnore LenanLs complalnLs arlses,
usually followed by a reLallaLory evlcLlon when Lhe LenanL Llres of belng a sLooge for Lhe landlord."
age 26 and 27 of LhaL 9/6/11 1enanL's Answer conLalns Lhe followlng:
"To magundaaol.com From: Zach Coughlin (zachcoughlinhotmail.com) Sent: Fri 8/12/11 1:24 AM To:
magundaaol.com Dear Matt, I was mistaken in my correspondence below. It was the June 2011 rent, not May 2011, Ior
which you approved, in writing, my deducting $350 Ior my "taking care oI the weeds". I have the written approval and I
would imagine your "sent Iolder" should have it as well. With respect to May, any shortIall is going to be Melissa's
responsibility. Please provide a copy oI the alleged $600 rent check you received Irom Melissa on or about 5/6/11. I
realize you may not Ieel that way, and, technically, you may have some valid arguments, however, I certainly gave
Melissa my entire share oI the rent Ior May. II it proves true that she only sent you a partial rent payment, then I will need
to review the relevant precedent and consider my options. I was not aware the power was in your name, however, I will
protect my legal right to have the power put in my name in my residence. I cannot stress enough that no one, NO ONE, is
to enter 121 River Rock St., Reno NV 89501 without my express written prior approval, and even then, only in my
presence shall anyone ever be permitted to enter the dwelling while I am it's tenant. I appreciate your consideration and
eIIorts to educate me with respect to the laws oI landlord tenant. I have developed some physical reactions to the mold
issues that I alerted you oI earlier and request that you respond to my written requests and inquiries in that regard.
Sincerely,
Zach Coughlin, Esq.
Attorney at Law
121 River Rock St.
Reno, NV 89509
775-338-8118
Licensed in the State oI Nevada From: zachcoughlinhotmail.com " (emphasis added).
October 5th, 2011 email Irom Coughlin to Baker:
"lrom: ZC [mallLo:zachcoughlln[hoLmall.com] SenL: Wednesday, CcLober 0S, 2011 12:S4 AM 1o: Casey
8aker, 8lchard C. Plll Casey 8aker Sub[ecL: 8L: lnLerrupLlon of essenLlal servlces
1he power was Lurned off aL abouL 10am Loday ouL of Lhe blue wlLh no warnlng whaLsoever. nvLnergy says lL
was ln Merllss's name. ?our represenLaLlon ln Lhe face of whaL seems qulLe clearly bad falLh by your cllenL,
and perhaps you, may be sancLlonable. Sudden and compleLe dlsrupLlon of a servlce as essenLlal as energy,
durlng Lhe S days accorded by law, whlle slmulLaneously conducLlng a bad falLh, lnspecLlon, whlch you
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elecLed Lo abandon [usL before underLaklng, wasLlng my Llme, ls surely golng Lo reflecL poorly on your flrm.
lurLher your cllenLs acLlons ln malnLalnlng Lhe power blll ln hls name arguably alLers whaLever you mlghL
Lhlnk Lhe lease says. All Lhls bad falLh mallclous and reprehenslble conducL has damaged my law pracLlce and
cosL me moneLarlly. And your asslsLanL shows up ln an 80k mercedes compressor wlLh a vldeo camera Lrylng
Lo go Lhrough a prlvaLe home and law offlce wlLhouL meeLlng Lhe requlremenLs "
Plus the commercial tenancy aspect/law oIIice (and possibly mattress business) was discussed in phone calls
with Baker prior to the 10/13/11 summary eviction proceeding and again prior to the 10/25/11 "Trial".
Coughlin's 10/15/12 email to cdbakerrichardhillaw.com contains the Iollowing:
"Choosing Whether to File A Summary or 'Formal Eviction Action
In most cases, the landlord can choose whether to Iile a summary or Iormal eviction action. However, there are
circumstances under which summary eviction cannot be used. For instance, summary eviction is not available Ior:
2) Eviction oI commercial tenants Ior other than nonpayment oI rent
(See NRS 40.254)
Using location Ior a "commercial" law practice, you Iiled a no cause, ie, "Ior other than Outlook Print
Message
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nonpayment oI rent, not based in law or Iact, Rule 11, plus this escrow thing gets put asunder. NRS
40.254 UnlawIul detainer: Supplemental remedy oI summary eviction and exclusion oI tenant Irom
certain types oI property. Lease allows Ior use Ior commercial purposes. Void, void, void! NJCRCP
59, 60... "
In a 9/14/11 email to cdbakerrichardhillaw.com, Coughlin inIorms Baker and Hill oI the commercial tenancy again in
writing: "The overhead light in the Iront oIIice is dangling. Please make that habitable to."
Also, the Iollowing correspondence:
"RE: Interruption oI essential services
From: ZC (zachcoughlinhotmail.com)
Sent: Wed 10/05/11 12:54 AM
To: Casey Baker (cdbakerrichardhillaw.com); Richard G. Hill Casey Baker (rhillrichardhillaw.com)
The power was turned oII at about 10am today out oI the blue with no warning whatsoever. NVEnergy says it was in
Merliss's name. Your representation in the Iace oI what seems quite clearly bad Iaith by your client, and perhaps you, may
be sanctionable. Sudden and complete disruption oI a service as essential as energy, during the 5 days accorded by law,
while simultaneously conducting a bad Iaith, inspection, which you elected to abandon just beIore undertaking, wasting
my time, is surely going to reIlect poorly on your Iirm. Further your clients actions in maintaining the power bill in his
name arguably alters whatever you might think the lease says. All this bad Iaith malicious and reprehensible conduct has
damaged my law practice and cost me monetarily. And your assistant shows up in an 80K mercedes compressor with a
video camera trying to go through a private home and law office without meeting the requirements Ior service and
notice, much less purpose and good Iaith oI an inspection under NRS. I am making a documentary."
Page 2 oI Coughlin's AIIidavit in Support oI Motion Ior Summary Judgement (and the RJC mixed up the order oI that
Motion Ior Summary Judgment and the AIIidavit Attached thereto, so the Motion should be Iile stamped, but instead, the
aIIidavit is...) Iile stamped October 25th, 2011 (at 10:10 am with Baker personally served a copy by Coughlin prior to the
"Trial" oI that date, at page 2: "4. Internet connection costs, car battery problems, gas, opportunity costs, lost business,
and other costs where incurred by the undersigned as a direct result oI the unnoticed electricity shut oIt: an essential
service and were occasioned by the emergency situation created by Merliss's and NY Energy's un-noticed shut oII oI an
essential service, electricity, to Coughlin's home law office."
Page 3, oI the 10/25/11 Motion Ior Summary Judgement/Trial Statement by Coughlin: "...does not entitle a
Chico, CaliIornia neurologist to retaliate against a liIelong Reno resident who has
served as a Legal Aid Organization attorney merely because that tenant does not
appreciate having his home law oIIice subject to the various problems which NRS
118a.510 prevents Dr. Merliss Irom relatiating against the undersigned Ior seeking
redress Ior." "...Additional protected complaints include crumbling stairs to the Iront entrance oI the home law
office..."
Page 5 oI the 10/25/11 Motion/Trial Statement by Coughlin: "The Green Action crew admitted to Coughlin (and Coughlin
was prevented Irom submitting video and audio recordings into the record by Judge SIerrazza, despite the salient
importance to Coughlin's counterclaims any statements they made would have as to whether Dr. Merliss is responsible Ior
or ratiIied the property damage to Coughlin careIul wool green law carpet installation, which was laid, cut, and notched
around the house and exterior Ience in a very exacting manner, only to be converted by the Green Action crew and leIt in
the street and sidewalk near the house, creating a theft hazard and exigent situation in which the undersigned's law
practice suffered economic damages and Coughlin was required to. take immediate action to mitigate the damages.
II the Reno Justice Court wants to implement something similar to Justice Court Rule 44 oI Las Vegas, it must Iirst have
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the rule approved by the Supreme Court oI Nevada. Sec, Nevada JCRCP RULE 83. "RULES BY JUSTICE COURTS:
Each justice or justice court in a township with more than one justice, by action oI a"
Also, on page 7, on 10/25/11 Coughlin wrote: "Oh, and, the same day, Baker and a videographer showed up to the home
law office to do a videotaped 'inspection and to 'Iix habitability issues, only to make some lame attempts to Iind a
breach rather than just conduct the inspection they had billed hours on to arrange."
On page 9 oI the 10/25/11 Motion Ior Summary Judgement/Motion Ior Sanctions/Trial Statement in RJC rev2011-001708
Iiled by Coughlin it reads: "(Mr. Baker can't be troubled to makc reasonably diligent inquiry, like reading the 20 pages oI
emails Coughlin provided him chronicling the written noti.:es oI habitability issucs, the agreed to rent deducdtions by his
client, and the rent portions Baker's client has already recovered Irom Coughlin's Iormer co-tenant and the arrangemnets
and agreements Dr. Merliss made in writing with that Iormer co-tenant, Melissa Ulloa, whereby Dr. Merliss and Ms.
Ulloa made arrangments Ior her to repay Dr. Merliss the portions oI rent Ior which Ms. Ulloa took the undersigneds usual
share oI the rcnt and Iailed to Iorward it on to Dr. Merliss (as was the co-tenants establ ished practice Ior the 18 months in
which they cohabitated at the residence/office the rented from Dr. Merliss). This is also a Motion to Strike Baker's
outrageous allegations of "lying"."
Page 19: "he Iull $1,000 should be awarded, in part Ior the $500 worth oI perishable and groceries spoliating, but Iurther
Ior the business and opportunity costs to Coughlin occasioned by the emergency situation created by Merliss's and NV
Energy's un-noticed shut off of an essential service, electricity, to Coughlin's home law office. NRS 118A.390 allows
tenant's to sue the landlord Ior $1,000 in statutory damages, plus actual damages. Merliss should be ordered to pay the
Iull $1,000 in statutory damages, plus actual damages oI another $2,200 dollars ($400 in perishables and groceries lost,
plus 5.5 billable hours attorney time at $200/hr, plus a $700 red adult male Gary Fisher Mountain Bike was stolen Irom
Coughlin's back yard upon NV Energy's un-noticed entrance into the backyard, which is gated, and exiting leaving the
gate wide open. The Lease Agrement is clear in holding Dr. Merliss responsible Ior such damages to Coughlin's
property."
Page 21: "Nev. JCRCP RULE 109. 'SETTING OF TRIAL IN ACTIONS PURSUANT TO NRS 40.290...(a) In no case
shall a trial on the merits be set less than 20 calendar days aIter service oI summons and complaint. Coughlin cited this
rule in open court on October 17th, yet counsel Baker inIormed the Court that it did not apply to eviction actions. It
certainly does apply. Now, the 'trial set Ior October 25th, is arguably no longer a summary eviction proceeding under
NRS 40.253, as such, the requirements oI a plenary unlawIul detainer action must be Iollowed. Further, Nevada's JCRCP
Rule 109 applies, and the 'trial date oI October 25th does not comply with the dictates oI Nev. JCRCP 109. As such,
Coughlin states his objection to this trial Ior the record. Indeed, there has been no 'service oI summons and complaint in
this matter, yet, Coughlin is being subject to all sorts oI plenary requirements without, seemingly, being aIIorded any oI
the plenary protections oI Iull unlawIul detainer actions."
Page 5 oI Coughlin's November 8th, 2011 Motion Ior Sanctions in RJC Rev2011-001708 also clearly rebuts Hill's
contention that Coughlin Iailed to allege his was a commercial tenancy, impermissilbly subject to a No Cause Summary
Eviction where non-payment oI rent was neither pled nor noticed: "shut off to Coughlin's home/law office, and usually
within some ultra short summary process time period Ior which Coughlin would need to be preparing Ior some summary
hearing, even though the dictates oI NRS 40.254 clearly require a plenary hearing, and where Merliss's whole case is void
in light oI the Iailure to Iile the USPS CertiIicate oI Mailing in relation to prooI oI service and notice oI the documents Ior
which such is required."
Also, page 8 therein reiterates Coughlin's previous assertion: "I have a law oIIice to run and cannot both pay rent and be
the pro bono handyman Ior the absentee landlord..."
On page 10 oI that 11/8/11 Motion Ior Sanctions, Coughlin wrote: "Coughlin noted to Baker that sueh clients oIt-times
get attorney's in trouble. particularly with regard to Rule 11 violalions, especially when a litigation involves something
of such primary importance to a litigant as his home/office. Coughlin queried Baker as to what, exactly. Baker had
done to veriIy that the debts Merliss was alleging were "based in law or Iact"". Baker was curiously evasive and or non
responsive in the various questions Coughlin posed in this respect when he was not displaying a complete an utter lack
oIknowledge with regard to the disputes between landlord and tenant. including ""hether his client had agreed to any rt:nt
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deductions, had been made aware oI any property damage caust:d by the landlord's agents or employees, had Iailed to
cure any habitability issues his client had been inIormed oI in writing Ior a period over 14 days since past, etc."
Page 16: "22. All the materials and arguments contained in Coughlin's original Tenant's Answer and Motion Ior Sanctions
and Motion Ior ClariIication are hereby incorporated by reIerence. Coughlin obtained the directed estimates for the
repair of the crumbling stairs/steps/risers at the home/office's entryway steps. Following Merliss's instructing yielded
a cost oI $ 1.250 Ior the repair oI the stairs. A $350 rent deduction lor one seasons oI noxious weed ordinance was agreed
to in writing by Merliss. another was agreed to implicitly tor a total yard work rent deduction 0|$750, This is all detailed
in painstakingly clear emails to and Irom the landlord and tenant attached to the original Tenant's Answer. Similarly, the
disposal repair came to $ I25. Coughlin's law practice. and liIe in general, ha . been adversely impacted a great deal by
Mcrliss's misdeeds as a landlord."
Page 17: "Further Baker asserts to the court that Coughlin has somehow impeded Baker and his brownshirted
videographer Irom entering Coughlin's home law office, opposing party domicile, with a videographer and who knows
what else, and Ior some purpose Ior which Baker cares not to clariIy or delimit in any way, and yct stilL Coughlin in no
way prevented Baker Irom so conducting any "inspection"."
SELECTIONS FROM THE TRANSCRIPT OF THE 10/13/11 SUMMARY EVICTION PROCEEDING AND
THE 10/25/11 UNLAWFUL DETAINER "TRIAL":
!udge: l wlll allow you Lo LesLlfy as Lo whaL happened and why you belleve Lhe summary
evlcLlon should noL be appllcable ln Lhls case. lf you esLabllsh a case Lo my saLlsfacLlon Lhen l
wlll seL lL over Lo Lrlal, rlghL? 8uL aL Lhls polnL you haven'L done LhaL.
uefendanL: ?es slr ?our Ponor.
!udge: ?ou've come ln Lo argue a moLlon Lo dlsmlss based on fallure Lo comply wlLh noLlce
and oLher lssues whlch l denled aL Lhls polnL. So you can slL down and lf you
wanL Lo LesL Lhe flre as Lo why Lhls should noL be a summary evlcLlon l wlll
permlL you Lo do so.
uefendanL: Lven were Lhls Lo go forward as a summary evlcLlon ?our Ponor l would [usL llke
Lo sLaLe for Lhe record l am movlng for a conLlnuance based upon Lhe unduly
pre[udlclal naLure of Lhe shuLLlng off Lhe elecLrlclLy ln Lhe mlddle of Lhe flve
days LhaL you were here.
!udge: Well you were here qulLe some Llme ago and knew all abouL Lhls, so LhaL's denled.
?ou flrsL came ln here Lo courL and back ln Lhls courL dlsmlssed Lhe prlor case
ln case number 1492 Lrylng Lo flnd Lhe daLe aL whlch.
uefendanL: l belleve lL was Lhe 26Lh ?our Ponor of SepLember Lhe hearlng approxlmaLely.
(page 10 oI unoIIicial "Transcript" and at 8:52 am on the certiIied audio transcript Irom 10/13/11 in rev2011-001708).
Judge: I will allow you to testiIy as to what happened and why you believe the summary eviction should not be applicable
in this case. II you establish a case to my satisIaction then I will set it over to trial, right? But at this point you haven`t
done that.
DeIendant: Yes sir Your Honor.
Judge: You`ve come in to argue a motion to dismiss based on Iailure to comply with notice and other issues which I
denied at this point. So you can sit down and iI you want to test the Iire as to why this should not be a summary eviction I
will permit you to do so.
DeIendant: Even were this to go Iorward as a summary eviction Your Honor I would just like to state Ior the record I am
moving Ior a continuance based upon the unduly prejudicial nature oI the shutting oII the electricity in the middle oI the
Iive days that you were here.
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Judge: Well you were here quite some time ago and knew all about this, so that`s denied. You Iirst came in here to court
and back in this court dismissed the prior case in case number 1492 trying to Iind the date at which.
DeIendant: I believe it was the 26th Your Honor oI September the hearing approximately.,,,
"Judge: Wait a second sir, no you may not what am asking you Ior is to establish a prima Iacie case oI retaliatory eviction
through your testimony and then iI I determine and establish the prima Iacie case then we`ll set it over Ior trial.
DeIendant: Yes sir Your Honor...."
...
"Judge: Yeah and |inaudible 0:48:58| that they are his agents I Iind they are in independent contractor and so iI you
deposit the rent by Monday at 9:00 o`clock with the court in the amount oI 2275 I will continue this for trial on the
merits to determine whether or not there really is a habitability issue. II the rent is not deposited then there will be no
continuance the eviction will be granted Iorthwith on Monday morning at 9:00 o`clock. And Iurthermore the court is now
making any Iinding other than that you have made an argument about habitability and that you are entitled to trial on
that issue iI you deposit the rent. Alright but you are not entitled to trial iI you don`t deposit the rent. And I have given
you credit based on your allegation which is, which I do not Iind was substantiated today; I simply Iind that you made that
allegation, that this is what you were owed. And so iI you deposit the rent then we will set this Ior trial and it will be the
Iollowing week aIter that on the same court day. The same day oI the week.
DeIendant: Tuesdays and Thursday. So on the Tuesday it will be at 10:00 AM.
Judge: What day is that?" (page 27 oI transcript Irom 10/13/11 in rev2011-001708).
From the audio and unoIIicial written transcript oI the "Trial" on 10/25/11:
"Judge: And we have a trial. Okay, the next is Matthew Merliss versus Casey -- oh, I'm sorry, versus Zachary Coughlin.
Casey Baker represents the plaintiII in this matter and this was the time set Ior determination on the no cause eviction and
-- are the parties ready to proceed?"
...(at the 10:02 mark oI the Iirst audio Iile Irom 10/25/11 the Iollowing ensues):
"Judge: Well, I accept that you did and that's why we're having the trial today. (page 32 Irom 10/25/11)
uefendanL: And LhaL's -- I'm g|ad you br|ng that up. ou sa|d tr|a|, our nonor. ?ou dldn'L
say summary evlcLlon, you dldn'L say summary execuLlon. ?ou sald Lrlal, plenary--
!udge: 1rlal on a reLallaLory naLure of Lhe evlcLlon. l assumed you made a prlma facle case on
LhaL as Lhere's no Lrlal on Lhe lssue. lL ls summary as Lo wheLher or noL you were glven
noLlce served, whlch Lhe courL flnds you were, wlLh a noLlce Lo LermlnaLe your lease.
uefendanL: lf l can [usL qulckly lnLer[ecL for Lhe record, ?our Ponor--
!udge: unless you had -- unless you have a lease Lo show LhaL you're noL Lhere aL wlll aL Lhls
polnL.
uefendanL: 1here -- for Lhe record, Lhere was no cerLlflcaLe ln my name, uS osLal Servlce
cerLlflcaLe malllng on flle wlLh respecL Lo a noLlce. ln Lhe conLexL of summary evlcLlon
proceedlngs, courLs are dlrecLed Lo adhere very sLrlcLly Lo Lhe noLes requlremenLs glven Lhe
summary naLure of lL. 1haL's one safeguard LhaL ls lnslsLed upon.
A rlghL Lo a [ury Lrlal ls granLed by Lhe unlLed SLaLes Supreme CourL from -- ln summary -- ln
evlcLlon cases. !ury Lrlal ls an absoluLe rlghL for all clLlzens ln Lhe unlLed SLaLes. l sald lL's a
1970s case. l Lhlnk lL mlghL be called earson. l belleve l clLe Lo lL ln my case. l don'L know
LhaL a cerLlflcaLe of malllng ls requlred whereas Mr. 8aker dld. Pe had apparenLly a process
server, posL someLhlng on Lhe door and conLesL Lo LhaL. l Lhlnk LhaL mlghL be a
[lnulSCL8nl8LL 12:40] Supreme CourL Lo clarlfy Lhe sLaLuLe aL some polnL.
l know l spenL Loo much Llme on LhaL, ?our Ponor, but when you say tr|a|, |t's -- we||, the
most |mportant th|ng, our nonor, to get across from my po|nt of v|ew, |s that 40.2S3(6)
says that when the court, as you [ust |nd|cated you d|d |mp|y that there |s a mater|a| |ssue
of fact, |t's a pause--
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!udge: No, I d|dn't |mp|y that there was. I found that you made a pr|ma fac|e case--" (page
33)
!udge: WlLh respecL Lo hablLablllLy and so l seL lL for a Lrlal Loday on LhaL lssue. 8uL Lhe
separaLe lssue ls wheLher you have any defense, whlch you haven'L glven me, Lo Lhe no
cause evlcLlon, whlch--
uefendanL: And l do and l can speak Lo LhaL brlefly, ?our Ponor, [usL--
!udge: 1hey're Lwo separaLe Lhlngs. Well, you're noL under oaLh, slr, so you're argulng now
and l dldn'L -- l leL you have some laLlLude, buL Lhe quesLlon ls do you
have any facLs Lo presenL Lo Lhe courL Loday?
uefendanL: ?es, ?our Ponor, buL [usL one lasL lnLroducLory maLLer--
!udge: Ckay.
uefendanL: ls LhaL 40.2S3(6) says once Lhe courL has found Lhere's a prlma facle showlng,
Lhe courL musL pause and converL Lhls Lo a full-scale unlawful deLalner
acLlon wlLh a complalnL and Lhe 20-days noLlce lncldenL Lo 8ule 109 of
Lhe summary evlcLlon proceedlngs, so -- and we don'L have LhaL
here. ..."
Any laLer aLLempLs by 8aker Lo confuse Lhe lssue do noL change Lhe facL LhaL Lhe
above was sald and ordered, and Lhereby, ln addlLlon Lo Coughlln's flllng a noLlce of appeal
on CcLober 18Lh, 2011, anoLher basls for dlvesLlng Lhe 8!C of [urlsdlcLlon Lo enLer any Crder
LhereafLer (lncludlng Lhose on 10/2S/11 and 10/27/11, exlsLs).
Contrary to the assertion in Repondent's Answering BrieI in CV11-03628 at page 5 (ie, that "Coughlin
aIIirmatively waived any argument that NRS Chapter 118A does not apply by basing his entire deIense
(retaliation/habitability) on what he alleged were violations oI that chapter...." (Coughlin Note: one, there is
more to the deIense, and two, Coughlin didn't say 118A didn't apply, just that NRS 40.253 is not permissible
against commercial tenant's where the non-payment oI rent is not pled, particularly Ior the events under which
this matter rose at the times oI relevant import and consdering what law then applies). Respondent continued:
"Additionally, since Coughlin never timely raised the argument below, it cannot Iorm the basis Ior any relieI
on appeal..." But, the Iact is, Coughlin did raise that argument, in his October 17th, 2011 Iiling (see page 97-99
oI ROA, Vol. 1), and at the hearing, and in other Iilings. It is Respondent who nows must Iact the Iact that his
Iailure to raise his arguments in opposition to that position put Iorth by Appellant bar him Irom now so doing.
(See Respondent's Opposition, Iailing to so counter Coughlin's argument, at page 108, ROA, Vol.1). But
"|p|arties `may not raise a new theory Ior the Iirst time on appeal, which is inconsistent with or diIIerent Irom
the one raised below.'" Dermody v. City oI Reno, 113 Nev. 207, 210, 931 P.2d 1354, 1357 (1997) (quoting
Powers v. Powers, 105 Nev. 514, 516, 779 P.2d 91, 92 (1989)). This rule is not meant to be harsh, overly
Iormalistic, or to punish careless litigators. Rather, the requirement that
parties may raise on appeal only issues which have been presented to the district court maintains the eIIiciency,
Iairness, and integrity oI the judicial system Ior all parties. Boyers v. Texaco ReIining and Marketing, Inc., 848
F.2d 809, 812 (7th Cir.1988). This is the case becaue Coughlin plead and established that he was a commercial
tenant even beyond the October 17th, 2011 Iiling....(p. 240, 248 oI ROA, Vol. 1, Tenant's Answer identiIies
rental as "PlaintiII's home law oIIice", etc...:"especially in light oI the recent bad Iaith attempts to inspect with
recording equipment plaintiII's home law oIIice hours aIter having the power shut oII at plaintiII's home law
oIIice where landlord had, apparently, a delinquent utility bill assigned to the property tenant rents, and where
no notice was provided to tenant oI the impending interruption oI essential services, causing attorney tenant
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Coughlin's law practice damages." Additionally, at page 11 oI the Answering BrieI, Respondent admits that
the REntal Agreement permitted Coughlin's commercial use oI the property, regardless oI Respondent's
attempts to make arguments in the record based upon what Respondent's think some witness who never
testiIied might have said had she done so.... also...
Coughlin clearly preserved his objection to the lower court exceeding the jurisdiction accord it under NRS
40.253(6) at ROA, Vol. 1, p 95-96, clearly invoked NRS 118A.290 (page 98 oI ROA, Vol.1), Respodent
clearly only served a 5 day unlawIul detainer notice oI the No Cause Eviction variety and thereIore Iailed to
allege non-payment oI rent against this commercial tennant (p. 269 ROA Vol.1) and Coughlin clearly pled that
he was a commercial tenant (p. 160-164, 196, 240, ROA Vol. 1, and page 9-11, ROA Vol. 2, and as set Iorth
previously above). It is patently dishonest an violative oI the Rules oI ProIessional conduct regarding candor to
a tribunal and Iairness to opposing counsel Ior Respondent's counsel to suggest they are blind sided by the
argument that this summary evicdtion involved a commercial tenant. However, Respondnent's counsel does
just that in its Answering BrieI in CV11-03628 (p. 6 oI that Answering BrieI): "3. Granting a no-cause
summary eviction against a "commercial" tenant Coughlin now argues that he was a "commercial" tenant, and
thereIore not subject to summary eviction. He Iirst raised this argument in his "opposition to motion Ior order
to show cause," which he Iiled on December 5, 2011, six weeks aIter the eviction was granted 31. ROA, Vol.
IV, pp. 253-261. (That is not true Coughlin raised the issue in the Justice Court case, both in the hearing and in
his Iiling oI October 17th, 2011, plead as a commercial tenant, and cited to the law Iorbidding the use oI
summary eviciton procedures against commercial tenants where the non-payment oI rent is not noticed or
alleged...Iurther NRCP 60(b)(4) will allow Ior challenging the Eviction Order as void Ior lack oI subject matter
jurisdiction (NRS 40.400 makes NRCP applicable). Merliss addressed it in his reply Iiled the Iollowing day.32
First, Coughlin has the law wrong. Summary evictions are available against a tenant oI any property that is
subject to NRS Chapter 118A, which Merliss' property unquestionably was.33 (well, actually, not against
commercial tenant's where the non-payment oI rent is not pled or noticed, as here).
And, actually, and this is awesome, really, Coughlin did in Iact raise the whole issue oI NRS
40.253 Iorbidding the use oI a summary eviction procedure against a commercial tenant where the non-
payment oI rent is not alleged in his Emergency Motion Iiled October 17th, 2011, page 99, ROA, Vol. 1: "In
most cases, the landlord can choose whether to lile a summary or I011l1al eviction action. However, there are
circumstances under which summary eviction cannot be used. For instance. summary eviction is not available
Ior: 2) Eviction oI commercial tenants Ior other than nonpayment oI rent (See NRS 40.254) Using location Ior
a "commercial" law practice, you Iiled a no cause, ie, "Ior other than nonpayment oI rent. not based in law or
Iact, Rule 11, plus this escrow thing gets put asunder." Plus, at page 108-115 oI the ROA Vol. 1, Respondent
Iailed to ever address Coughlin's argument that the court lacked jurisdiction to proceed under a summary
eviction statute (see pages 16 and 17 of the filing in the Nevada Supreme Court Richard G. Hill, Esq. was
served in 60331 on August 27th, 2012, then ask how much candor to the tribunal Hill displayed in his
testimony of 11/14/12 at Coughlin's Disciplinary Hearing, largely stemming from Hill's own 1/14/12
grievance against Coughlin in ng12-0204) against a commercial tenant where the non-payment oI rent was
not notice or pled....So, under Polk, Respondent's Iailure to Iile any opposition to that argument is taken as an
admission. At some point, Court's sua sponte chipping in arguments on behalI oI this tag team oI Respondent's
attorney's and their phalanx oI legal assistants who make enough to push Mercedes SL600 sport couples
equipped with V12 engines, when considering all that is in opposition to lil' ol crazy Zach Coughlin's legal
dribble....well, it all just seems kind oI unIair, doesn't it. Also, page 259 oI Vol. 4. oI the ROA makes clear that
Coughlin preserved his arguments related to the voidness oI any summary eviction order where the "service"
thereoI was as deeply Ilawed as the attempted service in this matter oI such an Order.
Further, Hill's sworn testimony at the Formal Disciplinary Hearing oI 11/14/12 in NG12-0204 was just
as dishonest, lacking candor to the tribunal and Iairness to opposing counsel as was his sworn testimony at the
criminal trespass trial upon which a conviction against Coughlin was rendered on 6/18/12. At that Trial,
Coughlin asked Hill, under oath: "Q Did you have any discussion as to whether or not the lease allowed Ior the
tenant to be practicing law at that location? (Page -39- oI oIIicial certiIied transcript on Iile in the appeal oI that
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11 CR 26405 conviction in CR12-1262) A (by Richard G. Hill, Esq.) The residential lease did not prohibit it.
We did come to understand that you didn't have a business license, so we didn't Ieel that you were lawIully
conducting a business in premises.
Having reviewed virtually everything that you have Iiled in that case, Mr. Coughlin, it's my
understanding"..."That you did not raise-"... "you did not assert that argument in the 1ustice Court. You have
appealed the case to the District Court, and the appeal has been decided adversely to you. That case is over,
you're bound. It's done."
The complete portion oI the transcript is Iound below:
"BY MR. COUGHLIN:
Q Did you ever have any conversation with your client about whether this was a
commercial tenant that he was seeking to evict? A I don't recall that conversation.
Page -37-
Q Are you aware oI whether or not there is an express prohibition against using
(inaudible) eviction proceedings against commercial tenants where the non-payment oI
rent is not alleged or noticed?
MR. HAZLETT-STEVENS: Judge, I'm going to object as that calls Ior a legal conclusion
Ior this witness. THE COURT: Well, I don't know how it's relevant is what I'm -I
understand what you're saying, Mr. Hazlett-Stevens. How is the issue oI whether someone
is a commercial client, or a commercial tenant rather, relevant to this case, Mr. Coughlin?
MR. COUGHLIN: Well, Your Honor, I think it's possible that even iIthe City were able
to establish that the eviction order was appropriately served, which I do not believe they
will be able to do, that nonetheless, that Order will be void and that Judge SIerrazza did
not have a jurisdictional basis Ior rendering it and that there is an express prohibition
against using (inaudible) eviction proceedings to evict commercial tenants.
Where, as here, in the non-payment oI rent, was not alleged. Despite what Mr. Hill might
be saying here, when it came time to put it on paper and Iace Rule 11, and put it to the
Court, Mr. Hill and Mr. Baker didn't want to do that. They just said no THE
COURT: Okay, you are losing me when you begin to ramble on, Mr. Coughlin.
SpeciIically, my question was how is the question as to whether or not you are a
commercial tenant relevant? And the more you wax on, the more I get -I'm not an expert
in landlord and tenant, and I begin to get detached Irom the issue here.
Page -38-
MR. COUGHLIN: I understand, Your Honor. That's what's so interesting about this case,
Your Honor.
THE COURT:
MR. COUGHLIN:
THE COURT:
relevant. MR. COUGHLIN: I just want you to tell me how it's relevant.
I am, Your Honor.
Mr. Coughlin, I just want you to tell me how it's
I will. This is a civil eviction that meets criminal
trespass nexus here. It's relevant in that iI the civil eviction order lacks a basis, a
jurisdictional basis, Ior it to be ordered, it is what, under 60(b), void. ThereIore, to the
extent the City is trying to say a warning did exist in that a notice was posted or it was
personally served. II it's void, that's a legal impossibility.
THE COURT: Okay, I'm going to allow you to ask a couple oI questions about your
status as a commercial tenant or a residential tenant (inaudible) Irom Mr. Hill, and Mr.
Hill, do your best to answer those questions.
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I'm trying to give Mr. Coughlin a great deal oI leeway here on cross-examination, in the
spirit oI getting all the evidence Ior the Court.
So, go ahead, Mr. Coughlin. BY MR. COUGHLIN:
Q You said you spoke with your client in August and were aware that the tenant was an
attorney?
A Yes.
Q Did you have any discussion as to whether or not the lease allowed for the tenant
to be practicing law at that location?
Page -39-
A The residential lease did not prohibit it. We did come to understand that you didn't
have a business license, so we didn't Ieel that you were lawIully conducting a business in
premises.
Having reviewed virtually everything that you have Iiled in that case, Mr. Coughlin, it's
my understanding-.
COUGHLIN: I'm going to ask you not to go on here.
THE WITNESS: That you did not raise-.
COUGHLIN: Just answer my question, sir.
MR. HAZLETT-STEVENS: I would like him to answer -I would like him to -Judge. I
would like the attorney not to interrupt the answer to the question. THE COURT: Mr.
Coughlin, you ask these questions oI a witness where they are opened ended questions.
They are not l'vIR.
COUGHLIN: It's not a blank check.
THE COURT: Listen, listen. When you are asking open ended questions, and you are not
utilizing leading questions on cross-examination, the witness is entitled to answer those
questions, and you're going to be stuck with the answer, and I think you understand that.
So, Mr. Hill, go ahead and brieIly Iinish up what you were saying. THE WITNESS:
Thank you, sir.
Mr. Coughlin, you raised -you did not assert that argument in the Justice Court. You have
appealed the case to the District Court, and the appeal has been decided adversely to you.
That case is over, you're bound. It's done.
Page -40-
THE COURT: Okay, thank you, Mr. Hill. Mr. Coughlin, next question.
MR. COUGHLIN: Yes, sir, Your Honor. I appreciate the point oI expertise on asking
leading questions on cross. That was something I was not intending to do. BY MR.
COUGHLIN:
Q Mr. Hill, you just testiIied that in August, your client and you had a discussion as to
whether or not the lease allowed Ior a commercial use, is that correct?
A Mr. Coughlin, I recall examining the document almost immediately. Whether I had a
discussion or not with my client or not, I don't recall.
Q I thought you just testiIied that you did, and you two just talked about how I didn't have
a business license. Was that not true?
A No, sir. No, sir. What I said was that he inIormed me that you were an attorney. At a
subsequent time, we contacted the City and ascertained that you did not have a business
license.
Q Okay, when you entered the property in November MR.
HAZLETT-STEVENS: Judge, that question exceeds the scope oI my direct examination.
There is no evidence that he entered any property in November. That was just not part oI
my direct at this point.
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THE COURT: Alright, Mr. Coughlin, Mr. Hill, in some substance, has testiIied that he
was contacted by a client to commence eviction proceedings where you were a resident
based on an issue that primarily concerned lack oI rent, and he began to Iurther up on that
Page - 41-"
Also, later in that Trial:
"Q Did you have any discussion as to whether or not the lease allowed for the tenant
to be practicing law at that location?
Page -39-
A The residential lease did not prohibit it. "
"SIerrazza ultimately determined did not exist, and you did not prove. Q So your
oIIice converted it to a no cause summary eviction notice?
A More precisely, sir, the decision was made to Iorego the rent eviction and simply do
a 30-day no cause.
Q Okay, and if subsequently the tenant was considered a commercial tenant,
would that not be tantamount to sort of a wrong side legal surgery?
Page -43-
A Well, I don't quite understand your metaphor, sir. But the Iact oI the matter is it was
a residence. The Iact that you were illegally conducting a business there, a side issue,
number one.
Number two, you didn't raise it in the 1ustice Court.
Q You say it was a residence. Is it zoned Ior just residential use?
A I don't have any idea, sir.
Q Well, why did you say it was a residence iI you don't have something to base that
upon?
A That's what the lease said, and there was no lawIul business being conducted.
Q The lease said -did the lease say a commercial use was acceptable?
A I don't know, Mr. Coughlin.
Q Well, how can you testiIy to what the lease said iI you don't recall?
A I'm giving you my best recollection, Mr. Coughlin. Q Okay, now whether or not the
lease -you said the Iirst thing you did was you read that lease.
A That's not what I said.
Q Well, did you say something substantially similar to that earlier when you were
testiIying? A I said I almost certainly looked at the document almost immediately.
Page -44-
Q Okay, so you -aIter your oIIice has billed 60 grand, you aren't sure whether or not
the lease said something about it being commercial use acceptable?
MR. HAZLETT-STEVENS: Judge, he's asked and answered that question already.
There's no evidence as to the 60 grand (inaudible).
THE COURT: Yeah, that's assuming a Iact not in evidence. I'm going to sustain the
objection. BY MR. COUGHLIN:
Q Did your oIIice bill approximately $60,000 to (inaudible)?
MR. HAZLETT-STEVENS: Objection, relevance.
THE COURT: Sustained. It's irrelevant, Mr. Coughlin. I've
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addressed that issue. Mr. Hill's Iinancial arrangement with his client is irrelevant to
this trespassing case. I'm really not legally interested in the amount oI money he billed
nor received. I think it's irrelevant. MR. COUGHLIN: I'm not oIIering to prove the
truth oI the matter asserted in what he billed. I'm oIIering it THE
COURT: I'm telling you it's irrelevant. That's a hearsay issue whether it's been oIIered
to prove the truth, and quite Irankly, I'm making a judicial determination that his
relationship with his client related to Iinances is irrelevant to this trespassing case.
So, I'm going to not allow any questions related to that line oI inquiry. So, let's move
on to our next question. MR. COUGHLIN: Yes, sir.
Page -45-
BY MR. COUGHLIN:
Q Was the issue oI whether or not the lease allowed Ior a
commercial use a very important issue in that summary eviction proceeding
Irom which this criminal trespass (inaudible)? A Are you asking was that an important
consideration in
my being able to undertake the assignment? The answer is no.
As to what exactly you did or said -(inaudible -both talking).
Q No, I'm asking you if it was important as to whether or
not it was permissible to pursue a summary eviction proceeding if it's a
commercial tenant where you are only alleging non-payment of rent.
THE COURT: II you can answer that, Mr. Hill, go ahead.
THE WITNESS: I didn't hear it, and I'm not sure that I can
understand it. But iI you'd like to try again, I'll--
THE COURT: Go ahead and rephrase the question, Mr. Coughlin. Speak loudly and
clearly and Mr. Hill will do his best to answer
that question.
BY MR. COUGHLIN:
Q Was it an important consideration to your office in the course of representing
Dr. Merliss whether or not the lease agreement allowed for use of the premises
for a commercial use?
A No.
Q You are testifying that your office's representation of Dr. Merliss did not
include a careful consideration of whether or not the lease allowed for a
commercial use of the premises?
Page -46-
MR. HAZLETT-STEVENS: Asked and answered, Judge. He said no.
THE WITNESS: That wasn't the question. The question was whether
THE COURT: I got three things going on here, and we're making an oral record so
let's try to keep it civil to the extent we're able to. Mr. Hazlett-Stevens has raised an
objection to the question. Mr. Coughlin, do you want to respond to that?
MR. COUGHLIN: Yes, sir. Mr. Hazlett-Stevens said it was asked and answered, I
believe?
MR. HAZLETT-STEVENS: Yes, there was an objection asked and answered aIter he
said no to the previous question, asked slightly diIIerently.
THE COURT: What's your response to Mr. Hazlett-Stevens?
MR. COUGHLIN: It was seeking clariIication because I was surprised to hear no to
such an important issue.
MR. HAZLETT-STEVENS: Surprise doesn't overcome.
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THE COURT: Okay, as a matter oI clariIication, so the record is clariIied, ask the
question again, and Mr. Hill, let's see iI we can answer that question to the best oI
your ability. Go ahead, Mr. Coughlin.
BY MR. COUGHLIN:
Q Mr. Hill, did you just testiIY that you did not Ieel it was an important consideration
in representing your client to determine whether or not the lease in question would
permit commercial use?
A No, it's not important. We were hired to evict you, and
Page -47-
that was the assignment.
Q Okay, so if the law has an express dictate prohibiting the use of summary
eviction proceedings against commercial tenants where the non-payment of rent
is not alleged or served as an eviction notice, would that present a situation
where it would be an important consideration?
A Mr. Coughlin, I'm having a real tough time Iollowing
your question.
Q Okay.
THE COURT: Go ahead and rephrase the question, Mr. Coughlin.
THE WITNESS: You've made it in small pieces.
THE COURT: Hang on, Mr. Hill. Rephrase the question. Let me tell you, I'm giving
you a great deal oIleeway on cross-examination in Iairness to you, and we're getting
into issues that really, really exceed the scope oI the direct examination. And I'm
willing to give you a great deal oI leeway, but at some point, the leeway limitation
comes to an end. So, go ahead and ask one more question related to this. Try to make
it speciIic, and then Mr. Hill will do his best to answer that question.
MR. COUGHLIN: Yes, sir, Your Honor. Just quickly, I'm a little green on this, but he
opened the door quite a bit, too.
THE COURT: Go ahead and ask a question, Mr. Coughlin.
BY MR. COUGHLIN: Q You just testiIied that you did not Ieel it was an important
consideration whether or not the lease allowed Ior commercial
Page -48
use, correct?
A Yeah, it was not that important.
Q Okay, would it become important if your entire case, or the order which you
prepared for your client was void because there is no jurisdictional basis for
entering such an order?
A If your presumptions were correct, which they're not, then it would become
important. But since you're wrong, it was not important.
Besides that, you didn't raise it. Q Was the fact that the property was being used
for a commercial purpose set forth in the tenant's affidavit?
A I don't know.
Q You don't know?
A I do not recall.
Q You just testified that it wasn't raised, so how could you do that with a straight
face, and then answer you don't recall now?
THE COURT: Mr. Coughlin, he's answered the question that he doesn't recall.
Your comments become argumentative so let's We're getting into an area where
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I'm not going to litigate in this Court the merits of the landlord/tenant
relationship, nor the -ultimately the basis for the eviction.
Mr. Hill has testified to a limited degree what he's done, and if you have anything
relevant to what he said, go ahead and ask it. If not, I think it would be a good
time to terminate your cross-examination unless you have any other relevant
questions."
Page -49 oI the oIIicial transcript Irom the CR12-1262 appeal Ior the 6/18/12 criminal
trespass trial in 11 CR 26405.
also, consider Casey Baker's malIeasance and the Iact that Coughlin hereby swears
under penalty oI perjury, pursuant to NRS 53.045, that the locksmith who conducted
the lockout on 11/1/11, Sean Cheathum, told Coughlin that the lockout occurred no
earlier than 4:48pm and, in Iact, it was a real rush and point oI issue with Baker and
the WCSO to get it done prior to the clock striking 5 pm on 11/1/11. Further,
Coughlin subpoened the Reno Justice Court in accord with the SBN/NNDB/Panel's
indicationg as to the particular SCR 105(4) and NRCP 45 application attendant and
attachign to Coughlin's Disciplinary Hearing, however the RJC Iailed to respond and
Iraud by Pat King prevented Coughlin Irom as Iully asserting his right to a
continuance or to make a show cause motion releative thereto at the 11/14/12 hearing.
WCSO Civil Division Roxy Silve told Coughlin the WCSO will eIIect lockouts even
where they know over "24 hours" has passed since their oIIice received the lockout
orders" as the WCSO oIIice Ieels entitled to do it how they like to and thinks they can
walk over tenant's in violation oI the law, purposeIully and willIully. Silva has
slammed the phone down several times when speaking with Coughlin and oIIered
evasive and vague answer respecting when her oIIice FIRST received either oI the
eviction orders in rev2011-001708, and Iurther silva, and Stuchell have indicated that
the Iaxed eviction orders they received Irom the RJC (and the RJC's Karen Stancil has
indicated it is the customary practice and policy oI the RJC to Iax such eviction orders
over the day they are signed or the next day at the latest) are taken Irom the wcso Iax
machine, and bare a Iax header indicating the time oI receipt oI the order, at which
point an employee manually enters a time into a soItware program that reIeclts not
when the Iaxed order was received, but rather the time at which the employee
undertakes manually typing into the soItward program a representation oI when they
pulled the order oII the Iax machine. silva and stuchell then indicate that no copy or
record oI that Iax with the Iax header indicating the time oI transmission or receipt is
kept, but rather that exact printout is Iiled with the AIIidavit oI Service aIter the
lockout is conduct by the wcso, which the RJC totally disputed to Coughlin and has
not been Coughlin's experience either)... Coughlin similarly supoened the WCSO and
it is unclear whether Coughlin coudl hire them to serve the subpoenas on themselves o
whether they and or Mary Kandaras waived service thereoI or are conIlicted out oI
seeking to quash such subpoenas. See the attach Reno Carson Messenger receipt
showing delivery oI the Lockout Order to the WCSO at 4:45 pm on 10/31/11 (and
note WCSO's Deputy Machen lists both the 10/25/11 Order and the 10/27/11 Orders
as both being "personally served" (his supervisor Stuchell later admitted that only
means "posted on the door when no one is home)...
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NRS 40.253 requires lockout orders incident to evictions contain an "order directing
the sheriff or constable of the county to remove the tenant within 24 hours after
receipt of the order"
NRS 40.253:
"3. A notice served pursuant to subsection 1 or 2 must:
(a) IdentiIy the court that has jurisdiction over the matter; and
(b) Advise the tenant:
(1) OI the tenant`s right to contest the matter by Iiling, within the time speciIied in subsection 1
Ior the payment oI the rent or surrender oI the premises, an aIIidavit with the court that has
jurisdiction over the matter stating that the tenant has tendered payment or is not in deIault in the
payment oI the rent;
(2) That iI the court determines that the tenant is guilty oI an unlawIul detainer, the court may
issue a summary order Ior removal oI the tenant or an order providing Ior the nonadmittance oI
the tenant, directing the sheriII or constable oI the county to remove the tenant within 24 hours
after receipt of the order
5. Upon noncompliance with the notice:
(a) The landlord or the landlord`s agent may apply by aIIidavit oI complaint Ior eviction to the
justice court oI the township in which the dwelling, apartment, mobile home or commercial
premises are located or to the district court oI the county in which the dwelling, apartment, mobile
home or commercial premises are located, whichever has jurisdiction over the matter. The
court may thereupon issue an order directing the sheriff or constable of the county to
remove the tenant within 24 hours after receipt of the order. The aIIidavit must state or
contain:
(1) The date the tenancy commenced.
(2) The amount oI periodic rent reserved.
(3) The amounts oI any cleaning, security or rent deposits paid in advance, in excess oI the Iirst
month`s rent, by the tenant.
(4) The date the rental payments became delinquent.
(5) The length oI time the tenant has remained in possession without paying rent.
(6) The amount oI rent claimed due and delinquent.
(7) A statement that the written notice was served on the tenant in accordance with NRS 40.280.
(8) A copy oI the written notice served on the tenant.
(9) A copy oI the signed written rental agreement, iI any.
(b) Except when the tenant has timely Iiled the aIIidavit described in subsection 3 and a Iile-
stamped copy oI it has been received by the landlord or the landlord`s agent, and except when the
landlord is prohibited pursuant to NRS 118A.480, the landlord or the landlord`s agent may, in a
peaceable manner, provide Ior the nonadmittance oI the tenant to the premises by locking or
otherwise.
6. Upon the Iiling by the tenant oI the aIIidavit permitted in subsection 3, regardless oI the
inIormation contained in the aIIidavit, and the Iiling by the landlord oI the aIIidavit permitted by
subsection 5, the justice court or the district court shall hold a hearing, aIter service oI notice oI the
hearing upon the parties, to determine the truthIulness and suIIiciency oI any aIIidavit or notice
provided Ior in this section. II the court determines that there is no legal deIense as to the alleged
unlawIul detainer and the tenant is guilty oI an unlawIul detainer, the court may issue a summary
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order Ior removal oI the tenant or an order providing Ior the nonadmittance oI the tenant. II the
court determines that there is a legal deIense as to the alleged unlawIul detainer, the court shall
reIuse to grant either party any relieI, and, except as otherwise provided in this subsection, shall
require that any Iurther proceedings be conducted pursuant to NRS 40.290 to 40.420, inclusive.
The issuance oI a summary order Ior removal oI the tenant does not preclude an action by the
tenant Ior any damages or other relieI to which the tenant may be entitled. II the alleged unlawIul
detainer was based upon subsection 5 oI NRS 40.2514, the reIusal by the court to grant relieI does
not preclude the landlord thereaIter Irom pursuing an action Ior unlawIul detainer in accordance
with NRS 40.251.
7. The tenant may, upon payment oI the appropriate Iees relating to the Iiling and service oI a
motion, Iile a motion with the court, on a Iorm provided by the clerk oI the court, to dispute the
amount oI the costs, iI any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230 Ior
the inventory, moving and storage oI personal property leIt on the premises. The motion must be
Iiled within 20 days aIter the summary order Ior removal oI the tenant or the abandonment oI the
premises by the tenant, or within 20 days aIter:
(a) The tenant has vacated or been removed Irom the premises; and
(b) A copy oI those charges has been requested by or provided to the tenant,
whichever is later.
8. Upon the Iiling oI a motion pursuant to subsection 7, the court shall schedule a hearing on the
motion. The hearing must be held within 10 days after the filing of the motion. The court
shall affix the date of the hearing to the motion and order a copy served upon the landlord
by the sheriff, constable or other process server. At the hearing, the court may:
(a) Determine the costs, iI any, claimed by the landlord pursuant to NRS 118A.460 or 118C.230
and any accumulating daily costs; and
(b) Order the release oI the tenant`s property upon the payment oI the charges determined to be
due or iI no charges are determined to be due...."
Richard Hill purported to be able to keep the RJC Irom giving Coughlin a hearing Ior six weeks,
until December 20th, 2011, thereby implying an improper ability to inIluence a tribunal, in his
November 21st, 2011 email to Coughlin
Baker's sworn testimony on 6/18/12:
that correct? A That's correct. Q AIter which Mr. Coughlin was no longer allowed to be
there, is that correct? A That's correct. Q So, the Findings oI Facts, Conclusions oI Law and
Order oI Eviction Iound in your Iavor, Mr. Merliss's Iavor, rather, and the date oI eviction was as
oI October 31" at 5:00 p.m., correct? A That's correct. That's what we announced in Court and put
on that Findings oI Fact. Q And that Order said that anyone there aIter that date could be
removed, is that correct? A That was the command given to the SheriII. Q "Shall be removed." A
Yes.
Page -66Q
Did you serve that document on Mr. Coughlin in any Iashion? A Notice oI Entry oI Order or
anything like that? Or was that served by the Court on him?
A The way it works is the Court -aIter the Court enters the Order, the Court Iorwards it to the
SheriII. Q Okay.
A And the SheriII goes out and enIorces the order.
Q Okay, now I'm going to draw your attention to the date oI November 13th, 201 1.
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THE COURT: What was that date again?
MR. HAZLETT-STEVENS: November 13, 2011, Your Honor.
THE COURT: Okay, give me just a second, counsel.
MR. HAZLETT-STEVENS: Certainly, Judge.
THE COURT: I'm making some notes here regarding some dates.
MR. HAZLETT-STEVENS: And I'm going to withdraw that question, Your Honor, so iI you
don't want to jot that note down, you don't have to at this point.
THE COURT: Okay, I'm looking at something else, okay. Go ahead. Thank you, counsel. BY
MR. HAZLETT-STEVENS:
Q I'm going to draw your attention to the date oI November 1 st, 2011. Do you recall what you
were doing that day?
A Yes, I was actually oII oI work that day. I was at home.
Page -67-
Q Okay. A But I was basically on stand-by because I knew that the eviction was going to happen.
Q Okay, and did you actually eventually respond or have to come to the area oI 121 River Rock?
A Yes.
Q Why?
A The way it works, again, I'm sorry to keep doing this.
Q Please, please, please, you are educating us all.
A You have to wait Ior the SheriII to contact you.
Q Okay.
A The SheriIIs Deputies are sent out with several oI these things on the days that they do them,
however, they do them every day. You can try to shoot Ior a speciIic time, but you are at the
mercy oI the SheriIIs Deputy's schedule. Some lockouts take longer than others. They try to give
you lead time.
I had spoken with the SheriIIs Deputy already, I believe, on Friday the 28th Q Okay. A I
believe. It was either that, or I contacted him on his cell phone. But I came back in
(inaudible) do the lockouts.
THE COURT: I'm sorry?
THE WITNESS: I came back in so we could do the lockout, to meet the SheriIIs Deputies at the
property aIter the SheriII calls. Q Okay, and so you actually did go to 121 River Rock?
Page -68-
A Yes.
Q And were there SheriIIs Deputies there?
A I got there Iirst.
Q Okay.
A Along with a member oI our staII.
Q Okay.
A And then two SheriII's Deputies arrived.
Q Okay.
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A And then we had to wait for the locksmith.
Q Okay, when the Sheriff's Deputies arrived, did they have any documents in their hand? A
I believe they had -yes, they had their copies of the Findings of Fact, and Order for
Summary Eviction. Q Okay, and do you recall what the deputies, or one or both of those
deputies did with the Findings of Facts and Order of Eviction?
A Yes.
Q Please tell.
A Once -the short answer is they take you to the door.
Q Okay.
A I can tell you the process, iI you want.
Q Please, tell us what happened.
A When the locksmith finally arrived, the Sheriffs bang on the door, announce their
presence, "Open up, police, sheriff."
There was no response. At that point, everybody stands back. They get the locksmith to go ahead
and open the door. He opens the door.
Page -69-
The SheriIIs go in. They clear the property, make sure nobody is there. Then they came back out
and they tape it to the door.
Q Okay, and you said the locksmith was there, too?
A Correct.
Q What did the locksmith do?
A The locksmith, his Iirst task was to open the Iront door.
Q Okay.
A AIter he did that, and aIter the SheriII clears the property, then he changes the locks, re-keys the
locks.
Q Okay.
A On the Iront door and the back door.
Q Okay, and what did the -were there new keys associated with re-keying the locks?
A Yes.
Q What did the locksmith do with the new keys?
A Gave them to me.
Q Okay.
A It was either me, or Sherry Hill, who was also with me Irom my oIIice. I think he gave to me. Q
I'm sorry? A I think he gave them to me. Q Okay, and so thus, the old keys that were Iormerly
associated with that lock would no longer work, is that correct?
A That's my understanding.
Page -70-"
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Conclusion:
Please consider those issues set forth herein and drop Hill's grievance and file this as a
formal grievance against Hill and Casey Baker, Esq. and SCR 104(3) against Bar Counsel for
their failure to investgiate Hill and Baker's malfeasance.
Dated this November 26th, 2012:
__________________________
Zachary Barker Coughlin
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CERTIFICATE OF SERVICE:
Pursuant to NRCP 5(b), and SCR 105(4) and the previous admission and indications by the
SBN/NNDB/Panel, I do hereby certiIIy that, on this date, I, Zach Coughlin I deposited in the United
States mail at Reno, Nevada, in a sealed envelope, postage prepaid, a true and correct copy oI the
Ioregoing MOTION FOR NEW TRIAL; MOTION FOR MISTRIAL; MOTION TO STRIKE;
MOTION FOR ARREST OF JUDGMENT and or electronically served (via electronic method oI
transmission previously given express permission to utilize by those with requisite authority to
provide it, upon which Couglin reasonably relied and or relies)
Dated November 26th, 2012.

Zach Coughlin
Repondent
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index to exhibits:
1. exhibit 1: various relevant materials including Declaration oI Zach Coughlin.
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six hundred and thirty seven (637) pages
http://sdrv.ms/ZJ1L2n
six hundred and thirty seven (637) pages
http://sdrv.ms/ZJ1L2n
EXHIBIT 1
EXHIBIT 1


































































































































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CASE NUMBER: ng12-0204 ng-0435 ng-0434
STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY BOARD
STATE BAR OF NEVADA,
PETITIONER
V.
ZACH COUGHLIN,
NV BAR 9473
RESPONDENT
.
)
)
)
)
)
)
ng12-0204 ng-0435 ng-0434
DECLARATION OF ZACHARY BARKER COUGHLIN
ZACHARY BARKER COUGHLIN, being Iirst duly sworn, deposes and under penalty
perjury avers:
1. I am a resident oI the City oI Reno, County oI Washoe, State oI Nevada,
and over 18 years oI age. This declaration is based on my personal knowledge, except those
matters stated on inIormation and belieI, and as to those items I believe them to be true.
This declaration is made in support oI deIendant's, and represents my testimony iI called on to
present same in court.
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DECLARATION OF ZACHARY BARKER COUGHLIN






































































































































































































































































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2. I am an attorney whose law license in the State oI Nevada is suspended but whose license
beIore the USPTO is intact.. I declare under penalty oI perjury that the Ioregoing is true and correct.
3. also, consider Casey Baker's malIeasance and the Iact that Coughlin hereby swears under
penalty oI perjury, pursuant to NRS 53.045, that the locksmith who conducted the lockout on
11/1/11, Sean Cheathum, told Coughlin that the lockout occurred no earlier than 4:48pm and, in Iact,
it was a real rush and point oI issue with Baker and the WCSO to get it done prior to the clock
striking 5 pm on 11/1/11. Further, Coughlin subpoened the Reno Justice Court in accord with the
SBN/NNDB/Panel's indicationg as to the particular SCR 105(4) and NRCP 45 application attendant
and attachign to Coughlin's Disciplinary Hearing, however the RJC Iailed to respond and Iraud by
Pat King prevented Coughlin Irom as Iully asserting his right to a continuance or to make a show
cause motion relative thereto at the 11/14/12 hearing. WCSO Civil Division Roxy Silva told
Coughlin the WCSO will eIIect lockouts even where they know over "24 hours" has passed since
their oIIice received the lockout orders" as the WCSO oIIice Ieels entitled to do it how they like to
and thinks they can walk over tenant's in violation oI the law, purposeIully and willIully. Silva has
slammed the phone down several times when speaking with Coughlin and oIIered evasive and vague
answer respecting when her oIIice FIRST received either oI the eviction orders in rev2011-001708,
and Iurther silva, and Stuchell have indicated that the Iaxed eviction orders they received Irom the
RJC (and the RJC's Karen Stancil has indicated it is the customary practice and policy oI the RJC to
Iax such eviction orders over the day they are signed or the next day at the latest) are taken Irom the
wcso Iax machine, and bare a Iax header indicating the time oI receipt oI the order, at which point an
employee manually enters a time into a soItware program that reIeclts not when the Iaxed order was
received, but rather the time at which the employee undertakes manually typing into the soItward
program a representation oI when they pulled the order oII the Iax machine. silva and stuchell then
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indicate that no copy or record oI that Iax with the Iax header indicating the time oI transmission or
receipt is kept, but rather that exact printout is Iiled with the AIIidavit oI Service aIter the lockout is
conduct by the wcso, which the RJC totally disputed to Coughlin and has not been Coughlin's
experience either)... Coughlin similarly supoened the WCSO and it is unclear whether Coughlin
coudl hire them to serve the subpoenas on themselves o whether they and or Mary Kandaras waived
service thereoI or are conIlicted out oI seeking to quash such subpoenas. See the attach Reno Carson
Messenger receipt showing delivery oI the Lockout Order to the WCSO at 4:45 pm on 10/31/11 (and
note WCSO's Deputy Machen lists both the 10/25/11 Order and the 10/27/11 Orders as both being
"personally served" (his supervisor Stuchell later admitted that only means "posted on the door when
no one is home)...Further, I was given permission by Clerk oI Court Peters, Bar Counsel, NNDB,
Panel to Iile electronically and also it was indicated to me by those possessing suIIicient authority to
so declare, and upon which I reasonably relied, that all my Iilings (including the attachments thereto)
were being copied by the SBN to all Panel Members, and Iurther, that I was granted the right to issue
subpoenas myselI, despite being a suspended attorney, and that all witness Iees or subpoena duces
tecum Iees were waived and that I would not be required to pay them. Also, It was declared to me by
the SBN, NNDB, BAR Counsel, Panel that the 8/23/12 certiIied mailing oI the Complaint and
anything included therein would never be put Iorth as a prooI oI service or return oI service oI the
Complaint, etc., even under SCR 109, especially where Clerk oI Court Peters admits to that certiIied
mailing being returned to the SBN without a signature card signed by Coughlin, on 9/10/12.
4. I declare under penalty oI perjury that the Ioregoing is true and correct..
AFFIRMATION Pursuant to NRS 239B.030
- 3/4 -
DECLARATION OF ZACHARY BARKER COUGHLIN














































































































































































































































































































































































































































































































































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The undersigned does hereby aIIirm that the preceding document does not contain the social security
number oI any person.
DECLARATION
The assertions herein are made, pursuant to NRS 53.045 under penalty oI perjury
and based upon my Iirst hand knowledge oI these matters.
DATED this 26th day oI October, 2012
/s/ signed electronically
Zach Coughlin
Respondent
- 4/4 -
DECLARATION OF ZACHARY BARKER COUGHLIN
CaseSummary
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CaseSummaryIorCase:CV11-03628
ZACHARYCOUGHLINVS.MATTHEWMERLISS(D7)
CaseNumber CV11-03628
CaseType
JUSTICECOURTCIVIL
APPEAL
Opened 12-21-2011
Status DISPOSED
PlaintiII ZACHARYCOUGHLIN
DeIendant MATTHEWMERLISS
Judge
PATRICKFLANAGAN-
DivisionD7
Show/HideParticipants
FileDate CaseHistory
09-17-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
09-15-2012
PlaintiII
Motion...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Motion...
09-06-2012
PlaintiII
$Notice/AppealSupremeCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
08-31-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
08-31-2012
PlaintiII
Replyto/inOpposition
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Replyto/inOpposition
- Exhibit1
08-29-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
08-29-2012
DeIendant
NoticeoIEntryoIOrd
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
08-28-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
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08-28-2012
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Order...
FiledbyorinbehalIoI:Court
Order...
08-22-2012
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FiledbyorinbehalIoI:Court
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Court
ProoIoIElectronicService
08-22-2012
DeIendant
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FiledbyorinbehalIoI:RICHARDHILL,ESQ.
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08-21-2012
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08-21-2012
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Order...
08-13-2012
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FiledbyorinbehalIoI:Court
ProoIoIElectronicService
08-10-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
08-10-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
08-10-2012
DeIendant
OppositiontoMtn...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
OppositiontoMtn...
- Exhibit1
08-02-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
08-02-2012
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SupremeCourtReceiptIorDoc
FiledbyorinbehalIoI:Court
SupremeCourtReceiptIorDoc
08-01-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
07-31-2012
PlaintiII
MtntoSetAsideDecree
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtntoSetAsideDecree
- Exhibit1
07-31-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
07-31-2012
OppositiontoMtn...
CaseSummary
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DeIendant
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
OppositiontoMtn...
07-31-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
07-31-2012
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CaseAppealStatement
FiledbyorinbehalIoI:Court
CaseAppealStatement
07-31-2012
Court
SupremeCtDeIiciencyNotice
FiledbyorinbehalIoI:Court
SupremeCtDeIiciencyNotice
07-31-2012
Court
CertiIicateoIClerk
FiledbyorinbehalIoI:Court
CertiIicateoIClerk
07-30-2012
PlaintiII
NoticeoIAppealSupremeCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
NoticeoIAppealSupremeCourt
07-24-2012
PlaintiII
Motion...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
Motion...
- Exhibit1
07-09-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
07-09-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
06-26-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
06-25-2012
DeIendant
OppositiontoMtn...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
OppositiontoMtn...
06-25-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
06-25-2012
DeIendant
NoticeoIEntryoIOrd
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
ProoIoIElectronicService
CaseSummary
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06-25-2012
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06-25-2012
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06-15-2012
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ProoIoIElectronicService
06-14-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
06-14-2012
DeIendant
Replyto/inOpposition
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
Replyto/inOpposition
- Exhibit1
- Exhibit2
06-11-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
06-11-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
06-09-2012
PlaintiII
Supplemental...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Supplemental...
06-08-2012
PlaintiII
MtnAlterorAmendJudgment
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnAlterorAmendJudgment
05-22-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
05-22-2012
DeIendant
NoticeoIEntryoIOrd
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
05-22-2012
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05-22-2012
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FiledbyorinbehalIoI:Court
Order...
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05-09-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
05-09-2012
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FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
04-19-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-19-2012
DeIendant
MtnIorAttorney'sFee
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
MtnIorAttorney'sFee
- Exhibit1
- Exhibit2
- Exhibit3
- Exhibit4
04-19-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-18-2012
DeIendant
OppositiontoMtn...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
OppositiontoMtn...
04-13-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-13-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-13-2012
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CertiIicateoIClerk
FiledbyorinbehalIoI:Court
CertiIicateoIClerk
04-13-2012
DeIendant
OppositiontoMtn...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
OppositiontoMtn...
04-13-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-13-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-13-2012
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CaseSummary
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Court
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-13-2012
PlaintiII
CaseAppealStatement
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
CaseAppealStatement
04-12-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
04-12-2012
DeIendant
Replyto/inOpposition
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
Replyto/inOpposition
- Exhibit1
04-09-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-09-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-07-2012
PlaintiII
MtnAlterorAmendJudgment
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnAlterorAmendJudgment
04-07-2012
PlaintiII
Oppositionto...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Oppositionto...
04-05-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-05-2012
PlaintiII
MtnAlterorAmendJudgment
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnAlterorAmendJudgment
04-04-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
04-03-2012
DeIendant
MemorandumoICosts
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
MemorandumoICosts
- Exhibit1
03-30-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
NoticeoIEntryoIOrd
CaseSummary
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03-30-2012
DeIendant
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
03-30-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-30-2012
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Order...
FiledbyorinbehalIoI:Court
Order...
03-27-2012
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FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-27-2012
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Order...
FiledbyorinbehalIoI:Court
Order...
03-26-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-26-2012
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***Minutes
FiledbyorinbehalIoI:Court
***Minutes
03-23-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-23-2012
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***Minutes
FiledbyorinbehalIoI:Court
***Minutes
03-14-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-14-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-13-2012
PlaintiII
Supplemental...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Supplemental...
03-13-2012
DeIendant
SubpoenaDucesTecum
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
SubpoenaDucesTecum
- Exhibit1
- Exhibit2
CaseSummary
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03-09-2012
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FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-09-2012
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FiledbyorinbehalIoI:Court
CertiIicateoIClerk
03-09-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-09-2012
DeIendant
NoticeoIEntryoIOrd
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
03-08-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-08-2012
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OrdDenyingMotion
FiledbyorinbehalIoI:Court
OrdDenyingMotion
03-08-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-08-2012
PlaintiII
CaseAppealStatement
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
CaseAppealStatement
03-07-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
03-07-2012
PlaintiII
MtnAlterorAmendJudgment
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnAlterorAmendJudgment
03-07-2012
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AIIidavitoIService
FiledbyorinbehalIoI:Court
AIIidavitoIService
03-05-2012
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03-05-2012
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SupremeCourtReceiptIorDoc
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ProoIoIElectronicService
CaseSummary
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02-27-2012
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02-27-2012
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Errata...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
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02-27-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
02-27-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
02-27-2012
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02-27-2012
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02-27-2012
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02-24-2012
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02-24-2012
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02-24-2012
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FiledbyorinbehalIoI:RICHARDHILL,ESQ.
AnsweringBrieI
- Exhibit1
- Exhibit2
- Exhibit3
- Exhibit4
- Exhibit5
- Exhibit6
02-24-2012
DeIendant
Motion...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
Motion...
- Exhibit1
02-22-2012
Court
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FiledbyorinbehalIoI:Court
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02-22-2012
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FiledbyorinbehalIoI:Court
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02-22-2012
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SupremeCtDeIiciencyNotice
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SupremeCtDeIiciencyNotice
02-16-2012
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ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
02-16-2012
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FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnProceedFormaPauperis
02-15-2012
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FiledbyorinbehalIoI:Court
ProoIoIElectronicService
02-15-2012
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FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
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02-14-2012
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02-14-2012
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FiledbyorinbehalIoI:RICHARDHILL,ESQ.
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02-14-2012
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02-14-2012
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02-14-2012
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02-14-2012
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FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
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02-14-2012
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Replyto/inOpposition
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
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02-14-2012
Replyto/inOpposition
CaseSummary
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PlaintiII
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Replyto/inOpposition
02-14-2012
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FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
Replyto/inOpposition
02-10-2012
Court
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ProoIoIElectronicService
02-10-2012
DeIendant
NoticeoIEntryoIOrd
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
02-09-2012
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FiledbyorinbehalIoI:Court
ProoIoIElectronicService
02-09-2012
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OppositiontoMtn...
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
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02-08-2012
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02-08-2012
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02-08-2012
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02-08-2012
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RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
02-07-2012
PlaintiII
Supplemental...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
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- Exhibit1
02-07-2012
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ProoIoIElectronicService
02-07-2012
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02-07-2012
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02-06-2012
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MtnIorExtensionoITime
02-06-2012
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MtnIorExtensionoITime
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnIorExtensionoITime
02-06-2012
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FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
OpeningBrieI
02-06-2012
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02-04-2012
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OpeningBrieI
02-03-2012
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02-03-2012
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OppositiontoMtn...
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02-03-2012
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FiledbyorinbehalIoI:RICHARDHILL,ESQ.
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02-02-2012
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02-02-2012
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01-31-2012
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FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-30-2012
PlaintiII
MtnAlterorAmendJudgment
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
MtnAlterorAmendJudgment
01-20-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
CaseSummary
Iile:///R,/...NEW20temp/cv11-0362820DTA20as20oI201020282012/cmsFullHistory20(Show20Hide20Participants).html|11/4/20123:52:01PM|
ProoIoIElectronicService
01-20-2012
DeIendant
MtnOrdtoShowCause
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
MtnOrdtoShowCause
- Exhibit1
- Exhibit2
- Exhibit3
- Exhibit4
- Exhibit5
- Exhibit6
- Exhibit7
01-17-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-17-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-14-2012
PlaintiII
OppositiontoMtn...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
OppositiontoMtn...
01-14-2012
PlaintiII
OppositiontoMtn...
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
OppositiontoMtn...
01-12-2012
Court
Supplemental...
FiledbyorinbehalIoI:Court
Supplemental...
01-11-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-11-2012
DeIendant
NoticeoIEntryoIOrd
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
NoticeoIEntryoIOrd
- Continuation
01-11-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-11-2012
Court
Order...
FiledbyorinbehalIoI:Court
Order...
01-10-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
CaseSummary
Iile:///R,/...NEW20temp/cv11-0362820DTA20as20oI201020282012/cmsFullHistory20(Show20Hide20Participants).html|11/4/20123:52:01PM|
01-10-2012
PlaintiII
NoticeoIAppearance
FiledbyorinbehalIoI:ZACHARYCOUGHLIN,ESQ.
NoticeoIAppearance
01-06-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-06-2012
Court
OrdIorBrieIingSchedule
FiledbyorinbehalIoI:Court
OrdIorBrieIingSchedule
01-06-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-06-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-06-2012
DeIendant
RequestIorSubmission
FiledbyorinbehalIoI:RICHARDHILL,ESQ.
RequestIorSubmission
01-06-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-05-2012
Court
NoticeoIAppearance
FiledbyorinbehalIoI:Court
NoticeoIAppearance
01-05-2012
Court
Reply...
FiledbyorinbehalIoI:Court
Reply...
- Exhibit1
- Exhibit2
01-04-2012
Court
Supplemental...
FiledbyorinbehalIoI:Court
Supplemental...
01-03-2012
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
01-03-2012
OppositiontoMtn...
FiledbyorinbehalIoI:Court
OppositiontoMtn...
- Exhibit1
- Exhibit2
- Exhibit3
- Exhibit4
CaseSummary
Iile:///R,/...NEW20temp/cv11-0362820DTA20as20oI201020282012/cmsFullHistory20(Show20Hide20Participants).html|11/4/20123:52:01PM|
Court
- Exhibit5
- Exhibit6
- Exhibit7
- Exhibit8
- Exhibit9
- Exhibit10
- Exhibit11
12-30-2011
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
12-30-2011
Court
ProoIoIElectronicService
FiledbyorinbehalIoI:Court
ProoIoIElectronicService
12-30-2011
Court
Amended...
FiledbyorinbehalIoI:Court
Amended...
- Exhibit1
12-30-2011
Court
MtnIorTRO
FiledbyorinbehalIoI:Court
MtnIorTRO
- Exhibit1
12-21-2011
PlaintiII
AppealIromJustice'sCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
AppealIromJustice'sCourt
12-21-2011
PlaintiII
AppealIromJustice'sCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
AppealIromJustice'sCourt
12-21-2011
PlaintiII
AppealIromJustice'sCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
AppealIromJustice'sCourt
12-21-2011
PlaintiII
AppealIromJustice'sCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
AppealIromJustice'sCourt
12-21-2011
PlaintiII
$AppealFromJustice'sCourt
FiledbyorinbehalIoI:ZACHARYCOUGHLIN
$AppealFromJustice'sCourt