1 30 12 Opposition To Motion To Dismiss 0204 2065 60838 22176 and All Attachments

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Document Code: 2645
Zach Coughlin, Esq.
Nevada Bar No: 4!"
#422 E. th $t. %2
&eno, N' (5#2
)ele: !!5*""(*(##(
+a,: 4*66!*!4-2
ZachCoughlin.hotmail.com
/ttorne0 1or /22ellant
3N )4E $EC5ND 67D3C3/8 D3$)&3C) C57&) 5+ )4E $)/)E 5+ NE'/D/
3N /ND +5& )4E C57N)9 5+ :/$45E
Z/C4 C57;483N<
/22ellant,
vs.
C3)9 5+ &EN5
&es2ondents.
=
=
=
=
=
=
=
=
=
=
C/$E N5: C&##*2-64
DE>). N5: #-
OPPOSITION TO MOTION TO DISMISS APPEAL
C5?E$ N5:, /22ellant Zach Coughlin, @0 and through his attorne0, Zachar0 BarAer
Coughlin, Esq , and o11ers his 522osition to ?otion to Dismiss /22eal. )his 522osition is @ased
u2on the attached >oints and /uthorities and the 2leadings and 2a2ers on 1ile in this case Bthough
the &ecord on /22eal is de1icient in that much o1 it is in the 1orm o1 an illegi@le C1our 2ages 2er
2ageC version o1 Dhat Das 2rovided the &eno ?unici2al Court, Dhereas a Cone 2age 2er 2ageC
version o1 those 2a2ers and 2leadings Dere 2rovided to the &eno ?unici2al Court and in a manner
e,2ressl0 authoriEed @0 the &eno ?unici2al Court.
POINTS AND AUTHORITIES
- 1
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
F I L E D
Electronically
01-30-2012:04:48:12 PM
Joey Orduna Hastings
Clerk of the Court
Transaction # 2730987
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
I. STATEMENT OF THE CASE
5n Novem@er "-, 2-##, the &eno ?unici2al Court held a )rial o1 /22ellant 1or the charge o1
>etit 8arcen0 B&?C F(.#-.-4-=. $ee Certi1ied Co20 o1 DocAet, 1iled Decem@er 2", 2-##. )hough
>am &o@erts had agreed in Driting to a continuance 2revious thereto, she decided to change her
mind on the date o1 the )rial, and 6udge 4oDard re1used one an0Da0. 3n 1act, 6udge 4oDard
thought it Das such an urgent matter o1 2u@lic im2ortance to get this 2etit larcen0 charge o1 a
Cchocolate @ar and some cough dro2sC done that he get literall0 an entire De2artment o1 the &eno
?unici2al Court DorAing until 2m at night on Novem@er "-th, 2-##, Dith ever0@od0 collecting
overtime, all courtes0 o1 the 2u@lic 1isc.
/22ellant received a 1ine in the amount o1G"6-.-- and 24 hours o1 communit0 service, @ut
then 6udge 4oDard realiEed he Das mistaAen in his @elie1 that /22ellant had 1ailed to a22ear 1or the
originall0 scheduled Novem@er #4th, 2-## )rial Date. $o 6udge 4oDard e,cised his earlier
requirement that /22ellant @e1ore 24 hours o1 :ashoe Count0 $heri11 DorA 2rogram communit0
service, Dith no e,tensions, @0 Decem@er #(ht, 2-##, des2ite the /22ellant @eing indis2osed
serving three da0s in :ashoe Count0 6ail immediatel0 1olloDing the )rial in this matter 2ursuant to
a 1inding $ummar0 Contem2t 5rder announced @0 6udge 4oDard at the conclusion o1 the
Novem@er "-th, 2-## )rial in this matter, onl0 to return to the 1ull time 2ractice o1 laD u2on the
conclusion o1 the three da0 sentence B/ ?otion 1or $ta0 requested @0 the /22ellant Dhile @eing
handcu11ed and arguing that his clientHs Dould @e undul0 2reIudiced @0 such a $ummar0 Contem2t
1inding= Das curtl0 dismissed @0 6udge 4oDard one sentence into arguing 1or it. $ee Certi1ied Co20
o1 DocAet. 5n Decem@er #", 2-## /22ellant 1iled a Notice o1 /22eal in this matter. $ee Certi1ied
Co20 o1 DocAet. /t the conclusion o1 the )rial in this matter, and on the record and 2art o1 the
o11icial audio recording o1 this matter, 6udge 4oDard announced to the undersigned that he Das
- 2
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
giving the undersigned an additional three da0s @e0ond that normall0 a11orded litigants, to 1ile a
Notice o1 /22eal on account o1 6udge 4oDardHs summaril0 sentencing the undersigned attorne0 to
three da0s in Iail 1or Ccontem2t committed in the 2resence o1 the CourtC.
3t is ver0, ver0 odd that the CCerti1ied DocAetC and the C&ecord on /22ealC do not seem to
veri10 the 1iling o1 man0 o1 the 2a2ers and 2leadings 1rom the undersigned in E,hi@it #. )his
manner o1 1iling 2a2ers and 2leadings Das e,2ressl0 authoriEed @0 &?C +iling 511ice $u2ervisor
Donna Ballard.
Another thing that is curious and clearl0 ver0, ver0 Drong is that the C6udgment and 5rder o1
the CourtC that Das allegedl0 1ile stam2ed on Novemer "-th, 2-## B0et lacAs a clerAHs handDritten
intials in the @lanA calling 1or as much= indicates that the undersigned 2led C;uilt0C to the charge.
NoD, hoD a 5 hour )rial could have taAen 2lace Dhen a Cguilt0C 2lea Das entered Band, again, the
undersigned did not ever 2led guilt0 in this case, 1ar 1rom it= is not clear, @ut a lot o1 things arenHt
clear. 4oD could the incredi@l0 im2lausi@le and shaA0 testimon0 and evidence 2ut on here 1or the
accused the1t o1 a@out G#- o1 edi@les Bin a Count0 that has had a@out #5J unem2lo0ment 1or a@out
" 0ears noD, Dith an accused that has received no 1oodstam2s, $ection ( housing, medi*caid, no
nothing....no to mention that the evidence strongl0 shoDs that there Das no the1t in this matter=. $o,
Dhat o1 the Cguilt0C 2lea mentionedK Does that invoAe N&$ #!!.-#5B4=K 5r does it Iust shoD the
slo220 and or 2reIudicial manner in Dhich 'eronica 8o2eE et al do their duties in De2artment 4K
N&$ #!!.-#5B4=: C/22eals to district court and $u2reme Court. )he 2art0 aggrieved in a criminal
action ma0 a22eal onl0 as 1olloDs:. 4. E,ce2t as otherDise 2rovided in su@section " o1 N&$
#!4.-"5, the de1endant in a criminal case shall not a22eal a 1inal Iudgment or verdict resulting 1rom
a 2lea o1 guilt0, guilt0 @ut mentall0 ill or nolo contendere that the de1endant entered into voluntaril0
and Dith a 1ull understanding o1 the nature o1 the charge and the consequences o1 the 2lea, unless the
- 3
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
a22eal is @ased u2on reasona@le constitutional, Iurisdictional or other grounds that challenge the
legalit0 o1 the 2roceedings. )he $u2reme Court ma0 esta@lish 2rocedures to require the de1endant to
maAe a 2reliminar0 shoDing o1 the 2ro2riet0 o1 the a22eal. C 4oD is it that this charge, alleging the
consuming o1 a Cchocalate @ar and some cough dro2sC results in a custodial arrest over one da0, a
G"6- 1ine 2lus another G4- 1or Ccourt 2rocessing chargesC, in addition to 24 hours o1 $heri11Hs CDorA
creDC communit0 service, to @e com2leted CDith no e,tensionsC in a matter o1 #5 da0s @0 one Dho
is engaged in the 1ull time @us0 2ractice o1 laD, immediatel0 a1ter that same attorne0 1inishes
serving three da0s in Iail Bno $ta0 granted, no tier time in Iail, no 2hone calls to 2rotect clientHs
a11airs= 1or a $ummar0 Contem2t 5rder in a case Dhere the indigent accused Das denied his $i,th
/mendment &ight )o Counsel, and an0 continuance, not even one, even Dhere a Drong1ul eviction
Dith all sorts o1 attendant 2rocedural and su@stantive errors in &E'2-##*--#!-( undul0 2reIudiced
the accusedHs a@ilit0 to 2ut on a de1ense, 2articularl0 Dhere materials essential to such a de1ense
Dhere @eing Drong1ull0 Dithheld @0 the o22osing counsel in the eviction matter BDhom Das also
Dithholding another attorne0Hs client 1iles and that attorne0Hs drivers license and Dhom the
undersigned canHt 1ind a single attorne0 in toDn Dho has a single good thing to sa0 a@out that
attorne0, his name @eing &ichard ;. 4ill, Esq.=K
II. STATEMENT OF THE FACTS
>lease see EL43B3) 4: Decem@er #2th, 2-## emailed 1iling Bas authoriEed @0 the &?C in
lieu o1 1a,ing= to the &?CHs renomunirecords.reno.gov that should, @ut does not a22ear
a22ro2riatel0 in the record on a22eal, containing Iust the email cover sheets 2roving the attached
2d1Hs Dere received @0 the &?C and there1ore the contents thereo1 should @e a22ro2riatel0 2rinted,
2rovided, and 1iled @0 the &?C to the District Court, rather than the illegi@le C1our 2ages 2er 2ageC
st0le the &?C has 2ut in the &ecord on /22eal. +urther, 2lease see EXHIBIT 2:
- 4
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
DECLARATION OF ZACHARY B. COUGHLIN ES!. 1or a someDhat thorough accounting o1
the relevant 1acts here. +urther, it seems a Ctolling motionC Das timel0 1iled her, so in the interest o1
Iudicial econom0 its is liAel0 necessar0 to 1igure out Dhether the Notice o1 /22eal and this &equest
to $et a 4earing Dith the 6- da0s 1rom the 1iling o1 the Notice o1 /22eal here is a22ro2riate or i1 it
Dould @e 1or naught. +urther, 6udge 4oDardHs signature on various 2a2ers and 5rders a22ears to @e
a Cru@@er stam2C mold o1 his signature, Dhich is, 2erha2s, not 2ermissi@le. /dditionall0, on the Cnot
on 2leading 2a2erC C . +urther, the $ummar0 Contem2t 5rder com2letel0 lacAs an >roo1 o1
$ervice, indeed, there is no record o1 an0 service o1 this $ummar0 Contem2t 5rder in the &ecord on
/22eal. /nother thing that is not onl0 interesting, @ut indicative o1 the ad hoc, sla2dash manner in
Dhich convictions are handed out and trials are conducted in 6udge 4oDardHs court room. $uch
convictions can require an attorne0 such as the undersigned to com2l0 Dith $C& ###. 5r entail
1iling an a22eal liAe this one, Dhich Dill not onl0 liAel0 cost the Cit0 o1 &eno quite a @it o1 mone0
during 2articularl0 doDn economic times, @ut Dhich have even more 1ar reaching e11ects u2on a
num@er o1 2eo2le. )he C6udgment o1 Conviction and Court 5rderC Bhave 1un 1iguring out i1 N&C>
5 is a22lica@le to something Dith that title= does not have a >roo1 o1 $ervice, 2er se, @ut there is
something 1or a litigant to sign, usuall0 Dith a @ull0ing ?arshal hulAing over he or she in a
demeaning, authoritarian, and derisive tone....4oDever, the ?arshal Dho initialed B0et 2rovided not
1urther identi10ing in1ormation= this section, Driting in C&E+7$EDC and a time o1 (:2" 2m,
a22arentl0 1iled to later adIust this Ctime o1 serviceC is 0ou can call it that. >erha2s he or she should
have, considering that the C+or )he &ecordC so1tDare the &?C uses and 2rovides litigants
2urchasing the recording o1 the audio o1 a trial indicates that the C6udgment and Court 5rderC in this
matter Das 1inall0 concluded at (:46 2.m. a 1ull tDent0 three minutes /+)E& the time the ?arshal
Drote on the quasi*>roo1 o1 $ervice 1orm o1 (:2" 2.m. BDhere the ?arshal Drote &E+7$ED, Dhich
- 5
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Das a lie, it Das not re1used, and 1urther, the handcu11ed and manhandled undersigned Das not reall0
in much o1 a 2osition to 2revent the 1ive to si, ?arshals there 1rom 1olding u2 such a document and
2utting in the undersigned la2to2 @ag or his 2ocAets, or otherDise 2roviding a co20 o1 the document.
:hat the &?C means @0 C&E+7$EDC is not clear. 'eronica 8o2eE, 6udge 4oDardHs menacing
C6udicial /ssistantC sneered to the undersigned on the 2hone, Dhen he called the 1olloDing ?onda0
seeAing a co20 o1 an0 such documents that the undersigned Chad his chance to get one and @leD itC
and then 8o2eE 2roceeded to taunt the undersigned some more and hang u2 a@ru2tl0 a1ter l0ing that
she Dould 1a, co20 o1 the CdocumentsC su22osedl0 re1used on Novem@er "-th, 2-## to the
undersigned 1a, num@er as listed on the $tate BarHs De@site. )he 1lagrant level o1 @elligerence
demonstrated @0 some man0 o1 the 2ersonnel associated Dith the &?C, 2articularl0 6udge 4oDardHs
De2artment, man0 o1 Dhom are C1ormer 2rosecutorsC or otherDise associated Dith a 2rosecutorial
incu@ation 2eriod reall0 suggests a com2lete lacA o1 oversight and accounta@ilit0 @eing a22lied to
the &?C @0 the Iudiciar0, the 2u@lic, and the 2oDers that @e. )he Novem@er "-th, 2-## C6udgment
o1 Conviction and Court 5rderC BDhich a22ears to @are a ru@@er stam2 mold o1 6udge 4oDardHs
signature, Dhich looAs com2letel0 inauthentic, Cru@@er stam2ishC, overl0 uni1orm, and identical
ever0 time 3 have seen it an0Dhere= (:"":## 2m on Novem@er "-th, 2-## in 6udge 4oDardHs court
room.
+urther, the Cinterrogation roomC video 1rom :al*?art 1iled Dith the &?C on #2M#"M## and
the materials in EL43B3) 5 BDhich includes Discover0 2roduced @0 &eno Cit0 /ttorne0 com2ared
to recei2t o1 C2urchasedC items, @oth 1iled in legi@le 1orm Dith the &?C, 0et not included in legi@le
1orm in the &ecord on /22eal= N5)E: )43$ 3$ )4E &ECE3>) +5& )4E 3)E?$ )4/) :E&E
&7N; 7> /ND +5& :43C4 ?5NE9 :/$ >/3D. :/8*?/&)H$ )45?/$ +&5N)3N5
/ND &$3C 5++3CE& C&/:+5&D 83ED :4EN )4E9 B5)4 )E$)3+3ED )4/) )4E9
- 6
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
'E&3+3ED )4/) )4E 7>C +5& )4E CC57;4 D&5>$C 5N )4E &ECE3>) 5N )4E >/;E
/B5'E )43$ 5NE D3D N5) />>E/& 5N )4E &ECE3>) +57ND BE85:=. 45:E'E&,
C8E/&89 )4/) $/?E 7>C />>E/&$ 5N B5)4 &ECE3>)$ B)4E 7>C 3$ -!"22##6"--"=.
+&5N)3N5 E'EN )&3ED )5 )E$)3+9 )4/) 4E :/$ /B8E )5 D3$CE&N +&5?
/>>&5L3?/)E89 5- +EE) /:/9 )4/) 4E C578D )E88 EL/C)89 :4/) 3)E?$
/ND :4/) 7>CH$ :E&E BE3N; &7N; 7> /) )4E &E;3$)E& /ND )4/) 4E :/$
/B8E )5 'E&3+9 )4/) )4E 7>CH$ +5& )4E C57;4 D&5>$ 5N )4E C$)58ENC
&ECE3>)C :E&E N5) +57ND 5N )4E C>7&C4/$EDC &ECE3>). 45:E'E&, C8E/&89,
+&5N)3N5 :/$ :&5N; 5& 893N;, 5& B5)4.
LEGAL ARGUMENT
$o, here is hoD much >am &o@erts, Esq. and 6ohn Nadlic, Esq. thinA o1 this Court, our
Iudicial s0stem, N&C> ##, rules governing 2rosecutorial misconduct :DC& #-, DC& #2, :DC&
#2B#=, &ules o1 >ro1essional Conduct related to re1raining 1rom su@orning 2erIur0, etc., etc. >am
&o@erts, Esq.Hs ?otion to Dismiss consisted o1 Iust thus:
C MOTION TO DISMISS APPEAL
C5?E$ N5: &es2ondent C3)9 5+ &EN5, @0 and through, >amela ;.
&o@erts, De2ut0 Cit0 /ttorne0, and 1iles its ?otion to Dismiss /22eal as 1olloDs:
)his ?otion is @ased u2on the 2leadings and documents on 1ile herein, and the
1olloDing 8egal /rgument.
LEGAL ARGUMENT
5n Novem@er "-, 2-##, the &eno ?unici2al Court convicted /22ellant o1
>etit 8arcen0 B&?C F(.#-.-4-=. $ee Certi1ied Co20 o1 DocAet, 1iled Decem@er
2", 2-##. /22ellant received a 1ine in the amount o1G"6-.--. $ee Certi1ied Co20
o1 DocAet. 5n Decem@er #", 2-## /22ellant 1iled a Notice o1 /22eal in this
matter. $ee Certi1ied Co20 o1 DocAet. >ursuant to N&$ # (.-#-, the /22ellant
had #- da0s 1rom Novem@er "-, 2-## to 1ile his Notice o1 /22eal. )his #- da0
rule a22lies to the &eno ?unici2al Court. $ee &oot v. Cit0 o1 8as 'egas, (4 Nev
25(, 4" >2d 2# B#6(=. )here are no e,ce2tions.
CONCLUSION
Based u2on the 1oregoing, &es2ondent res2ect1ull0 requests that this
4onora@le Court enter an 5rder dismissing this a22eal. D/)ED this #th da0 o1
- 7
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
6anuar0, 2-#2, 654N 6. N/D83C &eno Cit0 /ttorne0 B0: >/?E8/ ;.
&5BE&)$ De2ut0 Cit0 /ttorne0C
NoD, 1or the G##2,--- 2er 0ear in com2ensation that De2ut0 &eno Cit0 /ttorne0 >am
&o@erts has averaged over the last several 0ears, one might @e 1orgiven 1or e,2ecting that she could
2rovide some citation to the N&C> that 1orms the @asis 1or her ?otion to Dismiss /22eal. B$ee,
EXHIBIT ": $alar0 in1ormation 1or the 0ears 2-- and 2-#- 1or De2ut0 &eno Cit0 /ttorne0 >am
&o@erts, Esq. 1rom DDD.)rans2arentNevada.com=. 4oDever, &o@erts 1ailed to cite to N&C> #2B@=
at all, much less s2eci10 Dhich section o1 N&C> #2B@= she ma0 @e arguing 1or a Dismissal under.
$o, 2erha2s, &o@erts should @e on trial 1or the1t, as her ?otion certainl0 does not seem to suggest an
honest da0Hs DorA 1or an honest da0Hs 2a0. /s such, &es2ondentHs ?otion must 1ail. Certainl0, the
undersignedHs ?otionHs have 1ailed in other cases @e1ore this Court Dhere he has, allegedl0, 1ailed to
cite to a s2eci1ic 2rocedural rule su22orting the relie1 he requested. )hat is, unless this Court 2re1ers
to hold 2ro se litigants Dho are living at the 2overt0 line to a much higher standard than it holds
government attorne0s Dho are com2ensated e,tremel0 Dell to 2rosecute misdemeanor crimes and
assisted @0 several 1ull time sta11 mem@ers and a generous equi2ment and e,2ense account.
&egardless, &o@erts ?otion to Dismiss 1ails to com2l0 Dith :DC& &ule #2. : C?otions< 2oints and
authorities and decisions. #. E,ce2t as 2rovided in &ule #, all motions shall @e accom2anied @0
#o$nt% &n' &(thor$t$e%.C &o@erts motion contains no authorit0 to su22ort a num@er o1 as2ects o1
her argument.
+urther, the >roo1 o1 $ervice on &o@ertHs motion is addressed to an address 1or the
undersigned that &o@erts should have AnoDn Das no longer current given the 6anuar0 #-, 2-#2
Notice o1 /22earance the undersigned 1iled in this matter Dith his current #422 E. th $t. %2, (5#2
address. /s such, &o@erts motion is im2ro2erl0 notice and should 1ail. +urther, even i1 o22osing
- 8
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
counsel &o@erts Dishes to argue the ?otion to Dismiss ma0 have @een served electronicall0 via E*
+le, Bsomething she has not esta@lished or o11ered an0 2roo1 o1=, the >roo1 o1 $ervice she attached to
her ?otion to Dismiss does not indicated her ?otion Das so served electronicall0. /nd its this Aind
o1 slo220, careless, inattention to detail that 2ermeated throughout &o@ertHs 2ractice at )rial in this
matter, Dherein she su@orned the 2erIur0 o1 multi2le Ditnesses 1or her em2lo0er, the Cit0 o1 &eno,
des2ite the 1act that &o@erts hersel1 2ro2ounded to the undersigned video evidence Dhich 2roves the
testimon0 she 2ut on the stand amounted to su@orning 2erIur0.
>lease see the undersignedHs Declaration, under 2enalt0 o1 2erIur0 attached hereto, concerning
the 1olloDing e,cer2t 1rom the end o1 the audio record o1 the Novem@er "-th, 2-## )rial in &?C ##
C& 22#!6, Dhich re2resents a com2letel0 true and accurate transcri2tion Bmade 1rom the CD o1 the
)rial that the undersigned 2urchased 1rom the &?C and taAen 1rom the 1ile named:
CO?C+)&BPQ2-####"-*2-""Q-#cca1145#ed--C < this audio e,cer2t and 2erha2s the entire audio
record Dill liAel0 @e 2rovided to the District Court in the 1orm o1 an attachment to a $u22lemental to
a motion in com2liance Dith the indications given @0 /22eals ClerA 8ori ?atheus and ClerA o1
Court 5rduna 4astings= o1 Dhat Das said in o2en court, on the record, @eginning at (:"":## 2m on
Novem@er "-th, 2-## in 6udge 4oDardHs court room:
C64: alright De are @acA on the record in regard to Cit0 v. Zachar0 Coughlin.
3 Das admittedl0 remiss in not advising ?r. Coughlin o1 his right to a22eal.
:e do Dant to taAe care o1 that noD on the record. ?r. Coughlin, 0ou have
the right to a22eal the decision o1 this Court. 9ou can do so @0 1iling a Notice
o1 /22eal. Customaril0, itHs #- da0s and thats, uh, 3Hm sure 0ou are 1ull0
aDare o1 that...:hat 3 am going to do is grant an e,tension to that statute in
light o1 the 1act that 0ou Dill not @e released 1rom custod0 until Decem@er
"rd, so 0our #- da0s Dill run e11ective Decem@er "rd at ( 2m, so 0ou Dill
have #- da0s 1rom that date to 1ile a Notice o1 /22eal Dith this Court, noD
once 0ou 1ile 0our Notice o1 /22eal there are several things that 0ou Dill have
to do, 2rinci2al among those is to o@tain a co20 o1 the transcri2t at 0our
e,2ense. 5nce the transcri2t has @een 1orDarded to the District Court, there is
- 9
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
no )rial de novo, 0ou are 2ro@a@l0 aDare that the District Court Iudge Dill
revieD the 1our corners o1 the transcri2t to determine, one, Dhether this court
has made an0 legal errors that Dould Iusti10 a reversal o1 this matter or
Dhether there is su11icient evidence Dithin the transcri2t to Iusti10 the 1inding
o1 guilt that 3 have made here toda0. 3s there an0 questions at all Dith regard
to the a22eal 2rocessK
ZC: )he availa@ilit0 o1 a $ta0, that 3 guess Dould go more toDards the
1inding o1 Contem2tK 7m, Dhen 0ou sa0 Ca22eal 2rocessC are 0ou re1erring
to...K
64: )he 1iling o1 a22eal in regard to the 2etit the1t.
ZC: Not in regard to the Contem2tK
64: No, thats a summar0 2roceeding and De are going to go 1orDard Dith
that. 5ne thing that 3 Dill sa0 in regard to the 2etit the1t )rial and su@sequent
sentencing, hoDever, its m0 recollection, im2ro2erl0, that 0ou had 1ailed to
a22ear at the 2revious 2roceeding, and thatHs not correct, uh, there Das another
reason as to Dh0 De Dere una@le to 2roceed, so 3 am going to delete the 24
hours o1 communit0 service, the 1ine o1 G"6- Dill stand. /lright, an0 other
questions involving the /22eal 2rocessK
ZC: 9es, to the e,tent m0 laD 2racticeHs clients, that their cases Dill @e
undul0 2reIudiced @0 0our incarcerating me right noD...
64: 3 am standing @0 that and 3 Dish 0ou Dould have thought a@out that a1ter
each admonishment that 3 gave 0ou during the )rial.
ZC: 9ou are saddened @0 that.
64: :e are in recess. C Bcommotion o1 ?arshals can @e heard and the audio
recording o1 the record o1 the )rial ends=.
9ou AnoD Dhat m0 1avorite 2art o1 this isK )hat C1ile stam2C in the &ecord on /22eal 1or that
document, Dhatever it is, Aind o1 a court 2rintout thing in the &?C, Dith a 1iled on date stam2 o1
##M"-M##...Dh0, 3 guess the0 are calling that the C6udgment o1 Conviction and 5rderC...its not on
2leading 2a2er, hmmmn...AnoD Dhat elseK 3ts Iust a@out the onl0 document in the &ecord on
/22eal Dith a 1ile stam2 that doesnHt have a &?C De2ut0 ClerAHs handDritten initialing on it. :h0,
oh Dh0 isnHt there a De2ut0 ClerAHs initials on that 2articular 1ile stam2ingK :h0 is thatK 3snHt that
- 10
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
document and Dhen it Das CrenderedC under &?C& the Dhole 2oint o1 >am &o@ertHs ?otion to
Dismiss the /22ealK B&?C& &ule : C/22eals to District Court E,ce2t as otherDise 2rovided in
N&$ #!!.-#5 a de1endant in a criminal action tried @e1ore a ?unici2al Court 6udge ma0 a22eal
1rom the 1inal Iudgment therein to the $econd 6udicial District Court, at an0 time Dithin #- da0s
1rom the date that Iudgment is rendered.C=
/ssuming the &?C doesnHt have to closel0 adhere to the &6C 2ractices and 2rocedures o1 the
6ustice Courts*and it must under N&$ 5.-!" Con1ormit0 o1 2ractice and 2roceedings to those o1
Iustice courts ...=, @ut regardless, >am &o@ertsH motion Dastes ever0@od0Hs time here, as N&C> 6
holds that one doesnHt count the da0 o1 the event in com2uting and that one gets " additional da0s 1or
Dhere no 2ersonall0 service Das e11ectuated, and clearl0 the &?CHs conduct in shoDing 2a2ers in a
manHs 1ace Dhile he is handcu11ed, then snatching and dashing o11 Dith the a22ears a hu11...re1using
to even let the accused AnoD Dhat it is the0 Dant signed and or to alloD to revieD said 2a2ers is
ver0 telling Dith res2ect to the conce2tion o1 some in the &?C o1 the C1undamentals o1 due
2rocessC. $o , even i1 one measured 1rom an oral 2ronouncement 1rom the @ench on ##M"-M##
BDhich is de@ata@le, @ut &o@erts o11ers no legal research into Dhat a Iudgment @eing rendered or
Dhat rendition o1 the Iudgment actuall0 entails or meansK Does it mean reduced to DritingK Does it
mean orall0 2ronouncedK Doe is mean entered into a docAet or im2l0 some requirement 1or Notice
o1 Entr0 o1 the 5rder or 6udgment, Dith a 1ile stam2, 2roo1 o1 service, etc.K an0 time Dithin #- da0s
1rom the time o1 the rendition o1 the Iudgment /lso in the &ecord on /22eal B&5/= the ##M"-M##
$ummar0 Contem2t 5rder lacAs an0 sort o1 >roo1 o1 $ervice, so...has there not @een a 1inal
a22eala@le 5rder in this matter 0etK Do 3 not have to @e a22ro2riatel0 served that Contem2t 5rderK
:here is the 2roo1 o1 such +urther, the Ccerti1ied docAetC does not seem to contain the 1iling emailed
to the address &?CHs D. Ballard a22roved the use o1 on #2M#2M##.
- 11
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
N&$ #(.-#- /22eal must @e taAen Dithin #- da0s. E,ce2t as otherDise 2rovided in N&$
#!!.-#5, a de1endant in a criminal action tried @e1ore a Iustice o1 the 2eace ma0 a22eal 1rom the
1inal Iudgment therein to the district court o1 the count0 Dhere the court o1 the Iustice o1 the 2eace
is held, at an0 time Dithin #- da0s 1rom the time o1 the ren'$t$on o) the *('+,ent.
Ruite argua@l0 N&$ #(.-#- is ina22lica@le the the &?C as the &?C does not have Iustices
o1 the 2eace.
N&$ #(.-65 Dismissal 1or 1ailure to set or reset a22eal 1or hearing.
#. /n a22eal must @e dismissed @0 the district court unless 2er1ected @0 a22lication o1 the
de1endant, Dithin 6- da0s a1ter the a22eal is 1iled in the Iustice court, @0 having it set 1or hearing.
2. 31 an a22eal has @een set 1or hearing and the hearing is vacated at the request o1 the a22ellant,
the a22eal must @e dismissed unless a22lication is made @0 the a22ellant to reset the hearing Dithin
6- da0s a1ter the date on Dhich the hearing Das vacated.
)he undersigned here@0 a22lies 1or an0 such hearing that is required.
&ule #. /22eals 1rom munici2al and Iustice courts.
#. /ll a22eals 1rom the munici2al or Iustice courts in criminal cases shall @e set 1or trial or
hearing Dithin 6- da0s o1 the date o1 a22lication 1or setting. / setting @e0ond 6- da0s ma0 @e made
onl0 i1 a22roved in Driting @0 the trial Iudge or the chie1 Iudge. 31 a trial setting is continued @0 order
o1 the court, the case shall @e reset Dithin 6- da0s o1 the date o1 the order 1or continuance.
2. 31 multi2le settings 1or a22eal trials in an0 one court de2artment e,ceed the ca2acit0 o1 that
de2artment, settings shall @e made in the designated de2artment scheduled to handle the over1loD. 31
that courtSs calendar @ecomes 1ull, assignment shall @e made to an0 other availa@le de2artment.
". /22eals in criminal cases shall @e set 1or trial on )hursda0s and +rida0s, unless the trial Iudge
or the chie1 Iudge grants 2ermission to maAe such settings on other Iudicial da0s.
/ 2ost*Iudgment tolling motion Das timel0 1iled here, argua@l0 on Decem@er #2th, 2-##,
though, i1 not, then certainl0 on Decem@er #"th, 2-##. >lease see E,hi@it 4 attached hereto. /s
such, the time to a22eal 1rom the 1inal Iudgment is TtolledU until a1ter the tolling motions are
resolved. N&/> 4Ba=B4= lists the onl0 motions that are tolling: #. / motion 1or Iudgment as a matter
o1 laD under N&C> 5-B@=< 2. / motion under N&C> 52B@= to amend or maAe additional 1indings o1
1act< ". A ,ot$on (n'er NRCP -. to &/ter or &,en' the *('+,ent0 &n' 1. A ,ot$on )or & ne2
- 12
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
tr$&/ (n'er NRCP -.. /ccording to the stated rules, these motions must @e 1iled Dithin #- da0s o1
service o1 the notice o1 entr0 o1 Iudgment to e11ectivel0 toll the time to a22eal the 1inal Iudgment. )he
$u2reme Court has clari1ied that the counting 1or the #- da0s does not include intervening $aturda0s,
$unda0s, or non*Iudicial da0s according to N&C> 6Ba=. :inston >rods. Co., 3nc. v. DeBoer, #22
Nev. 5#!, #"4 >."d !26 B2--6=. /n0 additional time added 1or service is counted @0 calendar da0s
a1ter the initial #- da0s. 3d. 3n addition to tolling the time to 1ile a notice o1 a22eal, a tolling motion
also tolls the time to a22eal 1rom s2ecial orders made a1ter 1inal Iudgment, such as orders aDarding
attorne0 1ees and costs. 3d. 3n the event that 0our tolling motion is not 1iled Dithin the alloDed #-
da0s, 0ou should still 1ile the motion Dith the understanding that the time to a22eal the 1inal Iudgment
is not tolled. 31 the District Court is inclined to grant 0our motion a1ter a notice o1 a22eal has @een
1iled, the District Court does not technicall0 have Iurisdiction to enter an order dealing Dith su@Iect
matter that is 2ending on a22eal, @ut the District Court ma0 recommend its inclination to enter such
an order to the $u2reme Court. ?acA*?anle0 v. ?acA, #22 Nev. !5, #"( >."d 525 B2--6=. )he
$u2reme Court then has the authorit0 to remand the matter to the District Court to enter the order
according to the District CourtHs inclinations. 3d. $o, given that the undersigned has a series o1
legitimate legal arguments to somehoD change the Iudgment, the /22ellant here@0 requests, under
District Court &ule #"B!=, 2ermission to alloD this litigants to 1ile a motion 1or reconsideration u2on
leave o1 court. 5ther local rules, such as Eighth 6udicial District Court &ule 2.24B@= and $econd
6udicial District Court &ule #2B(=, require that a motion 1or reconsideration or rehearing @e 1iled
Dithin #- da0s o1 service o1 notice o1 entr0 o1 Iudgment. /lthough an order granting or den0ing a
motion 1or reconsideration is not itsel1 a22eala@le, the $u2reme Court Dill consider arguments raised
in the motion 1or reconsideration so long as the District Court considers 0our motion on the merits,
- 13
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
0our notice o1 a22eal is 1iled a1ter the order dis2osing o1 the motion and the motion and order are
included in the record on a22eal. /rnold v. Ni2, #6( >."d #-5- BNev. 2--!=.
TIMING TO FILE A NOTICE OF APPEAL
)he notice o1 a22eal is a @asic document that does nothing more than 2ut the su2erior Court on
notice o1 Dhich ?unici2al Court orders 0ou @elieve Dere decided incorrectl0. B0 Da0 o1 analog0
to the instant scenario, N&/> 4Ba=B#= requires that a notice o1 a22eal @e 1iled in the District Court
Dithin "- da0s a1ter ser*vice o1 notice o1 entr0 o1 the order 1rom Dhich an a22eal is taAen. 31 a
tolling motion has @een timel0 1iled, N&/> 4Ba=B4= alloDs the notice o1 a22eal to @e 1iled Dithin "-
da0s a1ter service o1 notice o1 entr0 o1 the order dis2osing o1 the 1inal tolling motion. 5neHs a22eal
to the $u2reme Court must @e taAen 1rom an a22eala@le order. N&/> "/B@= lists man0 o1 the
orders that can @e a22ealed. 31 one has not 2ro2erl0 2er1ected oneHs a22eal, occasionall0 the
Iurisdictional de1ect can @e corrected during the 2endenc0 o1 the a22eal, de2ending on the t02e o1
Iurisdictional de1ect. $ustaina@le ;roDth 3nitiative Comm. v. 6um2ers, 88C, #22 Nev. 5", #2(
>."d 452 B2--6=.
udgment is not made 1inal @0 a mere Dritten minute or an oral 2ronouncement @0 a court or
Iudge Dithout the 2re2aration and 1iling o1 a Iournal entr0. Euclid v. ?uller, #"4 5hio /22. "d !"!,
!"2 N.E.2d 4#- B(th Dist. Cu0ahoga Count0 #=. 3n ?agee v 8othro2 B#"= 6- Nev 2-2, 6
>2d 2-#, #-6 >2d !5#, it Das stated that the laD o1 Nevada is settled that the 2eriod o1 time 1or
taAing an a22eal runs 1rom the rendition o1 the decision o1 the court, not 1rom the time o1 the 1iling
o1 the 1ormal 1indings and 1ormal Iudgment. )he rule stated a@ove Das a22lied in Nelson v >aul
B#5#= 6( Nev "65, 2"" >2d (5!, in Dhich the trial Iudge 1irst signed a document entitled C52inion
/nd 5rders 5n Demurrer /nd ?otions )o $triAe,C Dhich, a1ter an e,tensive discussion o1 the legal
2rinci2les involved, 2rovided in 2art as 1olloDs: C+or the reasons given, it is there1ore ordered, that
- 14
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the de1endants 6oe /naca@e and +a@iana /naca@e, his Di1e, @e dismissed and stricAen as 2arties
de1endant herein.C $u@sequentl0 a document entitled C6udgmentC Das signed and 1iled @0 the trial
Iudge. )hat document stated: C)he demurrers o1 the de1endants 6oe /naca@e and +a@iana /naca@e,
his Di1e, having @een sustained @0 order dul0 made on the "rd da0 o1 6ul0, #5-, and said
de1endants having @een dismissed and stricAen as 2arties de1endant herein, Dithout leave to amend
as to said de1endants< noD, on motion o1 said de1endants 6oe /naca@e and +a@iana /naca@e, his
Di1e, 3t is ordered and adIudged that the com2laint herein @e, and the same is here@0, dismissed and
that said de1endants have and recover o1 the 2lainti11 a@ove*named their costs, ta,ed at G2.5-.C
/22eals taAen Dithin 6 months 1rom the 1iling o1 the document entitled C6udgmentC @ut more than
6 months a1ter the 1iling o1 the document entitled C52inion and 5rders, etc.,C Dere dismissed, the
court sa0ing: CB0 the order o1 the trial court the rights o1 the /naca@es Dere 1ull0 determined. No
1urther Iudicial determination remained to @e made. )he 1act that the H6udgmentH s2eci1ied more
clearl0 than did the order the action taAen @0 the court u2on the demurrers does not constitute the
H6udgmentH an e,ercise o1 1urther Iudicial determination in that res2ect. B0 its recitals it 2ur2orts to
relate Dhat had alread0 @een accom2lished @0 the order and does not 2ur2ort to taAe neD and
1urther action. )hat document, then, Das merel0 a more 1ormal statement o1 the Iudgment as it had
alread0 @een rendered.C /n instrument entitled CDecision and 52inion,C Dhich concluded that the
2lainti11s Dere entitled to Iudgment against the de1endants in a s2eci1ied sum o1 mone0 and directed
counsel 1or the 2lainti11s to 2re2are 1indings and 1acts and conclusions o1 laD in con1ormit0 Dith
this o2inion, and not the 1indings and 1ormal Iudgment su@sequentl0 1iled, Das held in 8ind v
&a0nor B#52= 6 Nev #64, 24" >2d !(", to constitute the Iudgment rendition o1 Dhich started the
time 1or a22eal running, and the a22eal, having @een 1iled more than 6 months a1ter the 1iling o1 the
CDecision and 52inion,C Das consequentl0 dismissed. )he court relied on the Dellesta@lished
- 15
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Nevada rule that time 1or a22eal 1rom the Iudgment commences to run 1rom the 2ronouncement @0
the court o1 its determination o1 the matter, Dhich constitutes a rendition o1 the Iudgment, and not
1rom the date o1 the 1iling o1 the 1ormal 1indings o1 1act, conclusions o1 laD, and Iudgment. )he
Nevada rule under Dhich the time 1or taAing an a22eal runs 1rom the rendition o1 the courtHs
decision, and not 1rom the time o1 the su@sequent 1iling o1 the 1ormal 1indings and 1ormal
Iudgment, Das held in Coleman v ?oore B#25= 4 Nev #", 24# > 2#!, to @e a22lica@le in a
situation in Dhich a Iudge, a1ter rendering a Iudgment, died and his successor signed the 1ormal
Iudgment. / statute 2roviding that in case o1 the death o1 a district Iudge a1ter rendition o1 a
decision, the succeeding Iudge should maAe an e,amination o1 the decision, and sign and settle the
1indings, and cause Iudgment to @e entered, Das held not to a11ect the time in Dhich an a22eal
might @e taAen a1ter the rendition o1 Iudgment, @ut merel0 to 2rovide hoD a succeeding Iudge
might 2er1ect a Iudgment rendered @0 a 2redecessor since deceased. )he 1olloDing additional
authorit0 is relevant to the issues discussed in this section: C7?78/)3'E $7>>8E?EN) Cases:
$ee /lasAa Nat. BanA v. 8incA, 55 >.2d #-4 B/lasAa #!!=, F 2-. /22ellate court 2ro2erl0
dismissed a22eal on grounds o1 lacA o1 Iurisdiction Dhere notice o1 a22eal Das 1iled 2rior to
issuance o1 1ormal order, and Dhere there Das no reason Dh0 a22ellant could not have amended
notice o1 a22eal a1ter @ecoming aDare that 1ormer order dis2osing o1 case Das actuall0 1iled< onl0
1inal Iudgments are a22eala@le and 1iling notice o1 a22eal is sole necessar0 Iurisdictional ste2.
$toermer v. Edgar, #-4 3ll. 2d 2(!, (4 3ll. Dec. 44-, 4!2 N.E.2d 4-- B#(4=. 6udgment that resolved
su@stantive issue @e1ore trial court Das a22eala@le, though trial court su@sequentl0 signed a
document denominated CIudgment,C stating its conclusions and reasoning 1or earlier order, that Das
not itsel1 an a22eala@le Iudgment. './.?.$. F 5##.-2-< './.?.&. !4.-2. ?artin v. Director o1
&evenue, 44 $.:."d (22 B?o. Ct. /22. $.D. 2--#=. /22eal @rought more than "- da0s a1ter order
- 16
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Das untimel0, notDithstanding that it Das @rought Dithin "- da0s o1 entr0 o1 Iudgment, Dhere order
a22ealed 1rom Bdismissing 2art0 on 2reliminar0 o@Iections in nature o1 demurrer= Das 1inal
a22eala@le order Dhich need not @e reduced to Iudgment. 7.$. Nat. BanA in 6ohnstoDn v. 6ohnson,
5-6 >a. 622, 4(! /.2d (- B#(5=. /22eal taAen 1rom oral decision o1 trial court Dould @e treated
as i1 it had @een timel0 1iled a1ter entr0 o1 su@sequent 1ormal Iudgment Dhich had @een entered
a1ter case had @een remanded to trial court, notDithstanding 1act that 2lainti11 1ailed to a22eal again
1olloDing entr0 o1 Dritten Iudgment Dhere litigation had @een 2rotracted, and it Das clear 1rom
record that trial courtHs oral decision Das intended to @e its 1inal act regarding case. Beauvais v.
Notre Dame 4os2ital, #2- &.3. 2!#, "(! /.2d 6( B#!(=. /22eal @ased on trial courtHs rendering
o1 Dritten C&easons 1or 6udgmentC 1olloDing granting o1 a22lication 1or neD trial Das 2remature
Dhere e11ect o1 granting neD trial Das to sus2end 2reviousl0 rendered and signed Iudgment, and
Dhere Iudgment 1olloDing neD trial had not @een reduced to Driting and signed @0 Iudge as
required @0 state statute. &ead0 v. $un 5il Co., "#5 $o. 2d (4- B8a. Ct. /22. #st Cir. #!5=.
F #25. )ime o1 rendition or entr0 :estHs Ne0 Num@er Digest :estHs Ne0 Num@er Digest, 6udgment
2(-, 2(# / Iudgment record or docAet should a11ord de1inite and relia@le in1ormation as to the time
o1 the rendition o1 a Iudgment.O#P $ometimes a Iudgment is entered as o1 the date Dhen it Das
signed @0 the IudgeO2P or as o1 the date Dhen the Iudgment Das rendered.O"P O+N#P 4errington v.
4eidel@erg, 244 ?iss. "64, #4# $o. 2d !#! B#62=. O+N2P $tate e, rel. 4ar2 v. 'ander@urgh Circuit
Court, 22! 3nd. "5", (5 N.E.2d 254, ## /.8.&.2d ##-( B#4=. O+N"P ?t. 'ernon*:ood@err0 ?ills
v. 7nion $2rings ;uano Co., 26 /la. /22. #"6, #55 $o. !#- B#"4=<46 /m. 6ur. 2d 6udgments F
#25. /s to determination o1 the time o1 entr0, see F #-(. /s to the time 1or 2er1ecting an a22eal as
com2uted 1rom the time o1 rendition or entr0 o1 Iudgment, see /m. 6ur. 2d, /22ellate &evieD F
22. /22eal o1 guilt0 2lea " &oot v. Cit0 o1 8as 'egas, 454 >.2d (4, (4V, (5 Nev. "26, "26V
- 17
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
BNev. ?a0 2!, #6= BN5. 56"-= 4 &oot v. Cit0 o1 8as 'egas, 4" >.2d 2#, 2#V, (4 Nev. 25(,
25(V BNev. /2r -", #6(= BN5. 52((=. &o@erts cites to &oot, as case not reall0 a22lica@le as it
relates to an entirel0 di11erent situation than the case at @ar. &oot concerned the a22eal o1 a guilt0
2lea, not a thoroughl0 o@Iected to and conducted in a sus2ect st0le contested trial.N' $) # D3$)
C) &ule ""< &ule "". /22eals to District Court in criminal matters 1rom 6ustice Court and
?unici2al Court. 4onestl0, the a22roach taAen @0 the +irst 6udicial District Court ma0 @e a more
sound one: &ule "". /22eals to District Court in criminal matters 1rom 6ustice Court and ?unici2al
Court. #. >ursuant to N&$ #(.-#- 1or a22eals 1rom 2roceedings in the 6ustice Court and 2ursuant
to N&$ 266.55 and N&$ 5.-!" 1or a22eals 1rom 2roceedings in the Carson Cit0 ?unici2al Court,
a Notice o1 /22eal in a criminal action tried @e1ore a 6ustice o1 the >eace or the ?unici2al Court
6udge must @e 1iled Dithin #- da0s 1rom the entr0 o1 the Iudgment. 2. /t the time o1 1iling o1 the
Notice o1 /22eal, the a22ellant shall 1ile a request Dith the 6ustice Court or ?unici2al Court that
2roceedings @e transcri@ed. ". >ursuant to N&$ #(.-65 or N&$ 5.-!", the 6ustice Court or
?unici2al Court shall transmit to the ClerA o1 the District Court the transcri2t o1 the case, all other
2a2ers relating to the case and a certi1ied co20 o1 its docAet o1 the case Dithin #- da0s a1ter the
Notice o1 /22eal is 1iled. 4. >ursuant to N&$ #(.-65 or N&$ 5.-!", the a22ellant must 2er1ect his
or her a22eal @0 having the a22eal set 1or hearing @0 the District Court Dithin 6- da0s a1ter the
Notice o1 /22eal is 1iled. 5. )he a22ellant shall 1ile his or her @rie1 Dithin "- da0s a1ter the matter
is set 1or hearing, 2rovided the Dritten transcri2t o1 the 2roceedings has @een 2re2ared and 1iled
Dith the District Court and 2rovided to the 2arties. )he res2ondent shall 1ile his or her o22osing
@rie1 Dithin 2- da0s therea1ter, and an0 re2l0 @rie1 @0 the a22ellant shall @e 1iled Dithin #- da0s
therea1ter. But the :DC& has a rule on the matter too: &ule #. /22eals 1rom munici2al and
Iustice courts. #. /ll a22eals 1rom the munici2al or Iustice courts in criminal cases shall @e set 1or
- 18
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
trial or hearing Dithin 6- da0s o1 the date o1 a22lication 1or setting. / setting @e0ond 6- da0s ma0
@e made onl0 i1 a22roved in Driting @0 the trial Iudge or the chie1 Iudge. 31 a trial setting is
continued @0 order o1 the court, the case shall @e reset Dithin 6- da0s o1 the date o1 the order 1or
continuance. 2. 31 multi2le settings 1or a22eal trials in an0 one court de2artment e,ceed the ca2acit0
o1 that de2artment, settings shall @e made in the designated de2artment scheduled to handle the
over1loD. 31 that courtSs calendar @ecomes 1ull, assignment shall @e made to an0 other availa@le
de2artment. ". /22eals in criminal cases shall @e set 1or trial on )hursda0s and +rida0s, unless the
trial Iudge or the chie1 Iudge grants 2ermission to maAe such settings on other Iudicial da0s. 4. 3n
civil a22eals 1rom the Iustice court, a22ellant shall 1ile Dithin "- da0s a1ter the 1iling o1 a notice o1
a22eal a Dritten @rie1 containing a statement o1 the errors committed in the Iustice court Dith
accom2an0ing authorities Dhich shall not e,ceed 5 2ages. :ithin 2- da0s a1ter the 1iling and
service o1 a22ellantSs @rie1, res2ondent shall 1ile a Dritten ansDering @rie1 Dhich shall not e,ceed 5
2ages. 7nder statute 2roviding that an a22eal shall @e dismissed unless 2er1ected @0 de1endant
Dithin 6- da0s a1ter a22eal is 1iled in IusticeHs court @0 having it set 1or trial, de1endant need not
actuall0 o@tain trial setting Dithin 6-*da0 limit, @ut need onl0 a22l0 1or trial setting Dithin that
time< disa22roving >lanAinton v. District Court, " Nev. 64", 5!2 >.2d 525. N.&.$. #(.-65.
)hom2son v. +irst 6udicial Dist. Court, $tore0 Count0, #(4, 6(" >.2d #!, #-- Nev. "52. 7nder
munici2al statutor0 charter 2rovision that a22eals to district court ma0 @e taAen 1rom an0 1inal
Iudgment o1 munici2al court in same manner as in cases o1 a22eal 1rom Iustice court, and statute
relating to a22eals 1rom Iustice court and requiring 2art0 intending to a22eal to 1ile Dith Iustice and
to serve u2on district attorne0, a notice o1 a22eal, 2art0 desiring to a22eal 1rom Iudgment o1
munici2al court su11icientl0 meets requirements Dhen notice o1 a22eal is 1iled Dith munici2al Iudge
and is served u2on cit0 attorne0 Dho conducted 2roceedings in munici2al court. $t.#4, c. #"2, F
- 19
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2< N.C.8.#2, FF ##"#-, ##"#". $tate e, rel. Dig@0 v. Eighth 6udicial Dist. Court o1 $tate, in and
1or ClarA Count0, #52, 244 >.2d (66, 6 Nev. #(6.
"", 4! N.E.2d 6( B#(5=. :here de1endant Das tried and convicted, and court im2osed
sentence and rendered Iudgment, @ut Dhere clerA 1ailed to enter Iudgment 2ursuant to rule, Court o1
/22eals lacAed a22ellate Iurisdiction. $tate v. 8ee, 562 $.:.2d !4 B?o. Ct. /22. #!(=.5riginal
unsigned minute @ooA entr0 o1 Iudgment Das not a22eala@le, since it did not meet statutor0
requirement that CrenditionC o1 Iudgment means that it @e reduced to Driting, signed and made a
matter o1 record, or 1iled. Eganto11 v. 4erring, #!! $o. 2d 26- B+la. Dist. Ct. /22. 2d Dist. #65=.
4ere, the undersigned, Coughlin, made numerous attemt2s to see that the C6udgment and Court
5rderC here Das a matter o1 record, and the &?C 1ilign o11ice, all the Da0 u2 to #2M#"M##, indicated
it Das not. 2ro2erl0 dismissed. Cornelius v. )u@@esing, 5!6 $.:.2d !5" B?o. Ct. /22. $.D. #!=.
/22eal Dould @e held in a@e0ance and cause remanded to trial court 1or rendition and entr0 o1 1inal
Iudgment Dhere onl0 indication o1 1inal Iudgment on transcri2t Das docAet entr0, and Dhere docAet
entr0 Das st0led in singular although de1endant had @een charged Dith tDo counts o1 2ossession o1
controlled su@stances. $tate v. ;onterman, 565 $.:.2d (-- B?o. Ct. /22. #!(=.
7nder &ev. 8aDs, F !5#", notice o1 a22eal 1rom a conviction and sentence in IusticeHs court
u2on @oth laD and 1act held su11icient. 6ensen v. District Court o1 $eventh 6udicial Dist., in and 1or
Esmeralda Count0, ##6, #6# >. #62, 4- Nev. #"5.< +urthermore, Iurisdiction cannot @e con1erred
u2on an a22ellate court @0 the consent or sti2ulation o1 the 2arties or WW#2"4 their counsel. 6as2er
v. 6eDAes, 5- Nev. #5", 254 >. 6( B#2!=< 3n &e 4anle0Hs Estate, 2" Cal.2d #2-, #42 >.2d 42"
B#4"=. 4oDever, this authorit0 does not a22l0 here. )his is not a sti2ulation o1 2arties situation,
6udge 4oDard maAes his 6udement and 5rder 1o the Court and he gets to decide Dhen it runs 1rom
and Dhen the 2eriod to 1ile a Notice o1 /22eal is measure 1rom. 4e did so here, and in accordance
- 20
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Dith the the 1iling o1 the Notice o1 /22eal in this matter is timel0. N&$ #(.-"- 2rovides that, X)he
Iustice must, Dithin #- da0s a1ter the notice o1 a22eal is 1iled, transmit to the clerA o1 the district
court all 2a2ers relating to the case and a certi1ied co20 o1 his docAet.SC 4ere, the &?C 1ailed to
transmit an accurate &ecord on /22eal. 3ndeed several 1iling @0 the undersigned are missing
entirel0. )here1ore the underl0ing conviction should @e overturned. N&C> 6-Hs Dra1ters Note 2--4
/mendment mentions that : )he revisions to su@division Bc= are technical Dith the e,ce2tion that
the 6*month limit noD starts to run 1rom service o1 notice o1 entr0 o1 the Iudgment rather than Tthe
date o1 renditionU o1 the Iudgment under the 1ormer rule.C 3t leaves to much u2 to the vagaries o1
Dhat ma0 have @een said in court, Dhat a Iudge might cross out later Bas ha22ened here=, Dhat a
Iudge ma0 realiEe 1ive minutes later Dhen the stresses and 2ride one deals Dith in a courtroom
su@side Bas ma0 have ha22ened here, Dhere 6udge 4oDard, to his credit, admitted he Das mistaAen
in @elieving the undersigned 1ailed to shoD u2 1or the original Novem@er #4, 2-## court date=.
)olling, time 1or a22eal ContractorHs 2ost*Iudgment Tmotion to amend orderU quali1ied as a motion
to alter or amend Iudgment, Dhich tolled the time contractor had to 1ile notice o1 a22eal< the motion
Das in Driting, invoAed rule on amendment o1 Iudgments, asAed to vacate the Iudgment o1
dismissal, and a22ended 2roo1 that the charter, 1or Dant o1 Dhich contractorHs suit Das lost, had
@een restored and urged the district court to consider statute, Dhich 2rovided that reinstatement o1
an administrativel0 revoAed limited lia@ilit0 charter related @acA to the date on Dhich the com2an0
1or1eited its right to transact @usiness as i1 such right had at all times remained in 1ull 1orce and
e11ect< disa22roving /lvis v. $tate, ;aming Control Bd., Nev. #(4, 66- >.2d (-, NardoEEi v.
ClarA Co. $chool Dist., #-( Nev. !, (2" >.2d 2(5, and :hitehead v. Norman Na0e &eal Estate, (-
Nev. "(", "5 >.2d "2. // >rimo Builders, 88C v. :ashington, 2-#-, 245 >."d $o long as a
2ost*Iudgment motion 1or reconsideration is in Driting, timel0 1iled, states its grounds Dith
- 21
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2articularit0, and requests a su@stantive alteration o1 the Iudgment, not merel0 the correction o1 a
clerical error, or relie1 o1 a t02e Dholl0 collateral to the Iudgment, there is no reason to den0 it
status as a motion to alter or amend Iudgment, Dhich tolls the time in Dhich a 2art0 has to 1ile
notice o1 a22eal< disa22roving /lvis v. $tate, ;aming Control Bd., Nev. #(4, 66- >.2d (-,
NardoEEi v. ClarA Co. $chool Dist., #-( Nev. !, (2" >.2d 2(5, and :hitehead v. Norman Na0e
&eal Estate, (- Nev. "(", "5 >.2d "2. // >rimo Builders, 88C v. :ashington, 2-#-, 245 >."d
##-. )he undersigned, Coughlin, 1iled tolling motions in this case, there1ore tolling should @e
1ound. >etitionerHs 2ostIudgment motions to amend or maAe additional 1indings o1 1act or to alter or
amend the Iudgment den0ing his 2etition to seal court records Dere Ttolling motions,U and thus,
2etitionerHs notice o1 a22eal 1iled @e1ore trial courtHs dis2osition o1 such motions Das 1iled too earl0
to vest Iurisdiction in the a22ellate court. 3n re Duong, 2--2, 5 >."d #2#-, ##( Nev. 2-. / notice
o1 a22eal 1iled a1ter the timel0 1iling o1 a 2ost*Iudgment tolling motion, @ut @e1ore the 1ormal
dis2osition o1 the motion, is ine11ective and 1ails to vest Iurisdiction in the a22ellate court. ?oran v.
Bonneville $quare /ssociates, 2--#, 25 >."d ((, ##! Nev. 525. )imel0 motion 1or neD trial is a
tolling motion 1or 2ur2oses o1 rule 2roviding that notice o1 a22eal 1iled @e1ore 1ormal dis2osition o1
an0 timel0 2ostIudgment motion shall have no e11ect. &ules Civ.>roc., &ule 5Ba=< &ules
/22.>roc., &ule 4Ba=B2=. Cha2man 3ndustries v. 7nited 3ns. Co. o1 /merica, #4, (!4 >.2d !",
##- Nev. 454. )imel0 motions 1or amendment o1 trial courtHs 1indings, amendment o1 the Iudgment
and neD trial tolled running o1 a22eal 2eriod and rendered ine11ective all notices o1 a22eal Dhich
Dere 1iled @e1ore 1ormal dis2osition o1 the timel0 2ostIudgment motions and thus, trial court erred
in concluding that it lacAed Iurisdiction to entertain the timel0 tolling motions. &ules Civ.>roc.,
&ules 52B@=, 5Ba, e=< &ules /22.>roc., &ule 4Ba=B2=. Cha2man 3ndustries v. 7nited 3ns. Co. o1
/merica, #4, (!4 >.2d !", ##- Nev. 454. $o, ever0thing in this case is a total mess i1 one
- 22
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
considers that the Decem@er #"th, 2-## 1iling @0 the undersigned Das @oth a Notice o1 /22eal and
a tolling motion and then 6udge 4oDard entered an 5rder that ma0 have dis2osed o1 it, @ut he ma0
have entered it so soon a1ter getting it that it suggests and e,treme 2reIudice on his 2art, Dhere the
&eno Cit0 /ttorne0 argua@l0 did not even have an o22ortunit0 to res2ond @e1ore 6udge 4oDard
teeHd o11 on it....then its Dhether the su@squent C$u22lementalC 2leadings @ene1it 1rom a Crelation
@acAC doctrine or Dhether tolling a22lies and Dhether the original or an0 su@sequent Notices o1
/22eal Dere time, 2remature, or even e11ective. NoD m0 head has e,2loded. /nd even i1 6udge
4oDards #2M#5M## 5rder dis2osed o1 the tolling motion, :ell, on #2M#6M## Coughlin 1iled another
Notice o1 /22eal, so this thing argua@l0 ought to go 1orDard, sorr0 ?s. &o@erts, going to have to
earn some o1 the G##2,--- a 0ear in 0our 2ursuit o1 ruining m0 li1e Balright, thatHs dramatic and
lacAs 2ers2ective= 1or the 2rice o1 a cand0@ar Dhile 0ou su@orn the 2erIur0 o1 a trio o1 testosterone
addled mid 2- something AnucAlheads high 1iving each other in the interrogation room video 0ou
2ro2ounded and out in the hallDa0s at trial until 2m at night....@ut its not liAe the &$3C 2olice and
:al*?art, Dhich lease the 2ro2ert0 its located on 1rom those Dho oDn and run the &$3C have a
con1lict o1 interest or an0thing, rightK >lus, no one ever asAed me or ascertained Dhether 3 have
an0 tri@al @lood, so this Iudgment ma0 @e void 1or lacA o1 Iurisdiction as, should that @e the case,
Iursidication is a22ro2riate @e1ore 6udge 'an :alraven, not 6udge 4oDard.
CONCLUSION
&egardless, the C6udgmentC or C5rderC here Das not a22ro2riatel0 served on the undersigned
on Novem@er "-th, 2-##. +urther, the undersigned made man0, man0 calls and Dritten attem2ts
and tri2s to the &?C to o@tain a co20 o1 the Contem2t 5rder, the ;uilt0 6udgment, and the audio
recording o1 the )rial and all Dere either not granted, not 2rovided, or 2rovided in such a dela0ed
manner as to create an undul0 2reIudicial situation adversel0 e11ecting the undersigneds rights
- 23
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
su11icient to im2ermissi@l0 com2romise 1undamentals notions o1 1airness and due 2rocess.
+urther, the 5rder is CrenderedC Dhen 6udge 4oDard sa0s it is CrenderedC, and 6udge 4oDard
clearl0 indicated, on the record, as demonstrated in the audio record, Dhich Dill @e availa@le to the
District Court ultimatel0, the #- da0 deadline 1or 1iling a Notice o1 /22eal Dould not @egin running
until a1ter the " da0 $ummar0 Contem2t 5rderHs three da0 Iail sentence concluded. Damn, this
stu11 is com2licated. $ure it nice to see the government goign hard as a mother to 2rotect lil olH
:al*?art Dhom is rumored to @e the su@Iect o1 a documentar0 a@out hoD the0 have a intricate
s0stem o1 Deasling out o1 their C&eturn >olic0C and retaliating against those Dho call them on it.
AFFIRMATION P(r%(&nt to NRS 2".B.3"3
/lso, this document does not contain an0 social securit0 num@er or other ina22ro2riate material
2ursuant to N&$ 2"B.-"-.
Dated this 6anuar0 "-th, 2-#2
MsM Zach CoughlinQQQQQQQQQQQQQQQQQ
Zach Coughlin, Esq.
N' Bar No. 4!"
#422 E. th $t. %2
&eno, N' (5#2
)ele: !!5*""(*(##(
+a,: 4*66!*!4-2
/ttorne0 1or /22ellant
- 24
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
PROOF OF SER4ICE
3, Zach Coughlin, declare:
5n 6anuar0 "-th, 2-#2, 3, ?r. Zach Coughlin served the 1oregoing document @0 1a,ing and
serving u2on registered e1ilers and de2ositing a true and correct co20 in the 7$ ?ail addressed to:
>/? &5BE&)$, E$R
654N N/D83C, E$R
Reno City Attorney's Office - Criminal Division
P.O. Box 1900 Reno , N !9"0"
P#one N$m%er& ''"(()*0"0
+ax n$m%er& ''"(()*)*0
/ttorne0 1or &es2ondent, Cit0 o1 &eno
*****************************
Zach Coughlin
/;EN) 5+ />>E88/N)
- 25
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
INDEX TO EXHIBITS
5. EXHIBIT 5: COLLECTION OF EMAILED CORRESPONDENCE AND FILING 6ITH
THE RENO MUNICIPAL COURT 7RMC80 One h(n're' &n' )$)t9 one 75-58 #&+e%.
2. EXHIBIT 2: DECLARATION OF ZACHARY B. COUGHLIN ES!.0 E/e:en 7558 #&+e%.
". EXHIBIT ": S&/&r9 $n)or,&t$on )or the 9e&r% 233. &n' 2353 )or De#(t9 Reno C$t9 Attorne9
P&, Ro;ert% E%<. )ro, 222.Tr&n%#&rentNe:&'&.=o,0 One 758 #&+e.
1. EXHIBIT 1: De=e,;er 52th 2355 e,&$/e' )$/$n+ 7&% &(thor$>e' ;9 the RMC $n /$e( o)
)&?$n+8 to the RMC@% reno,(n$re=or'%Areno.+o: th&t %ho(/' ;(t 'oe% not &##e&r
&##ro#r$&te/9 $n the re=or' on &##e&/ =ont&$n$n+ *(%t the e,&$/ =o:er %heet% #ro:$n+ the
&tt&=he' #')@% 2ere re=e$:e' ;9 the RMC &n' there)ore the =ontent% thereo) %ho(/' ;e
&##ro#r$&te/9 #r$nte' #ro:$'e' &n' )$/e' ;9 the RMC to the D$%tr$=t Co(rt r&ther th&n the
$//e+$;/e B)o(r #&+e% #er #&+eB %t9/e the RMC h&% #(t $n the Re=or' on A##e&/0 F$:e 7-8 #&+e%.
-. EXHIBIT -: D$%=o:er9 #ro'(=e' ;9 Reno C$t9 Attorne9 =o,#&re' to re=e$#t o)
B#(r=h&%e'B $te,% ;oth )$/e' $n /e+$;/e )or, 2$th the RMC 9et not $n/('e' $n /e+$;/e )or, $n
the Re=or' on A##e&/0 E$+ht 7C8 #&+e%.
- 26
5>>5$3)35N )5 ?5)35N )5 D3$?3$$ />>E/8
EXHIBIT #1
EXHIBIT #1
F I L E D
Electronically
01-30-2012:04:48:12 PM
Clerk of the Court
records request for incident report urgent please
From: Zach Coughlin (zachcoughlin@hotmail.com)
Sent: Tue 10/04/11 3:10 PM
To: renomunirecords@reno.gov
1 attachment
records request to reno city attorneys office oct 4.pdf (66.5 KB)
Zach Coughlin
121 River Rock St.
Reno, NV 89501
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not
the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you
have received this document in error and that any review, dissemination, copying, or the taking of any action based on the
contents of this information is strictly prohibited.
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=4b...
1 of 47 1/29/2012 8:20 PM
records request
CONFIDENTIALITY NOTICE
This message is confidential, intended only for the named recipient(s) and may contain information that is
privileged, work product or exempt from disclosure under applicable law. If you are not the intended recipient(s),
you are notified that any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on
the contents of this information is prohibited and may be unlawful. If you receive this message in error, or are not
the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any copies in
any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client,
work product, or other applicable privilege.
Sent: Tue 10/04/11 4:41 PM
2 attachments
RMC subpoena.pdf (67.8 KB) , RECORD_REQUEST_Zach Coughlin to RMC.pdf (20.2 KB)
2 of 47 1/29/2012 8:20 PM
Zach Coughlin
121 River Rock St.
Reno, NV 89501
Sincerely,
Zach Coughlin
U.S.C. 2510-2521, and may contain confidential information intended for the specified individual (s) only. If you are not the
intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have
received this document in error and that any review, dissemination, copying, or the taking of any action based on the contents
of this information is strictly prohibited.
3 of 47 1/29/2012 8:20 PM
Reno Municipal Court appointment of counsel
Sent: Mon 11/28/11 11:42 AM
To: ltaitel@sbcglobal.net; renomunirecords@reno.gov
Dear Mr. Taitel,
I understand you have been assigned to represent me in the Reno Municipal Court trespass Complaint against
me. Please note that my address has recently changed to:
Zach Coughlin
817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

I have recently been evicted and it has caused enormous upheaval to my life, and I am indigent, as such, I believe a
continuance is necessary and ask that you seek one for the December 13th, 2011 "trial" that I only became aware of through
calling the Reno Municipal Court. Also, please provide me a copy of any motions or pleadings you have filed on my behalf
and any documentation that you have been provided by the court, opposing counsel, or anyone else. I prefer such
documentation be emailed, but I realize that may not be possible. I would like to obtain a copy of the Complaint and
Discovery, including the probable cause sheets and any witness statements as soon as possible.

Sincerely,

Zach Coughlin
4 of 47 1/29/2012 8:20 PM
records request
FW: temporary address change and instruction to pursue a continuance
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: Mon 11/28/11 2:30 PM
1 attachment
RECORD_REQUEST_FORM_2010[1] rmc trespass 11 13 11 records request 11-22185.pdf (20.8 KB)
Zach Coughlin, 817 N. Virginia St. #2
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
5 of 47 1/29/2012 8:20 PM
Sent: Tue 11/29/11 3:14 PM
To: robertsp@reno.gov; renomunirecords@reno.gov
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,
I am forwarding this apology I sent to Judge Howard in response to his remonstration responding to my email to
him, in an abundance of caution to avoid ex parte communications with the court, outside your presence. Please
also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I am hereby serving on you,
invoking the 21 day safe harbor, with a reservation that any misconduct you commit in the court's presence may
be punished sua sponte or subject to contemporaneous sanctions requests, particular with regard to you blase
dismissal of the official misdoncut, malicious prosecution, 42 USC Sec 1983 deprivations of civil rights under
color of state law and all those other things your office and Hartshorn, et all have been sued for over the years.

Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
Licensed in Nevada and USPTO
privilege.

From: zachcoughlin@hotmail.com
To: howardk@reno.gov
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800
6 of 47 1/29/2012 8:20 PM
request of cd of trial in 11 CR 22176 2I

Zach Coughlin,
Sent: Thu 12/08/11 4:00 PM
Hello, I am writing to request a copy of the cd of the record of trial in 11 CR 22176 2I in addition to a copy of the Contempt
Order and any other orders made in that matter, in addition to a copy of the docket.

Please email these to me if possible. I will agree to pay the copying costs or the paper documents or the audio cd/dvd. I
need these as soon as possible please.
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
7 of 47 1/29/2012 8:20 PM
REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER
DOCUMENTATION URGENT PLEASE
privilege.
Sent: Thu 12/08/11 5:45 PM
1 attachment
RECORD_REQUEST_FORM_2010[1] trial cd and orders to RMC 12 8 11 final.pdf (441.5 KB)

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
8 of 47 1/29/2012 8:20 PM
signed REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER
DOCUMENTATION URGENT PLEASE
privilege.
Sent: Thu 12/08/11 5:56 PM
1 attachment
RECORD_REQUEST_FORM_2010[1] trial cd and orders to RMC 12 8 11 signed.pdf (446.2 KB)
I am resending the Records and REcording of Trial request form, SIGNED, just in case that is necessary.

Thank You,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
9 of 47 1/29/2012 8:20 PM
privilege.

Subject: REQUEST FOR RECORDS CD/DVD OF TRIAL AND OTHER DOCUMENTATION URGENT PLEASE
Date: Thu, 8 Dec 2011 17:45:27 -0800

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
10 of 47 1/29/2012 8:20 PM
RMC said I could file this by email
privilege.
Sent: Mon 12/12/11 7:28 PM
1 attachment
12 11 11 final motion for new trial city of reno v coughlin RMC 11 CR 22176.pdf (12.9 MB)
Zach Coughlin, Esq.
Reno, NV 8950
fax: 949 667 7402
11 of 47 1/29/2012 8:20 PM
Motion for New Trial Etc. in RMC 11 CR 22176
privilege.
Sent: Mon 12/12/11 7:40 PM
To: fiskm@reno.gov; renomunirecords@reno.gov
1 attachment
RMC 11 CR 2217 part two Exhibit 1 pages 1-300 of Motion for New trail from 12 12 2011.pdf (8.6 MB)
I received approval to file by email from RMC
This is the second file in the filing. Please note, the file name of the attachment should actually have the correct
case number of RMC CR 22176. It is missing the 6 on the end in the file name of the attachment
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
12 of 47 1/29/2012 8:20 PM
RMC 11 CR 22176 part four Exhibit 1 pages 601-701 of Motion for New
trail from 12 12 2011 ey
privilege.
Sent: Mon 12/12/11 7:57 PM
1 attachment
RMC 11 CR 22176 part three Exhibit 1 pages 301-600 of Motion for New trail from 12 12 2011.pdf (9.7
MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

13 of 47 1/29/2012 8:20 PM
Sent: Mon 12/12/11 8:23 PM
1 attachment
RMC 11 CR 22176 part four Exhibit 1 pages 601-701 of Motion for New trail from 12 12 2011 ey.pdf
(11.8 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
Sent: Mon 12/12/11 8:29 PM
1 attachment
(14.4 MB)
14 of 47 1/29/2012 8:20 PM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

Subject: Motion for New Trial Etc. in RMC 11 CR 22176
Date: Mon, 12 Dec 2011 19:57:50 -0800
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
15 of 47 1/29/2012 8:20 PM
audio of the November 30th Trial in Judge Howards court
privilege.

Sent: Mon 12/12/11 9:56 PM
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1031&parid=root
Maybe that will be easier, that is where the exculpatory video evidence is sent to you as well, a continuation of
exhibit one. I appreciate the RMC allowing me to file via email this way as sometimes my fax service is clunky.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
16 of 47 1/29/2012 8:20 PM
records request
privilege.
Sent: Tue 12/13/11 2:26 PM
1 attachment
(11.8 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
17 of 47 1/29/2012 8:20 PM
Sent: Tue 12/13/11 4:02 PM
To: renomunirecords@reno.gov; fiskm@reno.gov
2 attachments
RECORD_REQUEST_FORM walmart RMC 11 CR 22176 IC 110627 trial cd and orders to RMC 12 8 11
signed.pdf (453.4 KB) , RECORD_REQUEST_FORM_2010[1] rmc trespass 11 13 11 records request 11 CR
22185 City of Reno v Coughlin signed.pdf (510.9 KB)
Let this writing also werve as the cover letter called for in RMCR 5(D):
attorney's name,: Zach Coughlin, Esq.
the firms name: Zach Coughlin, Esq.
address, 817 N. Virginia St. #2
fax number 949 667 7402
telephone number: 775 229 6737
the attorneys state bar number: NV Bar No: 9473
18 of 47 1/29/2012 8:20 PM
12 11 11 Defendants Motion for New Trial, Set Aside, Vacate Judgment/Conviction of underlying crime and
Contempt in Court's Presence finding/ IFP Petition/ Motion for Reconsideration/Notice of Appeal, Case Statment
in case: city of reno v coughlin RMC 11 CR 22176; Records Request form Defendant and Request for
Transcription at Public's Expense and Request for a copy of the audio recording of the Trial of 11 30, 2011 1:45
pm to end in RMC 11 CR 22176.
Additionally, I never received service of any Notice of Appearance nor a Motion to Withdraw by Lew Taitel, Esq.
the attorney appointed to represent me as required by RMCR Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of
their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the
court and serve the City Attorney with the same. The court may rule on
the motion or set a hearing."
Further, RMCR state: "Rule 5: Motions by Facsimile
A. All rules and procedures that apply to motions filed in person at the
court shall also apply to motions filed by facsimile, except as otherwise
specified in this rule.
B. All persons are eligible to use motion-by-facsimile procedures.
C. All motions filed by facsimile must be accompanied by a cover sheet
which must include the persons name, address, fax number and
telephone number.
D. All facsimile motions filed by an attorney must include the attorney's
name, the firms name, address, fax number and telephone number. In
addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
E. All motions filed by facsimile must be accompanied by proof of service.
Service may be accomplished by facsimile when the receiving party is a
governmental agency, an attorney, or with the consent of the receiving
party. If service of the motion is accomplished by facsimile the 3-day
allowance for mailing shall not be computed into the time for response.
F. A defense attorney filing a motion in the first instance must also file a
proper authorization to represent.
G. Any motion received by the court after 4:30 p.m. or on a non-court day
shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except
for good cause. A motion or stipulation for continuance must state the reason
therefore and whether or not any continuance has previously been sought or
granted."
19 of 47 1/29/2012 8:20 PM
fax number 949 667 7402
And: "Rule 9: Appeals to District Court
Except as otherwise provided in NRS 177.015 a defendant in a criminal action
tried before a Municipal Court Judge may appeal from the final judgment
therein to the Second Judicial District Court, at any time within 10 days from
the date that judgment is rendered."
Judge Howard informed me during his oral pronounce of his Contempt Order and Guilty Verdict on 11 30,2011
that he would afford me an additional 3 non judicial days to file a Notice of Appeal or any other Motion, Request
for Reconsideration, or other Motion seeking relief from his 11 30 2011 rulings on account of his sua sponte, with
no possibility of Stay or prior judicial review ordering his Marshalls to slam be into handcuffs and throw me into
Jail, kind of like in Houston v. 8th Judicial District Court, escept Judge Howard didn't cool down like Judge
Pomeranz did and Houston wasn't defending a criminal charge that carred a possibility of incarceration of
substantial length after being denied his 6th Amendment Right to Counsel. I am formally complaining about
Judge Howard;s conduct in that regard, please place a copy of this in his personnel file and let me know whether
you think a Complaint to the Judicial Discipline Commission would be appropriate, in your professional opinion.
I filed my Notice of Appeal in 11 cr 22176 yesterday with the RMC via email, as previously given permission to do
by the RMC. To the extent that was ineffective, let this writing act as a Notice of Appeal and agreement to pay
all charges required for such.
PROOF OF SERVICE:
I emailed a copy of this to Pam Roberts for the Plaintiff City of Reno on this date, a true and correct copy and
further email her a copy of all the 12 11 11 MOtion for New Trial, etc. yesterday to:
Pamela G Roberts
Company: Reno City Attorney's Office - Criminal Divison
Address: P.O. Box 1900
Reno
, NV
89505
Phone Number: 775-334-2050
Fax number: 775-334-2420
Email: robertsp@reno.gov
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
20 of 47 1/29/2012 8:20 PM
IFP/ FINANCIAL INQUIRY APPLICATION
privilege.
Sent: Wed 12/14/11 12:22 AM
To: ballardd@reno.gov; renomunirecords@reno.gov
2 attachments
Coughlin IFP and Financial Inquiry Application RMC 11222011 11 CR 26405 2I.pdf (381.9 KB) , Coughlin
IFP and Financial Inquiry Application RMC 11222011 11 CR 22176 2I.pdf (372.0 KB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
ZachCoughlin@hotmail.com
Nevada Bar No: 9473
Ms. Ballard,
Please note, the gentleman I worked with at the filing office counter today informed me there were no
appeal fees, bonds, or other charges that I could pay (including transcription costs) as "all charges are
21 of 47 1/29/2012 8:20 PM
RE: Message left on 12/13/2011
being taken from" my bail in the respective matters. Please email me the audio from the November
20th,2011 Trial in 11 cr 22176 2I and proof of service of any Contempt Order or Guilty Verdict/Order
in that matter. Please file this as well as a Opposition to Any Motion to Continue Trial in 11 cr 26405,
dept 2, and a Motion to Set Aside or Vacate any Order Granting Continuance in response to such an
Order Granting Continuance. Please email, fax, or mail me a copy of the Notice of Appearances by
both Taitel and Puentes and the Motion and Order Granting Withdrawal of Taitel, if it exists. I would
like a copy of the docket in both 11 CR 26405 2I and 11 CR 22176, despite your informing me today
that I would need to subpoena the docket to have any chance of seeing it and that I would not be
provided access to documents in the public record, including Orders in both of these cases.
Sincerely,
Zach Coughlin
privilege.
Sent: Wed 12/14/11 6:52 PM
To: roperj@reno.gov; fiskg@reno.gov; ballardd@reno.gov; renomunirecords@reno.gov

22 of 47 1/29/2012 8:20 PM

23 of 47 1/29/2012 8:20 PM
24 of 47 1/29/2012 8:20 PM

25 of 47 1/29/2012 8:20 PM

26 of 47 1/29/2012 8:20 PM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.

Date: Wed, 14 Dec 2011 16:26:47 -0800
From: RoperJ@reno.gov
To: ZachCoughlin@hotmail.com
Subject: Message left on 12/13/2011
Mr. Coughlin,
I received your message that you left on my phone on December 13, 2011 in regards to a complaint against Marshal
Menzel. The Marshal Division takes all citizen complaints seriously and investigates all complaints received in writing or
verbally. However, I would need more information from you prior to moving forward with an investigation. I encourage
you to come to the court to obtain a statement form, or contact me directly should you wish to pursue this matter. As to
your request to obtain a copy of Marshal Menzel's personnel file, I am unable to provide that to you without a valid
subpoena or warrant.
27 of 47 1/29/2012 8:20 PM
RMC 11 CR 22176

You also stated you were attempting to obtain a copy of your J udgement of Conviction from Dept. 4, specifically Veronica
Lopez, you can reach her at 326-6673. I am aware that a copy of your J udgement of Conviction was provided to you and
booked into your property on the night you were arrested. You are entitled to another copy should you wish.

Thank you,
J ustin Roper
Chief Marshal/Department of Alternative Sentencing
Reno Municipal Court
775-334-1254
Sent: Thu 12/15/11 11:59 PM
To: howardk@reno.gov; ballardd@reno.gov; robertsp@reno.gov; fiskm@reno.gov;
renomunirecords@reno.gov; lopezv@reno.gov
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
DATE: December 15, 2011
TO: .RMC et al
FAX NO: RMC approved email ling
28 of 47 1/29/2012 8:20 PM
RE: . City of reno v Coughlin RMC 11 CR 22176 2I
Motion for New Trial,Notice of appeal and other issues
Dear RMC,

I do not mean to be disrespectful in contacting the court via email. I have been so stamped
out by the events of the last few months that its all I can do to try to protect my rights to get
information and media to the court in my attempts to access justice. Veronica Lopez told me on
the phone on Monday of this week that she would fax me a copy of the Order and Contempt finding from the 11
30, 2011 Trial, yet I have not received any such fax. I have not received any order in any form, not on my release
from the 3 days summary incarceration, not ever. The RMC confirmed there has been no Notice of Entry of any
order in their docket or anything, etc.

I believe the following should be added to record and presents a strong argument for a
conflict of interest or other 60(b) basis for setting aside the verdict and contempt Order in
RMC 11 CR 22176 2I. I did not plead guilty in that case, and any RMC record that
suggests that is completely inaccurate. Please let me know if your records indicate I plead
guilty in that matter. Further, I have never been provided a copy of the Guilty Verdict/Order
in this matter, I requested on to be emailed to me and sent in the USPS mail. Please serve
me a copy of the order, preferably by email and USPS mail. Further, the "RMC's official
court transcriptionist" informed me yesterday that she could not quote me or accept an
money from me for the transcript on appeal. Further I have been told by court staff that I
would never be provided access to the audio recording of the Trial of 11 30, 2011. I believe
I have a right to it, and need it on an exigent basis in connection with the various motions I
have, will, or intend to to file challenging the decision in this case. The RMC filing office
informed me there has been no Notice of Entry of Order in this matter at this point.

T
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
29 of 47 1/29/2012 8:20 PM
FW: RMC 11 CR 22176
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Fri 12/16/11 12:00 AM
1 attachment
emergency filing rmc 11 cr 22176 12 15 11.pdf (260.9 KB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
30 of 47 1/29/2012 8:20 PM
Nevada Bar No: 9473
privilege.
To: howardk@reno.gov; ballardd@reno.gov; robertsp@reno.gov; fiskm@reno.gov; renomunirecords@reno.gov;
lopezv@reno.gov
Subject: RMC 11 CR 22176
Date: Thu, 15 Dec 2011 23:59:45 -0800
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
31 of 47 1/29/2012 8:20 PM
TO: .RMC et al
FAX NO: RMC approved email ling
RE: . City of reno v Coughlin RMC 11 CR 22176 2I
Motion for New Trial,Notice of appeal and other issues
Dear RMC,



T
32 of 47 1/29/2012 8:20 PM
emergency filings
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Fri 12/16/11 7:55 AM
To: renomunirecords@reno.gov; robertsp@reno.gov
2 attachments
12 16 11 emergency filing with fax cover sheet rmc 11 cr 22176.pdf (330.0 KB) , fax cover sheet and
notice of denial of service clarification motion.pdf (202.1 KB)
33 of 47 1/29/2012 8:20 PM
FW: 121 River Rock
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Sat 12/17/11 12:15 AM
To: ballardd@reno.gov; howardk@reno.gov; robertsp@reno.gov; renomunirecords@reno.gov; hazlett-
stevensc@reno.gov; puenteslaw@aol.com
Unbelievable. The idea that exculpating evidence is being withheld under some "lien" is transmitted into the
universe, next thing I know, my law office is broken in to and the Richard B. Hill gang is stil asserting a lien on
property that was stolen, in my opinion, as a result of their own negligence, leaving a window air conditioner unit
in a window, without even putting a window jam between the top of the sill and lower pain, facing a sidewalk a
block from the Lakemill Lodge and across from City Center Apartments, great. Great. And I still have not been
faxed or appropriately served the Order and Contempt Order I was told would be faxed to me.
Zach Coughlin, Esq.
34 of 47 1/29/2012 8:20 PM
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.

To: cdbaker@richardhillaw.com; knielsen@richardhillaw.com; sgallagher@richardhillaw.com
Subject: RE: 121 River Rock
Date: Wed, 14 Dec 2011 15:43:38 -0800
Dear Mr. Baker,
I drove by the property recently and saw you had added boarding up the front door on very, very recently.
Unfortunately, your client and your firm, despite billing up some $1,060 for "securing" the property on top of
charging $900 for storage for what could fit inside a 10x20 foot storage shed, never once providing an inventory,
and contributing to a wrongful arrest and defamation causing me and my clients great damage, failed to take
even basic steps to secure the property, despite my making numerous written requests that you do so, including,
but not limited to, taking the damn window unit air conditioner out of the window facing the sidewalk on the
side of the house very close to the damn Lakemill Lodge, or even putting a strong stick in between the bottom
sliding window pain and the top of the sill to prevent someone from simply pushing in the window unit air
conditioner and pushing the window up to gain access. Further, a blanket that was on the orange circular couch
is clearly in the flower bed in front of the house. Additionally, there are reports that someone with your office
gave someone a mattress from the inventory of Coughlin Memory Foam (a Nevada licensed business located at
35 of 47 1/29/2012 8:20 PM
the property) and an expensive mattress platform has clearly been damaged and placed in the flower bed as
well, in addition to one of the wooden porch shades being removed from the front porch. You and your client
are, of course, liable for all of this.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
From: cdbaker@richardhillaw.com
To: zachcoughlin@hotmail.com
CC: rhill@richardhillaw.com
Subject: 121 River Rock
Date: Wed, 14 Dec 2011 13:50:02 -0800
Mr. Coughlin:

The River Rock property has been broken into. We believe the break-in occurred sometime on Monday,
36 of 47 1/29/2012 8:20 PM
emergency
December 12, 2011. There appear to be items missing, including the TV in the living room, perhaps a computer
monitor, and perhaps some stereo equipment. I cant tell what else. The contents of the residence appear to
have been rifled through.

I am providing you with this information as a courtesy. This email does NOT constitute permission for you to go
to the River Rock property.

Casey D. Baker, Esq.
Richard G. Hill, Chartered
652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858
Email: cdbaker@richardhillaw.com

CONFIDENTIAL: ATTORNEY WORK PRODUCT; ATTORNEY-CLIENT PRIVILEGE
This e-mail may contain legally privileged or confidential information. If you are not the intended recipient, please do not read, copy, use, or disclose this
communication to anyone other than the intended recipient. If you have received this message in error, please notify the sender and delete the email message from
your system. Thank you.
Circular 230 Notice.
To ensure compliance with requirements imposed by the IRS, we informyou 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: Mon 12/19/11 4:32 PM
supplement to motion to set aside all orders, see attached exhibit, there is no initialing on
the filestampe for the order on the 11 30th, 2011
Tom said there was no docket entry or record of anything as of 12 13 11, i wans't provided copy of discovery for
over 30 days after arrest, rmc said it didn't have pc and witness satements but rec'd date indicates otherwise,
potentially, release sheets fromjail property inventory does not show 11 30 11 order, I declare under penalty of
37 of 47 1/29/2012 8:20 PM
I will fax this to Ms. Roberts and the RMC as well, this is a courtesy copy
perjury i did not refuse any order or the chance to have a physical copy of one.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Mon 12/19/11 5:15 PM
1 attachment
RMC 11 CR 22176 12 19 11 filing with 3 exhibits.pdf (9.1 MB)
Zach Coughlin, Esq.
38 of 47 1/29/2012 8:20 PM
no reply from Transcriptionist
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Wed 12/21/11 12:02 AM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
39 of 47 1/29/2012 8:20 PM
Nevada Bar No: 9473

Dear RMC,
It is my understanding the J udge Howard's order regarding email does not extend to the
address to which I am sending this correspondence: renomunirecords@reno.gov which is
the email address filing office supervisor Donna Ballard indicated to me was acceptable for
sending correspondence and filings to the RMC in lieu of faxes. I am writing because the
email address I was provided for RMC "official transcriptionist" Pam Longoni yielded a
"return to sender/failed transmission" message when I wrote to the email address provided
for her: plongoni@charter.net. Further, please see the forwarded email below that I sent to
Ms. Longoni. I have not received a return call from her regarding my recent messages to
her. I was told by a RMC filing office counter employee that I must get the transcript
through Ms. Longoni, as she is the "official transcriptionist" for the RMC. Please confirm
that I am no able to have another certified court reporter or transcriptionist create the
official transcript and indicate by what date this must be done, how it must be done, etc.

I was told by RMC filing office staff, including Ms. Ballard, that the RMC would not accept
any filings fees, bonds, or any other payments from me in relation to the underlying case 11
CR22176 2I or the appeal of that matter given that the RMC was holding the bail money I
paid into the court. If this is not the case or if I must pay anything into the RMC to ensure
that my appeal goes forward, please indicate as much in writing and with particularity. If I
am able to use any other transcriptionists and or the RMC has a list of such with contact
information, please provide such in writing.

Sincerely,

/s/Zach Coughlin
Zach Coughlin, Defendant/Appellant
40 of 47 1/29/2012 8:20 PM
privilege.

To: plongoni@charter.net
Subject: where to pay and how much
Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,
I have left you several messages. I wish to pay whatever it is I have to pay to get this
appeal transcript going and to preserve all my rights to review of the decision in RMC 11 cr
22176. Further, I would like a copy of the audio from the hearing as soon as possible.
Please provide specific detailed instructions as to how to pay and how much and anything
else I need to do.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
41 of 47 1/29/2012 8:20 PM
proof of insurance and registration Affidavit/Declaration and supporting
documentation
privilege.
Sent: Mon 1/09/12 5:58 PM
To: renomunirecords@reno.gov; renodirect@reno.gov
1 attachment
Zach Coughlin license plate 838NER proof of insurance and registration for citations 544281 and
r47190389731.pdf (1737.4 KB)
Dear Reno Municipal Court Clerk's Office,

My name is Zachary B. Coughlin.
My vehicle and myself were appropriately insured, as verified by the attached Proof of Insurance for
my USAA automobile insurance at the time of both Traffic Citations No's: 544281 and R47190389731.
Copies of both citations are attached as well. My vehicle, at the time of both citations, was in
compliance with Nevada law with regard to vehicle registration. A true and correct copy of this
Affidavit and the attached copies of Traffic Citations No's: 544281 and R47190389731 and a true and
correct copy of the Proof of Insurance for the time of both citations from my USAA automobile
insurance (Policy Number 0098527 96C 7104 3) and a true copy of my DMV automobile Registration
Certificate for both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this Declaration under penalty of perjury
pursuant to NRS 199.145.

42 of 47 1/29/2012 8:20 PM
Please find attached a 6 page pdf with this Affidavit/Declaration and the accompanying copies of the
two citations and the proof of insurance at the time and date of both citations and the same for the
registration for the vehicle. I am disputing the "failure to come to a complete stop" part of the citation
in 544281 and understanding that I have a hearing in Reno Municipal Court on 2 6 12 at 8:30 am in
that regard, please correct me if that is not the correct date and time.

Also, I have called several times and keeping leaving messages about disputing the following parking
tickets, and do not believe any "additional fines" should have attached to the base fine where I have
communicated that I am disputing them and have not receive a response with regard to the date and
time of my hearing to dispute them:
Citation Details
Citation Number: 020146724
Amount Due: $60.00
Issue Date: 12/03/2011 10:30:00
Plate Number: 838NER
State: NV
Related Citations
We have found the following additional outstanding citations for this license plate
number. Please check the box next to each additional citation that you would like to pay
for at this time.
Citation Number Issue Date Amount Due
020145322 11/03/2011 03:20:00 $55.00

Sincerely,

43 of 47 1/29/2012 8:20 PM
debt validation documentation request and dispute letter under FDCPA
to City of Reno et al
Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
** Notice** This message and accompanying documents are covered by the electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and may
contain confidential information intended for the specified individual (s) only. If you are not the intended recipient or an agent responsible for delivering it
to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, copying, or the taking
of any action based on the contents of this information is strictly prohibited. This message is confidential, intended only for the named
recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable
law. If you are not the intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If you receive this message
in error, or are not the named recipient(s), please notify the sender, delete this e-mail from your computer, and destroy any
copies in any form immediately. Receipt by anyone other than the named recipient(s) is not a waiver of any attorney-client, work
product, or other applicable privilege.
Sent: Mon 1/09/12 6:09 PM
To: renodirect@reno.gov; renomunirecords@reno.gov
Dear City of Reno,
This writing is written notice to you that I dispute the debt your office and the City of Reno
and or the Reno Municipal Court has recently sent me, alleging that I owe some debt for
either parking tickets and or traffic citations. Further, I request verification and
documentation in support of your contention that I owe such a debt pursuant to the Fair
Debt Collection Practices Act.

Sincerely,
44 of 47 1/29/2012 8:20 PM
Zach Coughlin1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402

To: renomunirecords@reno.gov; renodirect@reno.gov
Subject: proof of insurance and registration Affidavit/Declaration and supporting documentation
Date: Mon, 9 Jan 2012 17:58:47 -0800
Dear Reno Municipal Court Clerk's Office,

My name is Zachary B. Coughlin.
My vehicle and myself were appropriately insured, as verified by the attached Proof of Insurance for
my USAA automobile insurance at the time of both Traffic Citations No's: 544281 and R47190389731.
Copies of both citations are attached as well. My vehicle, at the time of both citations, was in
compliance with Nevada law with regard to vehicle registration. A true and correct copy of this
45 of 47 1/29/2012 8:20 PM
Affidavit and the attached copies of Traffic Citations No's: 544281 and R47190389731 and a true and
correct copy of the Proof of Insurance for the time of both citations from my USAA automobile
insurance (Policy Number 0098527 96C 7104 3) and a true copy of my DMV automobile Registration
Certificate for both 2011 and 2012 is attached hereto.
I attest that the assertions contained herein are true and make this Declaration under penalty of perjury
pursuant to NRS 199.145.

Please find attached a 6 page pdf with this Affidavit/Declaration and the accompanying copies of the
two citations and the proof of insurance at the time and date of both citations and the same for the
registration for the vehicle. I am disputing the "failure to come to a complete stop" part of the citation
in 544281 and understanding that I have a hearing in Reno Municipal Court on 2 6 12 at 8:30 am in
that regard, please correct me if that is not the correct date and time.

Also, I have called several times and keeping leaving messages about disputing the following parking
tickets, and do not believe any "additional fines" should have attached to the base fine where I have
communicated that I am disputing them and have not receive a response with regard to the date and
time of my hearing to dispute them:
Citation Details
Citation Number: 020146724
Amount Due: $60.00
Issue Date: 12/03/2011 10:30:00
Plate Number: 838NER
State: NV
46 of 47 1/29/2012 8:20 PM
Related Citations
We have found the following additional outstanding citations for this license plate
number. Please check the box next to each additional citation that you would like to pay
for at this time.
Citation Number Issue Date Amount Due
020145322 11/03/2011 03:20:00 $55.00

Sincerely,

Zach Coughlin
1422 E. 9th St. #2
RENO, NV 89512
tel: 775 338 8118
fax: 949 667 7402
47 of 47 1/29/2012 8:20 PM
where to pay and how much

Sent: Fri 12/16/11 10:44 PM
Dear Ms. Longoni,
I have left you several messages. I wish to pay whatever it is I have to pay to get
this appeal transcript going and to preserve all my rights to review of the decision in
RMC 11 cr 22176. Further, I would like a copy of the audio from the hearing as
soon as possible. Please provide specific detailed instructions as to how to pay and
how much and anything else I need to do.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

** 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.

Page 1of 1 Hotmail Print Message
1/30/2012 http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=1198565f-dbcf-4a36-...
Fwd: Attached Image / Subpoena
RE: Attached Image / Subpoena
From: Donna Ballard (BallardD@reno.gov)
Sent: Tue 11/29/11 3:22 PM
1 attachment
0660_001.pdf (28.7 KB)

-----Original Message-----
From: "MUNI CT 1st Floor Clerks" <canon@reno.gov>
To: "DONNA" <ballardd@reno.gov>
Date: Tue, 29 Nov 2011 16:14:15 -0800
Subject: Attached Image

Donna Ballard
Senior Court Specialist
1 South Sierra Street
Reno, Nevada 89501
(775)334-3101
Sent: Tue 11/29/11 3:53 PM
To: Zach Coughlin (zachcoughlin@hotmail.com)
I am so sorry, I must have misunderstood.
These must be served and the affidavit portion completed before they can be file stamped in.
Thank you,
Donna
From: Zach Coughlin <zachcoughlin@hotmail.com>
To: <ballardd@reno.gov>
Date: Tue, 29 Nov 2011 15:48:31 -0800
Subject: RE: Attached Image / Subpoena
Dear Ms. Ballard,
Thank you sending these and agreeing to stamp and emal them back to me
today, very, very much appreciate.
Sincerely,
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=f54...
1 of 5 1/29/2012 9:39 PM
Zach Coughlin
email is the best way to contact me, having phone issues today.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
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
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.

Date: Tue, 29 Nov 2011 15:22:14 -0800
From: BallardD@reno.gov
Subject: Fwd: Attached Image / Subpoena

Date: Tue, 29 Nov 2011 16:14:15 -0800

Donna Ballard
Reno, Nevada 89501
2 of 5 1/29/2012 9:39 PM
Fwd: Attached Image
Re: IFP/ FINANCIAL INQUIRY APPLICATION
(775)334-3101
Donna Ballard
Reno, Nevada 89501
(775)334-3101
Sent: Tue 11/29/11 4:47 PM
1 attachment
0661_001.pdf (42.9 KB)

Thank you. I am taking it up to the Department now.
Donna
Date: Tue, 29 Nov 2011 17:42:28 -0800

Donna Ballard
Reno, Nevada 89501
(775)334-3101
Sent: Wed 12/14/11 12:09 PM
To: Zach Coughlin (zachcoughlin@hotmail.com)
I did not inform you that you would need a subpoena to get a copy of the docket. I advised you that your
records request will be sufficient for copies of documents as public record and did not specify specific
documents.
I am forwarding this email to Department 2, Department 4 and the Chief Marshal for further action.
3 of 5 1/29/2012 9:39 PM

To: <ballardd@reno.gov>, <renomunirecords@reno.gov>
Date: Wed, 14 Dec 2011 00:22:07 -0800
Subject: IFP/ FINANCI AL INQUIRY APPLI CATION

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

Ms. Ballard,
Please note, the gentleman I worked with at the filing office counter today informed me there were no appeal
fees, bonds, or other charges that I could pay (including transcription costs) as "all charges are being taken
from" my bail in the respective matters. Please email me the audio from the November 20th,2011 Trial in 11 cr
22176 2I and proof of service of any Contempt Order or Guilty Verdict/Order in that matter. Please file this as
well as a Opposition to Any Motion to Continue Trial in 11 cr 26405, dept 2, and a Motion to Set Aside or
Vacate any Order Granting Continuance in response to such an Order Granting Continuance. Please email,
fax, or mail me a copy of the Notice of Appearances by both Taitel and Puentes and the Motion and Order
Granting Withdrawal of Taitel, if it exists. I would like a copy of the docket in both 11 CR 26405 2I and 11 CR
22176, despite your informing me today that I would need to subpoena the docket to have any chance of
seeing it and that I would not be provided access to documents in the public record, including Orders in both
of these cases.

Sincerely,

Zach Coughlin
4 of 5 1/29/2012 9:39 PM

Donna Ballard
Reno, Nevada 89501
(775)334-3101
5 of 5 1/29/2012 9:39 PM
Sent: Tue 11/29/11 3:48 PM
To: ballardd@reno.gov
4 attachments
RMC subpoena Ellis Walmart Manager and loss prevention manager.pdf (42.7 KB) , RMC subpoena
Janice store clerk walmart arrest receipt cashier 2nd St. 89501 Walmart.pdf (44.3 KB) , RMC subpoena
Store Manager Brian Bain 2nd st Walmart Reno and LP supervisor 2nd St. 89501 Walmart.pdf (43.3 KB) ,
RMC subpoena fill in the blank for name stylein city of reno v coughlin 11 cr 22176 2I.pdf (43.7 KB)
Dear Ms. Ballard,
Sincerely,
Zach Coughlin
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

Date: Tue, 29 Nov 2011 15:22:14 -0800
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=e4...
1 of 22 1/29/2012 9:43 PM

Date: Tue, 29 Nov 2011 16:14:15 -0800

Donna Ballard
Reno, Nevada 89501
(775)334-3101
Sent: Tue 11/29/11 4:29 PM
1 attachment
RMC various walmart subpoenasreno v coughlin 11 cr 22176 2I.pdf (56.9 KB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
2 of 22 1/29/2012 9:43 PM
privilege.

Date: Tue, 29 Nov 2011 15:53:46 -0800
I am so sorry, I must have misunderstood.
These must be served and the affidavit portion completed before they can be file stamped in.
Thank you,
Donna
To: <ballardd@reno.gov>
Date: Tue, 29 Nov 2011 15:48:31 -0800
Dear Ms. Ballard,
Sincerely,
Zach Coughlin
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
3 of 22 1/29/2012 9:43 PM
IFP/ FINANCIAL INQUIRY APPLICATION

Date: Tue, 29 Nov 2011 15:22:14 -0800

Date: Tue, 29 Nov 2011 16:14:15 -0800

Donna Ballard
Reno, Nevada 89501
(775)334-3101
Donna Ballard
Reno, Nevada 89501
(775)334-3101
4 of 22 1/29/2012 9:43 PM
Sent: Wed 12/14/11 12:22 AM
To: ballardd@reno.gov; renomunirecords@reno.gov
2 attachments
Coughlin IFP and Financial Inquiry Application RMC 11222011 11 CR 26405 2I.pdf (381.9 KB) , Coughlin
IFP and Financial Inquiry Application RMC 11222011 11 CR 22176 2I.pdf (372.0 KB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
Ms. Ballard,
Please note, the gentleman I worked with at the filing office counter today informed me there were no
appeal fees, bonds, or other charges that I could pay (including transcription costs) as "all charges are
being taken from" my bail in the respective matters. Please email me the audio from the November
20th,2011 Trial in 11 cr 22176 2I and proof of service of any Contempt Order or Guilty Verdict/Order
in that matter. Please file this as well as a Opposition to Any Motion to Continue Trial in 11 cr 26405,
dept 2, and a Motion to Set Aside or Vacate any Order Granting Continuance in response to such an
Order Granting Continuance. Please email, fax, or mail me a copy of the Notice of Appearances by
both Taitel and Puentes and the Motion and Order Granting Withdrawal of Taitel, if it exists. I would
like a copy of the docket in both 11 CR 26405 2I and 11 CR 22176, despite your informing me today
that I would need to subpoena the docket to have any chance of seeing it and that I would not be
provided access to documents in the public record, including Orders in both of these cases.
Sincerely,
Zach Coughlin
5 of 22 1/29/2012 9:43 PM
RE: IFP/ FINANCIAL INQUIRY APPLICATION
privilege.
Sent: Wed 12/14/11 3:45 PM
You might want to ask the gentleman clerk I was working with about
everything he said.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
6 of 22 1/29/2012 9:43 PM
privilege.
Date: Wed, 14 Dec 2011 12:09:40 -0800
Subject: Re: IFP/ FINANCIAL INQUIRY APPLICATION
I did not inform you that you would need a subpoena to get a copy of the docket. I advised you that your
records request will be sufficient for copies of documents as public record and did not specify specific
documents.
I am forwarding this email to Department 2, Department 4 and the Chief Marshal for further action.

To: <ballardd@reno.gov>, <renomunirecords@reno.gov>
Date: Wed, 14 Dec 2011 00:22:07 -0800
Subject: IFP/ FINANCI AL INQUIRY APPLI CATION

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

Ms. Ballard,
Please note, the gentleman I worked with at the filing office counter today informed me there were no appeal
fees, bonds, or other charges that I could pay (including transcription costs) as "all charges are being taken
from" my bail in the respective matters. Please email me the audio from the November 20th,2011 Trial in 11 cr
22176 2I and proof of service of any Contempt Order or Guilty Verdict/Order in that matter. Please file this as
7 of 22 1/29/2012 9:43 PM
RE: Message left on 12/13/2011
well as a Opposition to Any Motion to Continue Trial in 11 cr 26405, dept 2, and a Motion to Set Aside or
Vacate any Order Granting Continuance in response to such an Order Granting Continuance. Please email,
fax, or mail me a copy of the Notice of Appearances by both Taitel and Puentes and the Motion and Order
Granting Withdrawal of Taitel, if it exists. I would like a copy of the docket in both 11 CR 26405 2I and 11 CR
22176, despite your informing me today that I would need to subpoena the docket to have any chance of
seeing it and that I would not be provided access to documents in the public record, including Orders in both
of these cases.

Sincerely,

Zach Coughlin

Donna Ballard
Reno, Nevada 89501
(775)334-3101
Sent: Wed 12/14/11 6:52 PM
To: roperj@reno.gov; fiskg@reno.gov; ballardd@reno.gov; renomunirecords@reno.gov
Dear Chief Marshal Roper, and the RMC,

Thank you for your quick reply. I actually requested a copy of some
documentation related to my complaints about both incidents with Marshal
Mentzel be placed in his employment or personnel file, not that you provide
8 of 22 1/29/2012 9:43 PM
me a copy of his file. I would like one, or a copy of any complaints against
any Marshals, but I realize a subpoena would likely be required to have any
chance at that. Negligent Training, Hiring, Supervision.

I never received a copy of the Contempt Finding and Guilty
Verdict/J udgment/ORder or whatever from the 11 30, 2011 Trial before Judge
Howard in 11 CR22176 2I, though "Veronica" (no one will tell me her last
name, but she works closely with the RMC Judges) said the only "service" of
those Orders that was ever attempted on me occured while I was handcuffed,
after which point some Marshalls (I did not catch their names and they
manhandled me roughly into handcuffs, refusing to even let me save my
notes on my laptop at the sudden conclusion of Judge Howards Order and
Contempt finding. This is truly reprehensible to not even let me save my
damn notes and act like I was some perp who just knocked of a god damn
liquor store with a firearm. Some people need to get a grip inside. Please
place a copy of this written complaint against whatever Marshals were
involved in that in their employment/personnel files as well. Please provide
me a copy of any complaints you have received against any Marshals.

I would like a copy of the 11 30, 2011 Order and the audio of the Trial. I
believe you have a duty to find out what those Marshals did with this
document that "Veronica" alleges they attempted to serve on me, though,
even 14 days after the Trial, the "docket" in the RMC filing office still
contains no Order, no mention of an Order, and certainly no Proof of Service
of anything of the sort, nor have they responded to any of my documentation
requests or a request of the audio of the Trial of 11 30, 2011, despite an
exigent need for such to prepare Relief from Judgment Motions that have
deadlines of 10-20 days from "service" of the "Order", and who knows how
that will be measure. Why it was necessary to cost the public a bunch of
overtime pay for the 5 or so Marshalls, and who knows how many court staff
to stay until nearly 9pm on 11 30, 2011 to complete this "Trial", and how it
was such a damn emergency, especially where Richard Hill was able to get a
continuance because he was going to be on vacation in the trespass case
against me 11 CR 22185 2I, despite the fact that Lew Taitel never receive my
consent to such a Motion for Continuance, and further Taitel was arguably
conflicted out of representing me considering his "association" with Nevada
Court Services and the torts the committed against me, which resulted in a
9 of 22 1/29/2012 9:43 PM
lawsuit being filed against them, or at least an IPF Petition and Proposed
Complaint in District Court, prior to Taitel's appointment and representation.
If the RMC can afford all that damn overtime for everyone, why couldn't it
appoint me a defense attorney in RMC 11 CR 22176, especially where Judge
Howard ruled, not 20 minutes into Trial that he was finding me in Contempt
of Court and would decide the sentence (which obviously included a
possibility of incarceration) at the conclusion of the Trial?
Further M. Mentzel clearly bumped Donna Ballard out of the way in his zeal
to establish dominance of me, a person who was providing absolutely no
resistance at the time. Mentzel went on to start order me to leave the
premises after my conversation with Ballard and the file clerk was done.
Duh, Mentzel, it was 5:00 pm or so "closing time" what do you think I am
going to do, hang out and chill with you guys? Look at the Notice of Hearing
or Docket in RMC 11 CR22176 2I (I am also hereby requesting a copy of
the audio or video of the hearing from the RMC) and the hand written
interlineations I made on the document M. Mentzel provided me in court on
10 11, 2011, where I mention the problems associated with asking questions
about my Sixth Amendment Right to Counsel where only the possibility of
jail time exists. I asked Mentzel at that time a question about the process and
he got very angry, threatening, and insulting with me, then later, criticized my
appearance before Judge Gardner, I believe he said I was "sarcastic" and or
rude to the Judge in the same way I had been to Mentzel himself. I submit
that citizens trying to access justice should not be taken as a personal affront
to RMC employees like Mentzel, and that he needs to strongly consider how
he comes across to the public when he acts the way he does, and carries a
firearm, color of law, a badge, and apparently, the blessing of the RMC in
carrying out behavior that seems more fitting for a nightclub bouncer than a
Marshal. Further, the video played at arraignments is overly hostile and
threatening in my opinion, especially the parts where Judge Gardner makes
statements on the "extremely" poor choice it would be to represent one's self
pro se and all these tones and words used that make it sound like pro se
defendants will be punished for not either copping a plea or going with one
of the "four former prosecutors" who are now drawing a paycheck from the
RMC/Citizenry to fulfill the Sixth Amendment. I am something completely
other than impressed with the work done by Lew Taitel, Esq. for me in RMC
11 CR 22185 2I, in that regard. Why shouldn't defendants in the RMC, after
viewing the arraignment video and receiving representation like that which I
10 of 22 1/29/2012 9:43 PM
received from Taitel, feel like lambs being led to slaughter? Baah,
baaaaaaaaah! Two other Marshals were there yesterday when Mentzel was
berating me, I would like their names, please.

Now, just awhile ago, "RMC Court Transcriptionist Pam Longoni" called me
on the phone ("while driving" according to Ms. Longoni) and informed me
that the RMC must permit her access to the audio files, and that, while she is
linked into "their system" (meaning the RMC's), the RMC must take some
additional step to allow Ms. Longoni to access the audio files and continue
with the process of tending ot a request for a Transcript on Appeal. I was
told by a female RMC counter clerk that I would not ever be provided a copy
of the audio recording of the 11 30, 2011 Trial, but that I may purchase from
Ms. Longoni an official transcript, and that "appeal transcripts are billed at
$4.10 per page" etc. and that a substantial deposit would be required, and that
"No Transcript is considered to be official ordered, and commencement of
transcription will not begin, until receipt of the required deposit..." I asked
Ms. Longoni to inform me of everything I must do or pay to have the
transcript deemd officialy ordered and she informed me that she could not tell
me that, despite the apparent hard and fast deadlines applied to ordering,
officially, such a transcript, with the RMC in an Appeal context, until the
RMC allowed Ms. Longoni to access the RMC "system" and view/hear the
audio of the 11 30, 2011 Trial in 11 CR22176 2I. Ms. Longoni angrily hung
up the phone on me and is now not returning my calls and has failed to
respond to my request that she inform me, in writing, as to where to send
money or a deposit or anything else required for the transcript. I have yet to
receive a fax from the RMC's "Veronica" (whose last name has repeatedly
been denied to me) despite her angry assurances on the phone on 12 12, 2011
that she would finally hae the RMC attempt to appropriately (or almost
appropriately) serve me a copy of the Contempt Finding and Guilty Order
stemming from the 11 30, 2011 Trial in RMC 11 CR 22176 2I. Please have
this request and communication reiterated to whoever it concerns at the
RMC, and have such a copy of those documents emailed, faxed, and mailed
in the US Postal Service mail immediately. Further, please do the same with
respect to the audio of the 11 30, 2011 Trial in RMC 11 CR 22176 2I, and of
course I will pay a reasonable cost for the cd to the extent my IFP is not
granted. The RJ C and Washoe District Court charge about $30 per cd. The
also provide copies of the dockets in cases without demanding a subpoena
11 of 22 1/29/2012 9:43 PM
force them to first. Please ask the gentleman Ms. Ballard saw me working
with yesterday what he said in that regard about providing me a copy of
anything, much less the docket in either RMC 11 CR 22176 2I or RMC 11
CR 22185 2I.

I believe I am entitled to a copy of the audio recording quickly, whether or
not a transcript has been officialy ordered, for the purposes of appeal or for
any other purposes. I believe in something called "transparency" in
goverment. Sunshine.

Let me ask you a question: If a J udge told you to jump off a bridge, would
you? It is my belief that Judge Howard ordered everyone to clear the
courtroom, including a female, shortly after my 11 20, 2011 Trial began and
it became clear that I was not going to lay down meekly for the Court, or for
Wal-Mart, or for the Reno City Attorney. 2 million of my people starved to
death during a "Great Famine" between 1848-1850 in Ireland, despite being
surrounded by water and fish, where the English were arresting Irishmen who
attempted to save their families and their own live's by fishing. I will be
fishing here, gentleman. Deal with it. I want that recording, for, among
many other reasons, to see if J udge Howard merely asked those who might
be called as witnesses to leave or whether he demanded every member of the
public leave before he sent me off to Guantanamo, er, I mean the Washoe
County Detention Facility after the Military Tribunal, er, the Trial in RMC.
Interestingly, while at the Washoe County Detention Facility, I have been
made to strip naked while being videotaped, wear a green dress for days on
end, go without a toothbrush for days, refused any opportunity to make
phone calls to protect my clients cases from prejudice, forced to spread apart
my buttocks and allow an overly long look at my anus by Sheriff's Deputies,
and further, I was forced to submit to a position on my knees in the
immediate vicinity of two Sheriff's Deputies crotches in some sadistic forced
simulation of performing oral sex upon those men. Rico/Negligent Hiring,
Training, Supervision, 42 USC Sec. 1983 Deprivation of Civil Rights Under
Color of State Law, etc., etc. Qui Tam, Whistleblower. Mr. Roper, I doubt a
Federal Court Judge would require that I have come obtained a Statement
From you to complain about any Marshal's conduct. I am pretty sure this and
my other correspondences have placed you on notice.

12 of 22 1/29/2012 9:43 PM
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.

Date: Wed, 14 Dec 2011 16:26:47 -0800
From: RoperJ@reno.gov
To: ZachCoughlin@hotmail.com
Subject: Message left on 12/13/2011
Mr. Coughlin,
I received your message that you left on my phone on December 13, 2011 in regards to a complaint against Marshal
Menzel. The Marshal Division takes all citizen complaints seriously and investigates all complaints received in writing or
verbally. However, I would need more information fromyou prior to moving forward with an investigation. I encourage
you to come to the court to obtain a statement form, or contact me directly should you wish to pursue this matter. As to
your request to obtain a copy of Marshal Menzel's personnel file, I am unable to provide that to you without a valid
subpoena or warrant.
13 of 22 1/29/2012 9:43 PM
RMC 11 CR 22176

You also stated you were attempting to obtain a copy of your J udgement of Conviction fromDept. 4, specifically Veronica
Lopez, you can reach her at 326-6673. I am aware that a copy of your J udgement of Conviction was provided to you and
booked into your property on the night you were arrested. You are entitled to another copy should you wish.

Thank you,
J ustin Roper
Chief Marshal/Department of Alternative Sentencing
775-334-1254
Sent: Thu 12/15/11 11:59 PM
ZachCoughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
TO: .RMC et al
FAX NO: RMC approvedemail ling
14 of 22 1/29/2012 9:43 PM
RE: . Cityof renovCoughlinRMC 11CR221762I
Motion for NewTrial,Noticeof appeal andother issues
Dear RMC,



T
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
15 of 22 1/29/2012 9:43 PM
FW: RMC 11 CR 22176
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Fri 12/16/11 12:00 AM
1 attachment
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
16 of 22 1/29/2012 9:43 PM
Nevada Bar No: 9473
privilege.
lopezv@reno.gov
Date: Thu, 15 Dec 2011 23:59:45 -0800
ZachCoughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
17 of 22 1/29/2012 9:43 PM
TO: .RMC et al
Dear RMC,



T
18 of 22 1/29/2012 9:43 PM
FW: 121 River Rock
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Sat 12/17/11 12:15 AM
19 of 22 1/29/2012 9:43 PM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.

Date: Wed, 14 Dec 2011 15:43:38 -0800
Dear Mr. Baker,
20 of 22 1/29/2012 9:43 PM
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Date: Wed, 14 Dec 2011 13:50:02 -0800
Mr. Coughlin:
21 of 22 1/29/2012 9:43 PM



652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858

This e-mail may contain legally privileged or confidential information. If you arenot theintended recipient, please do not read, copy, use, or disclosethis
communication to anyone other than the intended recipient. If you havereceived thismessage in error, please notify thesender and delete theemail message from
To ensure compliancewith requirements imposed by theIRS, weinform you that any U.S. federal tax advice contained in thiscommunication (including any
attachments) isnot 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,

22 of 22 1/29/2012 9:43 PM
request for arrest records
Sent: Tue 10/04/11 3:22 PM
To: lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org
1 attachment
records request to rsic police.pdf (65.8 KB)
lcooley@rsic.org, voldenburg@rsic.org, rariwite@rsic.org, police@rsic.org,
TO:
Larry Cooley, Chief of Police
October 4, 2011
Dear Reno Sparks Indian Colony Police Records Department and
Administrators, including Chief Cooley, Attorney Oldenburg, and Tribal
Administrator Ariwhite,
My name is Zach Coughlin. I wish to obtain any and all records available
incident to an arrest at the E. 2nd St. Walmart by the Reno Sparks Indian
Colony Police on or about Saturday October 10th, 2011 at between
approximately 9pm and 10:30pm. I want any and all records, video, audio,
paper documentation or otherwise that I have a right to. I am representing
myself. I have sought these records from the Reno Municipal Court's
Records Office and they kept telling me they didn't have them yet and that I
should return sometime soon. Finally, they admitted the do not keep these
records and they must be obtained from your office. This delay has unduly
prejudiced my case and I request that you provide these records to me at
once, with no delay, please. The RS Indian Colony Police refused to give me
a copy of these records today when I spoke with Sargent Avansino, who was
polite and helpful otherwise. I believe this case should be dismissed.
Signed electronically and signed in a signed attached PDF. I can come pick
the records up with identification if that is required or I hereby give you
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=66...
1 of 19 1/29/2012 10:01 PM
Subpoena and request for arrest records
permission to email them to me or mail them to the address below:
Zach Coughlin
121 River Rock St.
Reno, NV 89501
Sincerely,
Zach Coughlin
Sent: Tue 10/04/11 4:26 PM
2 attachments
gov.uscourts.nvd.52455.8.0 hernandez against reno sparks indian police.PDF (224.4 KB) ,
gov.uscourts.mied.209033.1.0 Sweeney Class Action Walmart.PDF (415.2 KB)
2 of 19 1/29/2012 10:01 PM
October 4, 2011
Dear Reno Sparks Indian Colony Police Department and Counsel,
My name is Zach Coughlin. I have now been informed by both the Reno
Municipal Court and the Reno City Attorney's officer that neither entity can
provide my requested records. You have them, I believe I have a
constitutional right to them. If you feel differently, please explain in writing
why that is the case. Please review:
Construction and effect, in false imprisonment action, of statute providing for
detention of sus-
pected shoplifters, 47 A.L.R. 3d 998
Liability of municipality or other governmental unit for failure to provide
police protection, 46
A.L.R. 3d 1084
Personal liability of policeman, sheriffs, or similar peace officer or his bond,
for injury suffered as
a result of failure to enforce law or arrest lawbreaker, 41 A.L.R. 3d 700
Admissibility of defendant's rules or instructions for dealing with shoplifters,
in action for false
imprisonment or malicious prosecution, 31 A.L.R. 3D 705
Genuine issue of material fact, as to whether homeowner voluntarily
consented to warrantless search of his residence, or whether he had been
coerced into giving his consent by officers' alleged refusal to honor his
requests to speak with attorney, and by their alleged threats that, unless he
consented, he would be forced to wait outside while officers obtained
warrant and then "t[ore] his house apart and arrest[ed] his girlfriend,"
precluded entry of summary judgment for government in civil for- feiture
3 of 19 1/29/2012 10:01 PM
action in which only evidence supporting government's position was
evidence that homeowner sought to suppress. U.S.C.A. Const.Amend. 4;
Comprehensive Drug Abuse Prevention and Control Act of 1970,
511(a)(7), 21 U.S.C.A. 881(a)(7). U.S. v. One Piece of Real Property
Located at 5800 SW 74th Ave., Miami, Fla., 363 F.3d 1099;Manning v
Commonwealth (1959, Ky) 328 SW2d 421.
Please consider this a subpoena requesting all records having anything to do
with this incident.
I wish to obtain any and all records available incident to IC110627 at the E.
2nd St. Walmart by the Reno Sparks Indian Colony Police on or about
Saturday October 10th, 2011 at between approximately 9pm and 10:30pm. I
want any and all records, video, audio, paper documentation or otherwise that
I have a right to. I am representing myself. I have sought these records from
the Reno Municipal Court's Records Office and they kept telling me they
didn't have them yet and that I should return sometime soon. Finally, they
admitted the do not keep these records and they must be obtained from your
office. This delay has unduly prejudiced my case and I request that you
provide these records to me at once, with no delay, please. The RS Indian
Colony Police refused to give me a copy of these records today when I spoke
with Sargent Avansino, who was polite and helpful otherwise. I believe this
case should be dismissed.
Zach Coughlin
121 River Rock St.
Reno, NV 89501
Sincerely,
4 of 19 1/29/2012 10:01 PM
RE: request for arrest records
Zach Coughlin
This message is confidential, intended only for the named recipient(s) and may contain information
that is privileged, work product or exempt from disclosure under applicable law. If you are not the
intended recipient(s), you are notified that any disclosure, copying, distribution or any action taken or
omitted to be taken in reliance on the contents of this information is prohibited and may be unlawful. If
you receive this message in error, or are not the named recipient(s), please notify the sender, delete
this e-mail from your computer, and destroy any copies in any form immediately. Receipt by anyone
other than the named recipient(s) is not a waiver of any attorney-client, work product, or other
applicable privilege.
Civil Results
Party Name Court Case NOS Date Filed Date Closed

1 Reno Sparks Indian Tribal Council (dft) nvdce3:2007-cv-00023 440 02/27/2007 07/17/2007
Appellate Results
Party Name Court Case NOS Date Filed Date Closed

2 Reno Sparks Indian Tribal Council (pty) 09cae 07-16422 3440 08/10/2007 12/27/2007
Saved: Sun 12/04/11 3:49 AM
Zach Coughlin, Esq.
5 of 19 1/29/2012 10:01 PM
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

To:pgoins@rsic.org, lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org
Subject: request for arrest records
Date: Tue, 4 Oct 2011 15:22:39 -0700
lcooley@rsic.org, voldenburg@rsic.org, rariwite@rsic.org, police@rsic.org,
TO:
Larry Cooley, Chief of Police
October 4, 2011
Dear Reno Sparks Indian Colony Police Records Department and
Administrators, including Chief Cooley, Attorney Oldenburg, and Tribal
Administrator Ariwhite,
My name is Zach Coughlin. I wish to obtain any and all records available
incident to an arrest at the E. 2nd St. Walmart by the Reno Sparks Indian
6 of 19 1/29/2012 10:01 PM
Colony Police on or about Saturday October 10th, 2011 at between
approximately 9pm and 10:30pm. I want any and all records, video, audio,
paper documentation or otherwise that I have a right to. I am representing
myself. I have sought these records from the Reno Municipal Court's
Records Office and they kept telling me they didn't have them yet and that I
should return sometime soon. Finally, they admitted the do not keep these
records and they must be obtained from your office. This delay has unduly
prejudiced my case and I request that you provide these records to me at
once, with no delay, please. The RS Indian Colony Police refused to give me
a copy of these records today when I spoke with Sargent Avansino, who was
polite and helpful otherwise. I believe this case should be dismissed.
Zach Coughlin
121 River Rock St.
Reno, NV 89501
Sincerely,
Zach Coughlin
7 of 19 1/29/2012 10:01 PM
your cop lying, see your video drivers license produce ap overview at
6:49 mark
Sent: Sun 12/04/11 4:05 AM
To: lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org; robertsp@reno.gov
pgoins@rsic.org, lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org
Subject: your cop lying, see your video drivers license produce ap overview at 6:49 mark
We spend half the "trial" arguing about whether your lying cops had enough
"information" (their definition included personally identifiable information to
identify the accused sufficiently to issue a citation, A CURRENT NEVADA'S
DRIVERS LICENSE WOULD DO JUST FINE ON THAT ACCOUNT) to
issue a citation, and how, because they didn't, they had to conduct a search
incident to arrest, yet YOUR OWN DAMN VIDEO (OR RATHER,
WALMART'S, BUT ITS HARD TO SEE WHERE YOU GUYS END AND
WALMART BEGINS), THAT YOU EFFING PRODUCED (OR RATHER
THE RENO CITY ATTORNEY PRODUCED AFTER THE BOYS AT
WALMART "COMPILED" VIDEO, WHICH CURIOUSLY DID CONTAIN
A FUCKING SECOND OF VIDEO SHOWING ANY OF THE ALLEGED
CONCEALING OR CONSUMING THE ITEMS IN QUESTION! SHOWS
THE ACCUSED HANDING THEM A DRIVERS LICENSE AND THEM
CALLING IT IN TO CHECK FOR PRIORS (THAT WILL SHOW UP IN
DISPATCH REPORTS AND OTHER DOCUMENTATION). THESE
KEYSTONE COP EFFUPS HAVE DEFAMED ME AND YOU
SPONSORED IT, CULTIVATED IT.
I CAN GIVE YOU UNTIL TUESDAY TO MAKE A STRONG EFFORT TO
CORRECT THIS, AFTER THAT, I HAVE TO MAKE MY MOVES AND
FILE MY MOTIONS. JUDGE VAN WALRAVEN WOULD BE
ASHAMED OF HOW THIS HAS BEEN HANDLED.
THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS A
8 of 19 1/29/2012 10:01 PM
FAR MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN EXTENT
THAT WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS
"PARTICIPATION", AND ITS ALL ON TAPE.
I want you to move for, OR ASK THE CITY ATTORNEY TO MOVE
FOR, a Rule 59 Motion to Set Aside or some other motion to have the
Judgment Set Aside. Your cop witness clearly had a driver's license
produced to him at the 6:49 mark of WALMART'S OWN DAMN VIDEO!
And you suborned his perjury on the witness stand in violation of many of
the POLICE CODES YOU ARE HELD TO. Further, what are you going to
say when the UPC from the alleged receipt appears on the purchased receipt,
in combination with Frontino's adamant assertion that they wouldn't, in
combination with the same from Crawford, in combination with Frontino
admitting he couldn't hear what was said between the accused and the
cashier, in combination with the "same UPC, hit the quantity number"
practice common at Walmart? Further, your Officer Crawford, as a witness,
admitted on tape at the trial that "he didn't have enough EVIDENCE to issue
a citation so he arrested and did a search incident to arrest" to get more
evidence before Reno City Attorney Roberts and Judge Howard could jump
in and cut him off. That's gametime. Frontino, Crawford, and Braunworth,
sat around joking like goofy frat boys the preceeding 30 minutes in the
hallway in front of the court room, like a group of 3 buddies who hang out all
the time, except, 2 get paid by you, and one gets paid by Wal-Mart, who pay
the people who pay you. Then all three of them wait around the hear the
verdict at 8 pm hours after Frontino and Crawford finished testifying.
Maybe the don't realize Judge Howard wasn't ruling on the Appeal, the Rule
59, 60 motions, Motion for Reconsideration, defamation, wrongful arrest,
false imprisonment lawsuits, etc. Fix it now while you can. Wait till I get the
video from Walmart that Frontino is hiding from you, and don't you just want
to know if some "other" audio or video exists of the interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
9 of 19 1/29/2012 10:01 PM
Re: your cop lying, see your video drivers license produce ap overview at
6:49 mark
privilege.
From: Pamela Roberts (robertsp@reno.gov)
Sent: Mon 12/05/11 7:49 AM
To: Zach Coughlin (zachcoughlin@hotmail.com); lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org;
police@rsic.org
Mr. Coughlin: Please discontinue any further correspondence with me via email. Please file and serve any
motions or notices in accordance with the rules of the applicable court. Pam Roberts, Deputy City Attorney.
To: <lcooley@rsic.org>, <voldenburg@rsic.org>, <rariwite@rsic.org>, <police@rsic.org>,
<robertsp@reno.gov>
Date: Sun, 4 Dec 2011 04:05:27 -0800
"information" (their definition included personally identifiable information
to identify the accused sufficiently to issue a citation, A CURRENT
10 of 19 1/29/2012 10:01 PM
NEVADA'S DRIVERS LICENSE WOULD DO J UST FINE ON THAT
ACCOUNT) to issue a citation, and how, because they didn't, they had to
conduct a search incident to arrest, yet YOUR OWN DAMN VIDEO (OR
RATHER, WALMART'S, BUT ITS HARD TO SEE WHERE YOU GUYS
END AND WALMART BEGINS), THAT YOU EFFING PRODUCED
(OR RATHER THE RENO CITY ATTORNEY PRODUCED AFTER THE
BOYS AT WALMART "COMPILED" VIDEO, WHICH CURIOUSLY
DID CONTAIN A FUCKING SECOND OF VIDEO SHOWING ANY OF
THE ALLEGED CONCEALING OR CONSUMING THE ITEMS IN
QUESTION! SHOWS THE ACCUSED HANDING THEM A DRIVERS
LICENSE AND THEM CALLING IT IN TO CHECK FOR PRIORS
(THAT WILL SHOW UP IN DISPATCH REPORTS AND OTHER
DOCUMENTATION). THESE KEYSTONE COP EFFUPS HAVE
DEFAMED ME AND YOU SPONSORED IT, CULTIVATED IT.
I CAN GIVE YOU UNTIL TUESDAY TO MAKE A STRONG EFFORT
TO CORRECT THIS, AFTER THAT, I HAVE TO MAKE MY MOVES
AND FILE MY MOTIONS. JUDGE VAN WALRAVEN WOULD BE
THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS
A FAR MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN
EXTENT THAT WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS
say when the UPC from the alleged receipt appears on the purchased
receipt, in combination with Frontino's adamant assertion that they
wouldn't, in combination with the same from Crawford, in combination
with Frontino admitting he couldn't hear what was said between the accused
and the cashier, in combination with the "same UPC, hit the quantity
number" practice common at Walmart? Further, your Officer Crawford, as
a witness, admitted on tape at the trial that "he didn't have enough
EVIDENCE to issue a citation so he arrested and did a search incident to
11 of 19 1/29/2012 10:01 PM
arrest" to get more evidence before Reno City Attorney Roberts and J udge
Howard could jump in and cut him off. That's gametime. Frontino,
Crawford, and Braunworth, sat around joking like goofy frat boys the
preceeding 30 minutes in the hallway in front of the court room, like a
group of 3 buddies who hang out all the time, except, 2 get paid by you, and
one gets paid by Wal-Mart, who pay the people who pay you. Then all
three of them wait around the hear the verdict at 8 pm hours after Frontino
and Crawford finished testifying. Maybe the don't realize Judge Howard
wasn't ruling on the Appeal, the Rule 59, 60 motions, Motion for
Reconsideration, defamation, wrongful arrest, false imprisonment lawsuits,
etc. Fix it now while you can. Wait till I get the video from Walmart that
Frontino is hiding from you, and don't you just want to know if some
"other" audio or video exists of the interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402

12 of 19 1/29/2012 10:01 PM
defamation lawsuit/wrongful arrest/perjury under color of state law
arrest.
Sent: Mon 12/12/11 10:07 PM
To: nhardjo@rsic.org; carthene@reno.gov; htobey@rsic.og
Dear RSIC Police and Ms. Carthen,
Please provide me a copy of the video cd/dvd that Walmart's Frontino handed
your two Officers, Kameron Crawford and Braunworth when they were
escorting the suspect from the interrogation room in RMC 11 CR 22176. I
don't care if you think the tape/disc is not probative. I want it. Plus I want all
the dispatch tapes, especially where Kameron is calling in the suspect's
driver's license (which he testified the suspect refused to give him, but darn
it, its right there on the interrogation room footage, Kameron being givent he
driver's license card. Then the walmart guy Frontino testifies there was not
footage other than the interrogation room footage, yet he clearly hands the
two RSIC officers a cd/dvd when there are leaving the room. I am still
bothered that Sargent Avansino stonewalled me on the discovery for a whole
month following the arrest.
Sincerely,
Zach Coughlin
<robertsp@reno.gov>
Date: Sun, 4 Dec 2011 04:05:27 -0800
13 of 19 1/29/2012 10:01 PM
DID CONTAIN A FriggING SECOND OF VIDEO SHOWING ANY OF
AND FILE MY MOTIONS.
14 of 19 1/29/2012 10:01 PM
FW: defamation lawsuit/wrongful arrest/perjury under color of state law
preceding 30 minutes in the hallway in front of the court room, like a group
of 3 buddies who hang out all the time, except, 2 get paid by you, and one
gets paid by Wal-Mart, who pay the people who pay you. Then all three of
them wait around the hear the verdict at 8 pm hours after Frontino and
Crawford finished testifying. Maybe the don't realize J udge Howard wasn't
ruling on the Appeal, the Rule 59, 60 motions, Motion for Reconsideration,
defamation, wrongful arrest, false imprisonment lawsuits, etc. Fix it now
while you can. Wait till I get the video from Walmart that Frontino is hiding
from you, and don't you just want to know if some "other" audio or
video exists of the interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV
fax: 949 667 7402

15 of 19 1/29/2012 10:01 PM
arrest.
Sent: Fri 12/16/11 7:56 AM
To: nharjo@rsic.org
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
To: nhardjo@rsic.org; carthene@reno.gov; htobey@rsic.og
Subject: defamation lawsuit/wrongful arrest/perjury under color of state law arrest.
Date: Mon, 12 Dec 2011 22:07:47 -0800
Dear RSIC Police and Ms. Carthen,
Please provide me a copy of the video cd/dvd that Walmart's Frontino handed
16 of 19 1/29/2012 10:01 PM
your two Officers, Kameron Crawford and Braunworth when they were
escorting the suspect from the interrogation room in RMC 11 CR 22176. I
don't care if you think the tape/disc is not probative. I want it. Plus I want all
the dispatch tapes, especially where Kameron is calling in the suspect's
driver's license (which he testified the suspect refused to give him, but darn
it, its right there on the interrogation room footage, Kameron being givent he
driver's license card. Then the walmart guy Frontino testifies there was not
footage other than the interrogation room footage, yet he clearly hands the
two RSIC officers a cd/dvd when there are leaving the room. I am still
bothered that Sargent Avansino stonewalled me on the discovery for a whole
month following the arrest.
Sincerely,
Zach Coughlin
<robertsp@reno.gov>
Date: Sun, 4 Dec 2011 04:05:27 -0800
DID CONTAIN A FriggING SECOND OF VIDEO SHOWING ANY OF
17 of 19 1/29/2012 10:01 PM
AND FILE MY MOTIONS.
preceding 30 minutes in the hallway in front of the court room, like a group
of 3 buddies who hang out all the time, except, 2 get paid by you, and one
gets paid by Wal-Mart, who pay the people who pay you. Then all three of
them wait around the hear the verdict at 8 pm hours after Frontino and
Crawford finished testifying. Maybe the don't realize J udge Howard wasn't
ruling on the Appeal, the Rule 59, 60 motions, Motion for Reconsideration,
defamation, wrongful arrest, false imprisonment lawsuits, etc. Fix it now
18 of 19 1/29/2012 10:01 PM
while you can. Wait till I get the video from Walmart that Frontino is hiding
from you, and don't you just want to know if some "other" audio or
video exists of the interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV
fax: 949 667 7402

19 of 19 1/29/2012 10:01 PM
motion for continuance
Sent: Fri 11/11/11 1:40 AM
To: robertsp@reno.gov
Dear Counselor Roberts,
I believe you are the prosecutor for the case against me, State v. Coughlin,
which I believe is still set for trial on November 14th, I think at 1pm. I am
not totally sure that there is a duty to serve you on such a thing, but I filed a
Motion for Continuance and a Motion for Appointment of Counsel
sometime within about the last 10 days, I would say. I believe I attempted to
copy you on it, but have recently been evicted and its been a very difficult
time in terms of coordinating paperwork, etc., etc. I apologize for any
inconvenience this may have cause you. I am unsure of whether the
November 14th trial is still set to take place. I believe fairness dictates that it
be continued to a later date. I have request counsel but have yet to receive
any, or wait, I was denied a request to receive counsel because J udge Howard
said there is not a 6th amendment right to counsel where, even though jail
time is technically a possibility, the state does not anticipate seeking jail
time...or something like that, however, I found some cases that say I should
still get counsel appointed, especially where I show I am indigent, and I
believe I qualify as indigent rather easily. Can and would you agree to a
continuance? I believe I tried to contact about this prior to filing my Request
for a Continuance. I maintain my innocence in this case and feel any sort of
conviction, especially one involving any sort of theft based charge, would
work a terrible injustice and greatly damage my reputation and employment
prospects. I want a jury trial, too.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
Hotmail Print Message http://by148w.bay148.mail.live.com/mail/PrintMessages.aspx?cpids=dd...
1 of 57 1/29/2012 9:44 PM
RE: motion for continuance
privilege.
Sent: Wed 11/16/11 3:35 PM
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any Walmart
employees had, previous to this incident, made any threats respecting
maliciously having the accused banned from Walmart's incident to a
disagreement over Walmart staff and managers curious practice of
"forgetting" their return policy, despite some individuals having worked there
over 10 years....Further, I believe it relevant and part of your duty to provide
exculpatory information to ascertain whether the RSIC police officer made
statements wherein he attempted to coerce a consent to an impermissible
search and further buttressed his probable cause finding to conduct a search
incident to arrest, expressly, in words, to the accused, upon the accused's
failure to consent to such a search.

Please provide a list of any witnesses you intend to call at trial, including a
summation of the matters the will testify to, in addition to producing a copy
or making available for reproduction any documentation, audio, video, or
other materials intended to be used in any way at trial.
Thank You,

2 of 57 1/29/2012 9:44 PM
Date: Mon, 14 Nov 2011 10:36:45 -0800
From: robertsp@reno.gov
Subject: Re: motion for continuance
Mr. Coughlin, we were closed on Friday and I have just read your email. I f you have not received confirmation
from the Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in
Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to
resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's
decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the
Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor
case.

I hope your housing situation improves. See you this afternoon. Pam Roberts, Deputy City Attorney.

To: <robertsp@reno.gov>
Date: Fri, 11 Nov 2011 01:40:53 -0800
Subject: motion for continuance
sometime within about the last 10 days, I would say. I believe I attempted
to copy you on it, but have recently been evicted and its been a very
difficult time in terms of coordinating paperwork, etc., etc. I apologize for
any inconvenience this may have cause you. I am unsure of whether the
November 14th trial is still set to take place. I believe fairness dictates that
it be continued to a later date. I have request counsel but have yet to receive
any, or wait, I was denied a request to receive counsel because J udge
Howard said there is not a 6th amendment right to counsel where, even
though jail time is technically a possibility, the state does not anticipate
seeking jail time...or something like that, however, I found some cases that
say I should still get counsel appointed, especially where I show I am
indigent, and I believe I qualify as indigent rather easily. Can and would
you agree to a continuance? I believe I tried to contact about this prior to
filing my Request for a Continuance. I maintain my innocence in this case
3 of 57 1/29/2012 9:44 PM
and feel any sort of conviction, especially one involving any sort of theft
based charge, would work a terrible injustice and greatly damage my
reputation and employment prospects. I want a jury trial, too.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118

Sent: Wed 11/16/11 5:30 PM
Thanks Ms. Roberts,
Can you tell me who the three witnesses are that showed up on November
14th, 2011 for trial at 1pm? I did obtain a copy of the "discovery" about the
second day it was made available to me from your office in person. At that
time, no video evidence was made available to me. Is there now some video
or audio recording to which I may be provided access? Would you mind just
emailing me the names of the intended witnesses. Do you believe you do not
have a duty to make a reasonably diligent inquiry of either Walmart or RSIC
4 of 57 1/29/2012 9:44 PM
do assess the validity of the matters mentioned in my last email, ie the
retaliatory motive vis a vis Walmart and or the impermissible search/ 42 USC
Sec 1983 police misconduct of the RSIC officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Wed, 16 Nov 2011 17:12:21 -0800
Subject: RE: motion for continuance
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for
reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to
copies of all the reports and witness statements and video we may have on this case. Since I am not calling any
additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send you
an additional list of witnesses. I am also not obligated to do any further investigation or interviews. Pam
Roberts.
5 of 57 1/29/2012 9:44 PM
Date: Wed, 16 Nov 2011 15:35:48 -0800
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any Walmart
employees had, previous to this incident, made any threats respecting
maliciously having the accused banned from Walmart's incident to a
disagreement over Walmart staff and managers curious practice of
"forgetting" their return policy, despite some individuals having worked
there over 10 years....Further, I believe it relevant and part of your duty to
provide exculpatory information to ascertain whether the RSIC police
officer made statements wherein he attempted to coerce a consent to an
impermissible search and further buttressed his probable cause finding to
conduct a search incident to arrest, expressly, in words, to the accused, upon
the accused's failure to consent to such a search.

summation of the matters the will testify to, in addition to producing a copy
or making available for reproduction any documentation, audio, video, or
other materials intended to be used in any way at trial.
Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
Mr. Coughlin, we were closed on Friday and I have just read your email. I f you have not received
confirmation from the Court that your trial date has been continued, you will need to appear this afternoon at
1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we
are unable to resolve the case, you can ask the Court again for a continuance and I won't object. However, it
is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so
the Court is not required to appoint you an attorney. I n addition, you have no right to a jury trial in
a misdemeanor case.


6 of 57 1/29/2012 9:44 PM
Date: Fri, 11 Nov 2011 01:40:53 -0800
not totally sure that there is a duty to serve you on such a thing, but I filed
a Motion for Continuance and a Motion for Appointment of Counsel
November 14th trial is still set to take place. I believe fairness dictates
that it be continued to a later date. I have request counsel but have yet to
receive any, or wait, I was denied a request to receive counsel because
Judge Howard said there is not a 6th amendment right to counsel where,
even though jail time is technically a possibility, the state does not
anticipate seeking jail time...or something like that, however, I found some
cases that say I should still get counsel appointed, especially where I show
I am indigent, and I believe I qualify as indigent rather easily. Can and
would you agree to a continuance? I believe I tried to contact about this
prior to filing my Request for a Continuance. I maintain my innocence in
this case and feel any sort of conviction, especially one involving any sort
of theft based charge, would work a terrible injustice and greatly damage
my reputation and employment prospects. I want a jury trial, too.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
** 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
7 of 57 1/29/2012 9:44 PM
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

Sent: Thu 11/17/11 3:37 PM
Dear Ms. Roberts,

I do not mean to suggest you do not know what your duty it. Believe me, I am well aware that you could mop
up the court room with a neophyte attorney such as myself. I was merely hoping to get some direction from you
regarding trial practice approaches in general.

Sincerely,

Zach
Sent: Mon 11/21/11 1:05 PM
Dear Ms. Roberts,
I wish to obtain a copy of the video and will go the your office's lobby
shortly hoping to be provided one. Please respond to me regarding my
request from a continuance.
Sincerely,
8 of 57 1/29/2012 9:44 PM
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart
employee) and Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the
video at the first trial date from the Walmart employee and it is available for you to view or get a copy. You
may want to view it at the City Attorney's Office as the CD doesn't seem to work on everyone's computer. Penie
Colter will be able to assist you. I am not clear on what you think my duty is, but I know what my duty is and I
will not debate it via email. Pam Roberts, Deputy City Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
14th, 2011 for trial at 1pm? I did obtain a copy of the "discovery" about the
second day it was made available to me from your office in person. At that
time, no video evidence was made available to me. Is there now some
9 of 57 1/29/2012 9:44 PM
video or audio recording to which I may be provided access? Would you
mind just emailing me the names of the intended witnesses. Do you believe
you do not have a duty to make a reasonably diligent inquiry of either
Walmart or RSIC do assess the validity of the matters mentioned in my last
email, ie the retaliatory motive vis a vis Walmart and or the impermissible
search/ 42 USC Sec 1983 police misconduct of the RSIC officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Wed, 16 Nov 2011 17:12:21 -0800
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request for
reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled to
copies of all the reports and witness statements and video we may have on this case. Since I am not calling
any additional witnesses that are not already mentioned in the reports/statements, I am not obligated to send
you an additional list of witnesses. I am also not obligated to do any further investigation or interviews. Pam
Roberts.
10 of 57 1/29/2012 9:44 PM
Date: Wed, 16 Nov 2011 15:35:48 -0800
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any
Walmart employees had, previous to this incident, made any threats
respecting maliciously having the accused banned from Walmart's incident
to a disagreement over Walmart staff and managers curious practice of
"forgetting" their return policy, despite some individuals having worked
there over 10 years....Further, I believe it relevant and part of your duty to
provide exculpatory information to ascertain whether the RSIC police
officer made statements wherein he attempted to coerce a consent to an
impermissible search and further buttressed his probable cause finding to
conduct a search incident to arrest, expressly, in words, to the accused,
upon the accused's failure to consent to such a search.

summation of the matters the will testify to, in addition to producing a
copy or making available for reproduction any documentation, audio,
video, or other materials intended to be used in any way at trial.
Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
confirmation from the Court that your trial date has been continued, you will need to appear this afternoon
at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and
if we are unable to resolve the case, you can ask the Court again for a continuance and I won't object.
However, it is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so
the Court is not required to appoint you an attorney. I n addition, you have no right to a jury trial in
a misdemeanor case.

11 of 57 1/29/2012 9:44 PM

Date: Fri, 11 Nov 2011 01:40:53 -0800
I believe you are the prosecutor for the case against me, State v.
Coughlin, which I believe is still set for trial on November 14th, I think
at 1pm. I am not totally sure that there is a duty to serve you on such a
thing, but I filed a Motion for Continuance and a Motion for
Appointment of Counsel sometime within about the last 10 days, I would
say. I believe I attempted to copy you on it, but have recently been
evicted and its been a very difficult time in terms of coordinating
paperwork, etc., etc. I apologize for any inconvenience this may have
cause you. I am unsure of whether the November 14th trial is still set to
take place. I believe fairness dictates that it be continued to a later date.
I have request counsel but have yet to receive any, or wait, I was denied a
request to receive counsel because Judge Howard said there is not a 6th
amendment right to counsel where, even though jail time is technically a
possibility, the state does not anticipate seeking jail time...or something
like that, however, I found some cases that say I should still get counsel
appointed, especially where I show I am indigent, and I believe I qualify
as indigent rather easily. Can and would you agree to a continuance? I
believe I tried to contact about this prior to filing my Request for a
Continuance. I maintain my innocence in this case and feel any sort of
conviction, especially one involving any sort of theft based charge,
would work a terrible injustice and greatly damage my reputation and
employment prospects. I want a jury trial, too.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
12 of 57 1/29/2012 9:44 PM
temporary address change and instruction to pursue a continuance
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: Mon 11/21/11 4:06 PM
To: howardk@reno.gov; robertsp@reno.gov

Dear J udge Howard Deputy City Attorney Roberts,

I have been evicted and perhaps subject to an illegal lockout and unlawful
rent distraint by an attorney representing my Beverly Hills High School
graduate California Neurosurgeon landlord, who has spent approx $30,000 in
attorneys fees pursuing a summary eviction, and whose attorney is
withholding my state issued indentification, wallet, and all materials
necessary to my law practice all in an unlawful rent distraint prohibited by
NRS 40.460 and 40.520. I am pursuing a continuance of the upcoming
hearing/trial, I cannot even access when that hearing is. I have informed
opposing counsel Roberts of some of the issues which will require extensive
discovery, a jury trial, and more time to afford myself a legitimate
opportunity to defend this case. I have not been served any Order responding
to my request for appointment of counsel, as I believe it is required even if
the State does not "intend" to seek jail time, where any incarceration is a
possibility, the Sixth Amendment guarantees it.
13 of 57 1/29/2012 9:44 PM

Please note that my temporary address for now is:
Zach Coughlin, Esq.
c/o Silver Dollar Motel
817 N. Virginia St., Unit #2
Reno, NV 89501

The opposing counsel in the summary eviction matter is withholding my
phone as well and refusing to allow me to access any mail that may remain at
the property from those times when the USPS was processing my official
Change of Address. Email is the best way to get in contact with me during
this transition period.

For instance, I am unware whether my Motion for Appointment of Counsel
was granted or not. I called J udge Howard's assistant and requested that she
email me the docket in this case and any pleadings or orders filed, including
any order that may have stemmed form any of my previous motions, as I am
not sure how those were ruled on. I believe my internet based fax service
will allow me to receive those materials at my number 949 667 7402, though
I would prefer email, but I know many governmental entities prefer to fax
such items. I am requesting a jury trial, a substantial continuance, and the
appointment of counsel. I object to the RMC's practice of refusing to tell
litigants who the 4 "house" appointed defenders are upon questioning.
Further, it has become clear that some of these "former prosecutors" who are
now the gang of four "house" defenders, do not even announce to accused
arraignees that they are, in fact, the defender or an attorney or that they may
be representing the arraignees. I am hereby filing a motion in limine
regarding any materials or information gleaned from the unlawful search by
the RSIC Officer, who clearly announced that they would base their probable
cause to arrest and conduct a search incident to arrest upon any failure to
consent to a search by the accused. Further, the alleged conduct did not
occur in the Officer's presence, and I believe there exists authority preventing
a minor misdemeanor arrest and transport under those circumstances.
Additionally, more time is needed to conduct discovery in this matter,
especially in light of allegations that Walmart had previously threatened
individuals, including, perhaps, the accused, with retaliatory action, including
illicit abuse of process, for the purported attempts by someone to have the
14 of 57 1/29/2012 9:44 PM
Walmart Return Policy enforced, and to hold accountable all Walmart
employees and managers, some of whom have over a decade experience in
their positions, who curiously "forget" they Return Policy Walmart holds out
to the public when it is convenient to do so, the same Return Policy that
Walmart used to drive out of business so many competitors. Further, this
case is likely to get extremely complicated given the apparent conflict of
interest stemming from the fact that the Walmart in question is on land
owned by the RSIC, which may own or employ the RSIC police, and which
is rented or owned in part by Walmart.

I know Opposing Counsel Roberts may appreciate a continuance as well and
the opportunity it would afford her to fulfill her NRCP 11 duty and other
prosecutorial duties to conduct a reasonably diligent inquiry into these
matters.

Sincerely,
Zach Coughlin
privilege.
Sent: Mon 11/21/11 7:18 PM
15 of 57 1/29/2012 9:44 PM
Ms. Roberts, the opposing attorney's unlawful rent distraint is preventing me from providing all the discovery I
would like to provide you with or ascertain the need to do, and further is preventing me from having access to
the materials and information I need to litigate this case.
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
privilege.

Date: Mon, 14 Nov 2011 10:36:45 -0800
Mr. Coughlin, we were closed on Friday and I have just read your email. I f you have not received confirmation
from the Court that your trial date has been continued, you will need to appear this afternoon at 1:00 pm in
Courtroom B of the Reno Municipal Court. We can discuss your case further at that time and if we are unable to
resolve the case, you can ask the Court again for a continuance and I won't object. However, it is the Court's
decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time, so the
Court is not required to appoint you an attorney. In addition, you have no right to a jury trial in a misdemeanor
case.


16 of 57 1/29/2012 9:44 PM
Date: Fri, 11 Nov 2011 01:40:53 -0800
November 14th trial is still set to take place. I believe fairness dictates that
it be continued to a later date. I have request counsel but have yet to receive
any, or wait, I was denied a request to receive counsel because J udge
Howard said there is not a 6th amendment right to counsel where, even
though jail time is technically a possibility, the state does not anticipate
seeking jail time...or something like that, however, I found some cases that
say I should still get counsel appointed, especially where I show I am
indigent, and I believe I qualify as indigent rather easily. Can and would
you agree to a continuance? I believe I tried to contact about this prior to
filing my Request for a Continuance. I maintain my innocence in this case
and feel any sort of conviction, especially one involving any sort of theft
based charge, would work a terrible injustice and greatly damage my
reputation and employment prospects. I want a jury trial, too.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
775 338 8118
17 of 57 1/29/2012 9:44 PM
verint user agreement

Sent: Mon 11/21/11 8:40 PM
Hi Ms. Roberts,
Sorry, don't mean to be a pain, but I DON'T AGREE to this Verint software
policy...its calls for allowign them to inspect my office and paying them for
their inspection fees and all this other stuff that is so unduly oppressive. Its
just an AVI file, its as though they disable it just for the purpose of preventing
you from watching the movie unless you agree to their oppressive, onerous,
contract terms, and how does this benefit taxpayers? Authentication issues
can be addressed through the traditional means, I don't see the value add.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
18 of 57 1/29/2012 9:44 PM
privilege.
Sent: Tue 11/29/11 1:33 PM
Dear Ms. Roberts,

The opposing attorney in the Summary Eviction Proceeding against me in my home law office/business is
asserting a lien against my office, law practice files, and materials necessary to discovery production and
defending the case that you are the prosecutor on. I believe a continuance is absolutely necessary in the
interests of justice. Additionaly, you have been informed that Walmart previous to the arrest in this matter
became upset at the accused and made threats of malicious prosecution and abuse of process incident to the
accused questioning various Wal-mart personnel and managers about Wal-Marts curious practice of remixing
and forgetting the Return Policy stated in writing at Walmart.com (and expressly made applicable to purchases
made in Wal-Mart stores). A manager named "Ellis", though who may have identified himself as "John" and a
Loss prevention associate at the West 7th Street Wal-Mart in Reno allegedly told the accused that they would
have him banned from all Wal-Marts in retaliation for the accused seeking to do something to which he was
legally entitled to do, return and item at a Wal-Mart stores in accordance with Wal-Mart's stated and written
Return Policy. There are other retaliatory aspects to the conducts and statements made by both Wal-Mart and
RSIC personnel in this case.

Additionally, the video "evidence" that you provided is shameful. It consists of two short clips in some Wal-Mart
back room where 5-6 people, including 2 RSIC officers acting under color of state law on land their employer
owns and leases to Wal-Mart attempt to coerce not only a confession, but a consent to search. There is no audio
of the video, at least not the video you provided, that is. Where is the video of the alleged acts? How you can
maintain a case such as this stemming from the accused acts in a store like Wal-Mart, that has hundreds of
cameras and only provide video from some backroom that proves nothing and, in the words of "Jeannie" the
contact person at your office "doesn't show anything", I am not sure, and whether that is violative of your duties
as a prosecutor, Nifong, NRCP 11 (see Schumacher's application of that civil rule to the DA) is not clear. You
have been informed that the RSIC officer committed police misconduct and yet you brazenly announce in writing
that you do not intend to follow up on that, nor do you feel compelled to.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
19 of 57 1/29/2012 9:44 PM
privilege.

Date: Tue, 22 Nov 2011 07:59:37 -0800
Dear Mr. Coughlin, you will need to file a motion to continue in compliance with Reno Municipal Court
procedures. As I have stated in a previous email, I do not object to your motion to continue, however, it is up
to the J udge whether or not he will grant your motion. Regarding the video which I obtained at your previous
court date, I have told you that you can come to our office and view the video. I f you still want a copy, I
believe our staff will be able to make one for you. NRS 174.235 does not require me to do more than what I
have already done. We have provided you with the reports we have, listed the witnesses we will call and made
the video available to you. Pam Roberts, Deputy City Attorney.
Date: Mon, 21 Nov 2011 13:05:28 -0800
Dear Ms. Roberts,
I wish to obtain a copy of the video and will go the your office's lobby
shortly hoping to be provided one. Please respond to me regarding my
request from a continuance.
Sincerely,
Zach Coughlin, Esq.
121 River Rock St.
20 of 57 1/29/2012 9:44 PM
Reno, NV 89501
775 338 8118
Licensed in Nevada

Date: Thu, 17 Nov 2011 07:40:44 -0800
CC: colterp@reno.gov
Mr. Coughlin, the three witnesses who were there at the first trial date include: Thomas Frontino (Walmart
employee) and Officers Crawford and Braunworth from the Reno Sparks Indian Colony Police. I obtained the
video at the first trial date from the Walmart employee and it is available for you to view or get a copy. You
may want to view it at the City Attorney's Office as the CD doesn't seem to work on everyone's computer.
Penie Colter will be able to assist you. I am not clear on what you think my duty is, but I know what my duty
is and I will not debate it via email. Pam Roberts, Deputy City Attorney.
Date: Wed, 16 Nov 2011 17:30:36 -0800
Thanks Ms. Roberts,
14th, 2011 for trial at 1pm? I did obtain a copy of the "discovery" about
the second day it was made available to me from your office in person. At
that time, no video evidence was made available to me. Is there now some
video or audio recording to which I may be provided access? Would you
21 of 57 1/29/2012 9:44 PM
mind just emailing me the names of the intended witnesses. Do you
believe you do not have a duty to make a reasonably diligent inquiry of
either Walmart or RSIC do assess the validity of the matters mentioned in
my last email, ie the retaliatory motive vis a vis Walmart and or the
impermissible search/ 42 USC Sec 1983 police misconduct of the RSIC
officers?

Sincerely,

Zach Coughlin, Esq.
121 River Rock St.
Reno, NV 89501
775 338 8118
Licensed in Nevada
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

Date: Wed, 16 Nov 2011 17:12:21 -0800
Mr. Coughlin, you should have already received a notice regarding the availability of discovery and request
for reciprocal discovery. You just need to call ahead at 334-2050 and arrange to pick it up. You are entitled
to copies of all the reports and witness statements and video we may have on this case. Since I am not
calling any additional witnesses that are not already mentioned in the reports/statements, I am not
obligated to send you an additional list of witnesses. I am also not obligated to do any further investigation
or interviews. Pam Roberts.
22 of 57 1/29/2012 9:44 PM
Date: Wed, 16 Nov 2011 15:35:48 -0800
Ms. Roberts,
Thanks for your reply. Please ascertain from Walmart whether any
Walmart employees had, previous to this incident, made any threats
respecting maliciously having the accused banned from Walmart's
incident to a disagreement over Walmart staff and managers curious
practice of "forgetting" their return policy, despite some individuals
having worked there over 10 years....Further, I believe it relevant and
part of your duty to provide exculpatory information to ascertain whether
the RSIC police officer made statements wherein he attempted to coerce
a consent to an impermissible search and further buttressed his probable
cause finding to conduct a search incident to arrest, expressly, in words,
to the accused, upon the accused's failure to consent to such a search.

Please provide a list of any witnesses you intend to call at trial, including
a summation of the matters the will testify to, in addition to producing a
copy or making available for reproduction any documentation, audio,
video, or other materials intended to be used in any way at trial.
Thank You,

Date: Mon, 14 Nov 2011 10:36:45 -0800
confirmation from the Court that your trial date has been continued, you will need to appear this
afternoon at 1:00 pm in Courtroom B of the Reno Municipal Court. We can discuss your case further at
that time and if we are unable to resolve the case, you can ask the Court again for a continuance and I
won't object. However, it is the Court's decision to grant your motion to continue.

It is also the Court's decision whether to appoint you a legal defender. I do not plan to ask for jail time,
so the Court is not required to appoint you an attorney. I n addition, you have no right to a jury trial in
a misdemeanor case.

23 of 57 1/29/2012 9:44 PM

Date: Fri, 11 Nov 2011 01:40:53 -0800
I believe you are the prosecutor for the case against me, State v.
Coughlin, which I believe is still set for trial on November 14th, I think
at 1pm. I am not totally sure that there is a duty to serve you on such a
thing, but I filed a Motion for Continuance and a Motion for
Appointment of Counsel sometime within about the last 10 days, I
would say. I believe I attempted to copy you on it, but have recently
been evicted and its been a very difficult time in terms of coordinating
paperwork, etc., etc. I apologize for any inconvenience this may have
cause you. I am unsure of whether the November 14th trial is still set to
take place. I believe fairness dictates that it be continued to a later
date. I have request counsel but have yet to receive any, or wait, I was
denied a request to receive counsel because J udge Howard said there is
not a 6th amendment right to counsel where, even though jail time is
technically a possibility, the state does not anticipate seeking jail
time...or something like that, however, I found some cases that say I
should still get counsel appointed, especially where I show I am
indigent, and I believe I qualify as indigent rather easily. Can and
would you agree to a continuance? I believe I tried to contact about this
prior to filing my Request for a Continuance. I maintain my innocence
in this case and feel any sort of conviction, especially one involving any
sort of theft based charge, would work a terrible injustice and greatly
damage my reputation and employment prospects. I want a jury trial,
too.
Sincerely,
Zach Coughlin
121 River Rock St.
Reno, NV 89501
24 of 57 1/29/2012 9:44 PM
FW: temporary address change and instruction to pursue a continuance
775 338 8118
** 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: Tue 11/29/11 3:14 PM
To: robertsp@reno.gov; renomunirecords@reno.gov
1 attachment
Motion for Continuance to Reno City Atty Roberts RMC.pdf (448.9 KB)
Ms. Roberts and RMC Records Supervisor Donna,
I am forwarding this apology I sent to Judge Howard in response to his remonstration responding to my email to
him, in an abundance of caution to avoid ex parte communications with the court, outside your presence. Please
also find attach e a NRCP Rule 11 safe harbor filing ready sanctions motions I am hereby serving on you,
invoking the 21 day safe harbor, with a reservation that any misconduct you commit in the court's presence may
be punished sua sponte or subject to contemporaneous sanctions requests, particular with regard to you blase
dismissal of the official misdoncut, malicious prosecution, 42 USC Sec 1983 deprivations of civil rights under
color of state law and all those other things your office and Hartshorn, et all have been sued for over the years.

Please find attached my Motion for Continuance, being filed by fascimile today with the RMC.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
25 of 57 1/29/2012 9:44 PM
6:49 mark
privilege.

To: howardk@reno.gov
Subject: RE: temporary address change and instruction to pursue a continuance
Date: Tue, 22 Nov 2011 17:22:45 -0800
Dear J udge Howard,

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

Sincerely,
Zach Coughlin,
Sent: Sun 12/04/11 3:37 AM
26 of 57 1/29/2012 9:44 PM
To: robertsp@reno.gov; kadlicj@reno.gov; kadlicj@ci.reno.nv.us
I want you to move for a Rule 59 Motion to Set Aside or some other motion
to have the J udgment Set Aside. Your cop witness clearly had a driver's
license produced to him at the 6:49 mark of YOUR OWN DAMN VIDEO!
the prosecutorial codes you are held to and NRCP 11. Furher, what are you
going to say when the UPC from the alleged receipt appears on the purchased
receipt, in combination with Frontino's adamant assertion that they wouldn't,
in combination with the same from Crawford, in combination with Frontino
cashier, in combination with the "same UPC, hit the quanity number" practice
common at Walmart? Further, your own witness admitted on tape at the trial
that "he didn't have enough EVIDENCE to issue a citation so he arrested and
did a search incident to arrest" before you and Judge Howard could jump in
and cut him off. That's gametime. I will avalanche you with motion and
lawsuits if you don't fix this defamation you funded and supported, what with
you little 30 minutes witness coaching session that kept all the other litigants
waiting from 1:00 to 1:30 while you called in Frontino, Crawford, and
Braunworth. Wait till I get the video from Walmart that Frontino is hiding
from you, and don't you just want to know if some audio exists of the
interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
27 of 57 1/29/2012 9:44 PM
FW: your cop lying, see your video drivers license produce ap overview at
6:49 mark
privilege.
Sent: Sun 12/04/11 3:45 AM
"information" to issue a citation, and how, because they didn't, they had to
conduct a search incident to arrest, yet YOUR OWN DAMN VIDEO, THAT
YOU EFFING PRODUCED! SHOWS THE ACCUSED HANDING THEM
A DRIVERS LICENSE AND THEM CALLING IT IN TO CHECK FOR
PRIORS (THAT WILL SHOW UP IN DISPATCH REPORTS AND OTHER
DEFAMED ME AND YOU SPONSORED IT, CULTIVATED IT, AND
SMUGLY TALK SMACK TO ME IN COURT ABOUT MY NEEDING TO
USE THE BATHROOM AND HOW YOU HAVE "HAD TWO KIDS AND
CAN HOLD MY BLADDER" GENDER SEXUAL HARRASSMENT. I
GET EVICTED (WRONGLY, COMMERCIAL LEASES PRECLUDE
SUMMARY EVICTION WHERE NO CAUSE EVICTION NOTICES ARE
ALL THAT IS SERVED) BY THE RICHARD G. HILL GANGBANG
EXPRESS, WHILE BEING ASSAULTED BY NEVADA COURT
SERVICES, WHICH LISTS MY COURT APPOINTED ATTORNEY LEW
TAITEL AS "ASSOCIATED WITH" ON THE NEVADA COURT
SERVICES WEB SITE, LEW AGREES TO A CONTINUANCE OF THE
TRESPASS TRIAL BECAUSE RICHARD HILL NEEDS TO GO ON A
VACATION, BUT I CAN'T GET A FUCKING CONTINUANCE WHERE
RICHARD HILL IS APPLYING AN UNLAWFUL RENT DISTRAINT TO
MY EVIDENCE TO DEFEND AGAINST THIS BULLSHIT FUCKING
28 of 57 1/29/2012 9:44 PM
WALMART FIASCO! THEN AFTER TAITEL AGRESS TO A
CONTINUANCE, ONLY THEN AFTER REVIEWING MY PERSONAL
FILE, HE FIGURES OUT I AM SUING HIM, OR AT LEAST NEVADA
COURTS SERVICES. SOMEBODY PUT A NICE COLLECTION OF
VIDEOS UP ON YOUTUBE ABOUT IT, SOME CRAZY
DOCUMENTARY FILMMAKER. YOU OUGHT TO BE ASHAMED.

I CAN GIVE YOU UNTIL TUESDAY, AFTER THAT, I HAVE TO MAKE
MY MOVES AND FILE MY MOTIONS.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

Date: Sun, 4 Dec 2011 03:37:24 -0800
I want you to move for a Rule 59 Motion to Set Aside or some other motion
to have the J udgment Set Aside. Your cop witness clearly had a driver's
license produced to him at the 6:49 mark of YOUR OWN DAMN VIDEO!
29 of 57 1/29/2012 9:44 PM
the prosecutorial codes you are held to and NRCP 11. Furher, what are you
going to say when the UPC from the alleged receipt appears on the purchased
receipt, in combination with Frontino's adamant assertion that they wouldn't,
in combination with the same from Crawford, in combination with Frontino
cashier, in combination with the "same UPC, hit the quanity number" practice
common at Walmart? Further, your own witness admitted on tape at the trial
that "he didn't have enough EVIDENCE to issue a citation so he arrested and
did a search incident to arrest" before you and Judge Howard could jump in
and cut him off. That's gametime. I will avalanche you with motion and
lawsuits if you don't fix this defamation you funded and supported, what with
you little 30 minutes witness coaching session that kept all the other litigants
waiting from 1:00 to 1:30 while you called in Frontino, Crawford, and
Braunworth. Wait till I get the video from Walmart that Frontino is hiding
from you, and don't you just want to know if some audio exists of the
interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
30 of 57 1/29/2012 9:44 PM
6:49 mark
privilege.
Sent: Sun 12/04/11 4:05 AM
To: lcooley@rsic.org; voldenburg@rsic.org; rariwite@rsic.org; police@rsic.org; robertsp@reno.gov
"information" (their definition included personally identifiable information to
identify the accused sufficiently to issue a citation, A CURRENT NEVADA'S
DRIVERS LICENSE WOULD DO JUST FINE ON THAT ACCOUNT) to
issue a citation, and how, because they didn't, they had to conduct a search
incident to arrest, yet YOUR OWN DAMN VIDEO (OR RATHER,
WALMART'S, BUT ITS HARD TO SEE WHERE YOU GUYS END AND
WALMART BEGINS), THAT YOU EFFING PRODUCED (OR RATHER
THE RENO CITY ATTORNEY PRODUCED AFTER THE BOYS AT
WALMART "COMPILED" VIDEO, WHICH CURIOUSLY DID CONTAIN
A FUCKING SECOND OF VIDEO SHOWING ANY OF THE ALLEGED
CONCEALING OR CONSUMING THE ITEMS IN QUESTION! SHOWS
THE ACCUSED HANDING THEM A DRIVERS LICENSE AND THEM
CALLING IT IN TO CHECK FOR PRIORS (THAT WILL SHOW UP IN
DISPATCH REPORTS AND OTHER DOCUMENTATION). THESE
KEYSTONE COP EFFUPS HAVE DEFAMED ME AND YOU
SPONSORED IT, CULTIVATED IT.
I CAN GIVE YOU UNTIL TUESDAY TO MAKE A STRONG EFFORT TO
CORRECT THIS, AFTER THAT, I HAVE TO MAKE MY MOVES AND
FILE MY MOTIONS. JUDGE VAN WALRAVEN WOULD BE
THE OFFICERS ARE KAMERON CRAWFORD AND BRAUNWORTH, WHO CAME ACROSS A
31 of 57 1/29/2012 9:44 PM
FAR MORE COGNITIVELY IMPAIRED IN COURT THAN HE DID IN PERSON, TO AN EXTENT
THAT WOULD SUGGEST HE WAS DISHONORING THE LEGAL PROCESS BY HIS
say when the UPC from the alleged receipt appears on the purchased receipt,
in combination with Frontino's adamant assertion that they wouldn't, in
combination with the same from Crawford, in combination with Frontino
cashier, in combination with the "same UPC, hit the quantity number"
practice common at Walmart? Further, your Officer Crawford, as a witness,
admitted on tape at the trial that "he didn't have enough EVIDENCE to issue
a citation so he arrested and did a search incident to arrest" to get more
evidence before Reno City Attorney Roberts and Judge Howard could jump
in and cut him off. That's gametime. Frontino, Crawford, and Braunworth,
sat around joking like goofy frat boys the preceeding 30 minutes in the
hallway in front of the court room, like a group of 3 buddies who hang out all
the time, except, 2 get paid by you, and one gets paid by Wal-Mart, who pay
the people who pay you. Then all three of them wait around the hear the
verdict at 8 pm hours after Frontino and Crawford finished testifying.
Maybe the don't realize Judge Howard wasn't ruling on the Appeal, the Rule
59, 60 motions, Motion for Reconsideration, defamation, wrongful arrest,
false imprisonment lawsuits, etc. Fix it now while you can. Wait till I get the
video from Walmart that Frontino is hiding from you, and don't you just want
to know if some "other" audio or video exists of the interrogation.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
32 of 57 1/29/2012 9:44 PM
discovery request;
privilege.
Sent: Wed 12/07/11 1:16 AM
To: robertsp@reno.gov; kadlicj@reno.gov
Dear Ms. Roberts,

In the discovery you provided in this matter there is a fax from the RSIC to
you that has a fax heading for what appears to be "page 1" followed by pages
without that heading...then a heading with "page 4" etc... I want the entire
contents of anything provided by the RSIC and Walmart to you or anyone
connected with the Reno City Attorney or the Reno Municipal Court.
Further, I want all media provided by Walmart, and I question why you
needed 45 minutes with the three witness who testified at the November 30th,
2011 trial, from 1pm to 1:45pm. Additionally, you are hereby served a
NRCP 11 motion requiring you to correct the perjury you suborned in court
with respect to the patently contradictory testimony of Officer Crawford vis a
vis the video evidence you yourself provided in discovery.

Further, I spoke with Mr. Hazlett-Stevens shortly after the September 9, 2011
arrest in this matter demanding a copy of all documentation or discovery that
I had any right to. I was told I would not have any opportunity to review
such materials prior to the arraignment, which was not set for a full 30 days
33 of 57 1/29/2012 9:44 PM
out from the arrest. Do I not have a right to a copy of the pc sheet, arrest
report, and witness statements within 48 hours of the arrest? The fax to your
office from the RSIC is dated 9/12/2011, yet my written demands and
requests for such discovery and documentation were met with refusals to
provide such materials, and, in some case, claims that your office did not
even have such materials and would not get them until after the arraignment.
Further, I spoke with and provided written requests to RSIC Sargent
Avansino within 2 days after the arrest and he refused to provide the
materials, as did the Reno Municipal Court. Please alert the court to any
wrongdoing on your's or the Reno City Attorney or the RSIC part in this
regard in prejudicing my ability to defend my case by delaying the
production of essential discovery, then refusing to agree to a continuance at
trial, after earlier providing a written agreement to such a continuance.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
34 of 57 1/29/2012 9:44 PM
RE: your failure to propound discovery
Sent: Thu 12/08/11 3:44 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov
Mr. Hazlett-Stevens,

We did definately talk on the phone regarding the matter to which I do not
have representation, the RSIC arrest case 11 DR 22176 2I for which Deputy
City Attorney Pam Roberts is the prosecutor. I was denied my Sixth
Amendment right to court appointed defense counsel in that matter, and
represented myself. As such, there is no rule precluded you from
communicating with me about 11 DR 22176 2I. You did speak with me
about that. I called you within a couple days of the September 9th, 2011
arrest in that matter describing my exigent desire to obtain a copy of the
discovery. I was transferred to you and we spoke at length about it, you
describing why you could not give it to me. Is it your contention that your
office or the State does not have a duty to provide the defendant a copy of
certain pieces of discovery within 48 hours of arrest?

Regarding the matter for which Mr. Puentes took the baton from Mr. Taitel, is
it clear to you how Mr. Taitel was somehow, apparently, able to assent to a
continuance, only to, apparently, find some need to pass the baton to Mr.
Puentes very, very shortly thereafter? Why did Mr. Taitel's status as attorney
of record change? Was it due to a conflict? Why didn't that conflict prevent
Mr. Taitel from abstaining from assenting to the continuance in the trespass
case, which was scheduled for trial December 13, 2011?

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
35 of 57 1/29/2012 9:44 PM
fax: 949 667 7402
privilege.

Date: Wed, 7 Dec 2011 07:34:25 -0800
From: Hazlett-StevensC@reno.gov
Subject: Re: your failure to propound discovery
Mr. Coughlin. You are represented by counsel and I cannot correspond with you. I have never correponded
with you, and your statement that you spoke with me is false. I have never spoken with you. You may have
your attorney, Roberto Puentes, contact me with any discovery issues or issues regarding the City's Motion to
Continue. Please do not correspond with me regarding this case in the future. As an attorney, you are fully
aware that I cannot communicate with a you as a represented party. Do not contact me without your counsel.

Thank you,

Chris
Christopher Hazlett-Stevens
Deputy City Attorney
City of Reno
Tel: 326-6628
Fax: 334-4226

ATTORNEY-CLI ENT PRIVILEGED

This e-mail message transmission and any documents, files or previous e-mail messages attached to it, are
confidential and are protected by the attorney-client privilege and/or work product doctrine. If you are not the
intended recipient or a person responsible for delivering it to the intended recipient you are hereby notified that
any review, disclosure, copying, dissemination, distribution or use of any of the information contained in, or
attached to this e-mail transmission is STRICTLY PROHI BI TED. I f you have received this transmission in error,
please immediately notify us by forwarding this e-mail to the sender or by telephone at (775) 334-2050 and
then delete the message and its attachments.
36 of 57 1/29/2012 9:44 PM
To: <hazlett-stevensc@reno.gov>
Date: Wed, 7 Dec 2011 01:48:03 -0800
Subject: your failure to propound discovery

Dear Mr. Hazlett-Stevens,

I am writing to request a copy of any and all discovery, pleadings, documentation,
correspondences, or media in any way connected to the trespass case against me for which
Lew Taitel was apparently my court appointed attorney, but whom no longer is. Further, I
wish to be copied on everything past and present in any way related to this matter until
and after I procure another attorney. I did not agree to the continuance you sought, nor
was I informed you were seeking it. I find it particularly troubling that a continuance was
granted in the trespass case to the same man who is applying an unlawful rent distraint on
both my client files, personal property, AND THE EXCLUPATING EVIDENCE I NEED
TO DEFEND MYSELF IN THE PETIT LARCENY CASE FOR WHICH I DETAIL THE
COMPLAINTS I HAVE AGAINST YOU AND YOUR OFFICE'S HANDLING
BELOW. NO CONTINUANCE WAS GRANTED OR AGREED TO AT TRIAL BY
THE RMC OR MS. ROBERTS, PERHAPS SHE WAS TOO BUSY ALLEGEDLY
SUBORNING THE PERJ URY OF RSIC OFFICER KAMERON CRAWFORD.

In the discovery your office provided in the petit larceny matter Ms. Roberts prosecuted
against me there is a fax from the RSIC to you that has a fax heading for what appears to
be "page 1" followed by pages without that heading...then a heading with "page 4" etc... I
want the entire contents of anything provided by the RSIC and Walmart to you or anyone
connected with the Reno City Attorney or the Reno Municipal Court. Further, I want all
media provided by Walmart, and I question why you needed 45 minutes with the three
witness who testified at the November 30th, 2011 trial, from 1pm to 1:45pm.
Additionally, you are hereby served a NRCP 11 motion requiring you to correct the
perjury you suborned in court with respect to the patently contradictory testimony of
Officer Crawford vis a vis the video evidence you yourself provided in discovery.

Further, I spoke with you, Mr. Hazlett-Stevens, shortly after the September 9, 2011 arrest
in this matter demanding a copy of all documentation or discovery that I had any right to.
I was told I would not have any opportunity to review such materials prior to the
arraignment, which was not set for a full 30 days out from the arrest. Do I not have a
right to a copy of the pc sheet, arrest report, and witness statements within 48 hours of the
37 of 57 1/29/2012 9:44 PM
Here is service of the Motion for a New Trial, Set Aside, Va
arrest? The fax to your office from the RSIC is dated 9/12/2011, yet my written demands
and requests for such discovery and documentation were met with refusals to provide such
materials, and, in some case, claims that your office did not even have such materials and
would not get them until after the arraignment. Further, I spoke with and provided written
requests to RSIC Sargent Avansino within 2 days after the arrest and he refused to provide
the materials, as did the Reno Municipal Court. Please alert the court to any wrongdoing
on your's or the Reno City Attorney or the RSIC part in this regard in prejudicing my
ability to defend my case by delaying the production of essential discovery, then refusing
to agree to a continuance at trial, after earlier providing a written agreement to such a
continuance.

Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
not the intended recipient or an agent responsible for delivering it to the intended recipient, y ou are hereby notified that

Sent: Mon 12/12/11 9:52 PM
To: hazlett-stevensc@reno.gov; robertsp@reno.gov; kadlicj@reno.gov
38 of 57 1/29/2012 9:44 PM
Is it about time for you to get that CD/DVD that Walmar'ts AP guy Faustino
handed the two Reno Sparks Indian Colony officers when they were leading
the suspect away in cuffs...not the video you gave me of sling blade
badgering the lawyer I got those two videos you gave me which just the
badgering in the interrogation room. I am talking about the cd/dvd that
Walmart's guy gave them as they were walking out....Doesn't it seem like you
really need to get that now, to stay on the right side of Nifong? You
remember Nifong, don't you. Walmart ap guy sit there on the stand, under
penalty of perjury and testify that no video was collected in any way related
to me or this case aside from the 2 interrogation room videos you provided
(with a highly suspect 14mb "codec" program required to view the
videos....can you indicate why that is necessary to watch a simple old .avi
file?).
why did you suborn the perjury of both the walmart guy and the officers
regarding no other video existing? I can't figure that one out. Ms. Roberts,
don't you practice in RMC quite a bit? Maybe I am confused, but doesn't the
RMC rules permit serving a government attorney such as yourself via email?
What do you have against email? It is economical for those of use who don't
have such public largesse to work with. Here is service of the Motion for a
New Trial, Set Aside, Vacate, etc., etc:
https://skydrive.live.com/redir.aspx?cid=43084638f32f5f28&resid=43084638F32F5F28!1031&parid=root
Its only something like 1,000 pages.
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
39 of 57 1/29/2012 9:44 PM
FW: records request
privilege.
Date: Mon,
Sent: Tue 12/13/11 4:02 PM
2 attachments
RECORD_REQUEST_FORM walmart RMC 11 CR 22176 IC 110627 trial cd and orders to RMC 12 8 11
signed.pdf (453.4 KB) , RECORD_REQUEST_FORM_2010[1] rmc trespass 11 13 11 records request 11 CR
22185 City of Reno v Coughlin signed.pdf (510.9 KB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
40 of 57 1/29/2012 9:44 PM
To: renomunirecords@reno.gov; fiskm@reno.gov
Subject: records request
Date: Tue, 13 Dec 2011 16:02:02 -0800
fax number 949 667 7402
Dear Mr. Fisk,
I really need a copy of the audio of the Trial in 11 CR 22176 and a copy of
both the Contempt Order and the Guilty Verdict (Veronica said she would fax
one and that the RMC never sent or served me a paper copy beyond shoving
some papers in my fax when I was being handcuffed then taking them away
from me separately in a huff when I stated that I might like to know what it
was I was to sign or read it (or 6th Amendment, etc). However, I have
received no fax of those Orders as Veronica said she would send me
yesterday. She said it in an angry unprofessional tone and I am hereby
complaining in writing about that and Marshall Monte's angry threatening
tone and language to me at the arraingment of October 11, 2011. Please
place a copy of this in their personnel files and the record in both of my CR
RMC cases.
I was told by a RMC filing office counter clerk yesterday that I was not
allowed to get a copy of the audio of my 11 30, 2011 hearing before J udge
Howard, that I would only be able to get a transcript after using the one
transcriptionist the RMC approves of and after paying her a substantial
amount of money up front, but that ultimately, the audio would never be
made available to me.
Is this the case? Please respond in writing or email me a copy of the audio
files and the pdf's or whatever file type the Contempt Order and Guilty
Verdict etc, in 11 CR 22176 are in, in addition please provide the Motion to
Withdraw and Notice of appearance in 11 CR 22185 by Taitel and then
Puentes. I sent you the video exhibits with the same mysterious Verint codec
that the RMC provided me. Why a simple .avi file needs some mysterious
41 of 57 1/29/2012 9:44 PM
codec that is about 13mb in size is truly a mystery to me.
12 11 11 Defendants Motion for New Trial, Set Aside, Vacate Judgment/Conviction of underlying crime and
Contempt in Court's Presence finding/ IFP Petition/ Motion for Reconsideration/Notice of Appeal, Case Statment
in case: city of reno v coughlin RMC 11 CR 22176; Records Request form Defendant and Request for
Transcription at Public's Expense and Request for a copy of the audio recording of the Trial of 11 30, 2011 1:45
pm to end in RMC 11 CR 22176.
Additionally, I never received service of any Notice of Appearance nor a Motion to Withdraw by Lew Taitel, Esq.
the attorney appointed to represent me as required by RMCR Rule 3: Authorization to Represent
A. Attorneys representing defendants shall promptly serve written notice of
their appearance with the City Attorney and file the same with the Court.
B. An attorney desiring to withdraw from a case shall file a motion with the
court and serve the City Attorney with the same. The court may rule on
the motion or set a hearing."
Further, RMCR state: "Rule 5: Motions by Facsimile
A. All rules and procedures that apply to motions filed in person at the
court shall also apply to motions filed by facsimile, except as otherwise
specified in this rule.
B. All persons are eligible to use motion-by-facsimile procedures.
C. All motions filed by facsimile must be accompanied by a cover sheet
which must include the persons name, address, fax number and
telephone number.
D. All facsimile motions filed by an attorney must include the attorney's
name, the firms name, address, fax number and telephone number. In
addition, the attorneys state bar number must be conspicuously
displayed on the cover sheet.
E. All motions filed by facsimile must be accompanied by proof of service.
Service may be accomplished by facsimile when the receiving party is a
governmental agency, an attorney, or with the consent of the receiving
party. If service of the motion is accomplished by facsimile the 3-day
allowance for mailing shall not be computed into the time for response.
F. A defense attorney filing a motion in the first instance must also file a
proper authorization to represent.
G. Any motion received by the court after 4:30 p.m. or on a non-court day
shall be filed on the following court day.
Rule 6: Continuances
No continuance shall be granted, including a stipulated continuance, except
for good cause. A motion or stipulation for continuance must state the reason
therefore and whether or not any continuance has previously been sought or
granted."
fax number 949 667 7402
42 of 57 1/29/2012 9:44 PM
And: "Rule 9: Appeals to District Court
Except as otherwise provided in NRS 177.015 a defendant in a criminal action
tried before a Municipal Court J udge may appeal from the final judgment
therein to the Second Judicial District Court, at any time within 10 days from
the date that judgment is rendered."
Judge Howard informed me during his oral pronounce of his Contempt Order and Guilty Verdict on 11 30,2011
that he would afford me an additional 3 non judicial days to file a Notice of Appeal or any other Motion, Request
for Reconsideration, or other Motion seeking relief from his 11 30 2011 rulings on account of his sua sponte, with
no possibility of Stay or prior judicial review ordering his Marshalls to slam be into handcuffs and throw me into
Jail, kind of like in Houston v. 8th Judicial District Court, escept Judge Howard didn't cool down like Judge
Pomeranz did and Houston wasn't defending a criminal charge that carred a possibility of incarceration of
substantial length after being denied his 6th Amendment Right to Counsel. I am formally complaining about
Judge Howard;s conduct in that regard, please place a copy of this in his personnel file and let me know whether
you think a Complaint to the Judicial Discipline Commission would be appropriate, in your professional opinion.
I filed my Notice of Appeal in 11 cr 22176 yesterday with the RMC via email, as previously given permission to do
by the RMC. To the extent that was ineffective, let this writing act as a Notice of Appeal and agreement to pay
all charges required for such.
PROOF OF SERVICE:
I emailed a copy of this to Pam Roberts for the Plaintiff City of Reno on this date, a true and correct copy and
further email her a copy of all the 12 11 11 MOtion for New Trial, etc. yesterday to:
Pamela G Roberts
Company: Reno City Attorney's Office - Criminal Divison
Address: P.O. Box 1900
Reno
, NV
89505
Phone Number: 775-334-2050
Fax number: 775-334-2420
Email: robertsp@reno.gov
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
43 of 57 1/29/2012 9:44 PM
RMC 11 CR 22176
privilege.
Sent: Thu 12/15/11 11:59 PM
ZachCoughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
FAX COVER SHEET
44 of 57 1/29/2012 9:44 PM
TO: .RMC et al
Dear RMC,



T
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
45 of 57 1/29/2012 9:44 PM
FW: RMC 11 CR 22176
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Fri 12/16/11 12:00 AM
1 attachment
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
46 of 57 1/29/2012 9:44 PM
Nevada Bar No: 9473
privilege.
lopezv@reno.gov
Date: Thu, 15 Dec 2011 23:59:45 -0800
ZachCoughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
47 of 57 1/29/2012 9:44 PM
FAX COVER SHEET
TO: .RMC et al
Dear RMC,


48 of 57 1/29/2012 9:44 PM
emergency filings

T
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Fri 12/16/11 7:55 AM
2 attachments
12 16 11 emergency filing with fax cover sheet rmc 11 cr 22176.pdf (330.0 KB) , fax cover sheet and
notice of denial of service clarification motion.pdf (202.1 KB)
49 of 57 1/29/2012 9:44 PM
FW: 121 River Rock
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Sat 12/17/11 12:15 AM
50 of 57 1/29/2012 9:44 PM
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.

Date: Wed, 14 Dec 2011 15:43:38 -0800
Dear Mr. Baker,
51 of 57 1/29/2012 9:44 PM
Sincerely,
Zach Coughlin, Esq.
Reno, NV 89501
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Date: Wed, 14 Dec 2011 13:50:02 -0800
Mr. Coughlin:
52 of 57 1/29/2012 9:44 PM



652 Forest Street
Reno, Nevada 89509
Phone: (775) 348-0888
Fax: (775) 348-0858

This e-mail may contain legally privileged or confidential information. If you arenot theintended recipient, please do not read, copy, use, or disclosethis
communication to anyone other than the intended recipient. If you havereceived thismessage in error, please notify thesender and delete theemail message from
To ensure compliancewith requirements imposed by theIRS, weinform you that any U.S. federal tax advice contained in thiscommunication (including any
attachments) isnot 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,

Sent: Mon 12/19/11 5:15 PM
1 attachment
RMC 11 CR 22176 12 19 11 filing with 3 exhibits.pdf (9.1 MB)
53 of 57 1/29/2012 9:44 PM
no reply from Transcriptionist
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
privilege.
Sent: Wed 12/21/11 12:02 AM
Zach Coughlin, Esq.
Reno, NV 89501
54 of 57 1/29/2012 9:44 PM
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473

Dear RMC,
It is my understanding the Judge Howard's order regarding email does not extend to the
address to which I am sending this correspondence: renomunirecords@reno.gov which is
the email address filing office supervisor Donna Ballard indicated to me was acceptable for
sending correspondence and filings to the RMC in lieu of faxes. I am writing because the
email address I was provided for RMC "official transcriptionist" Pam Longoni yielded a
"return to sender/failed transmission" message when I wrote to the email address provided
for her: plongoni@charter.net. Further, please see the forwarded email below that I sent to
Ms. Longoni. I have not received a return call from her regarding my recent messages to
her. I was told by a RMC filing office counter employee that I must get the transcript
through Ms. Longoni, as she is the "official transcriptionist" for the RMC. Please confirm
that I am no able to have another certified court reporter or transcriptionist create the
official transcript and indicate by what date this must be done, how it must be done, etc.

I was told by RMC filing office staff, including Ms. Ballard, that the RMC would not accept
any filings fees, bonds, or any other payments from me in relation to the underlying case 11
CR22176 2I or the appeal of that matter given that the RMC was holding the bail money I
paid into the court. If this is not the case or if I must pay anything into the RMC to ensure
that my appeal goes forward, please indicate as much in writing and with particularity. If I
am able to use any other transcriptionists and or the RMC has a list of such with contact
information, please provide such in writing.

Sincerely,

/s/Zach Coughlin
Zach Coughlin, Defendant/Appellant
55 of 57 1/29/2012 9:44 PM
privilege.

Subject: where to pay and how much
Date: Fri, 16 Dec 2011 22:44:37 -0800
Dear Ms. Longoni,
I have left you several messages. I wish to pay whatever it is I have to pay to get this
appeal transcript going and to preserve all my rights to review of the decision in RMC 11 cr
22176. Further, I would like a copy of the audio from the hearing as soon as possible.
Please provide specific detailed instructions as to how to pay and how much and anything
else I need to do.

Sincerely,

Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 229-6737
fax: 949 667 7402
Nevada Bar No: 9473
56 of 57 1/29/2012 9:44 PM
privilege.
57 of 57 1/29/2012 9:44 PM
EXHIBIT #2
EXHIBIT #2
F I L E D
Electronically
01-30-2012:04:48:12 PM
Clerk of the Court
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Document Code: 1520
Zach Coughlin, Esq.
Nevada Bar No: !"#
1!22 E. th $t. %2
&eno, N' (512
)ele: ""5*##(*(11(
+a,: !*--"*"!02
/ttorne0 1or /22ellant Zach Coughlin
3N )4E $EC5ND 67D3C3/8 D3$)&3C) C57&) 5+ )4E $)/)E 5+ NE'/D/
3N /ND +5& )4E C57N)9 5+ :/$45E
Z/C4 C57;483N<
/22ellant,
vs.
C3)9 5+ &EN5
&es2ondents.
=
=
=
=
=
=
=
=
=
=
=
C/$E N5: C&11*20-!
DE>). N5: 10
DECLARATION OF ZACHARY BARKER COUGHLIN, ESQ.
Z/C4/&9 B/&?E& C57;483N, E$@., Aeing 1irst dul0 sBorn, de2oses and under 2enalt0
o1 2erCur0 avers:
1. 3 am a resident o1 the Cit0 o1 &eno, Count0 o1 :ashoe, $tate o1 Nevada, and over 1( 0ears
o1 age. )his declaration is Aased on m0 2ersonal DnoBledge, e,ce2t those matters stated on
in1ormation and Aelie1, and as to those items 3 Aelieve them to Ae true. )his declaration is made in
su22ort o1 /22ellantEs 522osition to Fotion to Dismiss /22eal, and re2resents m0 testimon0 i1
called on to 2resent same in court.
- 1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2. 3 am an attorne0 dul0 licensed as such A0 the $tate o1 Nevada to 2ractice Ae1ore all courts
o1 this $tate and Ae1ore the 7nited $tates >atent and )rademarD 511ice, and the 7nited $tates
BanDru2tc0 Court 1or the District o1 Nevada.
#. F0 o11ice re2resents the /22ellant, Zach Coughlin, in this matter.
!. F0 o11ice Bas never 2ro2erl0 served Bith the instant motion A0 mail or hand*deliver0. C1.,
N&C> 5.
5. 3 Brote to the &eno Funici2al Court at the email address listed 1or corres2ondence on their
BeAsite: renomunirecords.reno.gov in addition to emailing AacD and 1orth Bith and s2eaDing on
the 2hone Bith &eno Funici2al Court G$enior Court $2ecialistG Donna Ballard, Bhom identi1ied
hersel1 to me on several occasions as the +iling 511icer $u2ervisor, as did several other &FC 1iling
o11icer 2ersonnel. Fs. Ballard gave me 2ermission to 1ile 2a2ers and 2leadings in the &FC via
email to the 1olloBing address: &enoFuni&ecords.reno.gov. Fs. Ballard assured me that this Bas
a22reciated given that 1a,es did not come through as clearl0 and that longer 1ilings Bould
unnecessaril0 ta, their 1a, machines. Ballard indicated that the 1ilings 3 emailed to her and the
&FC Bould Ae 2rinted out and included in the &ecord on /22eal should an /22eal Ae necessar0 or
2ursued. 4oBever, given the 2rimac0 o1 a Notice o1 /22eal Heven Bhere, as here, there Bas a
timel0 1iled tolling motion=, 3 Borried that the &FC Bould suddenl0 somehoB tr0 to assert that the
1ilings 3 emailed to the authoriIed &FC email address Bould not Ae acce2ted, and, there1ore, on at
least one occasion, 3 2rinted a G1our 2age 2er 2ageG version o1 Bhat Bas 1iled A0 email, and Bent
into the &FC and had it 1ile stam2ed, GCust in caseG. /las, Bhat Bound u2 in the &ecord on /22eal
Bas an illegiAle scanning o1 this G1our 2age 2er 2ageG version, not the much clearer Gone 2age 2er
2ageG version Ballard 2romised me Bould a22ear in the &ecord on /22eal.
- 2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-. 3t Bas on DecemAer 1#th, 2011 Bhen 3 2ersonall0 hand delivered that version o1 the Notice
o1 /22eal to the &FC 1or 1iling, and at that time an &FC 1iling o11ice clerD Bhom 3 Aelieve is
named G)omG con1irmed to me and Ballard that 'eronica 8o2eI has veri1ied to him that m0 Notice
o1 /22eal Bas timel0 1iled on that da0 and that 6udge 4oBard had e,2ressl0 a22roved so 1iling a
Notice o1 /22eal at that time and ruled that so doing Bould Ae and Bas timel0.
". 3n accordance Bith the 1actors enunciated A0 the Nevada $u2reme Court in BrunIell v.
;olden ;ate Nat. BanD, (5 Nev. #!5, #!, !55 2.2d #1 H1-= and as set 1orth in $C& 155, 3 shoB
the Court:
a= 3 have Aeen 2racticing laB in Nevada 1or a22ro,imatel0 " 0ears. F0 2ractice em2hasiIes
1amil0 laB, 2atent laB, 1oreclosure de1ense, real estate, real estate litigation, landlord*tenant BorD,
consumer rights, domestic violence advocac0, em2lo0ment laB, Ausiness, Ausiness litigation and
general commercial laB. F0 current standard hourl0 rate is J225.00 2er hour. 72on inquir0, 3
understand that rates to Ae Bell Bithin the range o1 1ees charged A0 other attorne0s Bith com2araAle
quali1ications in the communit0 1or similar services. )he 1ees charged Bere actuall0, reasonaAl0 and
necessaril0 incurred.
A= )he BorD that Bas actuall0 2er1ormed in connection Bith the instant o22osition is itemiIed
thusl0 and has Aeen actuall0 incurred and Ailled to m0 client: J1,500.00 1or 2re2aring and 1iling this
522osition to Fotion to Dismiss /22eal, Bhich Bas necessar0 and reasonaAle under the
circumstances.
(. 3 have 2ersonall0 revieBed all attached e,hiAits to the o22osition re1erenced aAove, and
each e,hiAit is a true and correct co20 o1 Bhat it 2ur2orts to Ae.
. 3, Zach Coughlin, do hereA0 sBear, under 2enalt0 o1 2erCur0, that the 1olloBing e,cer2t
1rom the end o1 the audio record o1 the NovemAer #0th, 2011 )rial in &FC 11 C& 221"- re2resents
- 3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
a com2letel0 true and accurate transcri2tion Hmade 1rom the CD o1 the )rial that the undersigned
2urchased 1rom the &FC and taDen 1rom the 1ile named: GKFC+)&BLM201111#0*
20##M01cca11!51ed00G = o1 Bhat Bas said in o2en court, on the record, Aeginning at (:##:11 2m
on NovemAer #0th, 2011 in 6udge 4oBardEs court room:
G64: alright Be are AacD on the record in regard to Cit0 v. Zachar0 Coughlin.
3 Bas admittedl0 remiss in not advising Fr. Coughlin o1 his right to a22eal.
:e do Bant to taDe care o1 that noB on the record. Fr. Coughlin, 0ou have
the right to a22eal the decision o1 this Court. 9ou can do so A0 1iling a Notice
o1 /22eal. Customaril0, itEs 10 da0s and thats, uh, 3Em sure 0ou are 1ull0
aBare o1 that...:hat 3 am going to do is grant an e,tension to that statute in
light o1 the 1act that 0ou Bill not Ae released 1rom custod0 until DecemAer
#rd, so 0our 10 da0s Bill run e11ective DecemAer #rd at ( 2m, so 0ou Bill
have 10 da0s 1rom that date to 1ile a Notice o1 /22eal Bith this Court, noB
once 0ou 1ile 0our Notice o1 /22eal there are several things that 0ou Bill have
to do, 2rinci2al among those is to oAtain a co20 o1 the transcri2t at 0our
e,2ense. 5nce the transcri2t has Aeen 1orBarded to the District Court, there is
no )rial de novo, 0ou are 2roAaAl0 aBare that the District Court Cudge Bill
revieB the 1our corners o1 the transcri2t to determine, one, Bhether this court
has made an0 legal errors that Bould Custi10 a reversal o1 this matter or
Bhether there is su11icient evidence Bithin the transcri2t to Custi10 the 1inding
o1 guilt that 3 have made here toda0. 3s there an0 questions at all Bith regard
to the a22eal 2rocessN
ZC: )he availaAilit0 o1 a $ta0, that 3 guess Bould go more toBards the
1inding o1 Contem2tN 7m, Bhen 0ou sa0 Ga22eal 2rocessG are 0ou re1erring
to...N
64: )he 1iling o1 a22eal in regard to the 2etit the1t.
ZC: Not in regard to the Contem2tN
64: No, thats a summar0 2roceeding and Be are going to go 1orBard Bith
that. 5ne thing that 3 Bill sa0 in regard to the 2etit the1t )rial and suAsequent
sentencing, hoBever, its m0 recollection, im2ro2erl0, that 0ou had 1ailed to
a22ear at the 2revious 2roceeding, and thatEs not correct, uh, there Bas another
reason as to Bh0 Be Bere unaAle to 2roceed, so 3 am going to delete the 2!
hours o1 communit0 service, the 1ine o1 J#-0 Bill stand. /lright, an0 other
questions involving the /22eal 2rocessN
ZC: 9es, to the e,tent m0 laB 2racticeEs clients, that their cases Bill Ae
undul0 2reCudiced A0 0our incarcerating me right noB...
- 4
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
64: 3 am standing A0 that and 3 Bish 0ou Bould have thought aAout that a1ter
each admonishment that 3 gave 0ou during the )rial.
ZC: 9ou are saddened A0 that.
64: :e are in recess. G Hcommotion o1 Farshals can Ae heard and the audio
recording o1 the record o1 the )rial ends=.
10. 4oBever, Bhat is reall0 interesting is that the &eno Cit0 /ttorne0O&FCO and &$3C >olice
all re1used to 2rovide even an arrest re2ort or 2roAaAle cause sheet 1or one month 1olloBing the
$e2temAer , 2011 arrest at the center o1 this matter. )he &eno Cit0 /ttorne0Es o11ice, Hincluding in
a tele2hone conversation 3 had Bith 4aIlett*$tevens, Esq.= re2eatedl0 re1used to 2rovide an arrest
re2ort, 2roAaAle cause sheet etc., indicating that the0 Gdid not even have those thingsG throughout the
2eriod AetBeen the OO11 arrest and the court date o1 5ctoAer 10, 2011, des2ite the 1act that
suAsequentl0 2ro2ounded discover0 1rom &oAerts shoBs the &eno Cit0 /ttorne0Es 511ice Bas 1a,ed
these items A0 the &$3C Han the &$3C, &$3C $argent /vansino, etc. all gave me the same song and
ance aAout GBe donEt have it, canEt give it to 0ou even i1 Be didG, etc., etc..
11. &FC 6udge 4oBard runs the &eno Funici2al Court Bith an iron 1ist, sentencing
attorne0s Bho sa0 GBoBG under their Areath u2on some incrediAle de2arture 1rom due 2rocess
1undamentals A0 6udge 4oBard to a summar0 contem2t order requiring 6udge 4oBardEs Farshals to
essentiall0 gang gro2e an attorne0, DnocD his la2to2 out o1 his hands so he cannot save his trial
notes, and taDe him aBa0 to a three da0 Aed and AreaD1ast u2 at 11 >arr Blvd, com2lete Bith no
o22ortunit0 to maDe a 2hone call to arrange the avoidance o1 2reCudicing client matters. 6udge
4oBard attem2ted to s2eci10 his rationale and Aasis 1or a summar0 contem2t 1inding A0 rotel0 read0
o11 some 1orm document or section o1 his Bench BooD checDing a Ao, Bith some generic
descri2tion liDe Gcommitted contem2t contrar0 to the administration o1 Custice or in derogation o1 the
authorit0 o1 the courtG in a manner that does not quite satis1ies the requirements that 6ose2h
- 5
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4ouston 1ought so eloquentl0 1or in 4ouston v. Eighth. 6udicial District Court, 122 Nev. /dv. 52.
51 H200-=. 6udge 4oBard maDes 5rders 1ar e,ceeding his Curisdiction, 5rdering memAers o1 the
2uAlic to never contact an0one at all associated Bith the &eno Funici2al Court A0 email, or even
use general email addresses liDe renomunirecords.reno.gov, Cum2ing into tra11ic cases in other
Cudges de2artments to have his 1iling o11ice o2eratives issue invective and threats, sometimes in the
1orm o1 Aeing accosted A0 1ive armed strangers demanding to DnoB in1ormation to Bhich the0 have
no right, in an aBesome shoB o1 1orce, 2oBer, control, and 1ascism. )he GDocDetG in this matter
contains no indication o1 a Notice o1 Entr0 o1 5rder ever Aeing made in the com2letel0 under 6udge
4oBardEs thumA and control GdocDetG in this matter. $everal 2ersonnel Hincluding a 0ounger 1emale
3 Bas Arought Bhen 3 asDed to veri10 something Bith a su2ervisor= in the &FC +iling 511ice
admitted to me that the &FC 1iling o11ice has Iero oversight over 6udge 4oBard, nor an0 s0stem o1
checDs and Aalances, as the0 entire 1iling o11ice coBers in 1ear o1 the Brath o1 6udge 4oBard liDe
some 2oor Aattered s2ouse ho2ing to avoid another three da0 tri2 to the hole 1or some minor
transgression, such as maDing e0e contact Bith him.
6udge 4oBard ignored his oBn GBench BooDG and Bent so 1ar outside his Curisdiction as to
resort to citing a case 1rom Fichigan 1or the 2ro2osition that 3, an indigent individual, Bas not
entitled to a22ointed counsel Bhere, as here, the charge carried Bith it the 2ossiAilit0 o1 Cail time.
/rgersinger v. 4amlin, !0" 7.$. 25, 2 $.Ct. H200-= held that i1 the 2ossiAle sentence includes an0
Cail time the de1endant must Ae a11orded an attorne0. 5ne thing is clear, at the conclusion o1
the11O#0O11 trial, 6udge 4oBardEs FarshalEs suddenl0 assaulted Coughlin, 2lacing him in cu11s,
re1using to alloB him to save his trial notes on his la2to2, then shoved some 2a2ers in CoughlinEs
1ace, demanding Coughlin sign them Bithout an0 o22ortunit0 to revieB Bhat the0 said or DnoB
Bhat the0 Bere. /s is so t02ical o1 those com2letel0 corru2ted A0 their un1ettered 2oBer, these
- 6
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Farshals quicDl0 Bere irDed at CoughlinEs meager attem2ts to inquire as to Bhat it Bas the0 Banted
him to sign, 2ulling the 2a2ers aBa0 1rom Coughlin Bhile re1using to e,2lain at all, mocDing him
Bith their derision and taunts that the0 Bould sim2l0 G2ut that 0ou re1usedG in the AlanD on the
1rom..../22arentl0 this shame1ul scene is tantamount to service o1 an order to some, hoBever, as
:ashoe Count0 6ail &ecords reveal, the Aelongings Coughlin came Bith and le1t Bith incident to his
# da0 getaBa0 tri2 to >arr, courtes0 o1 6udge 4oBardEs intem2erance shoB conclusivel0 that those
Farshals did not ever leave an 5rder o1 11O#0O11 Bith Coughlin or in an0 Ba0 alloB Coughlin to
maintain 2ossession o1 such, or even to later access it.
12. +urther, 6udge 4oBard<s 6udicial /ssistant, u2on CoughlinEs release 1rom :CDC,
re1used to 2rovide Coughlin a co20 o1 an0 such 5rder, then this 'eronica 8o2eI lied to Coughlin,
2romising to 1a, him a co20 in a darDl0 menacing tone, 0et 1ailing to ever do so. +urther, Bhat oral
2ronouncements Bere issued A0 6udge 4oBard at the 11O#0O11 )rialEs conclusion, certainl0 did not
re1lect all that Bas Britten in the ;uilt0 'erdict and concomitant $ummar0 Contem2t 5rder, as
such, no deadline 1or 1iling an a22eal suACect to &FC& could Aegin running until 2ro2er service o1
an0 such 5rder occurred, something that has 0et to Ae made clear, Bhether Gconstructive serviceG or
otherBise. >rior to divulging the &ecord on /22eal to the District Court, the &FC +iling 511ice
certainl0 never let the undersigned see an0 GdocDetG, much less a certi1ied one. &egardless, 3 Bas
re1used on multi2le instances A0 &FC 1iling o11ice 2ersonnel an0 co20 o1, vieBing, or access to the
docDet in 11 C& 221"-, Aut the same gentleman clerD H2erha2s named G)omG= did con1irm to me, on
DecemAer 1#th, 2011, 3 Aelieve, that, as o1 that date, there Bas aAsolutel0 no entr0 or indication
an0Bhere in his s0stem or an0 records, electronic or otherBise to Bhich he is normall0 a11orded
access to indicate an0 entries had Aeen made in the docDet since 2rior to the 11O#0O11 )rial in that
matter. )he undersigned sus2ects Bhat 6udge 4oBard hates so much aAout email is that he cannot
- 7
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
intimidate a com2uter into sa0ing something Bas 1ile or received at a di11erent time than that Bhich
the 1Es and 0Es o1 the com2uterEs 2rocessor tell it Bas the time and date, much less than manner or
content, all o1 Bhich is recorded in magni1icent clarit0, electronicall0, Bhen one sends H2ursuant to
an e,2ress 2ermission to so 1ile 2leadings in the &FC given A0 &FC +iling 511ice $u2ervisor
Donna Ballard= in an emailed 2leading.
1#. +urther, it seems ill advised 1or 6ohn ?adlic and the &eno Cit0 /ttorne0Es 511ice in
general to remain on this case, his name listed as 1iling 2leadings Hhe is listed Bith >am &oAerts as
G/ttorne0Es 1or the &es2ondentsG in the instant Fotion to Dismiss=, as ?adlic has Aeen DnoBn to asD
the undersignedEs 1amil0 2h0sician 1ather, in 1ront o1 the undersigned 1or a 2rescri2tion o1 this or
that or to Ae 1it in here or there and Bho DnoBs Bhat other Beird con1licts o1 interest Hie, Bhether or
not a certain 1amil0 2h0sician has a demonstrated tendenc0 toBard a FPnchhausennn by Proxy
st0le o1 2arenting, etc., etc.: htt2:OOemedicine.medsca2e.comOarticleO2525(*overvieB=, or Bhere
?adlic and Dr. CoughlinEs relationshi2 has a22arentl0 Aeen strained A0 Dr. Coughlin 1ailure to GtaDe
sidesG su11icient to 2lease Cit0 /ttorne0 ?adlic 2ursuant to the Cit0 /ttorne0 ?adlicEs divorce 1rom
his 1ormer Bi1e, >aulette and tensions emanating there1rom AetBeen ?adlic and his daughter Blair.
1!. >am &oAerts suAorned the 2erCur0 o1 &eno $2arDs 3ndian Colon0 511icer ?ameron
CraB1ord during the NovemAer #0th 2011 )rial in &FC 11 C& 221"- Bhen she called him as her
oBn Bitness, and he testi1ied that the accused 1ailed to 2rovide his driverEs license, thus giving
CraB1ord the 2roAaAle cause he needed to conduct a search incident to arrest. 4oBever, 2revious to
this, >am &oAerts hersel1 2ossessed securit0 camera 1ootage o1 the accused giving CraB1ord his
current $tate o1 Nevada DriverEs 8icense Hand dis2atch records con1irm that CraB1ord called in the
accused drivers license numAer in conCunction Bith the accused handing over his drivers license to
CraB1ord=. +urther, this video that &oAerts Bas in 2ossession o1 shoB )homas +rontino, :al*Fart
- 8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
/sset >rotection associate, handing the tBo &$3C o11icers additional video evidence Ae0ond that o1
the interrogation room video Bherein the undersigned 2rovided his $tate o1 Nevada driverEs license
to &$3C 511icer CraB1ord. +urther, &oAerts suAorned the 2erCur0 o1 +rontino Bhen he so 1alsel0
testi1ied that there e,isted no other video 1ootage Hdes2ite the legion o1 surveillance cameras
inters2ersed over 2racticall0 ever0 isle at +rontinoEs :al*Fart= o1 an0 matters 2ertinent to the
charge 1or Bhich the undersigned Bas accused, including, incrediAl0, aAsolutel0 no 1ootage o1 an0
o1 the alleged concealing or consuming or doing o1 an0 other elements o1 the crime charged, des2ite
the 1act that the0 ver0 interrogation room video &oAerts 2ossessed shoBed +rontino so 2roviding
such additional media evidence to &$3C 511icers CraB1ord and BraunBorth.
15. :hile N&$ 5.0"5 requires that: G+orm o1 docDet and records. )he Court /dministrator
shall 2rescriAe the 1orm o1 the docDet and o1 an0 other a22ro2riate records to Ae De2t A0 the
munici2al court, Bhich 1orm ma0 var0 1rom court to court according to the numAer and Dind o1
cases customaril0 heard and Bhether the court is designated as a court o1 record 2ursuant to N&$
5.010...G &FC Court /dministrator Fatt +isc a22arentl0 cease Aeing so em2lo0ed sometime in,
a22ro,imatel0, NovemAer 2011, throBing ever0thing into disarra0 and vitiating an0 sense o1 checDs
and Aalances or oversight as to the un1ettered dominance e,hiAited A0 6udge 4oBard over the
s0stem o1 Custice dis2ensed at the &FC, 2reventing the undersigned 1rom e,ercising his $i,th
/mendment &ight to Counsel and 1rom getting a Cur0 trial. )he &FC BeAsite claims: G)he &eno
Funici2al Court Bas estaAlished A0 charter in 1-- A0 the $tate 8egislature. :e are a high*volume,
limited Curisdiction court o1 record Bhich adCudicates criminal misdemeanor He.g., domestic
violence, D73, drug 2ara2hernalia and 2ett0 the1t= and tra11ic violations committed A0 adults Bithin
the Cit0 o1 &eno 2ro2er. We are a non-jr! "or# $%#& 'en"& #r%a() on(!. Fisdemeanor o11enses
- 9
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
committed Bithin the count0 limits are handled A0 the local 6ustice Courts as are all gross
misdemeanors and 1elonies.G
1-. 6udge 4oBard re1used to even grant the undersigned a continuance Bhere the undersigned
has recentl0 Aeen Brong1ull0 evicted 1rom his home laB o11ice via an im2ermissiAle a22lication o1 a
summar0 eviction 2roceeding against a commercial lessee Bhere 1ailure to 2a0 rent $a) no# alleged
and or the eviction Notice Bas a No Cause Eviction Notice. )he undersigned indicated that an
unlaB1ul rent distraint Bas at that time Aeing a22lied to e*"(+a#or! evidence and evidence
estaAlishing a retaliator0 motive and intent on the 2arts o1 Aoth :al*Fart and the &eno Cit0
/ttorne0Es 511ice Hgiven the s2ecter o1 multi2le 2olice misconduct and or negligent hiring, training,
and su2ervision, !2 7$C $ec. 1(#, de1amation laBsuits the Cit0 o1 &eno 1aces in connection Bith
misconduct 511icers committed against the undersigned in the 2ast si, months and o1 Bhich the
&eno Cit0 /ttorne0Es o11ice Bas aBare= necessar0 to the de1ense o1 the trial in this matter. $uch
evidence ma0 evince a retaliator0 intent and declaration on the 2art o1 various :al*Fart 2ersonnel
and &>D 2ersonnel Bhere the undersigned had Aeen Brong1ull0 arrested Cust some tBo BeeDs 2rior
to the 11O#0O11 )rial in this matter, and suACect to a Brong1ul locDout Cust 1our BeeDs 2rior to the
)rial Hnot Cust a locDout 1rom oneEs home or o11ice, Aut Aoth, and a laB o11ice no less=. )he
undersigned suAmitted a com2laint aAout &>D 511icer misconduct to the &>D 5n $e2temAer ",
2011, and again on several other occasion 5ne such com2laint involved re2orting that, at the time,
o1 the undersignedEs NovemAer 12, 2011 Brong1ul custodial arrest 1or Gtres2assG a &>D 511icer had
admitted to the undersigned that the o22osing attorne0 in that summar0 eviction 2roceeding,
&ichard ;. 4ill, Esq. G2a0s him a lot o1 mone0 and so he arrest Bhom 4ill tells him to arrest and
does Bhat 4ill sa0s to doG. )he &eno Cit0 /ttorne0Es 511ice de1ends the &>D in 2olice misconduct
laBsuits and has a vested interest in smearing the undersignedEs re2utation.
- 10
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1". /s 1or 6udge 4oBardEs $ummar0 Contem2t 5rder in this matter, it is entirel0 untrue to
sa0 that there Bas order that s2elled out the details o1 com2liance in clear, s2eci1ic and unamAiguous
terms so that the 2erson should have readil0 DnoBn e,actl0 Bhat duties or oAligations Bere im2osed
on him. 6udge 4oBard 1ailed to issue an0 5rder Gthat s2elled out the details o1 com2liance in clear,
s2eci1ic, and unamAiguous terms so that the 2erson should have readil0 DnoBn e,actl0 Bhat duties or
oAligations Bere im2osed on him...G. &ather, 6udge 4oBard, aAout 10 minutes into )rial, Aegan
menacingl0 threatening the undersigned, attem2ting to Aadger, Aerate, and intimidate the undersigned
into 1ailing to de1end himsel1 in this matter, to re1rain 1rom 2reserving oACections 1or the record, etc.,
etc.
1(. 3 declare under 2enalt0 o1 2erCur0 that the 1oregoing is true and correct.
AFFIR,ATION -r)an# #o NRS ./0B.1/1
)he undersigned does hereA0 a11irm that the 2receding document does not contain the social
securit0 numAer o1 an0 2erson.
D/)ED this #0th da0 o1 6anuar0, 2012.
MMMMMMMMMMMMMMMMMMMMMM
Zachar0 BarDer Coughlin
- 11
EXHIBIT #3
EXHIBIT #3
F I L E D
Electronically
01-30-2012:04:48:12 PM
Clerk of the Court
Search - Or view all jurisdictions
Searchfor: pamela roberts
Searchtype: Search by name
Search by title
J urisdiction: Reno
Year: Any
Search
2resultsforpam elaroberts
Name Position Base Pay Benefits
Total Pay
& Benefits
Jurisdiction Year
PAMELA ROBERTS 5750 Deputy City Attorney II $95,590.21 N/A $114,572.88 Reno 2010
PAMELA ROBERTS Deputy City Attorney II $92,457.02 $19,878.26 $110,582.44 Reno 2009
State Government: Salaries, CAFRS, Main Contracts Page, StateFinancial Documents
Education: CCSD Warrants, NSHE Budgets
Politicians: 2010 Transparency Survey, Congressional Disbursements
Connect: Facebook, Twitter
About Us: Contact Us, FAQ, Disclaimer
TransparentNevadais provided by theNevadaPolicy Research Institute as apublic service.
Page 1of 1 Search Results TransparentNevada
1/30/2012 http://transparentnevada.com/salaries/search/?q=pamela+roberts&t=name&j=reno&y=any
EXHIBIT #4
EXHIBIT #4
F I L E D
Electronically
01-30-2012:04:48:12 PM
Clerk of the Court
RMC said I could file this by email
Sent: Mon 12/12/11 7:28 PM
1 attachment
12 11 11 final motion for new trial city of reno v coughlin RMC 11 CR 22176.pdf (12.9 MB)
Dear RMC,
I called an wrote earlier and received approval to file the attached pdf and
media files by email rather than fax or other submission. This filing is large,
as such, it must be broken down into segments. this is part one, part two will
be in the next email. I will pay whatever filing fee or bond or whatever I
have to pay to access justice in this here case.
Sincerely,
Zach Coughlin, Esq.
Reno, NV 8950
fax: 949 667 7402
privilege.
Sent: Mon 12/12/11 7:40 PM
1 of 5 1/30/2012 6:19 AM
1 attachment
RMC 11 CR 2217 part two Exhibit 1 pages 1-300 of Motion for New trail from 12 12 2011.pdf (8.6 MB)
I received approval to file by email from RMC
This is the second file in the filing. Please note, the file name of the attachment should actually have the correct
case number of RMC CR 22176. It is missing the 6 on the end in the file name of the attachment
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.
Sent: Mon 12/12/11 7:57 PM
1 attachment
RMC 11 CR 22176 part three Exhibit 1 pages 301-600 of Motion for New trail from 12 12 2011.pdf (9.7
MB)
Zach Coughlin, Esq.
2 of 5 1/30/2012 6:19 AM
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
privilege.

Sent: Mon 12/12/11 8:23 PM
1 attachment
(11.8 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
3 of 5 1/30/2012 6:19 AM
privilege.
Sent: Mon 12/12/11 8:29 PM
1 attachment
(14.4 MB)
Zach Coughlin, Esq.
Reno, NV 89501
tel: 775 338 8118
fax: 949 667 7402
4 of 5 1/30/2012 6:19 AM
privilege.

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

5 of 5 1/30/2012 6:19 AM
EXHIBIT #5
EXHIBIT #5
F I L E D
Electronically
01-30-2012:04:48:12 PM
Clerk of the Court
NOTE: THIS IS THE RECEIPT FOR THE ITEMS THAT WERE RUNG UP AND FOR WHICH MONEY WAS PAID. WAL-
MART'S THOMAS FRONTINO AND RSIC OFFICER CRAWFORD LIED WHEN THEY BOTH TESTIFIED THAT THEY VERIFIED
THAT THE UPC FOR THE "COUGH DROPS" ON THE RECEIPT ON THE PAGE ABOVE THIS ONE DID NOT APPEAR ON
THE RECEIPT FOUND BELOW). HOWEVER, CLEARLY THAT SAME UPC APPEARS ON BOTH RECEIPTS (THE UPC IS
0732211630093). FRONTINO EVEN TRIED TO TESTIFY THAT HE WAS ABLE TO DISCERN FROM APPROXIMATELY 50
FEET AWAY THAT HE COULD TELL EXACTLY WHAT ITEMS AND WHAT UPC'S WERE BEING RUNG UP AT THE REGISTER
AND THAT HE WAS ABLE TO VERIFY THAT THE UPC'S FOR THE COUGH DROPS ON THE "STOLEN" RECEIPT" WERE
NOT FOUND ON THE "PURCHASED" RECEIPT. HOWEVER, CLEARLY, FRONTINO WAS WRONG OR LYING, OR BOTH.

1 30 12 Opposition To Motion To Dismiss 0204 2065 60838 22176 and All Attachments

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

1 30 12 Opposition To Motion To Dismiss 0204 2065 60838 22176 and All Attachments

Uploaded by

Copyright:

Available Formats

1

You might also like