Docket 63342 Document 2013-21712

DECLARATION SUPPLEMENT
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_ __ ._. LAh18 13-100306

On 0)-25-2013, ! Detective Yturbide wuS assigned |Icoriginal of this case in reference to a Violation ofa
Temporary IoSSmCnI LIut|. During my iVC8!lyI|Ou dC|<U\PCu !ul lIc uI|u80'0BIy LUuI
wa served the temporary order on 12-26-2012 at about 1458 0uIS. Lu IIuduIPO!0 1-0320 13 at about
I700 hours atter having been served the O!uC! WIstates that Zachary is prohibited, either dI0cIor
through an agent fro111 contacting lIcPCVad ;Iu!CUuIGCalCdat 9456 Double !Vu 0, did 8V0a
male individual contact |0I location attempting t file documents Ou behalf of Zachary Coughlin. WhI\c
working at this location 8u!dclcI8 wus working as a Paralegal/Investigator and du see this O\0uI She
also saw a vehicle tIat 8CuuW8 is /aCh0!yIuuh!I0'8. o0knows !!3 ISZachary's vU1cdue to
several previous contacts \vith him.
Zachary was contacted ulu 8IO!date anuurr8Icd IOtlhCv)O!8|OO Othe JCBOI0Iy \I0! !0IProtection
Against Harassment in the Workplace. This order is documented under K!t 2012-000607. I was issued
on 12-20-2012 dB0valid until 01-04-2013. Zachary Wd8 also arrested in relation to a violation of !\S
smne order that was extended on 01-04-2013. Reference case #13-2445
Pl!
WHEREFORE, Declarant requests that a finding be made by a magistratc tat probable cause t:xists to hold said pcrson Ior
prcIimInaryht1rt0(i!charcis a fClol1Y or gross misdemeanor) or for a tral (iIcharge is a m:sdcmcauor)
REVIEWED FOR PROBABLE CAUSE (IC)

PC FOUND _. __ 0._.__ PC NOT IOllNO

DECLARANT T. YTUBlDE !If LD.1 9078
OA1l. MAG!o1RATL
DEFENDANT ORDERED R!L|^SFO,O^

PAGE 2

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Online report processed at the CitiCenter Plaza Substation
RIP Laura PETERS submitted the following:
! MOdal . COlo|
GRAY
The State Bar had a temporary restraining order in place (Rep 2012-000607) which has since been extended.
Yesterday evening Mr. Coughlin parked his car at the end of the ofice complex's driveway and sent another
individual to the State Bar ofice to file a document. I and another female coworker were locking up the buiding to
leave for the evening when the man apprached us and said he would like to file the document. I told the man that
I would not fle the document and that it was after hours. He put the document through the mail slot and lef. I got
into my car and saw Zach parked in the street at the end of the driveway.
This moring the temporar restraining order was extended by Judge Pearson who confirmed that yesterday's
incident was, in fact, a violation of the temporary order.
;-Rpr Oficer'
R4617/GREENELL, M
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2 Thursday, April 18,2013
13-100306
RENO POLICE DEPARTMENT
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There is no further information available for this case at this time,
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,REPORT TO FOLLOW VIOLATION OF TPO/EOP/RO OR SERVICE OF
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'9456 DOUBLE R BLVD. , STE B RENO

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An extended restraining order is in place which specifically directs Mr. Coughlin not to contact the State Bar . . in
person, by telephone, through electronic mail (e-mail) facsimile (fax), or through another person. Adverse Party
may submit documents to the State Bar only through the US mail but those documents must not contain threats or
other intimidating statements." This morning I arrived at work to find our fax machine printing the first 24 pages of
371. I cancelled the transmission and unplugged the machine which must be used for other business purposes.
This is the second direct violation and the first since the extended order has been in place.
I haven't read the content of the doc- ument, and don't intend to, but documents we have received in the past from
Mr. Coughlin usually include both threatening and intimidating statements so I have to assume this one does as
RepOd0|ca|

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4 Thursday, April 18, 2013
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well. Document available upon request.

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At approximately 1 :30 p.m., the State Bar office was contacted by a person that would not identify himself but
wished to speak with Assistant Bar Counsel Patrick King. The phone call was transferred to Patrick who picked up
the phone and the caller identified himself as Zachary Coughlin. He began to ask Patrick a question and Pat hung
up on him. Mr. Coughlin is again in violation of the Restraing Order put in place on Jan. 4, 2013. If Mr. Coughlin
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has any business with the State Bar, which he shouldn't at this point, he is only allowed to contact this ofice
through the US mail. This is the third violation of the Restraining Order - Case No. RCP 2012-000607, Reno
Justice Court.
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04/18/2013 11:31
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Thursday, April 18, 2013
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1 200.591F ,EPO VIOLATION-HARASS

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THIS IS AN ONLINE SUPPLEMENTAL REPORT FILED FROM 69.227.158.31.
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Online report processed at the CitiCenter Plaza Substation
RIP Laura PETERS submitted the following:
PoaNo
09:48:51
Compla|ntf,;
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I am informed that yesterday aferoon at apprximately 4 p. m. Zachary Coughlin called the State Bar ofice and
spoke with a female employee for about 10-15 minutes. Mr. Coughlin then asked to speak to Assistant Bar
Counsel Patrick King who refused to speak with him and instructed the female employee to terminate the call by
hanging up which she did.

RepOfOfficer-

R4617/GREENWELL,M
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04/18/2013 11:31
8 Thursday, April 18, 2013
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Mr. Coughlin has repeatedly violated the restraining order - for which I have repored each individual instance. It is
clear that Mr. Coughlin either does not understand the restrictions for contact outlined in the Restraining Order or
has decided he can ignore the directive of the issuing Judge, Scott Pearson. The extended order limits his contact
with the State Bar to US mail only.
There is no further information available for this case at this time.
-xcOce
R46)7/JLL,

9 Thursday, April 18, 2013
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P.O. BOX 1900
455 E 2ND ST
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0004 02/08/2013
REPORT TO FOLLOW VIOLATION OF TPO/EOP/RO OR SERVICE OF
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ASSIGNED: Detective Thomas Yturbide, 01-25-2013
CASE #13-100306 and 13-2445
CASE STATUS:
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0004 EVIDENCE

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13:53 Su::e::?u|
PC exists for the arrest of Zachary COUGHLIN for Violation of a Temporary Order for Protection Against
Harassment in the Workplace and Violation of an Extended Order for Protection Against Harassment in the
Workplace.
Protection Orders are documented as follows.
RCP 2012-000607
Temporary Order issued on 12-20-2012
Temporary Order served to Zachary Coughlin on 12-26-2012 at about 1458 hours
Temporary Order was extended on 01-04-2013 at about 0830 hours.
Extended Order was served to Zachary Coughlin on 01-05-2013 at about 1000 hours
Pr|n|Od!

04/18/2013 11:31
!

11 Thursday, April 18, 2013

1-Jb
Supplaman|No
0004
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Extended Order is valid until 2359 hours on 01-04-2014
FOLLOW-UP DETAILS:
On 01-25-2013 I was assigned the original case for 13-100306. During my investigation I determined the above
information about the Protection Order through court records. After speaking with the witness Laura Peters, who
works for the State Bar of Nevada at 9456 Double R Blvd. #B, I found that Zachary violated the order on two
separate occasions.
On 01-03-2013 at about 1700 hours as Laura was closing the ofice at the above location an unknown male
individual contacted her through the front glass door which faces to the south of the building. The male asked to
file a document with the office and he was denied due to the hour and the office closing. The male said nothing
else, but placed the document through the mail slot. Laura picked up the document and saw it was a motion by
Zachary Coughlin representing himself in a case that he believes is being handled by this office. Laura knew this
to be a violation of the above listed order as she has had previous contact with Zachary and knew of the existing
order.
Later that same night as Laura was leaving the above office she saw the unknown male get in to a vehicle that
she knew was own by Zachary Coughlin. Laura knew this as she has had previous contacts with Zachary and this
vehicle. Laura said she saw the unknown male get in as a passenger of this vehicle, but did not see the driver.
This corroborated that this motion was being filed on behalf of Zachary by an agent of his.
In the temporary order it states that, "It is furher ordered that you, the Adverse Party (Zachar Coughlin), are
prohibited, either directly or through an agent, from contacting, intimidating, using, attempting to use, or
threatening the use of physical force, or otherwise interering in any way with the employer, an employee of the
employer while the employee is perorming his duties of employment and any person while the person is present
at the workplace of the employer, including, but not limited to, in person, by telephone, through the mail, through_
electronic mail (e-mail), facsimile (fax), or through another person.
Zachary violated this by having an agent contact the ofice located at 9456 Double R Blvd.
While speaking with Laura she told me she had already attended the hearing for the extension of the protection
order and had received the extension on the protection order until 01-04-2014
Laura went on to tell me that on the morning of 01-17-2013 when she came in to work at about 0700 hours there
was a fax being printed from the fax machine that was supposed to be 371 pages. Laura saw that the cover page
was addressed from "zachcouchlin" and canceled the rest of the fax and unplugged the machine. Laura knew this
was a violation to the extended protection because of the following.
In the Extended Order for Protection Against Harassment in the Workplace it states, "the Adverse Party (Zachar
Coughlin), are prohibited, either directly or through an agent, from contacting, intimidating, using, attempting to
use, or threatening the use of physical force, or otherwise interfering in any way with the employer, an employee_
of the employer while the employee is performing his duties of employment and any person while the person is
present at the workplace of the employer, including, but not limited to, in person, by telephone, through electronic
mail (e-mail), facsimile (fax), or through another person. Adverse Party may submit documents to the State Bar
only through the U.S. mail but those documents must not contain threats or other intimidating statements.
While refer
r
ing to the extended protection order it is a violation for Zachary to have sent a facsimile (fax) to the
State Bar of Nevada located at 9456 Double R. Blvd. Zachary could have mailed this to the office utilizing the
U.S. Mail and it would not have been a violation of the protection order.
After the two above mentioned violations, one for the temporary order and one for the extended protection order,
Laura advised that there was also a phone call from a subject representing themselves as Zachary Coughlin on
01-30-2013. I have not been able to identify this subject positively as Zachary Coughlin.
Attached with this report are copies of the restraining orders and the affidavits of service. Copies of these were
also booked in to evidence along with the documents dropped off by the unknown male subject at the State Bar of
Nevada on 01-03-2013 and a copy of the facsimile (fax) sent by "zachcoughlin" to the ofice on 01-17-2013. Also
/:..: . ..,|
12 Thursday, April 18, 2013
LNLLLLL LNLN
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Supplemen|No
0004
booked in to evidence are copies of condensed transcript and findings of fact and conclusion of law for the State
Bar of Nevada Northern Nevada Disciplinary Board cases concerning Zachary Coughlin.
SUMMARY:
On 01-03-2013 Zachary Coughlin violated the temporary protection order served against him as documented
above. On 01-17-0213 Zachary Coughlin violated the extended protection order served against him as
documented above.
CASE UPDATE:
On 02-08-2013 Officers Waddle and Wilson of the Reno Police Department contacted Zachary at his residence at
1471 E. 9th St. and arrested him on the above listed charges.
NFD
- --Printe(rAt
'04/18/2013 11:31
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Thursday, April 18, 2013