10 23 13 Sentencing Memorandum 72675 DDA Stege Ocrd Final Opt PDF

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1
ZO l3 0CT 23 PM 4! 52
IN THE JUSTICE COURT OF RENO
r:'r" '''''''' lf l ' ':':: --;1 (,F COUR 1
. \ V. '-" I - _
2 IN AND FOR THE COUNTY OF WASHOE,
j2. t UT Y
3
4
5
6
THE STATE OF NEVADA,
Plaintiff,
v.
7 ZACHARY BARKER COUGHLIN,
8 Defendant.
* * *
CASE NO: RCR2013-072675
DEPT: R05
9 /
10 SENTENCING MEMORANDUM
11 COMES NOW, the State of Nevada, by and through RICHARD A.
12 GAMMICK, District Attorney of Washoe County, and AMOS STEGE, Deputy
13 District Attorney, and submits the instant Sentencing Memorandum.
14 The exhibits to this filing contain items that the State will rely on
15 in its sentencing argument on November 7, 2013. Six exhibits are
16 attached to this filing.
17
18 AFFIRMATION PURSUANT TO NRS 239B.030
19 The undersigned does hereby affirm that the preceding
20 document does not contain the social security number of any person.
21
22
23
24
25
26
, 2013.
RICHARD A. GAMMICK
District Attorney
Washoe County, Nevada
Deputy
.
:',- ..

1
2
3
4
5
EXHIBIT I
INDEX OF EXHIBITS
CASE SUMMARY RCR2012-065630
NUMBER OF PAGES 9
6 EXHIBIT II CASE SUMMARY RCR2011-063341
7 NUMBER OF PAGES: 14
8
9 EXHIBIT III CASE SUMMARY RCR2012-067980
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
EXHIBIT IV
EXHIBIT V
EXHIBIT VI
NUMBER OF PAGES
NUMBER OF PAGES: 2
NUMBER OF PAGES 47
CASE SUMMARY RCP2012-000607
NUMBER OF PAGES: 56
3
EXHIBIT 1
EXHIBIT 1
The State of Nevada
vs.
Zachary Barker Coughlin
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630

Location:
Judicial Officer:
Filed on:
Case Number History:
Agency Number:
District Attorney Number:
Probable Cause Number:
CASE INFORMATION
Reno Criminal
Clifton, David
01123/2012
RCX2012-000103
RP12-000974 (RPD)
436377
RPD1200020C
Offense
Deg
M
Date
01112/2012
Case Type: Misdemeanor
1. Resist public officer
ACN: RP12-000974
Filed As: Unlawful use of emergency G 01123/2012
telephone number (911)
Arrest: 01123/2012 RPD - Reno Police Department
Related Cases
RCR2011-063341 (Same DefendantlRespondent)
RCR2012-067980 (Same DefendantIRespondent)
Statistical Closures
04/02/2013 Bench Trial- Conviction
Warrants
Bench Warrant Failure to Appear - Coughlin, Zachary Barker (Judicial Officer:
Clifton, David)
02/12/2013 1:01 PM Executed
02/12/2013 1:00 PM Issued
Fine: $0 $10,000.00
Bonds
Bail Bond
3/2/2012
Counts: 1
#AlO-00584726 $1,500.00
Surety Bond Posted
Bail Bond #AI0-00574495 $1,500.00
2/2112012 Posted
Counts: I
DATE
Plaintiff
Defendant
Current Case Assignment
Case Number
.court
Date Assigned
Judicial Officer
The State of Nevada
Coughlin, Zachary Barker
CASE ASSIGNMENT
RCR2012-065630
Reno Criminal
01123/2012
Clifton, David
P ARn; INFORMA nON
Case Status: 02/12/2013 Active
Case Flags: Sealed Transcript
Lead Attorneys
Young,Zach
775-328-3200 x3510(W)
Pro Se
949-667-7402(H)
DATE EVENTS & ORDERS OF THE COURT INDEX
01117/2012
[] Probable Cause Affidavit Filed
PAGE I OF9 Printed on 1011612013 at 9:49 AM
01117/2012
01123/2012
01/23/2012
0211412012
02/2112012
02/2112012
02/2112012
02/21/2012
02/22/2012
02/27/2012
02/2712012
02/28/2012
03/02/2012
0311512012
03/29/2012
05/23/2012
07/3112012
08/09/2012
08/09/2012
08/09/2012
08/2112012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
{iJ Public Defender Appointed
ru Case Filed
Formal Charges
USE OF THE 911 EMERGENCY SYSTEM WHEN NO ACTUAL OR PERCEIVED
EMERGENCY EXISTS, a violation ofNRS 207.245
CANCELED Arraignment (10:00 AM) (Judicial Officer: Pearson, Scott)
Vacated
Arraignment (10:00 AM) (Judicial Officer: Pearson, Scott)
Bail Set
1500.00 Bond or Cash Bail: Bail Conditions Set by the Honorable Jack Schroeder
Bail Set
1500.00 Bond or Cash Bail.: Bail Conditions Set by the Honorable Scott Pearson
[l Notice
Notice of Appearance, Entry of Plea of Not Guilty, Waiver of Right to Arraignment; Motion to
Dismiss filed.
QJ Motion Filed
Motion to Strike Fugitive Document and Object to AlloWing the Defendant to Act as Co-
Counsel filed.
Mandatory Status Conference (I :30 PM) (Judicial Officer: Schroeder, Jack)
[l Order for Competency Evaluation Filed
Case Transferred to Another Court
to D.G. 2127/2012 PSYCH
Surety Bond Posted
{iJ Bond Exonerated
CANCELED Mandatory Status Conference (1 :30 PM) (Judicial Officer: Lynch, Patricia)
Vacated
9J Remand from Second Judicial District Court Filed
QJ Motion Filed
Motionfor Leave of Court to Amend Complaint filed.
9J Request for Audio CD Filed
QJ Motion Filed
to Proceed in Forma Pauperis
Motion Denied
to Proceed in Forma Pauperis.
Motion Hearing (1 :30 PM) (Judicial Officer: Sferrazza, Peter)
PAGE 2 OF 9
Printed on 1011612013 at 9:49 AM
0812112012
08/27/2012
08/27/2012
08/27/2012
08/27/2012
08/27/2012
08/29/2012
08/29/2012
08/2912012
09/12/2012
10104/2012
1110512012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
06/12/2012 Continued to 07/16/2012 - MSC Reset/Continuance - The State of Nevada;
0711612012 Continued to 0810612012 - MSC Resetl Continuance - The State a/Nevada;
08/06/2012 Continued to 08/21/2012 - MSC Reset/Continuance - The State of Nevada;
Parties Present: Plaintiff The State of Nevada
Public Defender Dogan, Biray
Deputy District Attorney Young, Zach
Defendant Coughlin, Zachary Barker
al Hearing Result (Judicial Officer: Sferrazza, Peter)
Defendantfailed to appear, Defense requests that this case be continued and set with his
misdemeanor Reno Justice Court Case set for August 29, 2012 at 8:30A.M State opposes as
this is Mr. Caughlin's second time failing to appear. Defense's motion is GRANTED. MSC is
setfor August 29,2012 at 9:00A.M
Motion Hearing (8:30 AM) (Judicial Officer: Sferrazza, Peter)
Public Defender Leslie, James Briand
aJ Amended Criminal Complaint Filed (Judicial Officer: Sferrazza, Peter)
Stricken
Hearing Result (Judicial Officer: Sferrazza, Peter)
The State moved to strike Second Amended Criminal Complaint.
Motion Granted (Judicial Officer: Sferrazza, Peter)
to Strike Second Amended Criminal Complaint.
Hearing Result
The State read offered plea negotiations into the record at which time the Defendant accepted
the offered plea. The State filed Amended Criminal Complaints. Hearing proceeded At
conclusion of the hearing, the Court will not accept Defendant's plea. The State moved to
Strike Amended Criminal Complaint. GRANTED. Mandatory Status Conference remains set
August 29, 2012, at 9:00 A.M
The State's motion For Leave of Court to Amend Complaint will be addressed at a Motion
hearing set October 2, 2012 at 10:00 A.M
aJ Request for Audio CD Filed
Requested by Jim Leslie, Deputy Public Defender.
ru Request for Audio CD Filed
Denied
9J Request for Audio 'CD Filed
Denied. Hearing on 8/6/ 12 was continued at counter.
PAGE 3 OF 9
Printed on 1011612013 a19:49 AM
11/06/2012
11106/2012
11106/2012
11113/2012
11/20/2012
1112012012
11126/2012
11126/2012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
9J Correspondence
Recieved via mail from Reno City Attorney's Office Re: Written Objection Pursuant to Reno
Justice Court Rule 45 (RJCR 45) Regarding E-mailed Subpeonas to City of Reno Emergency
Communications Center from Zach Coughlin Concerning RCR2011-063341.
Motion Hearing (10:00 AM) (Judicial Officer: Clifton, David)
10/02/2012 COlJtinued to 10/30/2012 - MSC Reset/Continuance - The State of Nevada;
Coughlin. Zachary Barker
10/30/2012 Continued to 11106/2012 - MSC Reset/Continuance - The State of Nevada;
Public Defender Dogan. Biray
Deputy DistrictAttorney Young. Zach
Defendant Coughlin. Zachary Barker
QJ Amended Criminal Complaint Filed
J - Amending charge
9J Hearing Result (Judicial Officer: Clifton, David)
Motion hearing requested by the state proceeded. State moved to file an Amended Criminal
Complaint. The Defense did not oppose. however the Defendant is requesting to fire his
attorney and to object to the motion. The State's motion is GRANTED. The State was given
leave of the Court to file an Amended Criminal Complaint in open court. Defendant duly
arraigned on the Amended Criminal Complaint. Defendant moved to have Public Defender
Biray Dogan Esq. removed as his attorney. Trial setfor December 11.2012 at 9:00A.M. The
Defense is requesting a closed hearing pursuant to State v. Young. The State has been excused
from this portion of the hearing. After discussion. the judge reset Defendant's requestfor
hearing to November 20.2012 at 10:00A.M. The Court indicated that ifit grants Defendant's
request to represent himself, it will allow him to still oppose the Suite's motion to amend the
Complaint. The Defendant has inquired of the court on being able to file motions. Upon the
order of the Honorable David Clifton. the Defendant is tofile all motions and any other filings
through his attorney of Record Public Defender Biray Dogan as the Defendant is not the
attorney of record. The Defendant has informed the Court that he does not trust his attorney to
file any documents on his behalf. Upon instruction of the Honorable David Clifton. the
Defendant may either file all motions. documents and other filings through his attorney of
record or he may submit them through a court clerk to his honor for review. They will not be
filed in but delivered to the Honorable David Cliftonfor review. A Motion Hearing is set for
November 20.2012 at 10:00A.M. Defendant'S bail is continued infullforce and effect.
W Motion Filed
Motionfor Reconsideratioon of Order Allowing Amending of Complaint; Motionfor Mistrial
and for Self Representation and to Conflict out WDCA filed.
Parties Present: Plaintifl The State of Nevada
Public Defender Dogan. Biray
Deputy District Attorney Young. Zach
Hearing Result (Judicial Officer: Clifton, David)
Parties stipulate to continue motion hearing after RCR2012-063341. which is being heard at
this time with Department 2 in Courtroom B.
QJ Notice
Notice of Intent to Proceed on a Default Basis.
QJ Motion Filed
MOTION FOR ORDER PROHIBITING THE DEFENDANT FROM FAXING ANY
DOCUMENTATION TO THE WASHOE COUNTY DISTRICT ATTORNEY'S OFFICE.
PAGE 4 OF 9
Printed on 10/1612013 at 9:49 AM
11127/2012
11127/2012
11127/2012
11127/2012
11128/2012
11129/2012
12/03/2012
12/03/2012
12/03/2012
12/04/2012
12/05/2012
12/06/2012
1211112012
12/1112012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
Parties Present: Plaintiff The State a/Nevada
Hearing Result: (Judicial Officer: Clifton, David)
Motion/or Defendant to Represent himselfis hereby GRANTED. Public Defender Biray
Dogan, Esq. waived as counsel. Copies/axed to Reno Justice Court on November 13, 2012 are
orderedfiled in dated November 27,2012. Motionfor Reconsideration of Order Allowing
Amending of Complaint is hereby DENIED. Motionfor MIstrial and to Conflict out Washoe
County District Attorney is hereby DENIED. Motion to Supplement Motions is hereby
DENIED. Motionfor Order Prohibiting the Defendantfromfaxing any documents to the
Washoe County District Attorney's Office is hereby GRANTED. Defendant is prohibitedfrom
faxing any documents to the office of the District Attorney and/or Reno Justice Court, to have
no contact via e-mail, with the exception of Deputy District A ttorney Zachary Young, until the
Trial date of December 11. 2012, in addition, all phone messages are to remain under THREE
(3) minutes long. Defendant ordered no more faxing after 12:00 P.M on November 27, 2012,
as to this case. All documents must be mailed or hand delivered. Defendant requests Audio CD
for all hearings related to this case is hereby GRANTED.
J Motion Filed
Motionfor reconsideration of Order Allowing Amending of Complaint; Motionfor MIstrial
andfor Self Representation and to Conflict out Washoe County District Attorney.
JNotice
Notice of Intent to Proceed on a Default Basis filed
aJ Opposition to Motion Filed
OPPOSITION TO MOTION TO AMEND, OR ALTERNATIVELY, MOTION FOR
RECONSIDERATION OR ORDER GRANTING STATE'S JULY 31ST, 2012 MOTION TO
AMEND.
'" QJ Request for Audio CD Filed
requested by Zachary Barker Coughlin
J Motion Filed
aJ Motion Filed
QJ Motion Filed
r1::
9..J General Case Note
Affidavit of Service
W Motion Filed
Opposition to Motion to Amend, or Alternatively, Motionfor Reconsideration of Order
Granting State's July 31st Motion to Amend filed .
W Motion Filed
Misdemeanor Trial (9:00 AM) (Judicial Officer: Clifton, David)
PAGE50F9
Printed on /011612013 at 9:49 AM
12/1112012
12/1112012
12112/2012
12/1212012
12/19/2012
12/19/2012
12/27/2012
01/14/2013
01122/2013
01122/2013
02/05/2013
02/05/2013
02/05/2013
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
Judge Clifton has waived the witness fees at to Srgt. Sifre and Thew. Defendant requested to
serve subpoenas by email. Request was DENIED. All subpoenas must be served properly.
Audiofee.:rfor November 20,2012 and December 11,2012 are WAIVED.
9J Motion Filed
Motienfor Recusal and to Conflict out the RIC Judge Clifton and the WCDA Office from any
Presecution of Coughlin filed.
9J Motion Filed
Motion for Recusal and to. Conflict out the RIC Judge Clifton and the WCDA Office from any
Presecutien efCoughlinfiled.
J Opposition to Motion Filed
Opposition to Metion to Amend, or Alternatively, Motienfor Reconsideration of Order
Granting State's July 31st, 2012 Motien to Amend filed.
J Motion Filed
Motion To Preceed In Forma Pauperis . .
SJ Notice
QJNotice
of Death of Witness
Q;j Notice of Witnesses Filed
SUPPLEMENT
Parties Present: Plaintiff The State of e v a d ~
QJ General Case Note (Judicial Officer: Clifton, David)
Defendant movesfer Dismissal due to. Death of Witness. State Opposes. Motien is hereby
DENIED. Defendant stated he is questioning his competency at this time. The Honorable
David Clifton feels Defendant Coughlin is competent to proceed with Trial. Defendant made
Motionfor Recusal of Judge Cliftenand to Conflict eut the RIC. Metien is hereby DENIED.
Testimonyfrom December 11,2012 by Witness Beechler is hereby stricken and exhibit A is no
lenger admitted into. evidence. Upen further testimony by witness Carthen exhibit A is
admitted back into evidence. Trial centinued to. February 5, 2013 at 9:00 A.M (Defendant was
provided Court Slip with new date)
Defendant Ceughlin, Zachary Barker
Defendant submitted a SB89 request. State has opposed this request. Court has DENIED, the
SB89 request at this time. Defendant has requested a centinuance due to. recent incarceration
and lack of medication. State eppesed. Court has GRANTED Defendants request fer
continuance.
9J Notice
Notice Of Order Fer Competency Evaluatien requiring suspensien of all proceedings in all
PAGE 6 OF 9 Printed on /0116/2013 at 9:49 AM
02112/2013
02/12/2013
02/1212013
02/12/2013
02/1212013
02/13/2013
02/1312013
02/1312013
02/25/2013
02126/2013
02128/2013
03/05/2013
03/1312013
0311312013
03/1312013
03/1912013
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
departments of the Reno Justice Court. Filed in open court on 21512013 at 9: 17 am.
Misdemeanor Trial (9:00 AM) (Judicial Omcer: Clifton, David)
Warrant Executed
Taken into custody from Trial by RJC Bailiffs.
Warrant Issued
W Warrant Returned
General Case Note (Judicial Officer: Clifton, David)
Defendant taken into custody on a FTA Bench Warrant
Order to Show Cause (8:30 AM) (Judicial Officer: Clifton, David)
Attorney Lindsay, Robert Bruce
Order to Show Cause Hearing Held (Judicial Officer: Clifton, David)
Defendant appeared together with Attorney Bruce Lindsay who was appointed on February
12, 2013, only as to this hearing, the State was represented by Zach Young. Defendant found
guilty of contempt and is sentenced to serve FIVE (5) days in the County Detention FaCility,
with credit for TWO (2) days previously served Defendant remanded to the custody of the
Washoe County Sheriff
ru Judgment Commitment Filed (Judicial Officer: Clifton, David)
Misdemeanor Commitment filed
J Appeal Filed
Notice of Appeal of Order of 121131125 Day Incarcerationfor Contempt .
. General Case Note
Notice of Appeal of Order of 121131125 Day Incarcerationfor Contempt filed February 25,
2013. After review of the file it is noted that there are no Orders filed on December 13, 2012,
nor were there any hearings set or heard on December 13, 2012.
ru Proceedings Certified to the Second Judicial District Court
Justice Court Criminal Appeal Proceedings filed
CANCELED Order to Show Cause (2:00 PM) (Judicial Officer: Pearson, Scott)
Vacated
ru Motion Filed
Emergency Motion to Continue 311912013 TrialDate and Request to Submit it.
J Notice
Amended Supplemental Notice of Appeal
Misdemeanor Trial (9:00 AM) (judicial Officer: Clifton, David)
PAGE 7 OF 9
03119/2013
03/1912013
03/20/2013
03/20/2013
03/28/2013
03/28/2013
04/02/2013
04/02/2013
04/02/2013
04/02/2013
04/02/2013
04/02/2013
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
Deputy District Attorney
Defendant
Young. Zach
~ Misdemeanor Judgment Filed (Judicial Officer: Clifton, David)
on February 13. 2013. AMEMDED by Judge Clifton to read Misdemeanor commitment Order
Pursuant to the order of Judge Clifton. a subpoena shall be producedfor Seargent Thew. Trial
date continuedfor April 2. 2013 at 9:00 AM; Coughlin ordered to check in by 8:50 AM
[l Motion Filed
SUPPLEMENTAL MOTION FORA MISTRlAL AND NOTICE OF APPEAL OF 311912013
[l Motion Filed
Supplemental Motion for Mistrial and Notice of Appeal of March 19. 2013.
~ o t i c e
ofAppealof311912013
~ Motion Filed
Motionfor Mistrial and Subpoenafor RJC Clerk
J Request for Audio CD Filed
request by Zachary Barker Coughlin
J Order to Attend Filed
Disposition (Judicial Officer: Clifton, David)
Found Guilty
Sentence (Judicial Officer: Clifton, David)
SUSPENDED
Sentence to Confinement
Agency: Washoe County Jail
Term: 180 Days
Consecutive
CTS: 17 Days
Comment: which is to run consecutive to any and all other cases, not to exceed TWO
(2) years.
Amended Sentence (Judicial Officer: Clifton, David)
IMPOSED
Condition - Adult:
I. Proof of Evaluation and to Follow Evaluation Recommendations, To obtain a
Mental Health Evaluation by a licensed psychiatrist and comply with all counseling
recommendations. Defendant is to submit monthly reports to the court. 04/0212013,
Active 05102/2013
2. Abstain from Drugs and Alcohol, unauthorized. 04/02/2013, Closed 04/0212013
3. No Further Violations, including to not call 911 unless a true emergency exists.
04/02/2013, Closed 04/02/2013
PAGE 8 OF 9
Printed on 10/16/2013 at 9:49 AM
04/02/2013
04/0312013
04/0412013
04/0912013
04/09/2013
04112/2013
04115/2013
04116/2013
04116/2013
06/06/2013
06119/2013
07/29/2013
07/30/2013
DATE
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-065630
4. Department of Alternative Sentencing, to comply with all DAS requirements,
including, but not limited to, full search and seizure of his person, residence and
automobile at anytime without notice. 04/02/2013, Active 04/02/2015
5. Other, Defendant is to take all prescribed medications. 04/02/2013, Active
04/02/2013
QJ rv-tisdemeanor Judgment Filed (Judicial Officer: Clifton, David)
. requested by Zachary Barker Coughlin
QJ Request for Audio CD Filed
requested by Zachary Coughlin
J Motion Filed
MOTION FOR NEW TRIAL. ARREST, JUDGMENT AND CORRECT ILLEGAL SENTENCE.
(last page of this motion is an audio CD in a CD Sleeve acco-ed into the rest of the motion)
{i1 Request for Submission Filed
{ij Notice
OF APPEAL AND MOTION PROCEED IF (Eligible)
General Case Note
CASE IS NOT STAYED PER JUDGE CLIFTON.
W Proceedings Certified to the Second Judicial District Court
Justice Court Criminal Appeal Filed.
QJ Letter Sent
APPEAL LETTER
QJ Bond Exonerated
BJ Motion Filed
Ex-Parte MotionINoticelRequest of JAVS Audio.
QJ Request Filed
to view files
see notes
Total Charges
Total Payments and Credits
Balance Due as of 10116/2013
FINANCIAL INFORMATION
PAGE90F9
40.00
40.00
0.00
EXHIBIT 2
EXHIBIT 2
The State of Nevada
vs.
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341

Location:
Judicial Officer:
Filed on:
Agency Number:
District Attorney Number:
Probable Cause Number:
CASE INFORMATION
Reno Criminal
Pearson, Scott
08/24/2011
RPll-016399 (RPD)
432068
RPD1112566C
Offense
Deg
M
Date
08/24/2011
I. PETIT LARCENY
Arrest: 08/24/20 II
RPD - Reno Police Department
2. POSSESSION OF STOLEN
PROPERTY
M
08/2412011
Arrest: 08/24/2011
RPD - Reno Police Department ,
Related Cases
11120/2012 Bench Trial- Conviction
05/07/2012 Transferred (before/during trial)
Warrants
Bench Warrant Failure to Comply - Coughlin, Zachary Barker (Judicial Officer:
Sferrazza, Peter)
01/1112013 11 :33 AM Recalled
0111012013 10:27 AM Issued
01/0912013 2:49 PM Pending Clerk Review
Fine: $0 $500.00
Bonds
Cash Bail Without Notice $500.00
5/3/2013 Refunded
2/5/2013 Posted
Counts: 1,2
Cash Bail with Notice #63376 $465.00
11116/2011 8:53:40 Posted
AM
Counts: 1,2
Own Recognizance #62023 $.00
Counts: 1,2
DATE
Plaintiff
Defendant
, Case Number
Court
Date Assigned
Judicial Officer
The State of Nevada
CASE ASSIGNMENT
RCR2011-063341
Reno Criminal
08/24/2011
Pearson, Scott
PARTY INFORMATION
PAGE 1 OF 14
Case Flags: Sealed Transcript
' Young, Zach
775-328-3200 x351 O(W)
DATE
08/2212011
08/24/2011
08/24/2011
08/24/2011
0812512011
08/2512011
08/25/2011
08/25/2011
09108/2011
09/08/2011
10/05/2011
1011012011
10/12/2011
10/1312011
10113/2011
10118/2011
10/2612011
1111412011
1111412011
11128/201 I
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
EVENTS & ORDERS OF THE COURT
QJ Public Defender Appointed
Case Filed
FonnaI Charges
CT. I. PETIT LARCENY, a violation ofWCC 53.160 and 125.050 AMENDED CT. II.
POSSESSION OF STOLEN PROPERTY, a violation ofNRS 205.275
Plea (Judicial Officer: Sferrazza, Peter)
1. PETIT LARCENY
Not Guilty
9J Arraignment (10:00 AM) (Judicial Officer: Sferrazza, Peter)
Bail Set
Own Recognizance: Bail Conditions Set by the Honorable Jack Schroeder
Bail Set
465.00 Bond or Cash Bail: Bail Conditions Set by the Honorable Jack Schroeder
{ij Own Recognizance Release
Pre-Trial Conference (8:30 AM) (Judicial Officer: Clifton, David)
9J Order for Competency Evaluation Pursuant to NRS' 178.415
QJ Motion Filed
Emergency Ex Parte Motionfor Sanctions Pursuant to NRCP 11; and Other Relief
9J Letter Sent
Correspondence submitted on an Ex Parte basis
CANCELED Motion Hearing (10:00 AM) (Judicial Officer: Lynch, Patricia)
Vacated
CANCELED Motion Hearing (11:00 AM) (Judicial Officer: Sferrazza, Peter)
Vacated
{ij Information Filed
General Appearance by Named Defendants
Bail Set
465.00 Bond or Cash Bail: Bail Conditions Set by the Honorable Peter 1. Sferrazza
ru Own Recognizance Revoked
Per Judge Sferrazza
Pre-Trial Conference (8:30 AM) (Judicial Officer: Sferrazza, Peter)
PAGE 2 OF 14
INDEX
11130/2011
12/19/2011
02/1312012
02115/2012
02/15/2012
02/15/2012
02/1712012
02/2112012
02/2112012
0212112012
02123/2012
0212312012
02/27/2012
02/29/2012
05103/2012
0510312012
05107/2012
05107/2012
RENO CRIMINAL
CASE SUMMARY
CASE NO. RCR2011063341
!iJ Request for Audio CD Filed
QJ Request Filed
Request for Discovery
[] Motion to Suppress Filed [Mail Service]
KJ Authorization to Represent Filed
""
9J Motion Filed
Motion to Allow Late Filing Pre-Trial Notice
Q:J Motion Filed
Pre-Trial Motion
Q:J Notice of Appearance Filed
and Supplement to Motion to Accept Pre Trial Motions Where Untimely
{ij Motion Filed
Motion to Strike Fugative Document
8J Motion Filed
Motion to Continue Trial
[1 Motion Filed
Motion to Appoint Co-Counsel
[1 Notice of Witnesses Filed
li1 Opposition to Motion to Suppress Filed
ru Opposition to Motion to Continue Filed
Trial Date and Motion to Appoint Co-Counsel
Misdemeanor Trial (8:30 AM) (Judicial Officer: Sferrazza, Peter)
ru Response
Reply to State's Opposition to Motion to Suppress
J Request for Submission Filed
Public Defender Goodnight, Joe
J Mental Health Court (Judicial Officer: Sferrazza, Peter)
Defense requested to be transferred to Mental Health Court. State did not oppose as long as
the Defendant entered a plea to the charges. The Courtfinds that the Defendant does not in/act
have to enter a plea. State requested that if the Court decides to transfer this case to Mental
Health Court, prior to that happening, witness fees be paid in the amount of$75.00. Defense
PAGE 3 OF 14
0510712012
05/16/2012
05/30/2012
07/16/2012
0711612012
08/06/2012
08/09/2012
08/09/2012
08/09/2012
08/2712012
08/27/2012
0812712012
08/27/2012
08/27/2012
08/2912012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
opposed stating Defendant has no means of paying witness fees. It is ordered that the
Defendant is to pay $75.00 witness fees by May 7.2013. Uponfurther order of the Court. this
case is transferred to the jurisdiction of District Court Mental Health Court without a plea.
{ij Case Transferred to Another Court
requested by Joseph W. Goodnight. Deputy Public Defender.
QJ Remand from Second Judicial District Court Filed
Order Returning Case from Specialty Court to Original Department
Public Defender Bosler. Jeremy T.
Defense moves for continuance; Public Defender Jeremy Bosler indicated that a new Deputy
Public Defender shall be appointed to take over the case. State Agrees. Trial shall be set on
August 29. 2012. all motions shall be decided at that date.
J Request for u d i ~ CD Filed
{ij Motion Filed
Motion Denied
Notice
The Honorable Peter J. Sferrazza will hear Motion to Suppress at the time set for Trial.
Public Defender Leslie. James Briand
J Amended Criminal Complaint Filed
Stricken
Hearing Result
The State moved to strike Second Amended Criminal Complaint.
Motion Granted
to strike Second Amended Criminal Complaint.
Hearing Result
The State read offered plea negotiations into the record at which time the Defendant accepted
the offered plea. The State filed Amended Criminal Complaints. Hearing proceeded At
conclusion of the hearing. the Court will not accept Defendant's plea. The State moved to
Strike Amended Criminal Complaint. GRANTED. Trial remains set August 29. 2012. at 9:00
A.M
ZACHARY COUGHLIN CASE
PAGE 4 OF 14
0812912012
08/29/2012
08/29/2012
08/30/2012
09/05/2012
09/05/2012
09/0512012
09/07/2012
09/12/2012
09117/2012
09117/2012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
0812912012 Continued to 0812912012 - MSC Reset/Continuance - The State of Nevada;
Defendant addressed motion to appoint co-counsel. Defendant's Counsel addressed motion to
appoint co-counsel. The State opposes motion to appoint co-counsel. ,Motion DENIED. If
Defendant so chooses the Court will conduct a Faretta Canvass. Defendant movedfor self-
representation. The Court canvassed the Defendant regarding the Faretta inquiry. The State
objects to Defendant's motion to represent himself on the grounds that it is untimely and that
this is for the purpose of delay and not in good faith. Defendant'S counsel addressed motion for
self-representation. Motion DENIED. The State's motion to Strike all Documents that were
filed solely by the Defendant is hereby GRANTED. The Defendant previously filed Motion to
Suppress. Motion Hearing proceeded. The State opposes Defendant's Motion to Suppress.
Defendant's motion to Suppress GRANTED to the extent of the ''pat down search". Trial
proceeded. Witnesses held to subpoenas.
{i] Motion Filed
Pre-Trial Brief Motion for Summary Judgment
Misdemeanor Trial (10:00 AM)
Parties Present: Plaintiff
Defendant
. Public Defender
Witness
The State of Nevada
Young, Zach
Leslie, James Briand
Duralde, Nicholas
Trial proceeded. Pursuant to the Order of the Court, Audio Proceedings may be given to
Defendant at no cost. Defense moves for a competency evaluation. Motion GRANTED.
Defendant is ordered to obtain a Competency Evaluation. Trial continued to October 15, 2012
at 9:00 A.M Special Set for Judge Sferrazza.
Request for audio CD at public expense from Defendant granted by Judge Sferrazza.
J Order Filed
Order for Competency Evaluation Pursuant to NRS 178.415 filed
Requested by Zachary Coughlin.
requested by James Leslie, Deputy Public Defender
requested by James Leslie, Deputy Public Defender
PAGES OF 14
Printed on /0/16/2013 at 9:48 AM
10/0212012
10/22/2012
10/22/2012
10/23/2012
10/30/2012
1013012012
11107/2012
11107/2012
11107/2012
11108/2012
11108/2012
11108/2012
11108/2012
11108/2012
1111312012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
1m Evaluation Completed
Competency Evaluation
Competency/Motion Hearing
Parties Present: Plaintiff
Public Defender
Defendant
The State of Nevada
Leslie. Jim
Young. Zach
Defendant has been found competent. Defendant has indicated that he would like to represent
himself Defendant Faretta Canvassed Defendant'S motion to represent himselofis
GRANTED. The Court also appointes Public Defender Jim Leslie as standby counsel. Motion
by Defendant to have transcript prepared at public expense. Motion DENIED. Trial confirmed
setfor November 19.2012. at 8:30 AM
requested by Linda Gray from the Public Defender'S Office
'" QJ Authorization to Represent Filed
requested by Defendant
9J Motion Filed
Motion To Quash Subpoena Duces Tecum.
""
\J Response
Response To Subpoena Duces Tecums
J Motion Filed
Motionfor Protective Order to Quash Subpoenas andfor Protective Order Regarding
Issuance of Subpoenas
Motion to shorten time
Parties Present: Witness Skau. Creigton
J Order Filed
Ex Parte Emergency Order Pending Hearing
Ex-Parte Emergency Order Pending Hearing to be filed by the Reno City Attorney's office.
Hearing setfor November 13. 2012. at 9:00 A.M
Reno City Attorney's Office to prepare Ex Parte Emergency Order and serve Defendant and
the Public Defender's Office. Hearing set for November 13. 2012. at 9:00 A.M
r-::.
SJ Notice
Affidavit of Service
11/ 13/2012 Continued to 11/13/2012 - MSC Reset/Continuance - Coughlin. Zachary
Barker
Parties Present:
PAGE60F 14
11113/2012
I II14/2012
1 IIIS/2012
1 IIIS12012
11116/2012
1 III 6/20 12
1 II19/2012
11119/2012
1 II19/2012
11120/2012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
Defendant
Witness
Skau, Creigton
City of Reno City Attorney present, Creig Skau representing a number of City of Reno
Employees, which are listed in Mr. Skau's motions or pleadings. Pursuant to the Court's order,
Mr. Coughlin shall provide to the Court the subpoenas proof of witness fees paid. Mr.
Coughlin had served with original proof of service with no more than a one page document for
each subpoena as to why the person was subpoenaed; Why it is necessary for the person that
was supboenaed to be present for trial and why the subpoenaed testimony or documents are
relevant. Defendant shaff provide the the original subpoenas and the supporting documents by
Thursday, November 15, 2012 by 11 :00 A.M The Court will make a decision as to whether the
persons who have been subpoenaed, shaff be ordered to be present for this case. The City of
Reno is ordered to affow Mr. Coughlin to pick up the City of Reno Police Report and City of
Reno E-COMM materials regarding case RMC 2011-063341 without paying the cost of
$ 1 08.00. Mr. Skau indicates he will ensure this will happen, if Mr. Coughlin makes an
appointment to appear at the City Attorney's Office at a specific date or time. Defendant shaff
file all original affidavits or declarations or certificates of service with the Court, if Mr.
Coughlin wants the subpoenas to be honored The subpoenas served by mail must be properly
issued and served TEN (10) days in advance and must be revelant to this case. No new
subpoenas are to be issued unless the Court reviews them prior to service, must be relevant to
case and witness fees paid unless proof is provided that the Court ordered the subpoenas can
be served without a witness fee.
J Motion Filed
Motion To Quash Subpoenas
9J Motion Filed
Motionfor Mistrail and Memorandum of Law
ru Motion Filed
Submission of Materials Related to Return of Service of Subpoena and Motion for Order for
Austin Lichty's Addressfrom DMV
ru Order Filed
Order Denying Motions For Mistrial And Continuance.
r::,
9J Order Filed
THIS CASE RCR2011-063341 is a SPECIAL SET FOR JUDGE SFERRAZZA CONTINUED
TRIAL FOR COUGHLIN
1011512012 Continued to 11/19/2012 - Pre-Trial ResetlContinuance - The State of
Nevada; Coughlin, Zachary Barker
Defendant will be affowed the audio recordingfor this hearing at no cost. Court orders
payment of a witness fee to Colton Goble at a later time. Defense moved for continuance due
to missing witnesses. State opposed DENIED. Case continued to November 20, 2012.
W Motion Filed
Motionfor Mistrial and or Continuance
PAGE70F 14
11/2012012
1112012012
11120/2012
11120/2012
Il12012012
11/2012012
11/2112012
11126/2012
11126/2012
11126/2012
1112612012
11127/2012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
Public De/ender Leslie, James Briand
Jim Leslie a/the Public Defenders Office has been released as co-counsel and is no longer
required to attend any further hearings regarding this case.
Disposition (Judicial Officer: Sferrazza, Peter)
1. PETIT LARCENY
Found Guilty
2. POSSESSION OF STOLEN PROPERTY
Found Guilty
Sentence (Judicial Officer: Sferrazza, Peter)
1. PETIT LARCENY
SUSPENDED
Sentence to Confinement
Agency: Washoe County Jail
Term: 180 Days
CTS: 7 Days
Comment: not to exceed ONE (1) to TWO (2) years.
Amended Sentence (Judicial Officer: Sferrazza, Peter)
1. PETIT LARCENY
IMPOSED
Condition - Adult:
1. Department of Alternative Sentencing, Supervision for 1-2 years. All supervision
fees are WAIVED. 11120/2012, Active 11120/2014
2. Abstain from Drugs and Alcohol, 11/20/2012, Closed 11/20/2012
3. No Further Violations, 11/20/2012, Closed 11120/2012
4. Proof of Evaluation and to Follow Evaluation Recommendations, To obtain a
Mental Health Evaluation and provide proof to the Court. 11120/2012, Satisfied
04/05/2013
5. Other, Defendant is to take all prescribed medications. 11120/2012, Closed
11/2012012
J Order to Attend Filed
{iJ Request for Audio CD Filed

gJ Misdemeanor Judgment Filed
requested by Creig Skau, Esq., Reno City Attorney's Office
QJ Motion Filed
unreadable
J Motion Filed
Emergency Ex Parte Motion/or Extension a/Time to file Motion/or New Trial; Motion/or
Mistrial; Motion to Strike; Motion/or Arrest a/Judgment
QJ Motion Filed
Emergency Ex Parte Motion/or Extension a/Time to File Motion/or New Trial; Motion/or
Mistrial; Motion to Strike; Motion/or Arrest a/Judgment .
PAGE80F 14
11130/2012
12/03/2012
12/05/2012
12/05/2012
12/06/2012
12/10/2012
12/19/2012
01110/2013
01/11/2013
0111712013
02/04/2013
02/04/2013
02/05/2013
02/05/2013
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
[J Request for Audio CD Filed
requested by James Leslie. Deputy Public Defender
{i] Appeal Filed
Notice Of Appeal; Designation Of Record; Requestfor Transcript
Cash Bail Converted and Refunded
Bail converted to fines andfees in the amount of$175.00. Balance refunded in the amount of
$290.00check #040474
{i] Order Filed
W Proceedings Certified to the Second Judicial District Court
Letter Sent
.j Proceedings Certified to the Second Judicial District Court
Supplemental
!iJ Warrant Issued
First Bench Warrant issued bail set at $500.00 Cash Only
Warrant Recalled
Per Order of Steve Tuttle and Judge Pearson. warrant is recalled DAS to inform Defendant of
evaluation and-need to get it completed. DO NOT ISSUE WARRANT WITHOUT OK FROM
PEARSON.
CANCELED Warrant Arraignment (10:00 AM) (Judicial Officer: Schroeder, Jack)
Vacated
Mental Health Evaluation and comply with recommendations. Case is on Appeal.
tU Warrant Arraignment (10:00 AM) (Judicial Officer: Sferrazza, Peter)
FTC-DAS Violation. BAIL:$500 CASH
Parties Present: Defendant Coughlin. Zachary Barker
ru Bail Set (Judicial Officer: Sferrazza, Peter)
Bail Set at $500.00 CASH ONLY. Defendant Remanded to the Custody of the Washoe County
Sheriff.
'" aJ Order to Show Cause (8:30 AM) (Judicial Officer: Pearson, Scott)
FTC-DAS VIOLATION
QJ Order to Show Cause Hearing Held (Judicial Officer: Pearson, Scott )
Defendant has submitted an SB89 request. GRANTED. Court is to pay for evaluation.
Evaluator may contact the Defendant at (949) 667-7402 or bye-mail at
zachcoughlin@hotmail.com. Defendant is to continue checking in with DAS between 9:00 am
and 2:00 pm on Wednesdays. Defendant is to have no contact with RJC staff, byphone. letter
or e-mail. Defendant may file pleadings. but is to check in with security first at the entrance of
the Mills B. Lance Office Building. and a RJC BailifJwill be notified Bail is to remain infull
force and effect. In a Trial set in RCR 2012-065630. Deputy District Attorney Zach Young
requested to go back on the record before Judge Pearson to be heard regarding the previous
SB89 GRANTED in RCR 2011-063341. Defendant who is appearing without counsel.
objected. Judge Clifton GRANTS States request. Hearing proceeded before Judge Scott
Pearson. State is represented by Zach Young. Esq . Defendant is not represented by Counsel.
After further review of the file. the Court has reconsidered Defendants SB89 filed FebruQly 5.
2013. at 8:54 am and has DENIED it. The Court is still ordering the Defendant get evaluated
PAGE 9 OF 14 Printed on 1011612013 at 9:48 AM
02/0512013
03/0112013
03/05/2013
03/05/2013
03/11/2013
03/11/2013
03/1112013
03/1112013
03/1112013
03/11/2013
03/14/2013
03/19/2013
0312112013
03/2112013
RENO CRIMINAL
CASE SUMMARY
CASE NO. RCR2011-063341
lor competency at the Courts expense. De/endant requested that his medication be paid/or.
The Court indicated it will consider it at a later time. The order to show cause hearing has
been confirmed set/or February 25,2013, at 8:30 A.M De/endant 'is ordered to make an apt.
lor evaluation by February 12, 2013 and is to show DAS proof o/that apt.
Cash Bail Posted
in the amount 0/$500.00
ru Motion Filed
Motion/or Check/or Dr. Yasar Pursuant to Order Rendered on February 13,2013 and
Submission o/Proposed Order/or Mental Health Evaluationfiled. (Not addressed in Court)
9J Order to Show Cause (2:00 PM) (Judicial Officer: Pearson, Scott)
Parties Present: De/endant Coughlin, Zachary Barker
Hearing Result (Judicial Officer: Pearson, Scott)
Upon the order 0/ Judge Scott Pearson, Bruce Lindsay o/the Bob Bell Group, is hereby
appointed to represent the Defendant in this matter and the Administrative Order.
9J Order to Show Cause (8:30 AM) (Judicial Officer: Pearson, Scott)
02/25/2013 Continued to 03/11/2013 - Arraignment Reset/Continuance - Coughlin,
Zachary Barker
Order to Show Cause Hearing Held (Judicial Officer: Pearson, Scott )
Defendant is reinstated into DAS supervision/or up to THIRTY-SIX (36) months. De/endant is
ordered to obtain Evaluation at Court's Expense. Defendant is not to use or possess any
countrolled substance unless prescribed by Medical Doctor. De/endant is to give his attorney,
Bruce Lindsay, name 0/ Defendant's psychiatrist, who shall provide Evaluation. De/endant is
to be reinstated into the CCP Program to begin March 21,2013 at 1:30 P.M
Court Compliance Program
To begin 3/2112013
[] Motion Filed
Motion to Vacate any Order Issuingfrom March 11,2013 Hearing in RCR201 1-063341 filed.
ru Request for Submission Filed
QJ Motion Filed
Motion to Remove Bruce Lindsay, Esq. as Co-Counselfiled.
r;:,
t(l Motion Filed
Motion/or Check/or Dr. Yasar Pursuant to Order Rendered on 2/13/13 and Submission 0/
Proposed Order/or Mental health Evaluation
9J Motion Filed
Notice 0/ Appeal
Court Compliance Program Hearing (2:00 PM) (Judicial Officer: Pearson, Scott)
Parties Present: De/endant Coughlin, Zachary Barker
Court Counseling Compliance Program Hearing Held (Judicial Officer: Pearson, Scott )
Defendant appeared be/ore the Court/or his first appearance in the Courts Counseling
Compliance Program. Hearing proceeded. Defendant stated that NAMHS is paying/or
Defendant's medication and psychologist visits. Defendant ordered to bring in letter from Dr.
Yasar showing cost 0/ Evaluation. (Court will pay) If De/endant complies, Defendant will be
removedfrom Courts Counseling Compliance Program and DAS supervision. Hearing
continued to March 28, 2013 at 2:00 P.M
PAGE IOOF 14 Printed on 10/1612013 at 9:48 AM
03/2112013
03/26/2013
0312812013
03128/2013
04/04/2013
0411812013
04/18/2013
0412512013
04125/2013
04/26/2013
0412612013
04/26/2013
04/29/2013
04129/2013
04/29/2013
04129/2013
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
New Specialty Court Client (Judicial Officer: Pearson, Scott)
audio CD requested by Defendant/with response to request, copy of Appeal
Parties Present: Defendant Coughlin, Zachary Barker
Defendant appearedfor the Court Counseling Compliance Program Hearing this date.
Defendant indicated to the .court that he was unable to obtain a billfrom Dr. Yasar, but is
currently attending NAMHS. Defendant to bring proof of attendance with NAMHS or a release
form so the Court can obtain attendance information. Hearing continued to April1B, 2013, at
2:00 P.M to check status.
Audio CD requested by Defendant/with response to request and copy of Appeal
Address $500.00 cash bail
Defendant is unable to obtain a letter from his Doctor regarding bill. Defendant ordered to
obtain a copy of recent bill and Court will review to see ifwe can help pay. Hearing continued
to May 2, 2013 at 2:00 P.M Defendant to bring bill and proof of compliance with NNAMHS to
next hearing.
9J Transcript of Proceeding
May 7, 2012, Misdemeanor Trial
September 5, 2012 Misdemeanor Trial
July 16, 2012 Misdemeanor Trial
August 29,2012, Misdemeanor Trial
r>
November 20, 2012, Misdemeanor Trial
J Supplemental Proceedings Certified to District Court
on Appeal. Transcripts of Misdemeanor Trial Held on May 7, 2012.
ru Supplemental Proceedings Certified to District Court
on Appeal. Transcript of Misdemeanor Trial held on September 5, 2012.
J Supplemental Proceedings Certified to District Court
on Appeal. Transcript of Misdemeanor Trial held on July 16, 2012.
tiJ Supplemental Proceedings Certified to District Court
PAGE 11 OF 14
Prinled on 101/612013 a19:48 AM
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
on Appeal. Transcript of Misdemeanor Trial held on November 20, 2012.
04/29/2013 9J Supplemental Proceedings Certified to District Court
on Appeal. Transcript of Misdemeanor Trial held on August 29, 2012.
04/29/2013 [J Transcript of Proceeding
Misdemeanor Trial Monday, November 19,2012
04/30/2013 ru Supplemental Proceedings Certified to District Court
Transcript of Trial held Nov. 19, 2012
05102/2013 Court Compliance Program Hearing (2:00 PM) (Judicial Officer: Pearson, Scott)
ADDRESS $500.00 CASH BAIL
05102/2013 Court Counseling Compliance Program Hearing Held (Judicial Officer: Pearson, Scott)
Defendant appeared before the Court and indicated he went to NNAMHS and has another
appointment on May 15, 2013. Defendant indicates that NNAMHS is paying for those services
at this time. Defendant would like to obtain transcripts from an old Eviction matter and would
like the Court to pay for it. Defendant needs to research whether or not transcripts can be paid
through Specialty Court fees and if he brings proof that it can be; the Court will pay. Bench
warrant fees in the amount of$500.00 are hereby waived. Cash bail exonerated. Hearing
continued to May 23, 2013 at 2:00 P.M
05103/2013 Cash Bail Refunded
Bail refunded in the amount of$500.00 check #040756
05/23/2013 Court Compliance Program Hearing (2:00 PM) (Judicial Officer: Pearson, Scott)
05/2312013 Court Counseling Compliance Program Hearing Held (Judicial Officer: Pearson, Scott)
Defendant researched part of the statue for what funding can be applied to and unclear on
filing fees. Defendant was told Specialty Court fees can only be used to pay for treatment,
medications, and mental health for those who participate in the program. If Defendant does
not need help with medications, counseling or treatment then Defendant may not need to
remain in the program. Defendant was instructed by Judge Pearson to remain courteous to all
employees of the Court. Defendant to determine ifhe would like to remain in the program by
the next hearing. Hearing continued to June 20, 2013, at 2:00 P.M
05/24/2013 {i] Probable Cause Affidavit Filed
05/28/2013
05/28/2013
05/30/2013
0513012013
Arrest of Probationer
{i] Warrant Arraignment (10:00 AM) (Judicial Officer: Sferrazza, Peter)
FTC-DAS SUPERVISION, SET FOR CCP COURT FOR 05130113 @2:00P.M BAIL:$500
CASH
Bail Set (Judicial Officer: Sferrazza, Peter)
Bail Set at $500.00 CASH ONLY. Defendant Remanded to the Custody of the Washoe County
Sheriff.
liJ Court Counseling Compliance Program Hearing Held (Judicial Officer: Pearson, Scott )
Defendant appeared before the Court pursuant to probation violation and does not appear to
need assistance from the Court's Counseling Compliance Program; therefore, Defendant is
hereby released on his OWN RECOGNIZANCE on the following conditions: 1) Defendant
PAGE 120F 14 Printed on 1011612013 at 9:48 AM
05/3012013
06104/2013
0610412013
0610412013
06107/2013
06/10/2013
0611012013
06/18/2013
06/1912013
0611912013
06119/2013
06/20/2013
07/02/2013
07/02/2013
07/16/2013
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011063341
removedfrom the Court's Counseling Compliance program. 2) Defendant to remain under
supervision of the Department of Alternative Sentencing. Review Hearing set June 4,2013 at
8:30 A.M to address probation violation. .
Terminated Court Compliance Program
Review (8:30 AM) (Judicial Officer: Pearson, Scott)
Probation Violation Hearing
Review Hearing Held (judicial Officer: Pearson, Scott )
Defendant appeared without Counsel for Review Hearing. The Court asked Defendant if he
would like Counsel present for Review Hearing. Defendant would like Counsel present,
however he is requesting to be co-counsel. Review Hearing re-set at which time Defendant's
appointed Attorney Bruce Lindsay, Esq. shall be present to address probation violation.
"" Q,J Memorandum Filed
Jail Memo
General Case Note
DAS Status Report
J Review (8:30 AM) (Judicial Officer: Pearson, Scott)
TO BE HEARD BY JUDGE PEARSON. Bruce Lindsay, Esq. to be present
Parties Present: Conflict Attorney Lindsay, Robert Bruce
Review Hearing Held (Judicial Officer: Pearson, Scott )
Defendant appeared with Attorney Bruce Lindsay, Esq. before the Honorable Scott Pearson.
The State was not represented Mr. Lindsay was appointed to represent the Defendant and the
Defendant has filed a motion to have Mr. Lindsay removed as counsel. The Court has found
the Defendant indigent and is entitled to an attorney at the expense of the state. Review
Hearing is continued to June 19, 2013 at 8: 30A. M
ill Withdrawal of Defendant's Attorney Filed
KJ Review (8:30 AM) (Judicial Officer: Pearson, Scott)
Attorney Lindsay, Robert Bruce
Hearing Result (Judicial Officer: Pearson, Scott )
The Defense moved to have Bruce Lindsay removed as counsel. GRANTED. Defendant was
given an application for Public Defender and advised to fill it out if he wishes to be appointed
counsel. Review Hearing set for July 2,2013 at 8:30A.M
[J Motion Filed
CANCELED Court Compliance Program Hearing (2:00 PM) (Judicial Officer: Pearson, Scott)
Vacated
r:::
9.J Review (8:30 AM) (Judicial Officer: Pearson, Scott)
TO BE HEARD BY JUDGE PEARSON
Hearing Result (Judicial Officer: Pearson, Scott )
Matter continued to July 16, 2013, at 8:30 A.M
KJ Review (8:30 AM) (Judicial Officer: Pearson, Scott)
PAGE 13 OF 14
07116/2013
07/23/2013
07/29/2013
07/29/2013
07/29/2013
0712912013
08120/2013
08/20/2013
09/10/2013
0911012013
DATE
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2011-063341
Hearing Result (Judicial Officer: Pearson, Scott)
Matter continued.
Requested by Defendant; fee waived per Judge Pearson
QJ Request Filed
to view files
r::
QJ Motion Filed
to Dismiss Complaint; and Vacate Void Administrative Order 2012-01 Rebranded on 3/14/13
[l Request Filed
for Discovery; Litigation Hold Notice; Notice of Availability of Discovery and of Having so
Propounded
QJ Motion Filed
to Disqualify Judges Pearson. Clifton. and RJC (DISC INCLUDED)
Review (8:30 AM) (Judicial Officer: Hascheff, Pierre)
Review Hearing Held (Judicial Officer: Hascheff, Pierre)
Matter continued to be heard by the Honorable Scott Pearson.
Review (8:30 AM) (Judicial Officer: Pearson, Scott)
Review Hearing Held (Judicial Officer: Pearson, Scott )
Defendant is in compliance and is doing well.
Total Charges
Balance Due as of 10/16/2013
Bond Balance as of 1011612013
Bond Balance as of 10/16/2013
FINANCIAL INFORMA nON
PAGE 140F 14
675.00
675.00
0.00
0.00
0.00
EXHIBIT 3
EXHIBIT 3
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-067980
The State of Nevada
vs.
Offense Deg
I. False stmt to or obstruct public officer M
ACN: WC12-004498
Location:
Judicial Officer:
Filed on:
Case Number History:
Reno Criminal
Clifton, David
07/05/2012
RPC2012-001668

Agency Number: WC12-004498
District Attorney Number: 441175
Probable Cause Number: WAS00041988C
CASE INFORMATION
Date
06/28/2012
Case Status: 04/1112013 Concluded
Arrest:
WCSO - Washoe County Sheriff Office
Related Cases
04/10/2013 Dismissed (before trial)
Bonds
Cash Bail Without No'tice $500.00
4/15/2013 Refunded
7/23/2012 Posted
Counts: 1
Bail Bond #LX3-10008928 $1,000.00
7/2/2012 Surety Bond Posted
Counts: 1
DATE
Plaintiff
Case Number
Court
Date Assigned
Judicial Officer
The State of Nevada
CASE ASSIGNMENT
RCR2012-067980
Reno Criminal
07/05/2012
Clifton, David
PARTY INFORMATION
DATE
07/02/2012
07/0212012
07/05/2012
Surety Bond Posted
ru Probable Cause Affidavit Filed
BJ Criminal Complaint Filed
$500.00
PAGE IOF4
Lead Attorneys
Young, Zachary N.
775-328-3200 x35IO(W)
Lindsay, Robert Bruce
Retained
775-786-7117(W)
INDEX
Printed on 1011612013 ai 9:49 AM
07/05/2012
07/06/2012
07/06/2012
07/06/2012
07/09/2012
07/0912012
07/2312012
07/3112012
08/09/2012
08/0912012
08/09/2012
08/2312012
08/27/2012
08/2712012
08/29/2012
10/22/2012
RENO CRIMINAL
CASE SUMMARY
CASE No. RCR2012-067980
J Bond Exonerated
Certificate of Surrender of Defendant by Bail Agent filed.
Arraignment (10:00 AM) (Judicial Officer: Sferrazza, Peter)
Bail Set (Judicial Officer: Sferrazza, Peter)
Bail Set at $500.00 Defendant Remanded to the Custody of the Washoe County Sheriff.
QJ Public Defender Appointed (Judicial Officer: Sferrazza, Peter)
Judge Sferrazza
Bail Hearing (2:00 PM) (Judicial Officer: Pearson, Scott)
Public Defender Brady, Christine Jones
Deputy District Attorney Young, Zachary N.
Bail Hearing (Judicial Officer: Pearson, Scott )
Defense requests Defendant be released on his OWN RECOGNIZANCE. State opposes.
Defendants OWN RECOGNIZANCE release is hereby DENIED. Bail to remain at $500.00
bondable.
Cash Bail Posted
in the amount of$500.00
CANCELED Arraignment (10:00 AM) (Judicial Officer: "Pearson, Scott)
Vacated
liJ Motion Filed
Motion Denied
J Notice
Supplemental Notice of Witnesses Pursuant to NRS 174.234
Deputy District Attorney Young, Zachary N.
The State read offired plea negotiations into the record at which time the Defendant accepted
the offired plea. The Statejiled Amended Criminal Complaints in RCR 2011-063341 and RCR
2012-065630. Hearing proceeded. At conclusion of the hearing, the Court will not accept
Defendant'S plea. The State moved to Strike Amended Criminal Complaints. GRANTED. Trial
remains set September 18, 2012, at 9:00 A.M
tiJ Request for Audio CD Filed
Pre-Trial Conference (10:00 AM) (Judicial Officer: Sferrazza, Peter)
07/12/2012 Continued to 07/16/2012 - Pre-Trial Reset/Continuance - The State of
PAGE20F4 Printed on 1011612013 at 9:49 AM
10123/2012
11119/2012
12118/2012
12/18/2012
12/19/2012
12/19/2012
1212012012
01102/2013
02/05/2013
03/11/2013
RENO CRIMINAL
CASE SUMMARY
CASE NO. RCR2012-067980
Nevada; Coughlin. Zachary Barker
0711612012 Continued to 0810612012 - MSC ResetlContinuance - The State of Nevada;
0810612012 Continued to 0911812012 - Trial - Defense Attorney Request - The State of
0911812012 Continued to 10/15/2012 - Pre-Trial ResetlContinuance - The State of
1011512012 Continued to 10/22/2012 - MSC ResetlContinuance - The State of Nevada;
10/22/2012 Continued to 10/22/2012 - Pre-Trial ResetlContinuance - The State of
Deputy District Attorney Young. Zachary N.
requested by Linda Gray from the Public Defender's Office
CANCELED Misdemeanor Trial (8:30 AM) (Judicial Officer: Sferrazza, Peter)
Vacated
Defendant's Attorney Jim Leslie. Esq. movedfor release of the Public Defender's office as
attorney of record on this case. Defendant movedfor continuance. DENIED. Defendant
requests disclosure of any conflicts of interest. DENIED. Defendant movedfor the Honorable
David W. Clifton to recuse himselffromt his case. DENIED. The Public Defender's office is
hereby recusedfrom this case and the Alternate Public Defender's office is appointed to
represent the Defendant. Defendant has been provided with all written discovery from this
case. Attorney Jim Leslie to provide copies of all discovery to the Alternate Public Defender'S
office. Pre-Trial to remain set.
r.:.
ru Alternate Public Defender Appointed
J Motion Filed
to set aside Judge Clifton's order following improperly noticed and void hearing of 12118112
and to vacate any future court dates until right to counsel issues addressed.
J Conflict Attorney Appointed
Response
as to Motionfiled. No ruling at this time will address at next Trial setting.
CANCELED Pre-Trial Conference (9:00 AM)
Vacated
1112712012
0110712013
Continued to 0110712013 - Pre-Trial ResetlContinuance - The State of
Continued to 02/05/2013 - Pre-Trial ResetlContinuance - The State of
ru CANCELED Pre-Trial Conference (9:00 AM)
Vacated
02/25/2013 Continued to 03/11/2013 - Pre-Trial ResetlContinuance. - The State of
PAGE30F4 Printed on /0/16/2013 at 9:49 AM
04/0112013
04/03/2013
04/04/2013
04/04/2013
04/05/2013
04/08/2013
04/10/2013
04/10/2013
04/1112013
0411112013
04115/2013
04116/2013
04/22/2013
07/29/2013
DATE
RENO CRIMINAL
CASE SUMMARY
CASE NO. RCR2012-067980
Request for Audio CD Filed
rt!qut!stt!d by Zachary Coughlin
QJ Order Filed
from the Second Judicial District Court.
{ij Request for Audio CD Filed
{ij Request for Audio CD Filed
[J Withdrawal of Defendant's Attorney Filed
Motion
9J Dismissal Memo Filed
without prejudice pursuant to NRS 174.085
QJ Dismissal Order Filed
NRS information to be mailed to the Defendant.
Disposition (Judicial Officer: Clifton, David)
1. False stmt to or obstruct public officer
Dismissed Without Prejudice
9J Certificate of Mailirig Filed
Case Concluded
Cash Bail Refunded
Bail refunded in the amount of$500.00 check #040726
CANCELED Pre-Trial Conference (9:00 AM)
Vacated
Motion Denied
Motion to Withdraw as Counsel of Record
{i] Request Filed
to view files
Total Charges
Balance Due as of 10/16/2013
Bond Balance as of 1011612013
FINANCIAL INFORMATION
PAGE40F4
40.00 .
40.00
0.00
0.00
EXHIBIT 4
EXHIBIT 4
EXHIBIT 5
EXHIBIT 5
.,\ "
Washoe County
vs.
RENOCML
CASE SUMMARY
CASE No. RCP2012-000599

Location: Reno Civil
Judicial Officer: Pearson, Scott
Filed on: 12/18/2012
CASE INFORMATION
Statistical Closures Case Type: Protection Order - Workplace
12/18/2012 Decision without Trial/Hearing
DATE
Applicant
Adverse Party
DATE
1211 8/2012
1211 8/2012
12118/2012
1211 9/2012
01104/2013
01/04/2013
0111012013
07126/2013
07/30/2013
Case Number
Court
Date Assigned
Judicial Officer
Washoe County
CASE ASSIGNMENT
RCP2012-000599
Reno Civil
12118/2012
Pearson, Scott
PARTY INFORMATION
iij Application for Protection in the Workplace Filed
BJ Order Granting Application for Protection Order Filed
J Temporary Order of Protection Against Stalking Work Issued
!iJ Affidavit of Service Filed
Zachary Coughlin served by Bailiff Reyes 1211912012
9J StaIkingfHarassment (8: 15 AM) (Judicial Officer: Pearson, Scott)
Special Set
li1 Extended Order for Protection Against Stalking Work Issued
to expire 1-4-14 '
lij Affidavit of Service Filed
Zachary Barker Coughlin served 115113,
li1 Motion Filed
for an Award of Costs and/or Attorney fees (NRS 33.270)
iij Order Filed
Order Dissolving Previously issued Order for Protection, DENIED
PAGE I OF2
Lead Attorneys
Watts-Vial, David L.
Retained
775-337-5700(W)
INDEX
Printed on 1011612013 at 3:54 PM
07/30/2013
J Order Filed
RENO CIVIL
CASE SUMMARY
CASE No. RCP2012-000599
Regarding an Award a/Costs and/or Attorney Fees, DENIED
PAGE20F2
Printed on /011612013 at 3:54 PM
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Case No. Rep 2012-000599
Dept. No.4
FILtD
IN THE JUSTICE COURT OF RENO TOWNSIDP
COUNTY OF WASHOE, STATE OF NE.V ADA
13 JAN AM 9; 59

. RENO r [9)9 CW T
BY PUTY
WASHOE COUNTY
vs.
)
Employer,)
)
)
)
)
ZACHARY BARKER COUGHLIN
Adverse Party.
EXTENDED ORDER FOR
PROTECTION AGAINST
HARASSMENT IN THE WORKPLACE
(NRS 33.270)
Date Issued: JANUARY 4, 2013 Time: 8:30 a. m.
Expiration Date: JANUARY 4, 2014 Time: 11 :59
p.m.
WARNING: This is an official Court Order. If you disobey this Order, you may be arrested and
prosecuted for the crime of violating an Order for Protection Against Harassment in the Workplace
and any other crime that you may have committed in disobeying this Order. An intentional violation
of an Extended Order for Protection Against Harassment in the Workplace is a misdemeanor, unless
a more severe penalty is prescribed by law for the act that constitutes the violation of the Order.
Under NRS 193.150, a misdemeanor is punishable by imprisonment in the county jail for not more
than 6 months, or by a fine of not more than $1,000.00, or by both fine and imprisonment.
PURSUANT TO NRS 193.166, if the act that constitutes the violation of a protection order is itself a
felony, the violator shall, in addition to the term of imprisonment prescribed by statute for the crime, be
punished by imprisonment in the state prison for a minimum term of not less than 1 year and a maximum
term of not more than 20 years.
YOU ARE FURTHER NOTIFIED that YOU CAN BE ARRESTED even if the person who
obtained the Order invites or allows you to contact them. You have the sole responsi'Qility to avoid
or refrain from violating the terms of this Order. Only the Court can change the Order upon written
application.
The Court having considered the filings, testimony (if applicable) and evidence
presented at hearing, and the Court having found that the Adverse Party received notice of
hearing at which such person had an opportunity to participate and be heard, and the Adverse
Party 0 was present, X was not present, 0 was represented by counsel. _____ _
_______________ ,and the Applicant X was present, D was not
Form 8-25 Extended Order for Protection Against Harassment in the Workplace
Page 1 of4
102007 Nevada Supreme Court
Revised July 27.2007
1
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10
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present., [X] was represented by counsel DAVID WATTS-VIAL, and "the Court having
proper jurisdiction over the parties and this subject mattei', and it appearing to the satisfaction
of the Court that the Adverse Party has committed and/or is committing or remains a threat to
commit harassment in the workplace and good cause appearing,
IT IS HEREBY ORDERED that the Extended Order for Protection Against
Harassment in the Workplace is granted for the following reasons:
The Court has found that the employer has presented evidence sufficient to support the
granting of the application for an Extended Order of Protection Against Harassment in the
Workplace; and
The Court has found that the Adverse Party knowingly threatened " to cause or
committed an act causing bodily injury to himself or another person; and/or damage to the
property of another person; andlor substantial harm to the physical or mental health or safety
ofa person.
cnh&: ________________________________________________ __
IT IS FURTHER ORDERED that you, the Adverse Party, are prohipited, either
directly or through an agent, from contacting, intimidating, using, attempting to use, or
16 "
17
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21
22
23
24
25
threatening the use of physical force, or otherwise interfering in any way with the employer,
any 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 the mail, through electronic mail (e-mail),
facsimile (fax), or through another person.
IT IS FURTHER ORDERED that you stay away from the workplace of the
employer, wherever situated within the State, including, but not limited to, the following
specific workplace addressees): 350 S CENTER STAND 220 S CENTER STREET
Town/City of RENO, County of WASHOE, State of NEVADA
Other:
Form B-2S Extended Ordcr for Protection Against Harassment in the Workplace
Pagc2of4
C2007 Ncvada Supreme Court
Revised July 27, 2007
e
e
1
IT IS FURTHER ORDERED that the following additional restrictions apply:
2
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8
9
10
IT IS FURTHER ORDERED that the Clerk of the Court shall transmit, by the end
11
of the next business day after this Extended Order is issued, a copy of the Order, together with
12
a copy of the Application, to the following law enforcement agencies:
13
WASHOE. COUNTY SHERIFF. RENO POLICE DEPT. SPARKS POLICE DEPT.
14
RENO/SPARKS 1RIBAL POLICE. NEVADA HIGHWAY PATROL and UNR
15
POLICE
16
17
18
IT IS FURTHER ORDERED that the appropriate law enforcement agency/process
19
server promptly attempt to serve this Order upon the Adverse Party, and to file with or mail to
20
the Clerk of the Court proof of service by the end of the next business day after service is
21
made. Service must be made pursuant to the Rules of Civil Procedure.
22
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25
Form B-2S Extended Order for Protection Against HlIl1ISSITIcnt in 1be Workplace
Page30f4
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NOTICE TO LAW ENFORCEMENT
Any law enforcement officer, with or without a warrant, and whether or not a
violation occurs in the presence of the officer, may arrest and take into custody the
Adverse Party, when the law enforcement officer has probable cause to believe that (a)
an Order has been issued pursuant to NRS 33.270 against the Adverse Party; (b) the
Adverse Party has been served with a copy ofthe Order; and (c) the Adverse Party is
acting or has acted in violation of the Order.
Any law enforcement agency in Nevada may enforce a Court Order issued
pursuant to NRS 33.270 without regard to the county in which the Order was issued.
If a law enforcement officer cannot verify that the Adverse Party was served with
a copy of this Order, the officer shaD serve the Adverse Party with a copy of the Order if
a copy' is available.
IT IS SO ORDERED this 4
m
day of JANUARY, 2013.
PROOF OF SERVICE UPON ADVERSE PARTY
I, the undersigned, personally served the Adverse Party named above with a copy of this
Extended Order for Protection Against Harassment in the Workplace.
Form B-25 Extended Order for Protection Against Harassment in the Workplace
Page4of4
Signature
Print Name
Date of Service
Time of Service
(;12007 Nevliila Supreme Conn
Extended Order on Against
Harassment in the Workplace
State o/Nevada NRS 33.270
NU=-o.DRCP 2012-000599
Dept. No.4
Court
County
RENO JUSTICE COURT
WASHOE
EMPLOYERINAME OF BUSINESS
I WASHOE COUNTY
First Middle
v.
PARTY
\ ZACHARY \ BARKER \ COUGHLIN
First Middle Last
Adverse Party's Home Address and Phone Number:
1471 E 9
TH
ST RENO NV 89505
Last
SEX I RACE
M ICAUC
EYES HAIR
VEHICLE STATE
SEDAN
CAUTION: D ACCESS TO WEAPONS D OTHER:
THE COURT HEREBY FINDS:
DOB I HT IWT
9/27/76 16'4" 1225
DISTINGUISHING
FEATURES
TAG # MAKEIMODEIl
COLOR
That is has jurisdiction over the parties and subject matter, and the Adverse Party received actual notice of hearing at
which such person had an opportunity to participate and be heard.
THE COURT HEREBY ORDERS:
That the Adverse Party be prohibited from committing further unlawful acts of harassment in the workplace. Additional
terms of this order are as set forth on the following pages.
181 The terms ofthis" order shall expire at 11:59 p.m. on "(date)
unless otherwise ordered by the Court. Jmonth) .
112014 (year)
This Order meets the Full Faith and Credit provisions of the Violence Against Women Act and is enforceable in alISO
states, the District ofColurnbia, U.S. Territories and Indian Nations. All other courts and law enforcement with
jurisdiction within the United States and all Indian Nations shall give full faith and credit to this Order pursuant to 18
U.S.C. Sec. 2265. Violation of the Order may subject you to federal charges and punishment pursuant to IS.U.S.C. Sec.
2261 (a)(l) and (2) and 2262(a)(1) and (2).
Form 8-24 Extended Order for Protection Against Harassment in the Workplace Cover Sheet
June 30, 2007
--
e
I
Broadcast Report
I
Datemme 01-04-2013 1 I :07:27 a.m.
Transmit Header Text
RENO JUSTICE CIVIL DIVISION
LocaiiD 1 7753256715
local Name 1
Reno Justice Court - Civil
LocallD2
Local Name 2
This document: Confirmed
(reduced sample and details below>
Document size: a.S"x11 q
...
f Extended Order for Protection Against
I
I
! Harassment in the Workplace
I
Stote qt'Nevado NRS 33.270
J
-
C-No. RCP 201l-OOOS99
Dept. No.4
Court
Count)'

I WASHOI:: COUNT'l'
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M4KIIJMOUflU I
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SF..DAN"t I 1 :
CAUTION: 0 ACCESS TO WEAPONS 0 OTHER:
THE COt!llT HEREBY roms:
Tblll is hlIs jorisdiction oO\!t the paIIl.Ie lind !lUhject mauer.1Ind tin: A.!_1'II1) tl)I:,l>td acwal nClt!ce ofhclulng at
which $11(11 pmoclilad an "'III"'rfIlnity 10 panicipau: WId bet 11eard.
TIn: CO[JRT HltREBY ORDERS:
'1'IuIl \be Party be probibiled tMo C.,mlJl!lIi1!g iWrIJa' UI\!awfof lCIy oflranls._1 in , ... 'II'O!I<l'lttcc. Addltitmal
ICmls oflhls order &I'cl. set. fcll1b ()I) tilt; lWwine 1*1\'<1&
a Tht fetlllll 01 rbls IIf'Ih=r alulU 1!:lpln at 1!:9 p.m. OD I JA.\fl' ARY
by <:oun. (IIIMIhI
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ofColut/lbill, VS. Tmtt..vje.\.mI rndil!!l Nnti;tn5. All o1her t<lIlrtJI Md I.\w ... itl1
jurisd;"''\k>n wilkin UlllfOd Sulfl!t GlIlndi4ln lIIetio"" 'lIlall give full faith aIId 0liilln this Orcb- purOtl4nll" \ 8
\I s.c. 2265. \.'ioblit'fI\,,lheOtcier molY m fc.lnl Md posni$hlllem pursuant I\) 18.t).!).C. lic(.
:U61(J}ll)w l'to! 2262(&)(Ollld Ot.
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- ....
Total Pages Scanned: 5 Total Pages Confirmed: 30
No. Job Remote Station Start Time Duration Pages Une Mode Job Type Re5ults
001 968 1757859163 10:09:35 a.m. 01-04-2013 00:03:10 515 1 EC HS CP19200
002 968 7757841695 10:09:35 a.m. 01 -04-2013 00:01:15 5/5 1 EC HS CP28800
003 968 93342157 10:09:35 a.m. 01-04-2013 00:03:37 SIS 1 G3 HS CP14400
004 968 1753532436 10:09:35 a.m. 01-04-2013 00:02:03 515 1 EC HS CPI4400
005 968 7753283055 10:09:35 a.m. 01-04-2013 00:03:53 SIS 1 EC HS CP14400
006 968 7756870478 10:09:35 a.m. 01-04-2013 00:04:22 SIS 1 EC HS CP14400
Datemme
LocaiiD 1
Local 102
Abbreviations:
HS: Host send
HR: Host receive
ws: Waiting send
01-04-2013
7753256715
11:07:36 a.m.
PL: Polled local
PR: Polled remote
MS: Mallboxsave
. Broadca"st Report
Transmit Header Text
Local Name 1
Reno Justice Court - Ovll
Local Name 2
MP: Mailbox print
CP: Completed
FA: Fall
TU: Terminated by user
TS: Terminated bysystem G3: Group3
RP: Report EC: Error Correct
J
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IN tHE JUSTICE COURT OF
COUNTYOF U/ASttOE
FILED
12 DEC 18 AM 10: 50
. ..

UE:PU y ....
R-etJ 0 TOWNSHIP
STATE OF NEVADA
APPLICATION FOR TEMPORARY
ORDER FOR PROTECTION AGAINST
HARASSMENT INTHE WORKPLACE
(NRS 33.2SO)
l1 (NOTE: only br ODr Adnrsr Party.)
12
HARASSMENT IN THE WORKPLACE-:- Under NRS 33.240, harassment In the
13 workplace occurs when:
1. A penon knowlogly thrtatens to cause or commits an act that causes:
14 . (a> Bodily Injury to himself or another person;
(b) Damage to the property oC anotber person; or
15 (c) Substantial harm to the physical or mental htaltb Of safety of a person;
2. ne threat Is made or the act Is committed against an employer, an employee of the
16 employer whlle the employee performs his dutifs of employment or a'penon present
at the workplace oftheemployl'f; and
17 3. ne'threat would caust' a rt'asonabll' person to fesr that the thnat wiD be carrltd
oat or the ad would cause a nasonabll' pl'non to ftel telTortzed, Mghtened,
l8 intimidated or barassl'd.
19
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PLEASE TYPE OR PRINT CLEARLY.
COMPLETE THE APPLICATION TO THE BEST OF YOUR KNOWLEDGE.
I state the following facts nnder penalty of perjury:
o I am the employer.
I am the authorized agent of the employer.
o I 8lUnotthe employer or authorized agent of the employer. (If this bOIls
checked, you may Dot me this form.)

Applloatlon for Pro\80Uon In the Workplaoe
02007 Nevada SIIpRIDe Court
J=e30,2007
72821
Plse 10f6

. 1

1 I reasonably believe that the Adverse Party has threatened or committed an act or act(s) of
2
harassment in the workplace as dermed above. The event(s) occurred as follows:
3
NOTE: BE SPECIFIC AS TO WHO TllREA.TENED OR COMMI7TED WHAT ACTOR
ACTS AND AGAINST WHOM. INDICATE APPROXIMATE DATE(S) AND
LOCATION(S). ALSO LIST SPECIFIC EMPLOYEE(S)IPERSON(S) PRESENT AT THE
WORKPLACE WHO ARE THE FOCUS OF THE 1IARASSMENT OR WHOM THE
4
5
ADVERSE PARTY SHOULD BE DIRECTED NOT TO CONTACT.
6
7 THIS FORM IS A PUBLIC RECORD
S -eel b . t \, 1."
-ee ,c1A1 l
tlr1 . MCcA.Meyt.:\s 4.7
'611/ h;ts
l( 1-- A" tI j - E..
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NOTE: PLEASE DO NOT WRITE ON THE BACKS OF ANY PAGES,'
. CHECK BOX IF YOU ARE USING ADDITIONAL PAGES.
Chec1r If you ".. conti _. pal/< (/I) ". i.CDrpo;"'et/ bf. 5' ..... C<I
. . (S-ee t ".1.-'
22
23
24
25
Form 8-J Applicatioa Ibr Temponry Order for Proccc1ica Apmst in !be WorIcpIacc
02007 Novada SIlpRlllO eo.n
1_30.2007
Paae2of6
,
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2
3
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7
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12
NonCE REQUIREMENTS
A. l.t:t1 (Complete either A or B. not both)
e., wrJu '"
A. IILUlE peo-no octlirs Application to the Adverse Party by the Collowing
method(s):
o
o
In Person
Other:
Time:
o I have received confumation that the Adverse Party has received my Application for
a Temporary Order for Protection Against Harassment in the Workplace. Confirmation
of receipt is attached (i.e., fax, e-mail, postal mail. etc.).
X J haw not received cOD_n.
13 B. I HAVE. NOT given notice oUhls AppHeation to the Adverse Party because
immediate and irreparable injury, loss, or damage will result to the employer, an employee of the
14 employer while the employee perfOJ1ll$ the duties ofms employment, or a person who. is present
at the workplace of the employer, before the matter can be heard on notice. The irreparable
lS injury, loss. or damage that may result is: ______________________ _
16 It is irreparable because of:
17
o Possible economic or property damage which may include the following: __ _
18
19
o Continuous threat of stalkinglharassment
o AssaultlBattery (personal injury)
20
o Possible death to specified individuals named in the Application
21
o Other:

22
1. What efforts, if any. have been made to give notice to the Adverse Party? _
23
24
2. Facts supporting waiver of notice requirements: ____________ _
25
'ona B-3 APPLICATION !OR Tf:IDPCX1IIY On!u for Pralc:di0Q ApiDst in !he Wod;plKe C2007 NC'VIda .Supn:me CoM
1aao 30. 2007
Pap3of6
1 GENERAL INFORMATION
2
1. a) This matter does not have to be reported to law enforcement; however, has a related
3
4
5
6
7
8 b)
9
10
report ever been filed? 0 Yes No
(please complete information, ifknown. You may attach available copies)
Approximate date ofreport(s): ____________ ---' ___ _
Name(s) oflaw enforcement agencies: ______________ _
Casenumber(s): __ ______________ ---_
For purposes of this form, a "TPO Action" is defined to include the following Justice
Court actions:
(1) An Order for Protection Against Stalking and Harassment (NRS 200.591);
(2) An Order for Protection of Children (NRS 33.400);
(3) An Order for Protection Against Harassment in the Workplace (NRS 33.270). A
11 "TPO Action" is also defined to include the following JustiteIFamllylDlstrltt action:
12
13 1)(
14 r
15
16 0
17
18
19
20
21
2. a)
22
23
b)
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(a) An Order for Protection Against Domestic Violence (NRS 33.020)
Please Check the Appropriate Box Below:
In the last 2 years, AppliC81it or any party seeking has not filed a TPO action
against the Adverse Party anywhere in the State of Nevada, and the Adverse Party has no
filed a !PO action against Applicant or any party seeking protection anywhere in the
State of Nevada.
In the last 2 years, the following TPO action(s) in the State of Nevada have been filed
involving Applicant and the Adverse Party:
Case ## Court Place of
(if known) (JQstice/FamUy) Filing
Approx.
Date Filed
Outcome (pO
granted, denied,
restlnded. etc.)
Employer's name (if applicable, d/b/a): WAs HOE. . Ccu.-A. T'i P 1A.1U.l '- b r:J.J:Zi V"J:.J
The workplace is located in, and the employees primarily perform their duties at the
following address: S5D 5 , CeK.ier st.
Town/City of RetYo , CountY of uJA5Hl)t;? State of Ak"ltM
Phone #: 1'1'5'" '] - Yet"O
FOnD B-3 Appljeatiou!or Temporary Order fOf ProtectioD ApiDsI Huas8mcut ill \he WortpIaec C2007 Nevada SupraDII COUll
JIIM 30, 2007

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22 7.
23
24
25
ROPRIATE BOX(ES) BELOW, IF APPLICABLE.
PLEASE CHECK THE APP
Employee(s) also work at tb
in the Order: tou.r\
Street Address: i?: S.
Town/City of K-eUL '
.
e additional specific locations that need to be enumerated
riJ;"

County of JU.J$/JUff
, State

Phone #: 1'9." 3! 'I;;: ,
..
Street Address:. ____ _
Town/City of _...0.-__ .....) COWltyof
, State of
Phone #:. _____ _
(If you wish to designate mor
e specific addresses, please list them in this format on a
separate sheet.)
o The employees perform their duties statewide.
o Other comments on loe ations where protection is needed:

Authorized agent for employe
{er CtNA
Phone number for authorized a
'PIA. he. ee.
gent: 77 &./&tJO
Is employer represented by an attorney? ,18[ Yes ONo
IJa.J.+, - )/,&1 Attorney name: David
Address: (JY\e S. tiler-
Phone # for attorney: 17>'
Bar#:
5817
Sf . BA)Q i AJ 'i2..0
, (
5.7Q')Fax # for attorney:175- "r"J - Z.
Are there additional safety con cems that the Com should know (i.e., fireanns, dangerous
conditions, hazardous premise s, nature of business. etc.)? DYes DNo
If yes, please briefly explain:
Goa HuumIem in die Warflplace C2007 N_da Supreme Cour\
June 30. 2007
PqeSof6
~ ,.
1 8.
2
3
4
5
6
e
Have there been any other Court actions or any other relationships between the 'employer
and Ih< Adverse Party?. Yos 0 No ~ l
If yes. please describe: .Mforu -[iteM t -~ /6-'
RELIEF REQUESTED
I THEREFORE REQUEST that a Temporary Order for Protection Against Hamssment in
7 the Workplace be issued against the Adverse Party so that the Adverse Party will be prohibited from
8 contacting. intimidating. threatening, or otherwise interfering with the employer's business and/or its
.9 employees and/or any person present at the workplace. and that the Adverse Party will be ordered to stay
10 away from the employer's workplace. I also request that the CoUJ1 prohibit the Adverse party from
11 violating this Order via e-mail. cOITespondence. telephone. or by an agent.
12
13
14
15
16
17
18
19
20
I FURTHER REQUEST the following other conditions: _________ _
I FURTHER REQUEST that this Court set a bearing date for an Extended Order
as soon as possible.
~ Y e s 0 No
If yes, complete the Application for Extended Order for Protection Against
Harassment in the Workplace. NOTE: THIS HEARING WILL BE HELD WITHIN
TEN (10) JUDICIAL DAYS PURSUANT TO NRS 33.170(6)(c), UNLESS
COMPELLING REASONS REQUIRE OTHERWISE.
DECLARATION
(NRS 53.045)
1 DECLARE UNDER PENALTY OF PERJURY UNDER 'I1iE LAW OF THE STATE OF NEVADA
21 THAT: (1) I AM THE EMPLOYER OR AUTHORIZED AGENT HEREIN. (2) I HAVE READ THE
STATEMENTS CONTAINED HEREIN OR HAVE HAD THEM READ TO ME, (3) J BELlEVE THESE
22 STATEMENTS TO BE TRUE. AND (4) THE REQUESTED 0 S ED.
23 Dated: IZ/; B/;z:-
1 I
24
25
FQI'IIl B-3 Applicarioa far TaDpOrIIIy Order far Protectioa ApiDst iza !he ~ C2007 Nwada SIIpfOlllO c-t
1_ 30. 2(J(f1
EXHIBITl
i O
".
.'.-..... . .
. I . : ~
. :- ... .
EXHIBIT 1
" I
Exhibit "1" to Application for Temporary Order for Protection Against Harassment in the
Workplace
Zachary Coughlin is a client of the Washoe County Public Defender, and I have been
assigned to one or more of his criminal cases. It is anticipated that by Tuesday, December 18,
2012 our office will be relieved as counsel on Mr. Coughlin's single remaining case with this
Mr. Coughlin is an attorney on suspended status with the Nevada State Bar arising fr?m a
conviction for misdemeanor shoplifting which has been publicized in the press. Mr. Coughlm
represented himself in that criminal proceeding.
On December 12,2012, I received an email from Zachary Coughlin. a copy of which is
attached hereto as Exhibit "I-A". The email pertains to a misdemeanor petit larceny case of Mr.
Coughlin's involving theft or unlawful retention ofan iPhone, on which I and other attorneys in
our office previously represented him. During the course of the bench trial, our office was .
relieved as counsel upon Mr. Coughlin's request to represent himself. Throughout the em81l, Mr.
Coughlin makes various derogatory complaints about and references to me and other attorneys in
our office.
At the end of the first paragraph of the email.Mr. Coughlin complains that his various
attorneys and others in the local ,criminal justice system have ruined his life and ,he writes "I
remember when my life featured happy moments like the birth of twins ... but that was, before
your leviathan legal system wrecked shop on my existence. What, sir, shall be my
compensation?" The email thenreferencesthewebsitehttplltinyurl.comlbgmlfdr. When that
address is cut and pasted into a web browser, it directs the reader to a containing a video
segment from the movie "Cape Fear", which the website summarizes as a film that ''tells the
story of a convicted rapist who seeks vengeance against a fonner public defender whom he
blames for his l4-year imprisonment .... " In the movie, the client, played by Robert Di Nero,
carries out that vengeance by stalking and trying to kill his fonner public defender, played by
Nick Nolte. A copy of the priilt out of the website is attached hereto as Exhibit" I-B". The
video segment on the website is a scene in the movie where the client of the public defender has
just beaten two men. The client is wearing a shirt bloodied with his blood and the blood of the
men he just beat, and he is holding a blunt-instrument weapon or a chain in his hand. He vows to
continue his harassment of his fonner public defender, who is hiding nearby behind a garbage
dumpster.
The email from Mr. Coughlin is addressed to several attorneys in the office of the
Washoe County Public Defender, including attorneys Jim Leslie, Jeremy Bosler, Biray Dogan,
Joseph Goodnight, and Chris Fortier. Mr. Coughlin has previously and repeatedly expressed
significant dissatisfaction with his various attorneys in our office and has almost continuously, as
he does throughout the email attached hereto, blamed them for his current legal problems, his
recent criminal convictions, and his suspension from active attorney licensure with the Nevada
State Bar. The email is also addressed to several other persons outside our office, including but
not limited to Steve Tuttle of the Reno Justice Court, John Kadlic and Daniel Wong of the Reno
City Attorney's Office, Mary Kandaras of the Washoe County District Attorney's Office-Civil
Division, and David Clark and Patrick King of the Office of Bar Counsel of the Nevada State
Bar.
Based on Mr. Coughlin having included the various recipients to the email who are not
his attorneys, Mr. Coughlin has waived attorney-client confidentiality. Additionally, based upon
the nature of the references made in the first paragraph of the email to Mr. Coughlin's legal
problems and reference to the "Cape Fear" regarding violence and harassment against former
public defender, Mr. Coughlin has waived attorney-client confidentiality as per Nevada Rule of
Professi9nal Conduct 1.6(c).
Later the same day as the Coughlin showed up at the
offices of the Washoe County Public Defender without an appointment I and an investigator
went to the lobby to see him, since we had decided based on previous encounters with Mr.
Coughlin that it is best not to meet with him alone. With the investigator present in the lobby, I
asked Mr. Coughlin what he needed. He said he wanted his discovery documents. Since we
have had prior incidents where Mr. Coughlin received documents from us and later claimed we
did not provide them, 1 asked him to email me with his request and that I would respond to the
. email. our discussion I informed him that I would be asking that our office be relieved
from his pending misdemeanor Obstructing and Resisting criminal case. He became agitated and
upset and I asked him to leave and to schedule an appointment ifhe thought he needed one and
to send me his email request. He refused to leave, stating he was writing a note. I asked what
the note was and he became loud and verbally aggressive and said "None of your goddamned
business .... " His demeanor was visibly belligerent. I asked him again several times to leave
and he rose to his feet (he is approximately 6'3" and I am 5'4'') and went on a verbal rant against
me. I continued to tell him to leave while I turned to the front desk staff and asked them to call
the police. He tried handing me the note, and in response I held out my hand to receive it from
. him, but then he pulled the note back from me several times in a taunting manner while smiling.
As we waited for the elevator, he kept saying he was "chipping" at me. As he left in the
elevator, he kept saying "chip, chip, chip ... " in a taunting manner.
I asked my investigator to summarize the encounter in writing. A copy of that written
summary is hereto attached as Exhibit "I-e".
Given Mr. Coughlin's demeanor and behavior, and given the "Cape Fear" reference in
the email earlier that day, I felt it appropriate to call the police as a result of Mr. Coughlin's
refusal to leave, aggressive and hostile demeanor and statements, and the concern that he might
get physically violent. He left the building before the police arrived.
As a result of the email and the encounter with Mr. Coughlin in our lobby, we have
notified him via email that he is not to come to our offices without prior written confirmation of
an appointment with his assigned attorney. See Exhibit "1-0" attached hereto. We also advised
the front desk for the building, located on the first floor, of that limitation on his access to our
office. See Exhibit "I-E" attached hereto.
Based on what appears to be Mr. Coughlin's escalating animosity toward our office and
staff as. in the email reference to "Cape Fear", Mr. Coughlin's expressions in the email
rhostihty toward several of the attorneys in our office and his apparently blaming of them for
hiS legal problems and criminal convictions, and his demonstrated aggressiveness toward our
staff, we are applying for the restraining order to which this Exhibit" 1 " is attached.
i '" I
E;xmBITl .. A
EXHIBIT t .. A
Leslie, Jim
From:
Sent:
To:
Subject:
Attachmenb:

Zach Coughlin <zachcoughlln@hotmail.com>
Wednesday, December 12, 2012 2:35 PM
e
Leslie, Jim; Bosler, Jeremy; Dogan, Biray; Goodnight, Joseph W; Fortier, Chris; Tuttle,
Steve; Kandaras, Mary; Young, Zach; s!ceuc@reno.gov; wongd@reno.gov;
kadllcj@reno.gov; complaints@nvbar.org; cvellls@bhfs.com;je@eloreno.com;
patrickk@nvbar.org; davidc@nvbar.org; roseC@nvbar.org; laurap@nvbar.org;
skent@skentlaw.com; mlke@tahoelawyer.com; eifertnta@attnet;
nevtelassn@sbcglobal.netj fflaherty@dlpfd.com; fflaherty@dyerlawrence.com
The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17,
2012 to Coughlin in rcr2012-065630
12 7 12 declaration of zach coughlin 0204.pdt, 2 6 12 email from Fortier regarding
Dogan 065630.pdf; 10 11 12 email fwmisue of 911 case 065630 fortleretal.htm; .
transparent nevada Veronica lopez Marcia lopez 264052217600696065630 0204.pdf;
112 12 rpd police report 12 cr 00696 sifre leedy look nash young kandaras bradshaw
0204 065630 redaeted oerd.pdt, Beckett,.RI20110404 0204 065630.pdf; Beckett and
Tanner examples special treatement for prosecutor and tanner petty theft involve s16K
0204 BaCCounsel_ReporLJune_2011.pdf; 1122 12 .26405 Motion for Continuance
because Hill on vacation Hazlett Declaration 0204 065630.pdt, 12 6 12 not authorized
by Clifton Custodian of Records WCPD 065630.pdf; 12 6 12 subpoenas 065630 Thew
Sifre Schaur lopez Foreshee ECOMM.pdf; coughlin nsct docket search as of 12 7 12 .
0204 065630.pdf; 8 20 11 unredaeted dispatch logs 063341- back from tiffJpg.pdt, 97 12
063341 Order F9r Competency Evaluation 0204 065630 12420.pdf; 12 19 11 063341
GOODNIGHT'S REQUEST FOR DISCOVERY 0204 065630.pdt, nset docket 54844
coughlin v dlst ctjoshi 01168 0204 26405 6190l.pdf, 1127 12 065630 fax cover page
post it clifton 11 2812 don't file this in stays w case file however 1 of 69 pages.pdf; 12 6
12 26405 Notice of Defidency of Record on Appeal and FiUng of Judicial Discipline
Commission Complaint 0204 - Copy. pdf; 126 12 stamped 065630 emergency Motion
for Mistrial and Continuance Given state's failure timely provide discovery exculpatory-
Copy. pdf; 12 4 12 Affidavit of Service ruc Bailiff John Reyes lacks a lack number, lacks a
notary 065630 063341 067980 has no Order attached to it or incorporated by
reference.pdt, paes 1 to 17 from first fax judicial diSCipline commission complaints 0204
gardner elliot howard nash holmes sferrazza difton flnal-2-2.pdf; Paul-O-Elcano-
Jr--1070555-a stanford 0204 elliot echeverrla.pdf; 01955 docket coughlin elliot gardner
elcano.pdf; cr12-0376 coughlin judge steven elliot 0204 docket ccwashoe.pdf;
crl1-2064 docket coughlin v cIty of reno judge elliot city attorney roberts 0204.pdf; paul
elcano suing rutherform chlropractice and dr ross and nichols 0204 60317.pdt, 2 3 12
22176 60838 0204 roberts Gmail - courtesy copy of audio of trail exhibit 1 to
Supplement to Opposition to Motion to Dismiss.pdf; 1110 1'2063341 nrs 174.345
sbupoena on Duralde Rosa Alaksa and others rrr certified 1045 skau 0204.pdf; 11 26 12
5 big recent emails 60302 60317 Garin WLS Gardner 0204 60331 61383 063341 etc.pdt,
54844 COUGHUN VS. DIST. CT. and Linda Gardner 0204 0435 2640S.pdf
The Trial yesterday in RCRZ012-065630 featured extended discussions regarding
. e failure of the WCPD, Dogan, and Leslie, to tum over discovery p r o p o u ~ e by
DDA Young in the form of cd's featuring 911 calls DDA Young provided to the
WCPD on 8/13/12 and 8/17112 ... And the heavy hitters were there, too (Elliot
Sattler) ..... despite numerous written requests from Coughlin that the WCPD do so,
1

and multiple trips to the WCPD personally by Coughlin to pick such materials up,
and despite more flip flopping on their story by Leslie and Dogan regarding
whether they ever gave Coughlin some package of materials responsive to
Coughlin's request for his "file" ... But, Jim Leslie is stuck with the 7/27/12 date he
mentions in his email, then he is stuck with what his recent email wherein he.
to have therein digitally transmitted Coughlin his "file", which obviously
d:oesnot include the cd's of911 calls (the one's DDA Young took up an enormous
amount of court time playing, over and over (well, Young only played over and
over the particular calls he felt were strongest for his case and most prejudicial,
claiming some "cutting room floor mishap" for the reoccurrence of certain calls,
arguing that such a "happy accident" justified playing them again and again, at ever
increasing volumes, etc., etc.). Apparently, I am here to subsidize Young's baby
making, just like I was with Ms. Gorman, as a continuance of prejudicial length of
afforded to the State where none was forthcoming to Coughlin, despite Leslie and
Dogan's obstructionist tantrums, ones of a quality that would. J remember when my .
Ijfe featured happy moments like the birth of twins ... but that w before our
eviathan legal system wrecke s op on my existence. What sir. II be
Do you mind if I put my arm around ... bttp;#tinyurl.com/bgmlfdt
.
This is a formal grievance against Dogan, Leslie, .Bosler, Young ... etc.
IfSvengaliIDiann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases, and gag order
!them, he better be sure not to screw up the cases requiring a mistrial by failing to provide the client the cd's of
calls DDA Young gave the wcpd on 8/13 and 8/17/12 in rjc rev2011-065630, and clearly, any packet from
7rp/12 wouldn't have them (notto even get into the flip flopping contradictory accounts by Leslie and Dogan
as to gave Coughlin the packet, or who didn't or blah blah blah) ... and certainly Leslie email below only
a 57 page pdf ... way to close to the 12111112 trial date, and containing materials Coughlin had never
been given before .... so much easier, Jimmy Sleazy to email the client a "digital transmittal" proving what you
gave and when" " .. but, no, that would make it so hard to fudge the accounts of what was contained therein, or
who handed what to whom, or who failed to pick up this or that, or Dogan's slippery nonsense:
"From: Jleslie@washoecounty.us
To: zachcoughlin@hotmai1.com
CC: BDogan@washoecounty.us
'Subject: 911 Case
.
I
pate: Fri, 7 Dec 2012 17:09;08 +0000
.. ' !:;?
Coughlin:
Attached are the discovery materials in the case that you had requested and we had made an
copy of for you in response to your request. Please note that the July 27, 2012, cover letter was for
. your pick up and never it up. Note also that the July 27,2012, packet encloses a copy of the April
p, 2012. hand of the very same documents which you received.
2
".0'
:0.
Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at
our front desk. Since you failed to retrieve them, we provide the attached courtesy copy before final of
our file.
No response to this transmittal is required from you.
James B. Leslie, Esq."
So, while Dogan states on 7127/12 in 65630 "Your Honor, I have never even spoken
with Judge Dorothy NaSh Holmes" ... hecoyly fails to indicate whether he spoke
with anyone with the RMC, Marilyn Tognoni, included, 'or why his 2/28112 fax to
Coughlin was so insistent that it was "Lake's Crossing's Bill Davis, Ph.D." who
,must conduct the "Competency Evaluation", or how it was Judge Clifton's 2127112
. Order for Competency Evaluation could have possibly known and included Judge
'Elliott as the "randomly assigned judge" to that Competency Case in CR12-0376
(Judge Elliott on Committee to Aid Abused Women's Board, (CAAW) .. .Judge
Elliott presiding over Coughlin's wrongful termination lawsuit against WCDA's
Office ECR Partner, Washoe Legal Services, its Executive Director Paul Elcano,
CAA W, in CVI1-0195S .. .Judge Elliott fails to disclose conflict or recuse
himself, Judge Elliott manages to "randomly" be assigned Coughlin's two criminal
'appeals from RMC convictions (the Wal-Mart "candy bar" petty larceny leading to
a 6 months, so far, temporary suspension of Coughlin's law license in 11 cr 22176
in the RMC, then cr11-2064 in the appeal Judge Elliott canned based upon a civil
requiring a down payment for the preparation of transcripts and Elliott's
contention that he need not address the merits of Coughlin's appeal given the lack of
a written transcript (Coughlin paid for the audio cd, and its not even clear that the
RMC is a court of record anyways, and the RMC distributes to defendants
instrUctions sheets and enforces "house rules" regarding the preparation of
transcripts that require one utilizing the services ofRMC "official transcriptionist
Pam Longoni (whom hung up on Coughlin twice, and refused to prepare the
transcript in 11 cr 22176/crll-2064, failed to return emails/faxes, etc.)" and where
the RMC refused to even give Coughlin the audio recording for some time, insisting
Coughlin could merely have it made available to Longoni .... Oh, Coughlin didn't get
3
: ,..,
: . 1
,. f

no continuance from Judge Howard in that 11 cr 22176 (even where he was
wrongfully evicted in Rev2011-001708 (now on appeal in 60331 and 61383) on
11/1111, then wrongfully arrested on 11113/12 in 11 cr 26405 (now feature in
61901,62104,54844,60302,60317, etc .. ) and incarcerated between 11113/12 and
11/15/12, no continuance for the 11/30/12 Trial in 11 cr 22176, despite an
agreement in writing with City Attorney Pamela Roberts (whom put on perjured
testimony by three witnesses where she possess a video and other evidence
conclusively proving that Coughlin did provide his driver's license to RSIC Officer
Crawford ... and where Robert's prosecuted based on an arrest for a misdemeanor by
tribal officers where NRS 178.1255 bars such an arrest, and where Wal-Mart's
Thomas Frontino and Roberts herself admit no citizen's arrest was effectuated .... so,
about that RPC 3.8 violation ... ). Then there is the appeal in crl2-1262 that Judge
Elliott, again, was "randomly" assigned from the conviction by RMC Judge
William Gardner in 11 cr 26405 based upon the criminal trespass complaint signed
by Richard G. Hill, Esq. (opposing counsel in the summary eviction from
Coughlin's former home law office in rjc rev2011-00 1708, presided over by Judge
Sferrazza, though Hill and his associate Casey D. Baker, Esq. fax, on October 17th,
2011 to Judge Clifton (who was not Chief Judge at the time, or anything) an .
Emergency Ex Parte Motion for Inspection of Coughlin's Law Office, and where in
his October 19th, 2011 Order in that matter 001708, Judge Clifton ruled as "moot"
Coughlin' 11117112 Motion to Set Aside the 11/13112 Order following Summary
Eviction Proceeding by Judge Sferrazza setting the matter for "Trial" on 10/25/12,
~ ~ the condition that Coughlin deposit a rent escrow of $2,275 with the RJC
(though Judge Sferrazza admitted later on the record on 11n/12that the ruc )udges
.had a meeting wherein they all had to agree that Coughlin was absolutely correct
that the ruc was violating Nevada law in baving an unpublished "house rule"
corollary to JCRL V 44 requiring such rent escrow deposits in landlord tenants
matter here JCRCP 83 had not been followed in that the RIC had not published and
had approved by the N. S. Ct. any such deviation .from the statutory remedies set
forth in NRS 40 and 118A. Judge Elliott managed to torpedo that appeal of the
criminal trespass conviction stemming from the criminal complaint and custodial
arrest at Coughlin's former home law office by co-signing RMC Judicial Assistant
Lisa Wagner's and the RMC's nonsense about not having received Coughlin's
~ o t i c e of Appeal timely under NRS 189.010 . . The proof of delivery fax
com111llation indicates otherwise, Lisa. And regardless. the conveniently timed
arrest of Coughlin on 6/28/12, and the tolling nature of Coughlin's 6/26112 Motion
for New Trial in that matter, and the kited, dated 7/10/12 jailhouse Notice of Appeal
by Coughlin, and the curiously failure to grant Coughlin tier time in the interim
4
while Judge Gardner manageed to push through his 7/11112 Order Denying.
Coughlin's Motion for New Trial, is all the more reason to apply to
Judge Elliott's work on the appeal on CR12-01262 .. Then there IS Judge Lmda
Gardner being Judge Peter Breen, MO's law clerk, and Breen kicking Coughlin out
df the Mental Health Court based upon Sharon Dollarhid, Rene Biondo, and Breen
and theMHC's own breach of contract (if they provide program materials,
acceptance, and a contract that list certain medications as disallowed, how is, it
can claim non-compliance or "failure to abide" by the for taking a medIcation
not listed therein? Don't ask WCPD Joe Goodnight or Jetinifer Rains ... they know
what side their bread is buttered on .... MH12-0032 ... so DDA Young tries to jam
through a trial in 063341 on May 7th, 2012, despite the mandatory stay in NRS
178.405 and the then still pending Order for Competency Evaluation in rjc 2012-
065630 from the clandestine status conference Dogan and Young never quite seem
to refute happening on 2/27112 ... 0h, and Judge Clifton, then DA Dorothy Nash
Holmes, and Judge Linda Gardner were all co-workers once upon a time, working
closely with then Sparks City Attorney/prosecutor Steven Elliott, whom worked for
the law ftrm of the father of the Panel Chair for Coughlin's 11114/12 SBN v.
Coughlin fonnal Disciplinary Hearing in NG12-0204, 0434, 0435 (the last two
being grievances against Coughlin filed, in part, by RMC Judge William Gardner,
prior to Gardner failing to recuse himself from the criminal trespass case against
Coughlin before him in 11 CR 26405 ... even where Judge Gardner's sister Judge
Linda Gardner's April 2009 Order sanctioning Coughlin was cited by WLS's Elcano
as' the sole basis for fIring Coughlin, and where Coughlin filed a Mandamus Petition
'in 54844 challenging those sanctions, and where ng12-0435 was one of three
grievances fonning the 8/23/12 SCR 105 Complaint against Coughlin
{strangely ... the Wal-Mar "candy bar" petty larceny conviction and the formal
hearing for the "sole purpose" of determining Coughlin's punishment for such
by SCR 111 (8) and the Court's 6n 112 Order got particularly short shrift in
the 8/23112 triple grievance numbered SCR 105 Complaint by Bar Counsel Pat
"Patty Ice" King, a/kIa Pat Salieri, whom wants no part of explaining his statements
to Coughlin during the 3/26/12 appearance at the SBN by Coughlin, for the sole
p,:"rpose of taking King up on his offer to let Coughlin review the materials
submitted along with the grievances (therein King claimed to have received
grievances against Coughlin from three different Judges .... though, by 3/26/12, it
pouldn't have been Beesley, as Coughlin only filed the exhibits detailing Judge
Nash Holmes and the WCSO and WCDA impermissibly confiscating Coughlin's
smart phone without a warrant or court order and well after the end of the period to
do a search incident to arrest (the arrest was 2/27/12 for s<?me pastiche of summary
5
, ,
plenary civil criminal contempts statuts that Judge Nash Holmes whipped
up ... though she avoid NRS 22.030 and defmitely there wasn't no affidavit signin' by
01' RMC Marshal Harley for alleged conduct iIi a restroom or restroom stall, which
assuredly was not "under the watchful eye of the court" or "in the immediate
of the court .... so much easier for Bar Counsel to feed Judge Nash Holmes
the"clear and convicing evidence" standard from Schaefer required to prove an
ethical violation, have here copy and paste some RPC's into a second bite at the
apple and more than 10 days later (civil statute, NRS 22.010, NRCP and JCRCP 59
allow sua sponte amending within 10 days, no 12 days ... 2/27/12 to 3/12l12 .... void
Order of 3/12/12 by Judge Nash Holmes, so, sorry Patty Ice, nice try, no SCR
i 11(5) "an Order or conviction is conclusive proof of guilt and I don't recognize
Claiborne as binding authority because it makes my job harder.; .. " ....
Thank You Jim for continuing to prevaricate in writing, your recent email combined
with some, uh, other materials that have been culled, will surely be helpful in
. exposing you for the fraud that you are. And Biray Dogan too .. Oh, by the way,
that lIn /12 fax conf1I1llation page or proof of faxing? How is that coming along,
because I need to see it from you. My records show absolutely no receipt of any
fax of that sort, not on that day, not on any day ... whicil: means the ball is in your
court to show how Dogan's representations to Judge Sferrazza on 11/19112 in court
were not displaying a lack of candor to the tribunal and How Leslie Tibbals'
certificate on service therein is not fraud.
,Oh, attached is Goodnight's 12 19 11 Request for Discovery, which includes:
i'REQUEST FOR DISCOVERY
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and
through his attorney of record, Joseph W. Goodnight, Deputy Public Defender, and
hereby requests the following pursuant toNRS 174.235 to NRS 174.295,
. inclusive. 1. Inspect and receive copies or photograph any written or recorded
or confessions made by the Defendant or any witness, or copies thereof;
wlthm the possession, custody or control of the State, the existence of which is
known or by the . exercise of due diligence may become known to the prosecutor.
NRS 174.235(1)(a). This request includes any video and audio recordings.
including those preserved on pocket recording devices. 9-1-1 emergency calls. and,-
any dispatch logs. written or recorded. generated in connection with this case."
6
Jim, then there is you chiming in, in your role as "standby counsel", to
aid the Court and DDA Young in coercing from me my Fifth Amendment nghts at
the 9:06 am mark on the transcript from 11120/12 ("Your Honor, I'll remind the
Court that I am here to jump in in my role as standby counsel anytime the Court's
feels he is dragging his feet. .. ;He is wasting County assetst" ... very Atticus Finch,
Jim).
So, then there is'Jim's 10/3112 subpoena to EcommlKelley Wood .. given he was
counsel of record until 10/22/12, yet completely failed to tum over anything
(responsive or not) .in relation to that subpoena, and the fact that the entire
Suppression Motiontumed on "what information the RPD received from dispatch",
and the fact that the audio of the "radio traffic" between the RPD and Dispatch on
that night (or at least the portions of it I have been able to extract from the powers
that be) reveal, one, no report of a possible fight was received by RPD (they were
on the scene 'by the time the 11 :27:11 pm text was sent to the displays in their
vehicles, and the one audible "radio traffie' recording contains no mention of
anything beyond "check for possible larceny of a cell phone that just occurred,
suspect still on the scene, also reports of a loud verbal disturbance ... ". Then there is
Jim and Goodnight .completely whiffmg on the detaining argument, in addition to
. t;he whole "assuming we win on the pat down, make sure to oppose the notation that
there was sufficient probable cause for an arrest and search incident thereto .... ", not
to mention that it was Coughlin (whose filings Jim managed to cheerfully announce
"The Public Defender's Office is not joining in on those fugitive documents ... ",
despite the 2/21112 Filings by Goodnight that do just that. ... ) that pointed out the
whole NRS 171.360 basis for throwing out the search (which Jim managed to not
to or quote from in his closing argument as the Suppression Hearing ... where
'Jim did manage to ask Cory Goble questions on cross that were designed to do
nothing more than establish a citizen's arrest sufficient to rebut the NRS 171.360
basis for throwing out the arrest and fruits culled therefrom ... ).
Oh, then there is your office blacking out the numbers of the callers on the dispatch
logs and refusing to turn over even a redacted version of the alleged victim's call
records for the time in question, thereby completely obstructing the defendant's
ability to impeach the various lies testified to by all the witriesses. And "Coach"
DDA Young can tell you all about his 40 minutes coaching sessions visible through
the plexiglass in the Justice Court lobby with Zarate, Goble, Lichty, and Templeton,
and their constant parroting (along with RPD Duralde) of "prosecutor buzzwords'"
("wiIIfully withheld", "report from dispatch of a possible fight", "my training and'
7
,',
, .

experience", "detained", "I don't remember who made the call", "I can't remember
which one of my friends it was who was with me", etc., etc.) Also, the WCPD
practice of blacking out locations and addresses sure difficult to
inconsistencies between testimony and the reports/Wltness Statements or otherwise.
utilize them for impeachment purposes. '
So, now today, we get this Jim Leslie email with all it's revisionist history ... which
only contradicts the, position Leslie and Dogan have taken that Coughlin already.
picked up this 7/27/12 packet (at first Dogan claimed to have personally handed It
to Coughlin, then changed his story 2 minutes later and said he saw Leslie
personally hand it to Coughlin .... arid Dogan asserts to the Court at the 11/27/12
Hearing in rcr2012-065630 that he has never spoken with Judge Dorothy Nash
Holmes (see materials regarding clandestine status conference of 2/27/12 and
subsequent fallout with Judge Nash Holmes of 2/27/12 a couple hours after Dogan
secured his 2/27112 1:31 pm Order for Competeny Evaluation in 065630 from
Judge Clifton).
The SBN v. Coughlin Complaint of 8/23/12 specifically mentions the arrest of
1/14112 that theis 065630 case is based on, in addition to the 063341 iPhone arrest,
and RJC Judicial Secretary Lori Townsend sent Coughlin's 2121112 in 065630 to the
SBN, and offered to send Coughlin's 2115/12 filing in 063341 to the SBN ... and
Nash ;Holme's 3/12/12 Order in 11 TR 26800 mentions Coughlin quoting
lyrics" in a filing as a basisfor her transmogrifying a "simple traffic citation,j
to a "foimal disciplinary hearing on an ethics violation" wherein she quotes the
Schaefer standard for an ethical violation that Bar Counsel had fed her earlier in the
day ... and that window between the 1:00 pm noticed start time of the traffic citation
trial in 11 tr 26800 and the 3:30 pm eventual start time includes the 1 :25 pm
courthouse sanctuary doctrine violating service upon Coughlin (by RMC Marshal
Joel Harley, on behalf ofWCSO Deputy Machen, hired by Richard G. Hill, Esq., at
whose office Coughlin was retaliated against by RPD Sargent Tarter with the three
traffic citations shortly after Coughlin reported to Tarter the admissions regarding
bdbery by Richard G. Hill, Esq. by RPD Officer Chris Carter, Ir .... and Marshal
Harley was serving the Order to Show Cause for the 3/23/12 Hearing in the appeal
of the summary eviction from Coughlin's former law office (where RPD Carter
made the trespass arrest now detailed in N. S. Ct. case 6190 1), on behalf of Deputy
Machen, in the conference room within the Courtroom B of the RMC, despite
an efiler, having already been served it). However, the only filing by
<:;oughlin that could be said to quote "rock lyrics" is the 2121112 filing in Dogan's
8
I
I
j
case 065630 (the one where Dogan had appeared as attorney of record then failed to
show up for a hearing on 2/13/12, then retaliated against Coughlin for Coughlin's
2/21112 filing in 065630 by moving for a Competency Evaluation and basically
doing abs01utely nothing oothe case for the next 9 months besides raping from
Coughlin his medical privacy rights along with Judge Steven Elliot and DDA Zach
Young at the 4/19/12 hearing in (one of 3 criminal appeals Judge Elliot
was "randomly" assigned in which Coughlin is a party ... to go along with the
wrongful termination suit by Coughlin that Judge Elliot presided over in eV11-
01955 wherein Coughlin sued CAA Wand WLS, despite Judge Elliot sitting on
CAA W's Board, and where Judge Elliot, the Panel Chair at Coughlin's fonnal
disciplinary hearing of 11114/12, and Washoe Legal Service's Paul Elcano all went
toStanford together, and where Judge Elliot worked for Panel' Chair John
Echeverria's father'slaw firm, Echeverria andOsbome). Then there is Linda
Gardner being Judge Breen's law clerk, and Judge Breen reinoving Coughlin from
Mental Health Court in MHI2-0032, where the MHC's Rene Biondo and Sharon
Dollarhide lied about what medications were listed as accepted or not in the
materials provided.by Goodnight and or the MHC along with the contract entered
into with Coughlin, whom was accepted into the MHC. Then there is WCPD Joe
Goodnight and Jennifer Rains refusal to file anything directed towards the
MIlC's contract with Coughlin, wherein they both demonstrated they know what
their bread is buttered on and indicated "there just isn't a basis for seeking .
reconsideration of Judge Breen's Order". Judge Peter Breen, MD.
Funny how Dogan did not state to Judge Clifton that he never spoke with anyone
else at the Reno Municipal Court about Coughlin .... including Marilyn .
Tognoni",but, rather Dogan just indicated he never spoke with Judge Nash
Holmes, in his best innocent little boy.voice that he cops when he isn't busy tittering
away with Jim Leslie in the spectator area during the 11/19 and 11/20 Trial in
063341 (where he failed to apprise Judge Sferrazza of the fraud attendant to his
earlier attestations regarding proof of service (by fax no less) of his I1n/12 Motion
to Quash Coughlin's Subpoena ....
Also, its a bit strange how Dogan and the WCPD redact or black out the names of
the RPD Officers and Dispatch Operators beginning on page 16 of the 56 file
Jim Leslie fmally emailed me today titled "Coughlin Discovery 911 Case", which,
as is their wont, he and Dogan have continued to change their stories about whether
'they had or had not provided to me already until the last possible minute before
trial, whereupon, with a Trial date of December 11th, 2012 in rcr2012-065630, Jim
9

finally emails me a 56 page pdf purporting it to be my "file". One wonders,
where any audio recordings, dispatch recordings, 911 call recordings or other medIa
are any why Leslie arid Dogan did not provide them. Coughlin appeared at the
WCPD's Office today and asked for the hard copy of his file, yet was told by front
desk receptionist "Paula" (of course, no last name provided) that she "spoke with an
associate" and they told her that Jim Leslie had already provided Coughlin his file
and. that he, therefore, would not be given the hard copy. "Paula" eventually
seemed to have to admit that the misleading use of the term "associate" actually did
not connote her having spoken with an attorney about the matter ... but rather Linda
Gray, whom has been curiously silent as to the apparent misconduct-attendant to her
admitting that she did not mail out any written notice to Coughlin of the August 6th,
2012 "combo-hearing" in rcr2012067980 or rcr2012-065630 (Leslie glossed over
that fact by sending Coughlin a note about how he "saved the day" with his
,i advocacy" ... skipping past the part about how the client, Coughlin, was not noticed .
on the hearing in any matter, muchless in writing .... Leslie later refused to indicate
with any specificity whatsoever how he "knew" Coughlin had been noticed on the
.8/6112 hearing in writing ... and ruc Judges. are only too willing to "believe" Jim
Leslie, Esq. when he explains away vaguely such things ...
Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have
continued in your way (similar to. how you approached the rcr2011-063341 case
where Joe Goodnight, Esq. was counsel of record until you had him removed on
7116112, the morning of Trial...after Mr. Goodnight and I have completed a video .
conference fmal trial preparation at 4:30 pm on Friday, July 13th, 2012 while I was
in custody (pursuant to an arrest on July 3rd, 2012, ordered by RPD Sargent Kim
Bradshaw, she of the 1112112 custodial jaywalking arrest along with RPD Sargent
Paul Sifre ) .... Things fall through the cracks, Mr. Leslie, when you place a gag order
?n the associates you claim to supervise, then sfubbornly, petulantly, and
;retaliatorily refuse to work the cases you have snatched back from your
associates .... Similarly, WCPD Fortier's email to me of February 6th, 2012 may have
contributed to Mr. Dogan's confusion in failing to attend the Hearing on Feburary .
13th, 2012, which begat my filing of February 21st, 2012, which begat Mr. Dogan's
the February 27th, 2012 Order for Competency Evaluation, which begat
the 5 day summary incarceration for summary/plenary/criminallcivilltransmogrified
. disciplinary hearing on an ethics violation/what is jurisdiction? Order by RMC
Judge Nash Holmes on 2/27112 at 4:40 pm ... which begat NGI2-0434, and probably
0435 (the SBN v. Coughlin SCR 105 Complaint of 8/23112).
10
" e

However, Mr. Dogan, you are not off the hook just because Jim Leslie places a gag
order on you. Mr. Leslie sent this email today with a 56 page pdf file purporting to
be my "file
ll
I, as now a former client, have rights to "my file". I have requested
my file in writing from your office on numerous occasions, and given your removal " I
as counsel of record on 11122112 (amazingly Mr. Dogan probably managed to say
200 words on a case that he had been counsel of record on for nearly a year, and
had not managed to file a single document in that case, RCR2012-065630, and had
inanaged to get upset that a client would take issue with his missing the 2/13/12
Hearing, even though WCPD Fortier's 2/6/12 email makes clear, the matter was
assigned to Mr. Dogan at that point, and he had already sat down and discussed the
case with Coughlin for over one hour on or about February 8th, 2012, where
Coughlin went to check in with Mary Watson, whom was then represented by
WCPD Branzell, who dragged Watson over to the Sparks Justice Court Bailiff and
"demanded they breathalyze her client. They did, she was taken into custody.
So, after sitting down with Dogan for at least an hour and discussing various things,
some including matters related to the case he was then attorney of record on
RCR2012-065630, the February 13th, 2012 court date (Dogan and Coughlin have
conflicting views as to what was agreed upon and the applications of NRS
178.388).
NRS 178.388 provides that the defendant must be preSent at arraignment, trial, and sentencing and provides that the
defendant may waive his appearance when certain conditions are met.
Its kind of odd how Judge Clifton (whose attached bio indicates he has deep and
19n9standing ties to the domestic violence industry infrastructure) knew
instantaneous to signing the Order for Competency Evaluation of 2/27112 at 1 :31
pm that the matter would be randomly assigned to District Court Judge Steven
. Elliot (also a lifelong prosecutor with deep and longstanding ties to the domestic
violence industrial complex, and a member of the Committee to Aid Abused
Women's (CAA W, one of the named defendants in the wrongful termination
lawsuit Coughlin brought and over which Judge Steven Elliot presided in CVl1-
01955, where he failed to point out his per se conflict of interest to plaintiff
Coughlin at any time, and where he ultimately pulled out just about every wrinkle
in the insufficiency of service and or process and or service of process (a movie
showing a non party over 18 years of age serving a senior paralegal at Washoe
Legal Services, whose Executive Director Paul Elcano went to Stanford with Judge
Elliot and the Panel Chair of Coughlin's 11114/12 Formal Disciplinary Hearing
11
before the State Bar of Nevada, John Echeverria in the late 1960s ... and Judge Elliot
worked at John Echeverria's father's law fum, Echeverria and Osborne Board of
Directors, in addition to being a former ass
In CV11-01955, Coughlin sued his fonner employer Washoe Legal Services, whose
Executive Director Paul Elcano went to Stanford in the late 1960s with Judge
Steven Elliot and John Echeverria, the Panel Chair of Coughlin's 11114/12 Formal
Disciplinary Hearing before the State Bar ofNevada .. and Judge Elliot worked at
John Echeverria's father's law frrm, Echeverria and Osborne, and Judge Elliot
served on the Board for CAA W, and was a prosecutor as the Sparks City Attorney.
Also, Mr. Leslie, while the 56 page pdf you fmalIy sent me (gosh, was it that hard
to click "attach" ,load a 2 mb pdf file and hit "send" on an email to me? No .
debatin" no arguing about whether Leslie and Dogan left the package at the desk,
whether Dogan already gave it to Coughlin, or whether Dogan then changed his
story and said Leslie gave it to Coughlin, whether Coughlin already picked it up, no
'Claims by Jessica the Receptionist of anyone kickin' furniture ... notbing like that,
just a digitally verifiable means of ascertaining what you transmitted and .
when ... was that so hard? Heck, Jim, you could probably Just email those ECOMM
recordings too ... and if attachment size is an issue, sign up for a www.outlookcom
(the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive
functionality, and up to 100 mb attachments via plan email, and over 25 free gb of
storage on the Skydrive, etc., t c . ~ . . But its Leslie fmally sent the 56 page "client's
file" on or abou.t 12n 112, yet he failed to include the insipid Motion of 11126112 by
DDA Young (wherein,just after Judge Clifton fmishes telling Coughlin at the
11/27/12 Hearing that Coughlin is not allowed to even think about the other two
~ C shotgunnin' style splatter paint prosecutions by DDA Young, as "they are just
not relevant to this proceeding" ... and anytime Coughlin would point out specific
basis for undertaking a recusal or conflict analysis vis a vis either Judge Clifton, the
RJC, DDA Young, the WCPD, or the WCDA, Judge Clifton would say "your're
losing me ... your're losing me ... " as if Coughlin was speaking in tongues all the
sudden ...
So, while Coughlin is reportedly not even allowed to email DDA Young about
cases not even before Judge Clifton, or something like that. .. DDA Young is able to
get an unnoticed, ex parte, emergency Motion to Prho
Sincerely,
12
Zach Coughlin
1471 E. 9th St.
Reno, NY 89512
Tel and Fax: 949 667 7402
Z8chCoughlin@hotmail.com
From: Jleslie@washoecounty.us
To: zachcoughlin@hotmai1.com
Subject: 911 Case
Date: Fri, 7 Dec 2012 17:09:08 +0000
Mr. Coughlin:
Attached are the discovery materials in the above-referenced case that you had requested and we had maQe an
additional copy of for you in response to your request. Please note that the July 27,2012, cover letter was for
your pick up and you never picked it up; Note also that the July 27, 2012, packet encloses a copy of the April
i?, 2012, hand delivery transmittal of the very same documents which you.received.
Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at
our front desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of
our me.
James B. Leslie. Esq.
Chief Deputy Public Defender
Washoe County Public Defender's Office
350 South Center Street
Fifth Floor
Reno. NY 89509
i
13
Direct Dial: 775-337-4828
Fax: 775337-4856
Email: jleslie@wasboecounty.us
11Ie amtena of thl' communication and all accompanylns documents and auaehments contain CONPlDBtmAL"INPORMATlON, arelepUy prlYileged, and are Intended
for use and reYiew only by the party sencllps same and the Intended recipient. If you are not the Intended recipient. you are hereby notilled thaC any disclosure, copyln ..
d1sa1budon, use or lakin, any ac;don reliant on said contents are CONPlDBHTtAL and ItrIctIy prohibited. If you reoeIved IhII communication In error, pi ....
Immediately noUfy us at 175-337-4800 to BJTIIIIII return of the ortJllnal transmittal. Tbankyau. "
14

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think a couple of whacks to my good old boy ganna get
me down? Its going to take a hell of a lot more than that
Counselor, to prove you're better than mel
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EXHIBIT I-e
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Leslie, Jim
From:
Sent:
To:
Subject:
tt
Novak, Eva
leslie, Jim
Coughlin office visit 12-12-12
Knowing Mr. Coughlin's volatile past behavior I was asked to accompany Jim leslie to the lobby to assist Coughlin. He
was seated In a chair writing a note. Jim leslie asked Coughlin what he needed. Coughlin mentioned he needed some
dIscovery from a case. Jim leslie advIsed him make any communications by way of e-mail, he would handle that way.
Coughlin asked if I was present as witness. Jim leslie confirmed that. Jim stated that he was going to ask to be relieved
from the current Coughlin case. Coughlin's demeanor became belligerent. Jim leslie asked Coughlin to leave the office.
Coughlin refused claiming he was writing a note. Jim leslie asked what the note was. Coughlin said II It's none of your
goddamn business and walked past Jim and left the note at the reception desk. Coughlin was advise several times by Jim
Leslie to leave the office. Jim Leslie advised him that the police were going to be called. At that point the elevator
arrIved. Prior to the elevator door closing he continued his rant toward Jim leslie until the door closed. .
Evo Novak
1
EXHIBITI-D
EXlllBITI-D
" .
Leslie, Jim
From:
Sent:
To:
Subject:
Mr. Coughlin:
Leslie, Jim
'zachcoughlin@hotmail.com'
Coughlin
Based on your behavior at our offices on several past occasIons, IncludIng today where we had to call the police due to
you engaging In behavior constituting disturbing the peace, you are hereby directed NOT to come to our offices without
first having confirmed in writing an appointment with your assigned attorney.
If you violate this email notification, we will contact law enforcement.
James B. Leslie, Esq.
Afth Floor
Reno, NV 89509
1-800-762-8031
Direct Dial : 775-337-4828

Email: ileslle@washoecounty.us
The contents of this communication and all accompanying documents and auacbments conlaln CONFIDENTIAL INFORMATION, are legally privileged. and are Intended
ror use and review only by the party sending same and the Intended recipient Iyou are not the Intended recipient. you are hereby notified thatany disclosure. copying.
distribution, use or laking any action reliant on said contents are CONI'lDBNTIAL and strictly prohibited. If you received this communication In orror, please
Immediately notify us at 775-337-4800 to arrange retum of the orlBlnal transmittal. Thank you.
1
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EXHIBIT I-E
EXHIBIT I-E
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Leslie, Jim
From:
Sent:
To:
Cc:
Subject:
Julio:

leslie, Jim
Duarte, Julio
Vaughn, Valerie
FW: Coughlin

Val tells me she spoke to you briefly about Zachary Coughlin. Below Is my email to him stating he is NOT to come to our
,offices without a prior written confirmation of appointment with his assigned attorney. I am his only assigned attorney.
We ask that you NOT grant him admittance to the building without first letting us know he Is here. I will email you in
advance of any date and time that I set an appointment with him, but other than that there's rro reason to permit him
in.
Please let me know If you have any questions.
Thank You,
~ i e f Deputy Public Defender
Fifth Floor
Reno, NV 89509
1-800-762-8031
Fax: 775-337-4856
Email: jleslle@washoecountv.us
The contents of mis communication and all accompanying documents and attachments con min CONFIDENTIAL INFORMATION. are legaUy prlY1lcged. and are intended
for lise and review only by the party sending same and the intended recipIent If you are not the intended recipient, you are hereby noUned that any disclosure. coPyln80
distribution. use or taking any aeilon reliant on said contents are CONFIDENTIAL and strictly prohibited. Ifyotl receIved thIs communication In error, please
immediately notify us at 775-3374800 to ammge return of the original transmittal. Thank you.
From: Leslie, Jim
Sent: Wednesday, December 12, 2012 4:22 PM
To: 'zachcoughiln@hotmall.com'
SU.bject: Coughlin
~ r .. Coughlln:
eased on your behavior at our offices on .several past occasions, Including today where we had to call the police due to
you engaging In behavior constituting disturbing the peace, you are hereby directed NOT to come to our offices without
first having confirmed In writing an appointment with your assigned attorney.
If you violate this email notification, we will contact law enforcement.
1
[i' 111_ t 1/
" .
,.
J
James B, Leslie, Esq.
Fifth Floor
Reno, NV 89509
1-800-762-8031
Fax: 775-337-4856
: Email: lIeslie@washoecountv.us

. The contents of this commllnlcaUon and all 8ctompanyln, dOCllmenlS and attachments contain CONPfDBNTlAL INFORMATION, are lepllypliYlIepd. and are Intended
for lISe and review only by the party sending same and the Intended redplent l(you are not the hitended recipIent, YOII are hereby notllled that any disclosure, copying.
.' distribution. lISe or taking any action reliant on said content! are CONI'IDI!NTlAL and strictly prohIbited. rr you received thla communlcaUon In error, please
Immediately notify lIS at 7753374800 10 arranse return of the olislnaJ transmIttal Thank you.
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STATE OF NEVADA
COUNTY OF WASHOE

AFFIDAVIT OF ATTEMPTED SERVICE
I, David L. Watts-Vial, being first duly sworn and under
penalty of perjury do hereby depose and say:
1. I have personal knowledge of the following facts and am
competent to testify to the same.
2. I am employed by Washoe County as a Deputy District
Attorney in the Civil Division of the Washoe County i ~ t r i c t
Attorney's Office.
3. As part of my job duties, I represent the County in
workplace violence incidents and am the attorney of record for
this Application.
4. Mr. Leslie, as a Chief Deputy Public Defender, a County
employee who supervises other County employees in the Washoe
County Public Defender's Office, is an authorized agent of the
County for the purposes of this Application.
5. On December 17, 2012, I was provided the information
contained in the instant Application by email. At the time the
email was received, I was in a meeting with another client at
the Washoe County Complex which did not conclude until after
5:00 p.m, after the Courts were closed, and I was unable to file
the application until such time as I had reviewed it and Mr.
Leslie signed on behalf of the County_
6. On December 18, 2012, I reviewed the instant
Application, and had Mr. Leslie sign it upon his arrival prior

1 to a court action in the Reno Justice Court, at approximately
2 8:30 a.m.
3 7. After the Application was signed, I returned to my
4 office, drafted the instant affidavit, and gave the Application
5 to my staff for finalization, and then for filing.
6 8. Prior to filing, my Assistant, Cynthia Mendoza,
7 provided a copy of the instant Application and all attachments
8 to the email d d r ~ s s and fax numbers used and prQvided by Mr.
9 Coughlin in his correspondence with Mr. Leslie,
10 zachcoughlin@hotmail.com, fax number (949)667-7402.
11 9. Given Mr. Coughlin's repeated instances of harassment
12 and intimidation as described by Mr. Leslie in the Application,
13 it is very likely that Mr. Coughlin will react badly to any
14 decision to remove Mr. Leslie as counsel for Mr. Coughlin, and
lS will engage in further acts of harassment and intimidation
16 against Mr. Leslie.
17 10. Mr. Leslie's description of Mr. Coughlin's history of
18 unannounced appearances at the Public Defender's Office, despite
19 repeated instructions by Mr. Leslie that he is only to appear
20 with prior notice and at a set time, and his implied threat to
21 harm Mr. Leslie, paired with Mr. Leslie's efforts to withdraw
22 from further representation of Mr. Coughlin, demonstrate that
23 the County and its Public Defender's Office and employees will
24 suffer immediate and irreparable injury, loss or damage, and
25 that Mr. Coughlin will engage in further acts of harassment and
26 intimidation against the County and its employees before Mr.
' r

1 Coughlin can be heard in opposition to this Application, and the
2 Court is therefore requested to grant the temporary order and
3 set a hearing in the near future on the temporary and extended
4 orders for protection as indicated by the County.
5 Further affiant sayeth naught.
6
7 STATE OF NEVADA
8 COUNTY OF WASHOE
9 SUBSCRIBED and SWORN to before me
10 this 18th day of December, 2012
11 by David L. Watts-Vial.
12 N O T R Y ~
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EXHIBIT 6
EXHIBIT 6
RENO CIVIL
CASE SUMMARY
/ / ,
CASE No. RCP2012-000607
/ State Bar of Nevada
vs.

Location: Reno Civil
Judicial Officer: Pearson, Scott
Filed on: 12/20/2012 Zachary Barker Coughlin
CASE INFORMATION
12/20/2012 Decision without TriallHearing
Case Type: Protection Order - Workplace
DATE
Applicant
Adverse Party
DATE
12/2012012
12/20/2012
12/20/2012
12126/2012
01104/2013
01104/2013
01110/2013
03/20/2013
06/26/2013
07/26/2013
Case Number
Court
Date Assigned
Judicial Officer
State Bar of Nevada
CASE ASSIGNMENT
RCP2012-000607
Reno Civil
12/2012012
Pearson, Scott
P ARTY INFORMATION
QJ Application for Protection in the Workplace Filed
J Order Granting Application for Protection Order Filed
J Temporary Order for Protection Against Stalking Issued
J Affidavit of Service Filed
Adverse Party served by Bailiff 12/26/2012
{i] StalkinglHarassment (8: 15 AM) (Judicial Officer: Pearson, Scott)
{i] Extended Order for Protection Against Stalking Work Issued
to expire 1-4-14
QJ Affidavit of Service Filed
Zachary Barker Coughlin served 1/5/13.
QJ Motion Filed
Motion to Proceed Informa Pauperis filed
and request for Javs Audio of 1/4/13
J Motion Filed
for an Award of Costs and/or Attorney Fees (NRS 33.270)
PAGE IOF2
. I
Lead Attorneys
King, Patrick Owen
Retained
INDEX
,:., to wh!ch t:\1!'i
I. true nnd
" : ' cund In tire reca.G-tl
Printed on 1011612013 at 3:59 PM
07/26/2013
07/30/2013
9J Motion Filed
RENO CIVIL
CASE SUMMARY
CASE No. RCP2012-000607
to Modify, Dissolve, or Enforce Order for Protection Against Harassment in the Workplace.
liJ Order Filed
Order Dissolving Previously Issued Order for Protection DENIED
PAGE 2 OF 2 Prinled on 1011612013 a13:59 PM
12-19-2012
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2012DEC20 A
8:40
Case No, e. t..i' t.-D \- 2---000 '1
Dept. No. tg . '
R
STEVe' 'r
l) .. ' U i (!
IN THE JUSTICE COURT OF TOWNSHDr I. '-w. T .
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COUNTYOF . STATE OF NEVADA OEcUn;.- ,-_
o
e:w- cf tf\Jv/'udc.,)
Employer, ) APPUCATION FOR TEMPORARY
) ORDER FOR PROTEcnON AGAINST
) HARASSMENT IN THE WORKPLACE
vs. ) (NRS 33.2S0)
8.
Advene Party. )
(NOTE: caD only be aBC Adftrse Farty.)
HARASSMENT IN THE WORKPLACE- Under NRS 33.l4O, bal'1ll8ment In the
workplace ottars when:
1. A person knowingly tbreatens to cause or commits aa act that causes:
<a> Bodily Injury 10 bimself or anotber penon;
(b) Damage to the' property of another penon; or
(c:) Substantial barm to the pbysical or meatal bealth or safety of a persoo;
1. . The threat is made or the ad is agaiost an employer, an employee of the
employer while Hte employee performs bis duties of employment or a person present
at the workplace of tbe employer; and
3. The threat would cause a reasonable penoll to Cear that the threat will be carried
Olt or the act would cause a reasonable penon to r.1 terrorized, frighteQed
t
i .. timid.ted or harassed.
PLEASE TYPE OR PRINT CLEARLY.
COMPLETE THE APPLICATION TO THE BEST OF YOUR KNOWLEDGE.
( state the fonowing facts under penulty of perjury:
o I am lhe employer.
{ am the aUlhorized agent of the employer.
o { am not the employer or authorized agent of the employer, (If this box is
checked, you may not file wis form.)
form II-J '\I'fI"""''''''' for r <mpt\f;ofy 1!aIn I'Inttdl'lIJ. AJi'IIIUl " __ lit ItIC Wnrkpba ()1flGl l'upc-cme ""un
lumo )11. l001
Pa,e I 0(6
RCP2012-000807
APW
Appl101lflon for ProlBoUon In the WOrkplaot

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7753256715
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12-19-2012
218
e
[ reasonably believe that the Adverse Party has threatened or committed an act or act(s) of
harassment in the workplace as defined above. The event(s) occurred as follows:
NOTE: BE SPECIFIC AS TO WHO THREATENED OR COMMITTED WHAT ACT OR
ACTS AND A.GA11YST WHOM. INDICATE APPROXIMATE DATErs) AND
LOCA.TION(S). ALSO UST SPECIFIC EMPLOYEE(S)IPERSON(S) PRESENT AT THE
WORKPLACE WHO ARE THE FOCUS OF THE lIARASSMBNTOR WHOM THE
ADJlERSE PARTY SHOULD BE DIRECTED NOT TO CONTACT.
TBlS FORM IS A PUBLIC RECORD
Sea.. 6) rJ\. eO'l'\.=\ec\ r-aei
\r\
Obb-c t
_\ '( 1 h", 1:::5 l- - JO
\.
NOTE: PLEASE DO NOT WRITE ON THJ! BACKS OF ANY PAGES;
CHECK BOX IF YOU ARE USING ADDmONAL PAGES.
o C/reck if you use II cOlltinulllion poge (to be incorporated by reference)
( &cz. b; b
l
f".". U-J Appbc.ll,,'" r..r ren"""ay (It tier rllT .\p1DS1 "..-tot It,\he >Q2\r)7 ""'-Ia ljupm!III '""un

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12-19-2012
NOTICE REQUIREMENTS
(Complete either A or B. Dot both)
A. I HAVE given notice of .tbis ApplicatiOD to tbe Adverse Party by the following
metllod{l):
o In Person t)1 Email 0 Fax
o Telephone 0 Overnight Carrier 0 First Class Mail
o Other._ __________________ _
Date: iPC<ZN! l?g. 1 1, Time: ___ . ...J.3=O=__ __ _
o I have received confirmation that the Adverse Party has received my Application for
a Temporal}' Older for Protection Against Harassment in the ,Confirmation
orreccipt is attached (i.e., fax, e-mail. postal mail. etc.).
if I have not received confinnation.
B. I BA VE NOT given notice of tbis ApplkatiOD to the Advene Party because
13
immediate 8tld in'eparable injury, loss, or damage will result to the employer. an employee of the
14 employer while the employee performs the duties of his employment, or a person wbo is present
at the workplace of the .emplqyer, before the matter can be heard on notice. The irreparable
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injury. Joss, Of damage that may r:esuIt is: _______________ _
16 It is imparable because of
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o Possible economic or property damage which may include the following: __ _
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o Continuous threat of stalkinglhamssment
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o (personal injury)
o Possible death to speci fred individuals named in the Application
o Other: _____________________ .
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1. What efforts, if 3ny, have been mQde to give Dotice to the Advene Party? _
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Z. Facts supporfing lniver of notice requirements: ______ __ _
ZS.
hnR 8-J App/t(41IOft .ror TtTIIJ'O'uy t""'" rot I'tO\t1llll " ..... 11_ won.p,"" e2Q01
JulIe 311, 2001
P.tp Juf"
3/8

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12-19-2012
GENERAL INFORm TION
This matter does not have to be reported to law enforcement; howover, has a related
report ever been filed? 0 Yes
complete infonnation, ifknown. You may attach available copies)
Approximate date ofreport(s): _______________ _
Name(s} of law enforcement agencies: _____________ _
Casenumber(s): ___________________ _
For purposes of this form. a "TPO Action" is defined to include the following
Court actions:
(1) An Order for Protection Against Stalking and Harassment (NRS 200.591);
(2) An Order for Protection of Children (NRS 33.400);
(3) An Order for Protection Against Harassment in the Workplace (NRS 33.270). A
11 ''TPO Action" is also defined to include the following Justic:elFamilylDistrict action:
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(a) An Order for Against Domestic Violence (NRS 33.020)
Please Check the Appropriate Box Below:
In the last 2 years. Applicant or any party seeking protection has not filed a TPO action
against the Adverse Patty anywhere in the State of Nevada, and the Adverse Party has no
filed a TPO action against Applicant or any party seeking protection anywhere in the
State of Nevada. .
In the last 2 years. the following TPO action(s) in the State QfNevada have been filed
involving Applicant and the Adverse Party;
Case #
(iflmown)
Court Place of
(JusticelFamily) Filiag
Approx.
Date Filed
Outcome (TPO
graated, deaied,
resciaded etc.
2. a) Employer's name (if applicable, dIbla): '5=ke\e. bvc c?S-
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b) The workplace located in, and tl1e employees primarily perfonn their duties at the
following address: qt{S r;... )2cJ\.Jbla.... g" 'f9
A
,Q., l ..
Town/City of County of Slale of (\JuadC(
4/a--
Phone fl.; -13 '1

OlOlll Nc-'" So'I'f-'-
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12-17-2012
PLEASE CHECK. THE APPROPRIATE BOX(ES) BELOW, IF APPUCABLE.
o Employee(s) also work at the additional specific locations that need to be enumerated
in the Order:
______________________________________ ___
Town/City of ____ County of _____ ...J. Slate of ____ _
_____________________________________ ___
_________________________________________ _
Town/City of ____ -', County of ______ State of ______ ..:-_
____________________________________ __
(If you wish to designate more specifIC addresses, please list them in this format on a
separate lIbeeL)
o The employees perfonn their duties statewide.
o Other comments on locations where protection is needed: ________ _
agent for employer. c Ie D. 'h.. 'I M
" ,
... .
Phone number for authorized agent: J 7 S -.3 g"_';"'-=..{ 3::=:..:.g=.. ".J4 ___ _
Is employer represented by an attol'f.4'!V? i Yes 0 No '
__
Addres&: .'Ofl{5f:, ISh:, 6,
Phone # for attorney: 1t5:3 ?!?tB6?rax ## for attorney: 't-5 -3Cf,- 4 (C::::C:>
Are there addilionai safety concerns that the Court should know (i.e., firearms, dangerous
conditions, hazardous premises, nature of business, etc.)? 0 Yes 0 No
,ryes, please briefly explain: __________________ _
form Jl.J "I'PII<:>I"", r .... r (llIt.'<tl..,. Clnk!f " ... !'h\ltcl> ...I\ A!IoIimt 1t<IfZJII\Clll m Ihe Workplace 002007 Suvt- ('"wl
IItlIC lO. loo7
32135
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12-19-2012
1 8. Have there been any other Court actions or any other relationships between the employer
2 and the Adverse Party? 0 No
3 If yes, plcasedescribe: r-.Q.. \:\:ur\ 09 retc\ \(/ 'H/l; \1 c..
4
s.
.,
REI.IEF REOUESTED
I THEREFORE REQUEST that a Tempomy Order for Protection Against HaJaSSmCnt in
the Workplace be issued against the Adverse Party so that the Adverse Party will be prohibited fiom
8 intimidating, threat\:Ding. or othervQsc interfering with the employer's business and/or its
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employees and/or any petSOn present at the workplace, and that the Adverse Party win be ordered to $tay
away from the employer's workplace. I also request that the Court prohibit the Adveae Party from
violating this Ordu via e-mail, correspondence. telephone, or by aD agent
j
1 FURTHER REQUEST the following otitereonditions: _________ _
I FURTHER REQUEST that this Court set a hearing dale for an Extended Order
as
ij"'Yea . 0 No
If yes, complete the Application for Extended Onicr fot Protection Against
Harassment in the Workplace. NOTE; THIS HEARING wn.L BE HELD WlTIIIN
TEN (10) JUDICIAL DAYS PURSUANT TO NRS 33.270(6)(c), UNLESS
COMPELLING REASONS REQUIRE OTHERWISE.
DECLARATION
(NRS S3.o4S)
I DECLARE UNDER PENALTY OF PERJURY UNDER nit LAW OF THE STATE OF NEVADA
THAT: (1) I AM THE EMPLOYER. OR AUTHORIZED AGENT HEREIN, (1) I HAVE READ THE
Sf ATEMENTS CONTAINED HEREIN OR HAVE IIAD TIIEM READ TO ME, (3) I BELIEVE TIIESE
STATEMENTS TO BE TRUE, AND (4) THE REQUESTED ORDER IS NEEDED.
Datfd; J]ece&be-c let, 2Dr z. 0 7? \
SIGNATURE
'11
PRINT NAME .
6/8
Exhibit 1
On November 14, 2012, the Office of Bar Counsel held a disciplinary hearing at
its Reno office with two sheriff personnel in attendance as a measure of protection. As
a result of the hearing the panel unanimously agreed to permanently disbar Mr.
Coughlin from the practice of law. On Friday, December 14, 2012, the Panel's Order
was filed and copies were mailed to Mr. Coughlin both by r e g ~ l r and certified mail.
Mr. Coughlin continues to make repeated calls to the State Bar demanding
copies and information. He is getting increasingly antagonistic and will not listen to our
attempts to reason with him. This morning he announced that he ''wOUld be there in 15
minutes". It is our fear that if he shows up we won't be able to get rid of him - we are
not able to satisfy his demands and that just seems to aggravate the situation. He has
shown up after hours presumably to file documents; eventually he has used the mail
slot for the documents but has sat in his car in front of the office flashing his lights to get
attention. Employees have been afraid to leave and, on a couple of occasions, the
police have been called - we don't know if they have shown up because once he
leaves, we leave. On one particular occasion, a female employee was in the office
alone. Mr. Coughlin knocked on her window and gestured to the front door so he could
gain access to the building. Eventually the employee was able to get him to leave and
the police were called but did not arrive before Mr. Coughlin left the premises.
This past Monday Assistant Bar Counsel Pat King did dispatch the police
because Mr. Coughlin again announced that he was coming to the office - two officers
did show up and one was dispatched to the Panel Chairs office (9432 Double R Blvd.)
because Coughlin has also threatened and intimidated John Echeverria's office staff.
When' Coughlin called the Echeverria law firm that particular day he stated that he
needed some "face time" with John. Mr. King has received numerous e-mail,s detailing
what Mr. Coughlin perceives to be a miscarriage of justice in, his discipline matter and
has indicated that he will "expose him as a liar and a fraud".
In a letter dated 'November 7, 2012, prior to the discipline hearing, the Office of
Bar Counsel sent Mr. Coughlin a letter asking that he refrain from coming to the State
Bar offices without calling beforehand. On November 17, 2012, after the discipline
hearing, the Panel Chair issued an Order instructing Mr. Coughlin to refrain from
contacting any member of the Panel, the Court Reporter (whom Mr. Coughlin had
contacted by phone at her residence), any of the Panel Chair's office staff, or either
office of the State Bar of Nevada.
On one occasion, an e-mail was sent to several recipients, including four (4)
employees of the State Bar, which included a link to a violent scene from the movie
"Cape Fear". The State Bar feels that this is a direct suggestive threat to office staff and
State Bar personnel. Therefore, the State Bar requests' that a Protective Order be
issued and that Mr. Coughlin be prohibited from contacting the State Bars Reno and/or
Las Vegas offices in person, by telephone, bye-mail or by fax. Because he is currently
temporarily suspended , from the practice of law and his disciplinary hearing has
concluded Mr. Coughlin has no business on State Bar property (9456 Double R Blvd.,
Ste. B, Reno, NV. or 600 E. Charleston Blvd., Las Vegas, NV.) The record of his
... I
"
Exhibit 1
disciplinary matter will soon be submitted to the Nevada Supreme Court for a de novo
review at which time he will receive a complete set of all of the pleadings, both filed and
unfiled, in this matter.
It should be noted that the State Bar and its Reno staff find it very difficult to work
under these conditions. Mr. Coughlin continues to monopolize our time and resources
and is causing an unnecessary amount of stress. .
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iI. A mailing receipt.
,I.A unlqu, Identifier for your
I. Arecord of'dellvery kept by Postal SeJVIce for. two years
Reminders:
. _ Certified may"ONLY be combined with RrstClass or Priority Mal!,
, Certified MaIlls not available for any dass of IntemaonBI mail.
NO INSURANCE COVERAGE IS PROVIDED with Certified Mail. For
please consider' Insured or Registered Mail
For an addffional feel a Retum may be requested to proof of
To obtain Retum seN1ce
1
complete and attach a Return
Receipt (PS Form 38111 to and add applicable pOOage to coverthe
fee. Endorse mailplece Retum Requested
D
To receive a fee waiver for
retum a USPSe postmark on your Cer\lfled

i:. lf.8.,ark on the Certified Mall receipt Is desired, present the
,cle at. the post office for .arklng. If a P9:Stmark on the
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$00; AlP (RSijrse)PSN 7F@Oa02.()QO.9047
~ T A T E BAR OF AVADA
November 7, 2012
Zachary B. Coughlin
1471 E. 9
th
Street
Reno,NV 89505
EXHIBIT 1 ft
CERTIFIED MAIL:
70102780000354296257
Re: State Bar of Nevada v. Zachary B. Coughlin
Dear Mr. Coughlin:
600 East Charleston Blvd.
Las Vegas, NY 89104-1563
plIoo< 702.382.2200
oaII6.c 800.254.2797
fu 702.385.2878
9456 Double R BMi, Stc. B
Ikno, NY 89521-)977
p,-775.329.41oo
fu 775.329.0522
WUJUI.n"btzr.org
Yesterday you arrived at the State Bar office after 5:00 p.m. to file several
documents. When you discovered that the front door was locked, and although there is a
mail slot in the door, you elected to walk around the outside of the building until you found
someone inside. You stood outside an employee's window, got her attention 'and asked to be
let in. This employee unlocked the door and took receipt of your documents after which you
continued to ask further assistance.
Your behavior is becoming increasingly disturbing and harassing. Therefore, except
for your formal hearing, which will take place on November 14, 2012, beginning at 8:45
a.m., you are not to arrive at the Reno Office of the State Bar unannounced. If you have
papers or pleadings to present for filing, you are hereby instructed to either mail them or to
call the office (329-4100) prior to your arrival.
Please be advised that if you appear at the State Bar in the future, except for the
November 14, 2012, hearing or in the case of your need to file a document (for which you
must call 'ahead), the police will be summoned immediately.
Sincerely,
Patrick O. King
Assistant Bar Counsd
POKllp
r,
c:'
.J
EXHIBIT ili.
FILED
NOV 1.-Q
1 Case No: NG12-0204, NG12-0434 and NG12-0435
2 STATE BAR OF NEVADA STATE a.\R OF NEVADA
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NORTHERN NEVADA DISCIPLINARY BOARD
TATE BAR OF NEVADA,
Complainant,
vs.
CHARY B. COUGHLIN
BarNo. 9473
Res ondent.
ORDER
It has come to the attention of the Panel Chair that Zachary B. Coughlin
("Respondenf) has been contacting the Reno and Las Vegas Offices of Bar Counsel, the
Panel Chair's law office and the Court Reporter who recorded the disciplinary proceedings at
the State Bar office.
Therefore, IT IS HEREBY ORDERED:
That Respondent Immediately cease and desist contacting anyone at the State
Bar offices, the Panel Chair, the panel chair's staff, any of the Panel Members or their
staffs, or the Court Reporter including her employer, Sunshine Reporting while this matter is
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pending decision. Respondent is hereby reminded that the Panel will be deliberating at a
future date and may take this conduct into consideration.
DATED this of November, 2012.
verria, Esq., Chair
'ng Panel
1
' . ,
1 CERTIFICATE OF SERVICE
2 The undersigned hereby certifies that a true and correct copy of the foregoing Order was
3 deposited in the United States Mail at Reno, Nevada, postage fully pre-paid thereon for certified and
4 first class mail addressed to the following:
5 Zachary B. Coughlin
1471 E. 9th St.
6 Reno NV 89505
7 DATED this 16
th
day of November, 2012.
8
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L u eters, an employee of
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the State Bar of Nevada
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/ I
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EXHIBIT lc.,
Case No: NOI2-0204, NOI2-0435 and NGI2-0434
, STATE BAR OF NEVADA
NORTHERN NEVADA DISCIPLINARY BOARD
6 STATE BAR OF NEVADA,
FINDINGS OF FACTS AND
CONCLUSIONS OF LAW
7
8
VS.
Complainant,
9 ZACHARY B. COUGHLIN, ESQ.,
10
11
12
BarNo. 9473
Respondent.
13 TIllS MAITER came before a designated Formal Hearing Panel of the Northern Nevada
14 Disciplinary Board (the "Panel") for hearing on Wednesday, November 14, 2012. The Panel
15 consisted of John P. Echeverria, Esq., Chairman; Lay-Member Karen Stephen Kent, Esq.,
16 Clark V. Vellis, Esq., and Michael K. Johnson, Esq .. The State Bar of Nevada (the "State Bar")
17 appeared and was represented by Deputy Bar Counsel, Patrick O. King, Esq.. The Respondent,
18 Zachal}' Barker Coughlin, Nevada State Bar No. 9473 (the "Respondent" or "Coughlin") appeared-
19 in propria persona.
20 OF FACT
21 Based upon the pleadings filed, the documentary evidence admitted as Hearing Exhibits 1
22 through 16, and the testimonial evidence of the Honorable Judge Bruce Beesley, Richard Hill, Esq.,
23 Paul Elc,ano, Esq., the Honorable Judge Dorothy Nash Holmes, Zachary B. Coughlin, Esq. and
24 Mary Barker presented at the hearing of these proceedings, the Panel makes findings of facts as
25 fonows:
26 1. Coughlin is an attorney licensed to practice law in the State of Nevada. At all
27 relevant times prior to and at the time of the filing of the Complaint in this matter. the Respondent's
28 principle office, as filed with the State Bar of Nevada in accordance with Rule of Professional
I'RISTEOCll'/
RECYCLED PAPER
- ,

PRINT1!OO!l:
Conduct ("RPC") 79(1)(a), was Post Office Box 3961, Reno, NV 89505. See Hearing Exhibit 1 at
2 0001, lines 7-10 (State Bar of Nevada vs. Zachary B. Coughlin. Esq., Case No: NG12-0204, NOI2
3 0435, NG120434, Complaint at PI (filed August 23,2012
4 2.
Coughlin was admitted as a member of the State Bar of Nevada on March 25, 2005.
5 See Hearing Exhibit 1 at 0001, lines 78 (State Bar of Nevada vs. Zachary B. Coughlin, Esq., Case
6 No: NG120204, NG120435, N0120434, Complaint at PI (filed August 23, 2012
7 3. On September 9, 2011, Coughlin shoplifted a candy bar and cough drops from a
8 Wal-Mart store with an approximate value of fourteen dollars ($14.00). On November 30, 2011,
9 Municipal Court Judge Kenneth R. Howard found Coughlin guilty of the offense of Petit Larceny, a
10 violation of RMC 8.10.040. Coughlin appealed the judgment of conviction. On Marcb 15, 2012,
11 the Honorable District Court Judge Steven P. Elliot affirmed the judgment of conviction on appeal.
12 See Hearing Exhibit 1 at 0002,,5, lines 11-15; (State Bar of Nevada vs. Zachary B. Coughlin, Esq.,
13 Case No: NG12-0204, NG12-0435, NG120434, Complaint at P2 (filed August 23, 2012
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4. Coughlin's conduct during the trial of the petit larceny case on November 30, 2011,
in which Coughlin appeared in propria persona, was so disruptive that Judge Howard found
Coughlin in direct contempt of court and sentenced him to jail that same day to be released on
December 3, 2011 at 8:00 PM. Judge Howard specifically found Coughlin's conduct to be
disorderly and was either contemptuous or behavior insolent toward the judge in that Coughlin
refused:
... to obey directives of the Judge, continuing lines of inquiry after
being advised by the Court to refrain from doing so; demeaning the Court
with statements such as "WOW" in response to court rulings; laughing
during testimony and further questioning the court and its authority.
See Hearing Exhibit 1..1 ORDER FOR SUMMARY PUNISHMENT OF CONTEMPT
COMMITIED IN THE IMMEDIATE VIEW AND PRESENCE OF THE COURT, November 30,
2011.
5. On June 7, 2012, the Supreme Court of the State of Nevada, upon petition of Bar
27 Counsel for the State Bar of Nevada pursuant to SCR 111, ordered Coughlin temporarily suspended
28 from the practice of law in Nevada. The Order further directed that the matter be referred to the
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appropriate disciplinary board, as mandated by SCR 111 (8), with directions for the board to
institute a formal hearing "before a hearing panel in which the sole issue to be determined shall be
the extent of the discipline to be imposed." In the Matter of Discipline of ZACHARY B.
COUGHLIN, Esq., BarNo. 9473, No. 6 0 8 ~ 8 June 7,2012.
6. On November 15, 2011 Coughlin was arrested and charged with three violations of
the Reno Municipal Code . . The charges of Failure to Provide Evidence of Security or Insurance (a
violation of RMC 6.06.555(a and Failure to Provide Vehicle Registration (a violation of RMC
6.06.560(a were dismissed at arraignment . . On February 27, 2012 a trial was held in Reno
Municipal Court before the Honorable Judge Dorothy Nash Holmes on the remaining charge of a
Right of Way Stop Sign violation at an intersection (a violation of RMC 6.06.170(a. Coughlin
again appeared in propria persona. The trial commenced at 3 p.rn. and was concluded by the Court
at 4:30 p.m., without a verdict, after the court held Coughlin in criminal contempt of court for his
behavior and activities committed during the course of the trial and in the presence of the Court.
See Hearing Exhibit 4. ORDER FINDING THE DEFENDANT IN CONTEMPT OF COURT AND
IMPOSING SANCTIONS.
7. Judge Nash Holmes ordered Coughlin into custody on February 27,2012 and to be
incarcerated at the, Washoe County Regional Detention Facility for the term of five (5) days.
Alternatively Coughlin could pay a fine of $500. The Court's sentence was based on its detailed
findings regarding Coughlin's conduct in his own defense.
The court fmds that defendant's contemptuous conduct consisted of his
rude, sarcastic, inappropriate, insubordinate, disrespectful, antagonistic,
deceitful, disruptive, argumentative and childish behavior during trial, all
of which appeared to be done to vex and annoy the court, the witness, and
the opposing party, and to disrupt the trial process. The court finds that
the following occurred, and constitute contempt: 1) defendant's mime-
like, clownish antics of making faces at the court; sagging down into his
seat and hanging his head; looking behind himself and inside his coat as if
searching for a better way to ask a question; rolJing his eyes; and
mimicking others words; 2) defendant's incessant arguing with the court,
talking over the court, and interrupting the court; 3) defendant's repeatedly
restating matters after being told by the court to "move on" or "ask the
next question;" 4) defendant's repeatedly injecting allegations of bribery,
perjury, and police retaliation into the matter after the court instructed him
not to, and directed him to limit himself to issues pertaining to the facts of
the "Boulevard Stop;" 5) defendant's repeatedly trying to insert ,. Richard
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Hill" into his questions and statements when such person was not relevant
to the proceeding and the defendant had been ordered to stop discussing
that; 6) defendant's disregarding the rules of evidence and court procedure
by continually posing improper questions after being directed by the court
to properly phrase his questions 7) defendant's continually accusing the
court of denying him the right or ability to ask questions and telling the
court to "give me a list of questions you want me to ask;" 8) defendant's
suggesting that the court "tell me what would make you happy;" 9)
defendant's lying to the court in response to direct questions posed by the
court with regard to his recording the proceedings; and 10) defendant's
failing and refusing to properly examine the witness, despite nwnerous
admonitions by the court to stop repeating questions, misstating answers,
injecting irrelevant material, arguing with the witness and
mischaracterizing the testimony.
10 See rtearing Exhibit 4, ORDER FINDING THE DEFENDANT IN CONTEMPT OF COURT AND
11 IMPOSING SANCTIONS.
12
8. The trial of the matter was continued to March 12, 20 t 2. Coughlin failed to appear
13 and failed to contact the court to explain or excuse his absence. However, after serving the five-day
14 Contempt of Court sanction and after being released from custody, Coughlin fax-filed a 224-page
15 document entitled ''Notice of Appeal of Summary Contempt Order; Motion to Return Personal
16 Property Confiscated by Reno Municipal Courts and Its Marshalls; Motion for New Trial and to
17 Alter or Amend Summary Contempt Order." See Hearing Exhibit 5, ORDER, P 2, lines 1-6.
18
9. Judge Nash Holmes observed that the pleading filed by Coughlin failed to address
19 most of the topics listed in the caption. Rather, she observed, the document contained rambling
20 references to Coughlin's personal life., his father's football career in college; dozens of pages of
21 string citations taken from the and other unrelated references. Judge Nash Holmesfound
22 the pleading to be disjointed and incoherent and a "pathetic demonstration of what might once have
23 been legal and academic prowess that appears to now be greatly damaged." See Exhibit 5,
24 ORDER, P2, lines 9-15; P2.lines 16-20.
25 10. Judge Nash Holmes also found that Coughlin, after being released from custody
26 following the February 27, 2012 Contempt of Court incarceration, filed other nonsensical pleadings
27 including a 218 page document
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. . purported to be yet another motion in this case entitled "Motion
to Return Cell Phones; Motion to Set Aside Swnmary Contempt Order;
and Notice of Appeal of Summary Contempt Order." With scant
discussion of, or relevance to, the above captioned matter, said document
mostly argues against Judge Howard in a Department 4 case and again
contains more than 200 pages of string legal citations; lyrics to rocks (sic)
songs; Mr. Coughlin's personal family history; discussion of an eviction
case and another contempt case; disjointed legal citations and other
nonsensical matters that have no apparent relevance to his traffic citation
case.
See Hearing Exhibit 5, ORDER., P3. lines 11-19.
8 . 11. After observing that Coughlin's conduct had been inappropriate, bizarre, dishonest,
9 irrational and disruptive, . Judge Nash Holmes concluded, by clear and convincing evidence, that
10 Coughlin had committed numerous acts of attorney misconduct, including, but not limited to,
11 violating Rules of Professional Conduct 8A(c), 8.4(d), 3.3(a), 3.1, 3.2, 3A(c), 1.3 and 1.1. See
12 Hearing Exhibit 5, ORDER, P,3, lines 25-26; P4, lines 5-23.
13 12. Judge Nash Holmes also concluded that Coughlin violated Nevada Supreme Court
14 Rwe 229, section 2(b), as amended by ADKT 449 on August 1, 2011 by surreptitiously recording
15 the traffic court proceedings without advance permission and lying to the court when questioned
16 regarding the matter by denying that he had done so. See Hearing Exhibit 5, ORDER, P,4, lines 24-
17 28.
18 13. Judge Nash Holmes ordered, among other orders, that the traffic court matter be
19 continued and all proceedings relating to the traffic court matter be tolled pending referral of the
20 matter to the State Bar of Nevada. See ~ n g Exhibit2. ORDER., P,4, lines 7-18.
21 14. On March 14,2012, Judge Nash Holmes referred the matter of Coughlin to State Bar
22 Counsel David Clark and suggested the matter had some urgency. See Hearing Exhibitj, Letter
23 dated March 14, 2012 from Reno Municipal Court Judge Dorothy Nash Holmes to Office of State
24 Bar Counsel, Nevada State Bar.
2S ) 5. Judge Holmes testified at the hearing of this disciplinary matter that one of the
26 purposes of her March 14,2012 Order was to provide the panel to hear this matter with clear and
27 convincing evidence, based on her experience and background as an attorney, prosecutor and judge,
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that Coughlin had violated numerous provisions of the Nevada Rules of Professional Conduct. See
Transcript of Proceedings, Wednesday, November 14,2012, P 137, L 22 - P 138, L 9.
16. U.S. Bankruptcy Judge Bruce Beesley was called to testify at the hearing of this
matter. During the time frame 2011 to 2012, Coughlin appeared before Judge Beesley two or three
times as an attorney representing clients in a bankruptcy matter. On one occasion Coughlin
appeared wearing aT-shirt and a tie .and no jacket See Transcript of Proceedings Wednesday.
November 14,2012, P 10, L 10-16. Coughlin had flIed a pleading in the bankruptcy matter, on
behalf of his client. Judge Beesley testified that the pleading was "lengthy, didn't make any sense,
and just sort of rambled through a great deal of irrelevant stuff." See Transcript of Proceedings
Wednesday, November 14,2012, P 10, L 24 - P 11, L 1. On other occasions, although Coughlin
appeared polite and intelligent, his pleadings and arguments didn'1 make any sense. See Transcript
of Proceedings Wednesday, November 14,2012, P 11, L2-7
17. Judge Beesley became concerned, wrote a letter to the State Bar explaining his
experience with Coughlin and indicated that he did not believe Coughlin, in his current state, was
able to adequately represent his clients. See Transcript of Proceedings Wednesday, November 14,
2012,P 13,L24-P 14,L 7.
18. In Judge Beesley's opinion, Coughlin is not competent to practice law. See
Transcript of Proceedings Wednesday, November 14, 2012. P 15, L 11 - 15.
19. State Bar Counsel called attornc;y Richard Hill to testify at the hearing of this matter.
Mr. Hill has been a member in good standing with the State Bar of. Nevada for 33 years. See
Wednesday, 14,2012, P 36, L 22 - P 37 L 4. Mr. Hill was
retained by Dr. Merliss to assist Dr. Merliss in a landlord tenant dispute with his tenant Coughlin.
See of Proceedil.!g Wednesday, November 14, 2012, P 37, L14 - 20. Mr. Hill
represented Dr. Merlissin Reno Justice Court and Washoe County District Court and two appeals to
the Nevada Supreme Court in the matters involving Dr. Merliss and Coughlin. See Qf
Wednesday, November 14, 2012, P 39, L 13 - 24. Mr. Hilt has also reviewed filings in
a case in which Coughlin is involved with Washoe Legal Services. See Transc;riP!..Qf
Wednesday, November 14,2012, P 39, L 25 - P 40, L 3.

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1 20. In the eviction proceeding between Dr. Merliss and Coughlin, Mr. Hill's ftrm
2 obtained an eviction order allowing Coughlin one week to vacate the premises. Ultimately,
3 Coughlin failed to comply with the eviction order and was convicted of 'criminal trespass. See
4 Transcript of Proceedings Wednesday', November 14,2012, P 41, L 18 - P 44, L 12.
5 21. On behalf of his client Dr. Merliss, Mr. Hill sought and obtained an order in favor of
6 Dr. Merliss and against Coughlin awarding Dr. Merliss attorney's fees in the amount 0[$42,065.50.
7 Washoe District Court Judge Patrick Flanagan entered the order on June 25,2012. See Transcript
8 of Proceedings Wednesday, November 14, 2012, P 47, L 37. See Hearing Exhibit 2, PJ, L 10-11.
9 The motion seeking attorney's fees was based on Coughlin's conduct in the defense of the eviction
10 matter, which conduct was characterized as frivolous and vexatious and preswnably so found by
11 Judge Flanagan. See Hearing Exhibit 2, P 2, L 8-13; P 3, L 4-11.
12 22. Based on Mr. Hill's experience and background, his review of the pleadings in the
13 litigation between Dr. Merliss and Coughlin and his review of the pleadings in Coughlin's litigation
14 with Washoe Legal Services, Mr. Hill is of the opinion that Coughlin is not competent to practice
15 law. See Transcript of Proceedings Wednesday, November 14,2012, P 39, L 1"': 12.
16 23. Based on Mr. Hill's experience in litigating with Coughlin, Coughlin was not
17 truthful with either counselor the court. See Transcript of Proceedings Wednesday, November 14,
18 2012, P 53, L 6 -.16. Mr. Hill felt that Coughlin's filings were abusive, at one point calling Mr.
19 Hill's associate a lichen. Coughlin has accused Mr. Hill of bribing the Reno Police Department to
20 have Coughlin arrested. Mr. Hill's staff is terrorized by Coughlin. See Transcript
21 Wednesday, November 14,2012. P 54, L 4 - 15.
22 24. State Bar Counsel called attorney Paul Elcano to testify at the hearing of this matter.
23 Mr. EIcano is the executive director of Washoe Legal Services that provides legal services to
24 indigents. See Transcript of.Proceeding Wednesday, November 14, 2012, P 88, L 25 - P 89, L 14.
25 Coughlin was employed by Washoe Legal Services from August 19. 2007 to May 1 I, 2009. See
26 Transcr!.,p.t of Proceedigg Wednesday, November 14,2012. P 93. L 17 - 20. Mr. EIcano became
27 aware of an order entered by Judge Gardner on April 10, 2009 in the matter of Joshi v Joshi and, as
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1 a result, reviewed the taped transcript of the hearing. See Transcript of Proceedings Wednesday,
2 November 14,2012, P 94, L 22- P 95, L 6.
3 25. Judge Gardner's order in the Joshi matter indicated that Coughlin had conducted no
4 discovery in the case and failed to present any documentary evidence at the trial of the matter on
5 behalf of his client Mrs. Joshi. f!ee Hearing Exhibit 3. P 12, L 4 - 6. After commenting on various
6 negative aspects of Coughlin's representation ofhis client Mrs. Joshi, (See Hearing Exhibit 3. P 12,
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L 9 - P 13. L 40) Judge Gardner specifically held:
The most troubling aspect of this case was Mr. CougbIin's rude, sarcastic
and disrespeCtful presentation at trial; Mr. Coughlin's inability to
understand a balance sheet; his failure to conduct discovery; and his lack
of knowledge with regard to the rules of evidence and trial procedure. All
of this was compounded with a continuously antagonistic presentation of
. the case that resulted in a shift from a fairly simple divorce case to a
contentious divorce trial lasting an excessive amount oftime.
13 See Hearing Exhibit 3, P 13, L 5 -10
14 26. Judge .Gardner sanctioned Coughlin personally and awarded attorney's fees to Mr.
15 Joshi in the amount of $934 to be paid personally by Coughlin within 30 days of the order. See
16 Hearing Exhibit 3, P 13, L 14 - 17
17 27. Based on the order and Coughlin's conduct in the Joshi matter, Coughlin was
18 t e ~ e by Washoe Legal Services. See Transcript of Proceedings Wednesday, November 14,
19 2012, P ltO, L 7-8
20 28. In Mr. Elcano's opinion, Coughlin is not competent to practice law. See Transcript
21 of Proceedings Wednesday, November 14,20"12, P 94, L 3 - 8.
22 29. State Bar Counsel called Coughlin to testify at the hearing of the matter. Coughlin
23 was questioned with regard to a letter dated February 14,2012 from Assistant Bar Counsel King to
24 Coughlin in which Bar Counsel forwarded to Coughlin correspondence received from Richard G.
25 Hill. See Transcript of Proceedings Wednesday, November 14,2012, P 163, L 13 - P 164. L 23.
26 See Hearing Exhibit 6. Coughlin's response, dated March 9, 20i 2, asked for additional time in
27 which to respond. Se-e Hearing Exhibit 1. No evidence was presented that Coughlin substantively
28 responded to Bar Counsel's letter of February 14,2012 prior to the filing of the Complaint in this
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1 matter. Coughlin failed to directly respond to Bar COW1SeI's questions inquiring if Coughlin ever
2 subsequently responded to Bar Counsel's letter of February 14, 2012. See Transcript of
3 Proceedings Wednesday, November 14,2012, P 169, L 13 - P 172, L 16.
4 30. Coughlin also failed to directly respond to questioning regarding whether or not he
5 had substantively responded, prior to the filing of the Complaint in this matter, to a letter forwarded
6 to him from Bar Counsel regarding the letter received by the Nevada State Bar from Judge Dorothy
7 . Nash Holmes and dated March 14,2012. See Transcript of Proceedings Wednesday, November 14,
8 2012, P 174, L 13 - P 180, L 4. See Hearing Exhibit 8.
9 31. On March 7,2012 Coughlin caused to be filed an "Affidavit of Poverty in Support of
10 Motion to Proceed Informa Pauperis." See Hearing Exhibit 9. In his Affidavit, Coughlin
11 represented that he was self-employed as a "Jack of all Trades." See Hearing Exhibit 9. The
12 Affidavit does not identify Mr. Coughlin as a lawyer or identify any income from the practice of
13 law. See Hearing Exhibit 9.
14 32. The record also indicates that Coughlin had also filed a motion on November 14,
15 2011 to proceed in Fonna Pauperis in case number HCR 22176 pending in the Reno Municipal
16 Court before Judge Kenneth R. Howard. See Hearing Exhibit 10. Judge Howard
7
s Order denying
17 Coughlin's motion specifically noted'that Coughlin's "affidavit of poverty" did not identify any
18 income from the practice of law yet Coughlin had implied to the court when sentenced to
19 incarceration for contempt that his incarceration would adversely affect his clients. See Hearing
20 P 2, L 19 - 23.
21 33. Although Coughlin claims to suffer the impainnent of attention deficit disorder, for
22 which he is prescribed medication and which medication he took on the day of his hearing, he does
23 not feel he needs any additional help. See Iranscript9f Wednesday, November 14,
24 2012, P 199, L 13 - P 204, L 9.
25 34. On August 23, 2012, the State Bar of Nevada filed its Complaint in this matter and
26 served it upon Respondent Coughlin by Certified Mail to his address then registered with the State
27 Bar of Nevada. See pleadings Complaint.
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1 35. Not having received a response to the Complaint, on October 9,2012 the State Bar
2 of Nevada filed and served on Respondent Coughlin, by certified mail. a "Notice of Intent to
3 Proceed on a Default Basis." The Notice attached an additional copy of the Complaint and
4 indicated that unless a responsive pleading to the Complaint was received by the State Bar by
5 October 24,2012, the matter would proceed on a default basis. See Pleadings Docket, Notice of
6 Intent to Proceed on a Basis.
7 36. On October 31, 2012 Panel Chair Echeverria issued the Panel's Order denying
8 Coughlin's "Motion to Dismiss" filed October 16,2012; Denying Coughlin's "Motion for Order to
9 Show Cause Regarding Improper Attempt by Bar Counsel and, Possibly, NNDB to Delay and
10 Obstruct Hearing Required by Courts (sic) June 7, 2012 Order in Case No. 60838 and Coughlin's
11 SCR 102(4)(d) Petition in Case 61426 filed October 2, 2012; Granting Coughlin's Motion, to
12 Review and Inspect Bar Records filed October 16. 2012 and Denying Coughlin's Motion to
13 Bifurcate Hearing and Motion to Dismiss for (sic) Complaint (sic) Failure to Sufficiently State the
14 Charges with Specificity and Support and for Utter Failure of Bar Counsel to Perform Reasonable
15 Investigation." See Pleadings Docket, Order Dated October 31, 2012. In that Order, Chainnan
16 Echeverria further ordered that the Formal Hearing would proceed on a default basis unless
17 Coughlin filed a Verified Answer to the Complaint by November 9, 2012. See Pleadings Docket,
18 Order Dated October 31,2012, P 2, L 7 -10.
19 37. Again on November 7, 2012, Chainnan Echeverria, in an Order Granting the State
20 Bar's Motion to Quash certain Subpoenas reminded Coughlin that unless a Verified Answer to the
21 Complaint was filed by 5:00 p.m. on November 9, 2012 the panel would proceed on a default basis.
22 See Docket, Order Dated November 7, 2012, P 2, L 8 -13.
23 38. Following a lengthy attempt to detennine whether or not Coughlin believed he had
24 filed a timely verified answer or response to the State Bar's Complaint. Coughlin attempted, at the
25 hearing of the matter, to transfonn a pleading previously filed in the Reno Municipal Court into a
26 "New Verified Response (sic) Pre-Hearing Motion to Dismiss/Summary Judgment. Memorandum
27 of Law (See and to transfonn an "Emergency Ex Parte Motion to Dismiss ... "
28 previously dated November 12,2012 and altered at the hearing to reflect a date of November 14,
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1 2012 into a "Declaration and Verified Response." See Hearing Exhibits 15 and 16. See Transcript
2 of Proceedings Wednesday, November 14,2012, P 244, L 16 - P 270, L 11.
3 39. During the course of the hearing of this matter Coughlin continued to demonstrate a
4 pattemof conduct similar to, if not identical to, conduct in other forums for which he had repeatedly
5 been sanctioned. See Transcript of Proceedings Wednesday, November 14,2012. Pleadings in this
6 matter filed by Coughlin were exceedingly lengthy, demonstrated a lack of focus and Wlderstanding
7 of the issues involved, were rambling aild incoherent and contained discussion of irrelevant issues.
8 See, e.g. Hearing Exhibits 14, 15 and 16. See also, Pleadings Docket, "Motion for Order to Show
9 Cause ... " dated October 2, 2012; "Motion to Review and Inspect Bar Records ... " Filed October 16,
10 2012; Pleading entitled "Well Would You Look at That..." dated November 7, 2012; "Emergency
11 Ex Parte Motion to Dismiss or Quash ... " Filed November 13,2012.
12 40. Coughlin's conduct at the hearing included conduct not reflected in the transcript of
13 the proceedings by way of facial gestures, body language, voice intonation and volume. See
14 Transcript of Proceedings Wednesday, November 14,2012, P 181, L 19- P 182, L 1.
15
16 CONCLUSIONS OF LA
17 Based on the foregoing Findings of Fact, the Panel hereby issues the following Conclusions
18 of Law:
19 (A) The Panel was designated by the northern Nevada Disciplinary Board Chair to
20 adjudicate the Complaint filed by the State Bar of Nevada against Zachary B. Coughlin, Case Nos.
21 NG12-0204, NG12-0435 and NG12-0434 and to determine the extent of the discipline to be
22 imposed pursuant to the Nevada Supreme Court Order of Temporary Suspension and Referral to
23 Disciplinary Board entered in Case No. 60838, In the Matter of Discipline of Zachary B. Coughlin,
24 Esq., Bar No. 9473, entered June 7, 2012.
25 (B) The Panel has jurisdiction over the Respondent and the subject matter of these
26 proceedings. See Nev. Sup. Ct. R. 99.
27 (C) Venue in this matter is properly with the Northern Nevada Disciplinary Board and in
28 the COWlty of Washoe, State of Nevada. Nev. Sup. CL R. 105.
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(D)
Coughlin received notice and a copy of the Complaint, notice of his right to respond,
2 as well as notice of the evidence and witnesses upon which the State Bar intended to rely at a formal
j hearing. Notice of the fonnal hearing was served on Coughlin. Coughlin appeared in the matter,
4 filed nwnerous motions, appeared at the hearing of the matter, cross-examined, witnesses and testified
5 on behalf of the State Bar and on his own behalf. Accordingly, the State Bar complied with the
6 procedUral requirements ofSCR 105. ,
7 (E) Coughlin was afforded ample opportunity to prepare a verified answer or response to
8 the allegations of the Complaint and failed to timely do so. See Findings of Fact 34. 35 and 36.
9 , Accordingly, the matter could proceed on a default basis and the allegations of the Complaint deemed
10 admitted. SCR 105(2) Notwithstanding the fact that the matter could have been decided on a default
11 basis, the Panel permitted the State Bar and Coughlin to present evidence.
12 (F) Submitted to the panel for decision are the following issues:
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(1)
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(5)
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(6)
Tribunal)
(7.)
(8)
(9)
(10)
(11)
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Whether Coughlin violated RPC 1.1 (Competence).
Whether Coughlin violated RPC 1.2 (Diligence).
Whether Coughlin violated RPC 3.1 (Meritorious Claims and Contentions)
Whether Coughlin violated }{pC 3.3 (Candor to the Tribunal).
Whether Coughlin violated RPC 3.4 (Fairness to Opposing Party and
Whether Coughlin violated RPC 3.5 (Impartiality and Decorum of the
Whether Coughlin violated RPC 3.5A (Relations with Opposing CoWlSel)
Whether Coughlin violated RPC 4.1' (fruthfulness in Statements to Others)
Whether Coughlin violated RPC 4.4 (Respect for the Rights of Third Persons)
Whether Coughlin violated RPC 8.1 (Disciplinary Matters)
Whether Coughlin violated RPC 8.2 (Judicial and Legal Officials)
Whether Coughlin viollited RPC 8.4 (Misconduct)
The extent of the discipline to be imposed pursuant to SCR 111 as a result of
Coughlin's o ~ v i t i o n ofthe-"serious" crime of Petit Larceny.
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(0) The State Bar must prove by clear and convincing evidence that Coughlin violated
RPC 1.1, 1.2,3.1,3.3,3.4,3.5,4.1,4.4, SA (sic), 8.1, 8.2, and 8.4. See Nev Sup. a. R. 105(2)(e); In
re Stuhff, 108 Nev. at 633-634, 837 P.2d at 856; Gentile v State Bar, 106 Nev. 60,62, 787 P.2d
386,387 (1990).
Competence
(H) RPC 1.1 states "A lawyer shall provide competent representation to a client.
Competent representation requires the legal knowledge, skill, thoroughness and p ~ t o n
reasonably necessary for the representation."
(I) The record clearly and convincingly establishes that Coughlin lacks the competency
to represent clients, including himself.
(J) First, the record demonstrates severe criticism by the trial court in the handling of the
Joshi matter, including Coughlin's lack of understanding of a balance sheet, his failure to conduct
discovery, his lack of knowledge of the ruJes of evidence and trial procedure. Supra' 25
(1<) Second, Judge Beesley testified that the pleadings filed by Coughlin on behalf of his
client hi a bankruptcy case were "lengthy, didn't make any sense, and just sort of rambled through a
great deal of irrelevant stuff." Judge Beesley also testified that Coughlin's pleadings and arguments
on behalf of his client "didn't make any sense." Supra 1 16 Judge Beesley became concerned
enough about Coughlin's competency as a lawyer that he contacted the State Bar. Supra' 17
(L) fhird, Judge Nash Holmes questioned Coughlin's competency as a lawyer and in her
Order finding Coughlin in Contempt of Court noted that Coughlin disregarded the ruJes of evidence,
continually imposed improper questions, failed to properly examine witnesses, repeatedly asked the
same question. misstated answers, injected irrelevant material, argued with witnesses and
mischaracteri7.ed testimony. Supra 7
(M) Fourth, Judge Nash Holmes fOWld that Coughlin's pleadings failed to address topics
listed in the caption. contained rambling references to Coughlin's personal life and other irrelevant
material, were overly lengthy, disjointed and incoherent Supra' 9 & 10
(N) Fifth, the State Bar called two Judges an'd two practicing attorneys, each with
significant experience with Coughlin and each of whom rendered an expert opinion regarding
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Coughlin's.competency as a lawyer. Judge Beesley testified that in his opinion, Coughlin was not
competent to practice law. Supra ,18. Judge Nash HoImes testified that in her opinion, Coughlin
violated nmnerous Rules of Professional Conduct including his laCk of competency ta practice law.
Supra '15. Attorney Richard Hill also testified that in his opinion Coughlin is not competent to
practice law. Supra' 22 Attorney Paul Elcano, who once supervised Coughlin as a lawyer and'
ultimately terminated him from Washoe Legal Services, also testified that, in his opinion, Coughlin is
not competent to practice law. Supra 128
(0) Sixth, the record establishes that Coughlin offered no expert opinion or evidence as to
his competency.
Diligence
(p). RPC 12 states "'A lawyer shall' act with reasonable diligence and promptness in
representing a client"
(Q) The record is less clear as to whether or not Coughlin violated RPC 1.2 on more than
on occasion.
(R) Judge Howard, in the Joshi case, certainly found that Coughlin fulled to conduct
discovery on behalf ofbis client in that matter. Supra' 25
(S) The record and Pleading Docket in this case establish that Coughlin failed to provide a
verified responsive pleading even in the defense ofbis own disciplinary action. Supra' 38
(T) The record and Pleading Docket in this case establish that Coughlin habitually fileS.
numerous, untimely and repetitive motions
Meritorious Claims and Contentions .
(U) RPC 3.1 in pertinent part .states "A lawyer shall Dot bring or defend a proceeding, or
assert or controvert an issue therein, unless there is a basis in . law and fact for doing so that is not
fiivolous, which includes a good faith argument for an extension, modification or reversal of existing
law.'t
(V) The record clearly and convincingly establishes that Coughlin continuously and
repetitively files irrelevant pleadings, pleadings unrelated to the issue at hand and continuously and
repetitively injects irrelevant matters into proceecling.'l.
(W) Judge Nash Holmes foWld, for example, that Coughlin repeatedly injected allegations
2 of bribery, petjury and police retaliation in a simple traffic case,involving the failure to stop at a stop
3 sign. Supra 1 She also fOWld that Coughlin repeatedly injected attorney Richard Hill into questions
4 and statements when Mr. Hill was in no way involved in the traffic citation trial. Supra' 7 She also
5 fOWld that pleadings filed subsequent to Coughlin's incarceration were lengthy (more than 200 pages)
6 contained scant discussion of, or relevance to, the matter and contained irrelevant discussion of facts
7 unrelated to the proceedings at hand. Supra' 10
8 (X) The record establishes that in the Merliss eviction action, Coughlin's conduct was so
9 vexatious and fiivolous as to result in substantial sanction ofattomey's fees. Supra 21 See Hearing
10 Exhibit 2, P2, L 8 -13; P3, L 4 -11.
11 (Y) The Pleading Docket in this matter establishes also that Coughlin's filings. even in his
12 own defense of the disciplinary matter, inject lengthy. irrelevant facts and legal issues into this
13 proceeding.
14 Candor to the Tribunal
15 (Z) RPC 3.3(a)(I) states "A lawyer shall not knowingly; (m)ake a false statement offect
16 or law to a tribunal or fail to correct a false statement of material fact or law previously made to the
t 7 tribunal by the lawyer."
18 (AA) The record clearly and convincingly establishes that Coughlin violated RPC 3.3(aXl)
19 when he .lied to- Judge Nash Holmes as to whether or not he was surreptitiously and without
20 pennission to record the proceeding. Supra 7 Of note, Coughlin did not deny that he had lied to
21 Judge Nash Holmes. Instead, his cross examination of Judge Nash Holmes focused on how she had
22 learned of the true facts. See Transcript Wednesday, November 14, 2012, P 139, L
23 JO-P 146, L 14.
24 (B8) Attorney Richard HiU testified that based on his experience in litigating with
25 Coughlin, Coughlin was not truthful with either counselor the Court. Supra 23
26 (cq The record also establishes that Coughlin was less than candid with the Court in
27 two separate applications to proceed in forma pauperis, when he failed to disclose his true
28 occupation as an attorney and instead indicated he was self-employed as a "Jack of all Trades" and
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failed to"identify any income from the practice of law after having represented to the court that his
2 incarceration would adversely affect his clients. Supra" 31 & 32
3 Fairness to Opposing Party and Counsel
4 (DD) RPC 3.4(c) states "A lawyer shall not: (k)nowingly disobey an obligation under the
5 rules of a tribunal except for an open refusal based on an assertion that no valid obligation exists."
6 (EE) The record clearly and convincingly establishes that Coughlin has a clear and
7 continuing pattern of knowingly ignoring and disobeying instructions from the Court.
8 (FF) In his Order of Contempt, Judge found that Coughlin refused to obey
9 directives of the Judge and continued lines of questioning after being instructed to refrain from doing
10 so. Supra' 4
11 (GG) Judge Nash Holmes, in her Order of Contempt, found that Coughlin incessantly
12 argued with the Court, interrupted the Court, repeatedly restated matters after having been
13 admonished to refrain from doing so, disregarded directives to ask properiy phrased questions and
14 disobeyed numerous admonitions by the court to stop repeating questions, misstating answers,
15 injecting irrelevant material, arguing with the witness and mischaracterizing testimony. Supra 1 7
16 traDs6ipt of the hearing in this matter clearly demonstrates that Coughlin
17 repeatedly arid" htcessantly interrupts witnesses, counsel, Panel members and Panel Chainnan and
18 refuses to heed admonitions to refrain from doing so. See generally Transcript of Proceedings
19 Wednesday, November 14, 2012.
20 Impartiality and Decomm or the trlJ;tunal"
21 (II) RPC 3.S(d) states "A .lawyer shall not engage in conduct intended to disrupt a
22 tribunal."
23 (JJ) The disruption must have occurred in the courtroom. One cannot disrupt a tribunal
24 with conduct outside of the courtroom. In re Michael Stuhff, 108 Nev. 629, 837 P.2d 853 (1992)
25 (KK) The record overwhelmingly, clearly and convincingly establishes that Coughlin
26 repeatedly conducts himself in a manner that is disruptive of the tribunal while in the courtrOom.
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1 (LL) The various orders of contempt or imposing sanctions issued by Judges Kenneth
2 Gardner, Linda Gardner, Dorothy Nash Holmes and Patrick Flanagan each describe a similar pattern
3 of conduct and behavior that is intentionally disruptive of the tribunal. Supra" 4, 7, 10, 21 and 25
4 (MM) The transcript of the proceedings in this matter reveal a continuation of a similar
5 pattern of conduct by Coughlin despite his having been sanctioned twice with an adverse award of
6 attorney's fees and twice by inccirceration. See generally Transcript of Proceedings Wednesday,
7 November 14,2012.
8 Relations with Opposing Counsel
9 (NN) RPC 3.5A states "When a lawyer knows or reasonably should know the identity of a
10 lawyer representing an opposing .party, he or she should not take advantage of the lawyer by causing
11 any default or dismissal to be entered without first inquiring about the opposing lawyer's intention to
12 proceed."
13 (00) Although the State Bar pled a violation of RPC 3.5A in its Complaint, no evidence
14 was presented that Coughlin ever violated the rule. Accordingly, the Panel finds that the State Bar
15 failed to meet its burden of proof on this issue as an evidentiary matter but finds that as a matter of
16 default the violation may be deemed admitted.
17 Truthfulness in Statements to Others
18 (PP) RPC 4.1 (a) states "In the course of representing a client a lawyer shall not knowingly:
19 (a) (m)ake a false statement of material fact or law to a third person."
20 (QQ) Although the evidence established that Coughlin knowingly made false statements to
21 Court and Counsel (See fir (AA), (BS) and (CC) no evidence was presented that Coughlin
22 knowingly made false statements of material fact or law to a third person. Accordingly, the Panel
23 finds that the State Bar failed to meet its burden of proof on this issue as an evidentiary matter but
24 finds that as a matter of default the violation may be deemed admitted.
25 for of Third
26 (RR) RPC 4.4(a) states "In representing a client. a lawyer shall not use means that have no
27 substantial purpose other than to embarrass, delay, or burden a third person ... t1
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1 (SS) The record establishes clearly and convincingly that in the Merliss eviction
2 Coughlin conducted himself in a manner that was abusive, vexatious and for purposes of delay. The
3 matter was a simple eviction action that apparently lasted through several proceedings at the
4 Municipal Court level, an appeal to the District Court and two appeals to the Nevada Supreme Court
5 and which also resulted in Coughlin's conviction for criminal trespass. Supra 'IMf 19 and 20
6 Coughlin's conduct in the proceedings was so egregious that Judge Flanagan ordered Coughlin to pay
7 Dr. Merliss $42,065.50, an amount that is still unpaid. Supra' 21
8 (TI') The record also establishes that Coughlin habitually prolongs proceedings
9 unnecessarily; fLIes lengthy, irrelevant, nonsensical pleadings requiring court, staff and counsel to
10 spend unnecessary effort in evaluating and/or responding to the pleadings. Supra" 4, 7, 8, 9, 10, 11,
11 16,21,23,25,27,39 and 40
12 Disciplinary Matters
13 (UU) RPC 8.1 (b) provides, in pertinent part, ..... a lawyer ... in connection with a discipIinary
14 matter, shall not: (b) ... knowingly fail to respond to a lawful demand for information from an
15 admissions or disciplinary authority ... "
16 (VV) The record clearly and convincingly establishes that Coughlin knowingly failed to
17 respond to the State Bar's request for infonnation in the disciplinary proceeding and failed to timely
18 file a required verified responsive ans,wer or pleading to the Complaint
19 (WW) First, Coughlin asked for an extension of time to respond to the letter of Februruy 14,
20 2012 regarding the Richard Hill Complaint and then failed to respond at all. Supra 29
21 (XX) Second, Coughlin failed to respond to a subsequent letter from the State Bar regarding
22 the Complaint filed with the Bar by Judge Nash Holmes. Supra' 30
23 (YY) Third, Coughlin ignored SCR 105(2) when he failed to timely file a verified response
24 or answer to the despite several warnings to do so. 34, 35, 36, 37, 38 Coughlin
25 compounded this violation when he attempted, during the course of the hearing in this matter, to
26 transfonn a pleading previously filed in Reno Municipal Court into a "New Verified Response (sic)
27 Pre-Hearing Motion to DismisslSuttllllaty Judgment, Memorandum of Law by cl'Qssing out the
28 original caption and handwriting the "new" caption. Supra 38 Coughlin also attempted, during the
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1 hearing, to transform a pleading he had filed the day before the hearing entitled "Emergency Ex Parte
2 Motion to Dismiss .. " by handwriting the words "Declaration and Verified Response ... " onto the
3 caption of the pleading. Supra' 38
4 (ZZ) The conduct described herein not only demonstrates a lack of cooperation with the
5 State Bar, but a lack of competency as well.
6 Judicial and Legal Officials
. 7 (AM) RPC 82(a) states "A lawyer shall not make a statement that the lawyer knows to be
8 false or with reckless disregard as to its truth or nusity concerning the qualifications or integrity of a
9 judge, adjudicatory officer or public legal officer ...
10 (BBB) During the course of the hearing, Coughlin accused Judge Nash Holmes of lying
11 during her testimony. Coughlin has expressed similar views concerning Judge Nash Holmes in
12 various pleadings filed in this proceeding as well as others. Coughlin has also uttered other
13 derogatory remarks about various judges with whom he bas intemcted.
14 (CCC) The State Bar presented scant evidence on this issue and no evidence from which the
15 panel could conclude that the expressions were knowingly false as opposed to an expression of
16 . opinion. While the conduct displayed is, in the view or the Panel reprehensible, the Panel concludes
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that the State Bar failed to meet its burden of proof on the issue as an evidentiary matter but finds that
as a matter of default the violation may be deemed admitted.
Misconduct
(DOD) RPC 8.4 provides (in pertinent parts):
It is professional misconduct for a lawyer to :
(a) Violate or at1tm1pt to violate the Rules of Professional Conduct ...
(b) Commit a criminal act that reflects adversely on the lawyer's honesty,
trustworthiness or fitness as a lawyer in other respects;
( c) Engage in conduct involving dishonesty, fraud, deceit or misreprC$Cntation;
(d) Engage in conduct that is prejudicial to the administration of justice.
25 (EEE) The Pleadings, Hearing Exhibits and Transcript of these proceedings overwhelmingly,
26 clearly and convincingly establish a repeated, unrelenting and obstinate pattern of misconduct by
27 Respondent Coughlin evincing numerous and repeated violations of several provisions ofRPC 8.4 in
28 violation ofRPC 8.4(a).
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(FFF) Coughlin was convicted of petit larceny on November 30, 2011, a violation of RPC
8.4(b). Such violation is sufficient alone to nigger application of SCR 111. The Nevada Supreme
Court referred the matter to the appropriate disciplinary panel for a determination of the extent of
punishment that should follow from the conviction. Supra,S
(GOO) The record also establishes that Coughlin was convicted of criminal trespass in the
prolonged eviction proceedings Dr. Merliss, a violation ofRPC 8.4(b). Supra' 20
(HHH) The Complaint in this matter alleges that Coughlin has been arrested and is awaiting
trial on a larceny charge involving a cell phone and on a charge of abusing 911 emergency
procedures. However, no evidence was presented on these charges but as a matter of default the
allegations may be deemed admitted and would constitute additional violations ofRPC 8.4(b).
(JJJ) The record, as described at length above, establishes several violations ofRPC 8.4(c).
See" (AA), (BB), (Ce), (AAA), (BBB) and (CCC).
(KKK) The entire record in this matter is replete with instances' demonstrating that Coughlin's
conduct is prejudicial to the administration of justice. Coughlin has been repeatedly sanctioned
monetarily and by way of incarceration for his conduct, has repeatedly filed lengthy, irrelevant and
nonsensical pleacUngs requiring staffs, courts and counsel to expend needless and unnecessary time in
! responding to such pleadings, has repeatedly disrupted proceedings and failed to follow instructions
and admonitions of the courts. The record establishes that the pattern of conduct continues despite
the severe sanctions administered and continues up to and during the disciplinary process and hearing
of this matter.
The Extent of to to SCR 111 As a J!esuJt of
Conviction of the "Serious"
(LLL) The matter of the referral from the Supreme Court was considered in conjlUlction with
the allegations in the Complaint filed by the State Bar. While the conviction at issue in the Supreme
Court Order of June 7. 2012 may not alone warrant the discipline recommended in this Panel's
recommendations, taken as a whole and in conjunction with the nmnerous and repeated other
violations of the Rules of Professional Conduct, warrant, in this -Panel's view, the discipline
recommended herein.
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1 DECISION AND RECOMMENDATION
2 In assessing the fonn of discipline to recommend, the Panel has accounted for a number of
3 aggravating and mitigating factors that must be considered.. The Panel finds that the State Bar has
4 shown by clear and convincing evidence the presence of at least eight of the eleven aggravating.
5 circmnstances to be considered in accordance with the provisions of SCR 102.5(1).
6 First, while there have been no fonnal prior disciplinary proceedings by the State Bar. the
7 record establishes that Coughlin has been disciplined by way of sanctions on at least four prior
8 occasions.
9 Second, the record reflects, at least with respect to the Merliss matter and the two criminal
10 trials, that the pattern of conduct was for selfish reasons: to preserve an unlawful tenancy and to delay
11 and prolong criminal convictions.
12 Third, the record clearly and convincingly establishes that the pattern of misconduct is
13 consistent and includes, without limitation: the disruption of the proceedings; the refusal to heed the
14 directions and admonitions of the court; the injection of irrelevant material and matters; the filing of
15 lengthy, irrelevant and nonsensical pleadings; the willingness to lie to court and counsel and the
16 inability to understand and follow the rules of evidence and procedure.
17 Fourth, the record clearly and convincingly establishes that Coughlin has committed multiple
18 violations of the Rules of Professional conduct, as more fully discussed above.
19 Fifth, the record clearly and convincingly establishes that Coughlin engaged in a bad faith
20 obstruction of the discipUnary process by failing to file the pleading required by SCR 105(2) and
21 instead filing several lengthy, irrelevant and nonsensical pleadings, mostly pleadings fIled in other
22 matters. and refiled in the disciplinary acti!Jn Wlder a similar but diffe.rent caption. In some instances.
23 Coughlin simply crossed out the case name and hand wrote the names of the parties in the
24 disciplinary proceeding.
25 Sixth. the record clearly and convincingly establishes that Coughlin has refused to
26 acknowledge the wrongful nature of his conduct despite having been sanctioned on at least four prior
27 occasions.
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Seventh, the record clearly and convincingly establishes that Coughlin has shown a complete
indifference to making restitution and basso far ignored orders to do so.
Eighth, the record clearly and convincingly establishes tbat some of Coughlin's misconduct
involves illegal y n d u ~ t that evinces fraud and dishonesty. For example, he was convicted of one
instance of petit larceny and is awaiting trial on a second.
The Panel finds few potentially mitigating factors to be present. While the Panel fmds that
there is a Jack of prior public discipline by the State Bar, the Panel notes that Coughlin has been
publicly criticized in the Joshi matter, has been heavily sanctioned with an adverse award of
substantial attorney's fees in the Merliss matter, and has been incarcerated at least twice for criminal
contempt of court. Although there has been an absence of prior public discipline by the State Bar,
there have been multiple instances of judicial censure and sanction.
Although Coughlin suggested at the bearing that he may have personal or emotional problems
or a mental disability, he denied that he needed further help. Furthennore. no medical evidence was
presented regarding the potential impact of a mental disability, no evidence that the disability was the
cause of the misconduct, no evidence of recovery by rehabilitation and no evidence that a recovery
has ru.:rested the misconduct and t a recurrence is unlikely to occur.
These potentially mitigating factors are weak at best and do not excuse the well established
numerous and repeated violations of the Rules of Professional Conduct and do not outweigh the
aggravating circumstances established overWhelmingly by the State Bar.
RECOMMENDATIONS
The Panel recommends that the Respondent be ordered:
(1) Irrevocably disbarred by the Supreme Court. While irrevocable disbannent is clearly
the harshest fonn of discipline, the WlusuaI circumstances here. compounded by the repetitive nature
of the misconduct prior to and even during the disciplinary process and hearing, clearly warrant the
level of punishment recommended.
(2) That his temporary suspension be continued pending final resolution of this matter.
(3) Within three (3) days of the effective date of disbannent. to demonstrate to Bar
Counsel that he has placed all his Nevada clients with other counsel, otherwise concluded the
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representation, or with the assistance of Bar Counsel thereafter attempted to expeditiously aid any
remaining client in finding new counsel.
(4) To pay the costs associated with these proceedings pursuant to SCR 120.
. ~
DATED and ENTERED th1S l'f/ day of December, 2012.
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1 CERTIFICATE OF SERVICE
2 The undersigned hereby certifies that a true and correct'copy of the foregoing Order was
3 deposited in the United States Mail at Reno, Nevada, postage fully pre-paid thereon for certified and
4 first class mail addressed to the following:
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Zachary B. Coughlin
1471 E. 9th St.
Reno NV 89505
DATED this 14th day of December, 2012.
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think a couple ofwhacks to my good old boy gut's gonna get
me down? Ifs going to take a hell of a lot more than h a ~
Counselor, to prove you're better than me!
Max looks around in an attempt to find where Sam is hiding.
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Laura Peters
From:
Sent:
To:
Subject:
Patrick King
Thursday, December 13, 2012 11:07 AM
obc; Kimberly Farmer; 'ffiaherty@dlpfd.com'; David Clark
FW: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and
8/17,2012 to Coughlin in rcr2012-065630
This attorney feels that his law firm staff was tlireatened by Zach Coughlin.
I am concerned for our staff.
Please advise.
Patrick King
--Original Message---
From: Leslie, Jim [mailto:Jleslie@washoecounty.us]
To: Patrick King
Subject: FW: The Three E's; wcpd failure to provide essential 911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012-065630
Mr. King:
The below email from Mr. Coughlin contains a .reference at the end of the first paragraph to a website containing a video
clip from the movie Cape Fear. Please advise whether any action is required of our office or yours regarding this
possible veiled or indirect threat of violence against attorneys in this office by Mr. Coughlin.
Thank you,
Washoe County Public Defender'S Office
Fifth Floor
Reno, NV 89509
1-800-762-8031
Fax: 775-337-4856
Email: jleslie@washoecounty.us
The contents of this communication and all accompanying documents and attachments contain CONFIDENTIAL
INFORMATION, are legally privileged, and are intended for use and review only by the party sending same and the
intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying,
distribution, use or taking any action reliant on said contents are CONFIDENTIAL and strictly prohibited. If you received
this communication in error, please immediately notify us at 775-337-4800 to arrange return of the original
transmittal. Thank you.
-----0 rigi na I M essage---
1
1 Zach Coughlin Imailto:zachcougln@hotmailocoml
To: Leslie, Jim; Bosler, Jeremy; Dogan, Biray; Goodnight, Joseph W; Fortier, Chris; Tuttle, Steve; Kandaras, Mary; Young,
Zach; skauc@reno.gov; wongd@reno.gov; kadlicj@reno.gov; complaints@nvbar.org; cvellis@bhfs.com;
je@eloreno.com; eatrickk@nvbar.org; davidc@nvbar.orgj rosec@nvbar.org; laurap@nvbar.org;
mike@tahoelawyer.com; eifert.nta@att.net; nevtelassn@sbcglobal.net; ff1aherty@dlpfd.com;
ff1aherty@dyerlawrence.com
Subject: The Three E's; wcpd failure to provide .essentiaI911 call cd discovery of 8/13 and 8/17, 2012 to Coughlin in
rcr2012-Q65630
The Trial yesterday in RCR2012-065630 featured extended discussions regarding the failure of the WCPD, Dogan,' and
Leslie, to turn over discovery propounded by DDA Young in the form of cd's featuring 911 calls DDA Young provided to
the WCPD on 8/13/12 and 8/17/12 ... And the heavy hitters were there, too (Elliot Sattler) ..... despite numerous written
requests from Coughlin that the WCPD do so, and multiple trips to the WCPD personally by Coughlin to pick such
materials up, and despite more flip flopping on their story by Leslie and Dogan regarding whether they ever gave
Coughlin some package of materials responsive to Coughlin's request for his "file" ... But, Jim Leslie is stuck with the
7/27/12 date he mentions in his email, then he is stuck with what his recent email wherein he purports to have therein
digitally transmitted Coughlin his "file", which obviously does not include the cd's of 911 calls (the one's DDA Young took
up an enormous amount of court time playing, over and over (well, Young only played over and over the particular calls
he felt were strongest for his case and most prejudicial, claiming sOlT)e "cutting room floor mishap" for the reoccurrence
of certain calls, arguing that such a "happy accident" justified playing them again and again, at ever increasing volumes,
etc., etc.). Apparently, I am here to subsidize Youngts baby making, just like I was with Ms. Gorman, as a continuance of
prejudicial length of afforded to the State where none was forthcoming to Coughlin, despite Leslie and Dogan's
obstructionist tantrums, ones of a quality that would. I remember when my life featured happy moments like the birth
of twins ... but that was before your leviathan legal system wrecked shop on my existence. What, sir, shall be my
compensation? Do you mind if I put my arm around .... http://tinyurl.com/bgmlfdr
This is a formal grievance against Dogan, Leslie, Bosler, Young; .. etc.
If Svengali/Diann Ross Diva Jim Leslie is going to micromanage Dogan and Goodnight's cases, and gag order them, he
better be sure not to screw up the cases requIring a mistrial by failing to provide the client the cd's of 911 calls DDA
Young gave the wcpd on 8/13 and 8/17/12 in rjc rev2011-Q65630, and clearly, any packet from 7/27/12 WOUldn't have
them (not to even get into the flip flopping contradictory accounts by Leslie and Dogan as to who gave Coughlin the
packet, or who didn't or blah blah blah) ... and certainly Leslie email below only contained a 57 page pdLway to close to
the 12/11/12 trial date, and containing materials Coughlin had never been given before .... so ml!ch easier, Jimmy Sleazy
to email the client a "digital transmittal" proving what you gave andwhen" .... but, no, that would make it so hard to
fudge the accounts of what was contained therein, or who handed what to whom, or who failed to pick up this or that,
or Dogan's slippery nonsense:
"From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
Subject: 911 Case
Date: Fri,7 Dec 201217:09:08 +0000
Mr. Coughlin:
2
... r _ _
~ . . f _ _
Attached are the discovery materials in the above-referenced case that you had requested and we had made an
additional copy of for you in response to your request. Please note that the July 27,2012, cover letter was for your pick
up and you never picked it up. Note also that the July 27,2012, packet encloses a copy of the April 17, 2012, hand
delivery transmittal of the very same documents which you received.
Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front
desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of our file.
James B. Leslie, Esq."
So, while Dogan states on 7/27/12 in 65630 "Your Honor, I have never even spoken with Judge Dorothy Nash
Holmes" ... he coyly fails to indicate whether he spoke with anyone with the RMC, Marilyn Tognoni, included, orwhy his
2/28/12 fax to Coughlin.was so insistent that it was "Lake's Crossing's Bill Davis, Ph.D." who must conduct the
"Competency Evaluation", or how it was Judge Clifton's 2/27/12 Order for Competency Evaluation could have possibly
known and included Judge Elliott as the "randomly assigned judge" to that Competency Case in CR12-0376 (Judge Elliott
on Committee to Aid Abused Women's Board, (CMW) .. .Judge Elliott presiding over Coughlin's wrongful termination
lawsuit against WCDA's Office ECR Partner, Washoe Legal Services, its Executive Director Paul Elcano, and CMW, in
CV11-01955 .. Judge Elliott fails to disclose conflict or recuse himself, Judge Elliott manages to "randomly" be assigned
Coughlin's two criminal appeals from RMC convictions (the Wal-Mart "candy bar" petty larceny leading to a 6 months, so
far, temporary suspension of Coughlin's law license in 11 cr 22176 In the RMC, then crl1-2064 in the appeal Judge Elliott
canned based upon a civil statute requiring a down payment for the preparation of transcripts and Elliott's contention
that he need not address the merits of Coughlin's appeal given the lack of a written transcript (Coughlin paid for the
audio cd, and its not even clear that the RMC is a court of record anyways, and the RMC distributes to defendants
instructions sheets and enforces "house rules" regarding the preparation of transcripts that require 'one utilizing the
services of RMC "official transcriptionist Pam Longoni (whom hung up on Coughlin twice, and refused to prepare the
transcript in 11 cr 22176/crl1-2064, failed to return emails/faxes, etc.)" and where the RMC refused to even give
Coughlin the audio recording for some time, insisting Coughlin could merely have it made available to Longonl .... Oh,
Coughlin didn't get no continuance from Judge Howard In that 11 cr 22176 (even where he was wrongfully evicted in
Rev2011-o01708 (now on appeal in 60331 and 61383) on 11/1/11, then wrongfully arrested on 11/13/12 in 11 cr 26405
(now feature in 61901, 62101l, 54844, 60302, 60317, etc .. ) and incarcerated between 11/13/12 and 11/15/12, no
continuance for the 11/30/12 Trial in 11 cr 22176, despite an agreement in writing with City Attorney Pamela Roberts
(whom put on perjured testimony by three witnesses where she possess a video and other evidence conclusively
proving that Coughlin did provide his driver's license to RSIC Officer Crawford ... and where Robert's prosecuted based on
an arrest for a misdemeanor by tribal officers where NRS 178.1255 bars such an arrest, and where Wal-Mart's Thomas
Frontino and Roberts herself admit no citizen's arrest was effectuated .... so, about that RPC 3.8 violation ... ). Then there
Is the appeal In cr12-1262 that Judge Elliott, again, was "randomly" assigned from the conviction by RMC Judge William
Gardner in 11 cr 26405 based upon the criminal trespass complaint Signed by Richard G. Hill, Esq. (opposing counsel in
the summary eviction from Coughlin's former home law office in rjc rev2011-001708, presided over by Judge Sferrazza,
though Hill and his associate Casey D. Baker, Esq. fax, on October 17th, 2011 to Judge Clifton (who was not Chief Judge
at the time, or anything) an Emergency Ex Parte Motion for Inspection of Coughlin's law Office, and where in his
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October 19th, 2011 Order in that matter 001708, Judge Clifton ruled as IImoot
ll
Coughlin' 11/17/12 Motion to Set Aside
the 11/13/12 Order following Summary Eviction Proceeding by Judge Sferrazza setting the matter for "Trial" on
10/25/12, on the condition that Coughlin deposit a rent escrow of $2,275 with the RJC (though Judge Sferrazza admitted
later on the record on 11/7/12 that the RJC Judges had a meeting wherein they all had to agree thatCoughlin was
absolutely correct that the RJC was violating Nevada law in having an unpublished IIhouse rule
ll
corollary to JCRLV 44
requiring such rent escrow deposits in landlord tenants matter here JCRCP 83 had not been followed in that the RJC had
not published and had approved by the N. S. ct. any such deviation from the statutory remedies set forth in NRS 40 and
l1SA. Judge Elliott managed to torped.o that appeal of the criminal trespass conviction stemming from the criminal
complaint and custodial arrest at Coughlin's former home law office by co-signing RMC Judicial Assistant Lisa Wagner's
and the RMC's nonsense about not having received Coughlin's Notice of Appeal timely under NRS 189.010. The proof of
delivery fax confirmation indicates otherwise, lisa. And regardless. the conveniently timed arrest of Coughlin on
6/28/12, and the tolling nature of Coughlin's 6/26/12 Motion for New Trial in that matter, and the kited, dated 7/10/12
jailhouse Notice of Appeal by Coughlin, and the curiously failure to grant Coughlin tier time in the interim while Judge
Gardner manageed to push through his 7/11/12 Order Denying Coughlin's Motion for New Trial, is all the more reason
to apply consternation to Judge Elliott's work on the appeal on CR12-01262.. Then there is Judge Linda Gardner being
Judge Peter Breen, MD's law clerk, and Breen kicking Coughlin out of the Mental Health Court based upon Sharon
DoJ\arhid, Rene Biondo, and Breen and the MHC's own breach of contract (if they provide program materials,
acceptance, and a contract that list certain medications as disallowed, how is it they can claim non-compliance or
IIfailure to abide" by the rules for taking a medication not listed therein? Don't ask WCPD Joe Goodnight or Jennifer .
Rains ... they know what side their bread is buttered on .... MH12-oo32 ... so DDA Young tries to jam through a trial in
063341 on May 7th, 2012, despite the mandatory stay in NRS 178.405 and the then still pending Order for Competency
Evaluation in rjc 2012-065630 from the clandestine status conference Dogan and Young never quite seem to refute
happening on 2/27/12 ... 0h, arid Judge Clifton, then DA Dorothy Nash Holmes, and Judge linda Gardner were all co-
workers once upon a time, working closely with then Sparks City Attorney/prosecutor Steven Elliott, whom worked for
the law firm of the father of the Panel Chair for Coughlin's 11/14/12 SBN v.Coughlin formal Disciplinary Hearing in
NG12-0204, 0434, 0435 (the last two being grievances against Coughlin filed, in part, by RMC Judge William Gardner,
prior to Gardner failing to recuse himself from the criminal trespass case against Coughlin before him in 11 CR
26405 ... even where Judge Gardner's sister Judge Linda Gardner's April 2009 Order sanctioning Coughlin was cited by
WLS's Elcano as the sole basis for firing Coughlin, and where Coughlin filed a Mandamus Petition in 54844 challenging
those sanctions, and where ng12-0435 was one of three grievances forming the 8/23/12 SCR 105 Complaint against
Coughlin (strangely ... the Wal-Mar "candy bar" petty larceny conviction and the formal hearing for the "sole purpose" of
determining Coughlin's punishment for such required by SCR 111(8) and the Court's 6/7/12 Order got particularly short
shrift in the 8/23/12 triple grievance numbered SCR 105 Complaint by Bar Counsel Pat "Patty Ice" King, a/k/a Pat Salieri,
whom wants no part of explaining his statements to Coughlin during the 3/26/12 appearance at the SBN by Coughlin, for
the sole purpose of taking King up on his offer to let Coughlin review the materials submitted along with the grievances
(therein King claimed to have received grievances against Coughlin from three different Judges .... though, by 3/26/12, it
couldn't have been Beesley, as Coughlin only filed the exhibits detailing Judge Nash Holmes and the WCSO and WCDA
impermissibly confiscating Coughlin's smart phone without a warrant or court order and well after the end of the period
to do a search incident to arrest (the arrest was 2/27/12 for some pastiche of summary plenary civil criminal contempts
statuts that Judge Nash Holmes whipped up ... though she avoid NRS 22.030 and definitely there wasn't no affidavit
signin' by 01' RMC Marshal Harley for alleged conduct In a restroom or restroom stall, which assuredly was not "under
the watchful eye of the court" or "in the immediate presence" of the court .... so much easier for Bar Counsel to feed
Judge Nash Holmes the "clear and convicing evidence" standard from Schaefer required to prove an ethical violation,
have here copy and paste some RPC's into a second bite at the apple and more than 10 days later (civil statute, NRS
22.010, NRCP and JCRCP 59 allow sua sponte amending within 10 days, no 12 days ... 2/27/12 to 3/12/12 .... void Order of
3/12/12 by Judge Nash Holmes, so, sorry Patty Ice, nice try, no SCR 111(5) "an Order or conviction is conclusive proof of
guilt and I don't recognize Claiborne as binding authority because it makes my job harder .... l1 ....
Thank You Jim for continuing to prevaricate in writing, your recent email combined with some, uh, other materials that
have been culled, will surely be helpful in exposing you for the fraud that you are. And Biray Dogan too ... Oh, by the way,
that 11/7/12 fax confirmation page or proof of faxing? How is that coming along, because I need to see it from you. My
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records show absolutely no receipt of any fax of that sort, not on that day, not on any day .. ;which means the ball is in
your court to show how Dogan's representations to Judge Sferrazza on 11/19/12 in court were not displaying a lack of
candor to the tribunal and How Leslie TIbbals' certificate on service therein is not fraud.
Oh, attached is Goodnight's 12 19 11 Request for Discovery, which includes:
"REQUEST FOR DISCOVERY
COMES NOW, the Defendant, ZACHARY BARKER COUGHLIN, by and through his attorney of record, Joseph W.
Goodnight, Deputy Public Defender, and hereb.y requests the following discovery pursuant to NRS 174.235 to NRS
174.295, inclusive. 1. Inspect and receive copies or photograph any written or recorded statements or confessions made
by the Defendant or any witness, or copies thereof, within the possession, custody or control of the State, the existence
of which is known or by the exercise of due diligence may become known to the prosecutor. NRS 174.235(1)(a). This .
request includes any video and audio recordings, including those preserved on pocket recording devices, 9-1-1
emergency calls, and any dispatch logs, written or recorded, generated In connection with this case. II
Jim, then there is you chiming In, in your role as "standby counsel", attempting to aid the Court and DDA Young In
coercing from me my Fifth Amendment rights at the 9:06 am mark on the transcript from 11/20/12 ("Your Honor, I'll
remind the Court that I am here to jump in In my role as standby counsel anytime the Court's feels he is dragging his
feet.. .. He is wasting County assetsl" ... very Atticus Finch, Jim).
So, then there is Jim's 10/3/12 subpoena to Ecomm/Kelley Wood ... and given he was counsel of record until 10/22/12,
yet completely failed to turn over anything (responsive or not) in relation to that subpoena, and the fact that the entire
Suppression Motion turned on "what information the RPD received from dispatch", and the fact that the audio of the
"radlo traffic" between the RPD and Dispatch on that night (or at least the portions of It I have been able to extract from
the powers that be) reveal, one, no report of a possible fight was received by RPD (they were on the scene by the time
the 11:27:11 pm text was sent to the displays In their vehicles, and the one audible "radio traffic" recording contains no
mention of anything beyond "check for possible larceny of a cell phone that just occurred, suspect still on the scene, also
reports of a loud verbal disturbance ... ". Then there is Jim and Goodnight completely whiffing on the detaining
argument,.in addition to the whole "assuming we win on the pat down, make sure to oppose the notation that there
was sufficient probable cause for an arrest and search incident thereto .... ", not to mention that it was Coughlin (whose
filings Jim managed to cheerfully announce liThe Public Defender's Office is not joining in on those fugitive
documents ... ", despite the 2/21/12 Filings by Goodnight that do just that .... ) that pointed out the whole NRS 171.360
basis for throwing out the search (which Jim managed to not cite to or quote from in his closing argument as the
Suppression Hearlng ... where Jim did manage to ask Cory Goble questions on cross that were designed to do nothing
more than establish a citizen's arrest sufficient to rebut the NRS 171.360 basis for throwing out the arrest and fruits
culled .. ).
Oh, then there is your office blacking out the numbers ofthe callers on the dispatch logs and refusing to turn over even
a redacted version of the alleged victim's call records for the time in question, thereby completely obstructing the
defendant's ability to impeach the various lies testified to by all the witnesses. And "Coach" DDA Young can tell you all
about his 40 minutes coaching sessions visible through the plexiglass in the Justice Court lobby with Zarate, Goble,
Lichty, and Templeton, and their constant parroting (along with RPD Duralde) of "prosecutor buzzwords" ("willfully
withheld", "report from 'dispatch of a possible fight", limy training and experience", "detained", "I don't remember who
made the call", "I can't remember which one of my friends it was who was with me", etc., etc.) Also, the WCPD practice
of blacking out locations and addresses sure makes it difficult to establish inconsistencies between testimony and the
reports/Witness Statements or otherwise utilize them for impeachment purposes.
So, now today, we get this Jim Leslie email with all it's revisionist history ... which only contradicts the position Leslie and
Dogan have taken that Coughlin already picked up this 7/27/12 packet (at first Dogan claimed to have personally handed
it to Coughlin, then changed his story 2 minutes later and said he saw Leslie personally hand it to Coughlin .... and Dogan
asserts to the Court at the 11/27/12 Hearing in rcr2012-065630 that he has never spoken with Judge Dorothy Nash
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Holmes (see materials regarding clandestine status conferen'ce of 2/27/12 and subsequent fallout with Judge Nash
Holmes of 2/27/12 a couple hours after Dogan secured his 2/27/12 1:31 pm ,Order for Competeny Evaluation in 065630
from Judge Clifton).
The SBN v. Coughlin Complaint of 8/23/12 specifically mentions the arrest of 1/14/12 that theis 065630 case is based on,
in addition to the 063341 iPhone arrest, and RJC Judicial Secretary lori Townsend sent Coughlin's 2/21/12 in 065630 to
the SBN, and offered to send Coughlin's 2/15/12 filing in 063341 to the SBN ... and Judge Nash Holme's 3/12/12 Order in
11 TR 26800 mentions Coughlin quoting "rock {yrics" in a filing as a basis for her transmogrifying a "simple traffic
citation" to a "formal disciplinary hearing on an ethics violation" wherein she quotes the Schaefer standard for an ethical
violation that Bar Counsel had fed her earlier in the day ... and that window between the 1:00 pm noticed start time of
the traffic citation trial in 11 tr 26800 and the 3:30 pm eventual start time includes the 1:25 pm courthouse sanctuary
doctrine Violating service upon Coughlin (by RMC Marshal Joel Harley, on behalf of WCSO Deputy Machen, hired by
RlchardG. Hill, Esq., at whose office Coughlin was retaliated against by RPD Sargent Tarter with the three traffic citations
shortly after Coughlin reported to Tarter the admissions regarding bribery by Richard G. Hill, Esq. by RPD Officer Chris
Carter, Jr .... and Marshal Harley was serving the Order to Show cause for the 3/23/12 Hearing In the appeal of the
summary eviction from Coughlin's former law office (where RPD Carter made the trespass arrest now detailed in N. S.
Ct. case 61901), on behalf of Deputy Machen, in the conference room within the Courtroom B of the RMC, despite
Coughlin, an efiler, having already been served it). However, the only filing by Coughlin that could be said to quote "rock
lyrics" Is the 2/21/12 filing In Dogan's case 065630 (the one where Dogan had appeared as attorney of record then failed
to show up for a hearing on 2/13/12, then retaliated against Coughlin for Coughlin's 2/21/12 filing In 065630 by moving
for a Competency Evaluation and baSically doing absolutely nothing on the case for the next 9 months besides raping
from Coughlin his medical privacy rights along with Judge Steven Elliot and DDA Zach Young at the 4/19/12 hearing in
CR12-0376 (one of 3 criminal appeals Judge Elliotwas "randomly" assigned in which Coughlin is a party ... to go along
with the wrongful termination suit by Coughlin that Judge Elliot presided over in CV11-01955 wherein Coughlin sued
CAAW and WLS, despite Judge Elliot sitting on CAAW's Board, and where Judge Elliot, the Panel Chair at Coughlin's
formal disciplinary hearing of 11/14/12, and Washoe legal Service's Paul Elcano all went to Stanford together, and
where Judge Elliot worked for Panel Chair John Echeverria's father's law firm, Echeverria and Osborne). Then there is
linda Gardner being Judge Breen's law clerk, and Judge Breen removing Coughlin from Mental Health Court in MH12-
0032, where the MHC's Rene Biondo and Sharon Dollarhide lied about what medications were Iisted'as accepted or not
in the materials provided by Goodnight and or the MHC along with the contract entered into with Coughlin, whom was
accepted into the MHC. Then there is WCPD Joe Goodnight and Jennifer Rains refusal to file anything directed towards
enforcing the MHC's contract with Coughlin, wherein they both demonstrated they know what side their bread is
buttered on and indicated "there just isn't a basis for seeking reconsideration of Judge Breen's Order". Judge Peter
Breen, MD.
Funny how Dogan did not state to Judge Clifton that he never spoke with anyone else at the Reno Municipal Court about
Coughlin ... .including Marilyn Tognoni...but, rather Dogan just indicated he never spoke with Judge Nash Holmes, in his
best innocent little boy voice that he cops when he isn't busy tittering away with Jim leslie In the spectator area during
the 11/19 and 11/20 Trial in 063341 (where he failed to apprise Judge Sferrazza of the fraud attendant to his earlier
attestations regarding proof of service (by fax no less) of his 11/7/12 Motion to Quash Coughlin's Subpoena ....
Also, its a bit strange how Dogan and the WCPD redact or black out the names of the RPD Officers and Dispatch
Operators beginning on page 16 of the 56 page file Jim Leslie finally em ailed me today titled "Coughlin Discovery 911
Case", which, as is their wont, he and Dogan have continued to change their stories about whether they had or had not
provided to me already until the last possible minute before trial, Whereupon, with a Trial date of December 11th, 2012
in rcr2012-065630, Jim leslie finally emails me a 56 page pdf purporting it to be my "file". One wonders where any
audio recordings, dispatch recordings, 911 call recordings or other media are any why leslie and Dogan did not provide
them. Coughlin appeared at h ~ WCPO's Office today and asked for the hard copy of his file, yet was told by front desk
receptionist "Paula" (of course, no last name provided) that she "spoke with an associate" and they told herthatJim
Leslie had already provided Coughlin his file and that he, therefore, would not be given the hard copy. "Paula"
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eventually seemed to have to admit that the misleading use of the term "associate" actually did not connote her having
spoken with an attorney about the matter ... but rather linda Gray, whom has been curiously silent as to the apparent
misconduct attendant to her admitting that she did not mall out any written notice to Coughlin of the August 6th, 2012
"combo-hearing" in rcr2012-067980 or rcr2012-065630 (Leslie glossed over that fact by sending Coughlin a note about
how he "saved the day" with his "advocacy" ... skipping past the part about how the client, Coughlin, was not noticed on
the hearing in any matter, much less in writing: ... Leslie later refused to indicate with any specificity whatsoever how he
"knew" Coughlin had been noticed on the 8/6/12 hearing in writing ... and ruc Judges are only too willing to "believe" Jim
Leslie, Esq. when he explains away vaguely such things ...
Mr. Leslie, the thing is, I have a Trial in this case rcr2012-065630. You have continued in your way (similar to how you
approached the rcr2011-Q63341 case where Joe Goodnight, Esq. was counsel of record until you had him removed on
7/16/12, the morning ofTrial...after Mr. Goodnight and I have completed a video conference final trial preparation at
4:30 pm on Friday, July 13th, 2012 while I was in custody (pursuant to an arrest on July 3rd, 2012, ordered by RPD
Sargent Kim Bradshaw, she of the 1/12/12 custodial jaywalking arrest along with RPD Sargent Paul Sifre) .... Things fall
through the cracks, Mr. Leslie, when you place a gag order on the associates you claim to supervise, then stubbornly,
petulantly, and retaliatorily refuse to work the cases you have snatched back from your associates .... Similarly, WCPD
Fortier's email to me of February 6th, 2012 may have contributed to Mr. Dogan's confusion In failing to attend the
Hearing on Feburary 13th, 2012, which begat my filing of February 21st, 2012, which begat Mr. Dogan's procurring the
February 27th, 2012 Order for Competency Evaluation, which begat the 5 day summary incarceration for
summary/plenary/criminal/civil/transmogrified diSCiplinary hearing on an ethics Violation/what is jurisdiction? Order by
RMC Judge Nash Holmes on 2/27/12 at 4:40 pm ... whlch begat NG12-0434, and probably 0435 (the SBN v. Coughlin SCR
105 Complaint of 8/23/12).
However, Mr. Dogan, you are not off the hook just because Jim Leslie places a gag order on you. Mr. Leslie sent this
email today with a 56 page pdf file purporting to be my "file". I, as now a former client, have rights to "my file". I have
requested my file in writing from your office on numerous occasions, and given your removal as counsel of record on
11/22/12 (amazingly Mr. Dogan probably managed to say 200 words on a case that he had been counsel of record on for
nearly a year, and had not managed to file a single document in that case, RCR2012-065630, and had managed to get
upset that a client would take issue with his missing the 2/13/12 Hearing, even though WCPD Fortier's 6 1 2 email
makes clear, the matter was assigned to Mr. Dogan at that point, and he had already sat down and discussed the case
with Coughlin for over one hour on or about February 8th, 2012, where Coughlin went to check in with Mary Watson,
whom was then represented by WCPD Branzell, who dragged Watson over to the Sparks Justice Court Bailiff and
demanded they breathalyze her client. They did, she was taken into custody.
So, after sitting down with Dogan for at least an hour and discussing various things, some including matters related to
the case he was then attorney of record on .RCR2012-065630, the February 13th, 2012 court date (Dogan and Coughlin
have conflicting views as to what was agreed upon and the applications of NRS 178.388).
NRS 178.388 provides that the defendant must be present at arraignment, trial, and sentencing and provides that the
defendant may waive his appearance when certain conditions are met.
Its kind of odd how Judge Clifton (whose attached bio indicates he has deep and longstanding ties to the domestic
violence Industry Infrastructure) knew instantaneous to signing the Order for Competency Evaluation of 2/27/12 at 1:31
pm that the matter would be randomly assigned to District Court Judge Steven Elliot (also a lifelong prosecutor with
deep and longstanding ties to the domestic violence industrial complex, and a member of the Committee to Aid Abused
Women's (CAAW, one of the named defendants in the wrongful termination lawsuit Coughlin brought and over which
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( Elliot presided in cVll-ols, where he failed to point out his per s!nflict of interest to plaintiff
Coughlin at any time, and where he ultimately pulled out just about every wrinkle in the insufficiency of service and or
process and or service of process (a movie showing a non party over 18 years of age serving a senior paralegal at
WaShoe Legal Services, whose Executive Director Paul Elcano went to Stanford with Judge Elliot and the Panel Chair of
Coughlin's 11/14/12 Formal Disciplinary Hearing before the State Bar of Nevada, John Echeverria in the late 1960s ... and
Judge Elliot worked at John Echeverria's father's law firm, Echeverria and Osborne Board of Directors, in addition to
being a former ass
In CVll-01955, Coughlin sued his former employer Washoe Legal Services, whose Executive Director Paul Elcano went
to Stanford in the late 1960s with Judge Steven Elliot and John Echeverria, the Panel Chair of Coughlin's 11/14/12 Formal
Disciplinary Hearing before the State Bar of Nevada .. and Judge Elliot worked at John Echeverria's fathers law firm,
Echeverria and Osborne, and Judge Elliot served on the Board for CMW, and was a prosecutor as the Sparks City
Attorney.
Also, Mr. Leslie, while the 56 page pdf you finally sent me (gosh, was it that hard to click "attach", load a 2 mb pdf file
and hit "send" on an email to me? No debatin', no arguing about whether Leslie and Dogan left the package at the desk,
whether Dogan already gave it to Coughlin, or whether Dogan then changed his story and said Leslie gave it to Coughlin,
whether Coughlin already picked it up, no claims by Jessica the Receptionist of anyone kickin' furniture ... nothing like
that, just a digitally verifiable means of ascertaining what you transmitted and when ... was that so hard? Heck, Jim, you
could probably just email those ECOMM recordings too ... and if attachment size is an issue, sign up for a
www.outlook.com (the new HoTMaiL, allowing up to 300 mb attachments via the SkyDrive functionality, and up to 100
mb attachments via plan email, and over 2S free gb of storage on the Skydrive, etc., etc; .. ). But its Leslie finally sent the
56 page "client's file" on or about 12/7/12, yet he failed to include the insipid Motion of 11/26/12 by DDA Young
(wherein, just after Judge Clifton finishes telling Coughlin at the 11/27/12 Hearing that Coughlin is not allowed to even
think about the other two RJC shotgunnin' style splatter paint prosecutions by DDA Young, as "they are just not relevant
to this proceeding" .. :and anytime Coughlin would point out specific basis for undertaking a recusal or conflict analysis vis
a vis either Judge Clifton, the RJC, DDA Young, the WCPD, or the WCDA, Judge Clifton would say "your're losing
me ... your're losing me ... " as if Coughlin was speaking in tongues all the sudden ...
So, while Coughlin is reportedly not even allowed to email DDA Young about cases not even before Judge Clifton, or
something like that ... DDA Young is able to get an unnoticed, ex parte, emergency Motion to Prho
Sincerely,
Zach Coughlin
1471 E. 9th St.
Reno, NV 89512
Tel and Fax: 949 667 7402
ZachCoughlin@hotmail.com
From: Jleslie@washoecounty.us
To: zachcoughlin@hotmail.com
8
At , .
a J ~ 'I-
cc': BDogan@washoecounty.us
Subject: 911 Case
Date: Fri, 7 Dec 201217:09:08 +0000
Mr. Coughlin:
Attached are the discovery materials' in the above-referenced case that you had requested and we had made an
additional copy of for you in response to your request. Please note that the July 27, 2012, cover letter was for your pick
up and you never picked it up. Note also thatthe July 27,2012, packet encloses a copy of the April 17, 2012, hand
delivery transmittal of the very same documents which you received.
Since we have been removed from the 911 case, we are closing our file. The attached materials were sitting at our front
desk. Since you failed to retrieve them, we provide the attached courtesy copy before final closure of our file.
Fifth Floor
Reno, NV 89509
1-800-762-8031
Fax: 775-337-4856
Email: jleslie@washoecounty.us<mailto:jleslie@washoecounty.us>
The contents ohhis communication and all accompanying documents and attachments contain CONFIDENTIAL
INFORMATION, are legally privileged, and are intended for use and review only by the party sending same and the
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Case No. RCP 2012-000607
Dept. No.4
IN THE JUSTICE COURT OF RENO TOWNSIDP
COUNTY OF WASHOE, STATE OF NEVADA
STATE BAR OF NEVADA, )
EmployerJ
)
)
VS. )
)
ZACHARYBARKERCOUGBLffi)
Adverse Party)
EXTENDED ORDER FOR
PROTECTION AGAINST
HARASSMENT ffi THE WORKPLACE
~ 3 3 . 2 7 0
Date Issued: JANUARY 4,2013 Time: 8:30 a. m.
Expiration Date: JANUARY 4, 2014 Time: 11:59
p.m.
WARNING: This is an official Court Order. If you disobey this Order, you may be arrested and
13 prosecuted for the crime of violating an Order for Protection Against Harassment in the Workplace
and any other crime that you may have committed in disobeying this Order. An intentional violation
14 of an Extended Order for Protection Against Harassment in the Workplace is a misdemeanor, unless
a more severe penalty is prescribed by law for the act that constitutes the violation of the Order.
15 Under NRS 193.150, a misdemeanor is punishable by imprisonment in the county jail for not more
than 6 months, or by a fine of not more than $1,000.00, or by both fme and imprisonment.
16
17
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20
21
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PURSUANT TO NRS 193.166, if the act that constitutes the violation of a protection order is itself a
felony, the violator shall, in addition to the term of imprisonment prescribed by statute for the crime, be
punished by imprisonment in the state prison for a minimum term of not less than 1 year and a maximum
term of not more than 20 years.
YOU ARE FURTHER NOTIFIED that YOU CAN BE ARRESTED even if the person who
obtained the Order invites or allows you to contact them. You have the sole responsibility to avoid
or refrain from violating the terms of this Order. Only the Court can change the Order upon written
application.
The Court having considered the filings, testimony (if applicable) BUd evidence
presented at hearing, and the Court having found that the Adverse Party received notice of
hearing at which such person had an opportunity to participate and be heard, and the Adverse
Party 0 was present, X was not present, 0 was represented by counsel'--____ _
________________ .and the Applicant X . was present, 0 was not
Form B-2S Extended Order for Protection Against Harassment in the Workplace
Page I of4
C2007 Nevada Supreme Court
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present, [X] was represented by counsel PATRICK OWEN KING , and the Court having
proper jurisdiction over the parties and this subject matter, and it appearing to the satisfaction
of the Court that the Adverse Party has committed and/or is committing or remains a threat to
commit harassment in the workplace and good cause appearing,
IT IS HEREBY ORDERED that the Extended Order for Protection Against
Harassment in the Workplace is granted for the following reasons:
The Court has found that the employer has presented evidence sufficient to support the
granting of the application for .an Extended Order of Protection Against Harassment in the
Workplace; and
The Court has found that the Adverse Party knowingly threatened to cause or
committed an act causing bodily injury to himself or another person; and/or damage to the
property 'of another person; and/or substantial harm to the physical or mental health or safety
ofaperson.
13'
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24'
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Other:

IT IS FURTHER ORDERED that you, the Adverse Party, 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,
any 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.
IT IS FURTHER ORDERED that you stay away from the workplace 'of the
employer, wherever situated within the State, including, but not limited to, the following
specific workplace addressees): _________ _
Page 2 of4
Revised July 27; 2007

1
Town/City of RENO, County of WASHOE, State of NEVADA
2
Other:
3
IT IS FURTHER ORDERED that the following additional restrictions apply:
4
5
6
7
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10
11 IT IS FURTHER ORDERED that the Clerk of the Court shall transmit, by the end
12 of the next business day after this Extended Order is issued, a copy of the Order, together with
13 a copy of the Application, to the following law enforcement agencies:
14 WASHOE COUNTY SHERIFF. RENO POLICE DEPT, SPARKS POLICE DEPT,
15 RENO/SPARKS TRIBAL POLICE, NEVADA HIGHWAY PAlliOL and UNR
16 POLICE
17
18 IT IS FURTHER ORDERED that the appropriate law enforcement agency/process
19 server promptly attempt to serve this Order upon the Adverse Party, and to file with or mail to
20 the Clerk of the Court proof of service by the end of the next business day after service is
21 made. Service must be made pursuant to the Ru1es of Civil Procedure.
22
23
24
25
Form B-lS Extended Order for Protection Against Harassment in the Workplace
Page 3 of4
ClO07 Nevada Supreme Court
Revised July 27. 2007
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NOTICE TO LAW ENFORCEMENT
Any law enforcement officer, with or without a warrant, and whether or not a
violation occurs in the presence of the officer, may arrest and take into custody the
Adverse Party, when the law enforcement officer has probable cause to believe that (a)
an Order has been issued pursuant to NRS 33.270 against the Adverse Party; (b) the
Adverse Party has been served with a copy ofthe Order; and (c) the Adverse Party is
acting or has acted in violation of the Order.
Any law enforcement agency in Nevada may enforce a Court Order issued
pursuant to NRS 33.270 without regard to the county in which the Order was issued.
If a law enforcement officer cannot verify that the Adverse Party was served with
a copy of this Order, the officer shall serve the d v e ~ e Party with a copy of the Order if
a copy is available.
IT IS SO ORDERED this 4
TH
day of JANUARY, 2013.
~
PROOF OF SERVICE UPON ADVERSE PARTY
I, the undersigned, personally served the Adverse Party named above with a copy of this
Extended Order for Protection Against Harassment in the Workplace. .
Page 4 of4
Signature
Print Name
Date of Service
Time of Service
Extended Order Against.
State of Nevada NRS 33.270
EMPLOYERINAME OF BUSINESS
I
STATE BAR OF
. NEVADA
First
ADVERSE PARTY
Middle
v.
Case No. RCP 2012-000607
Dept. No.4
Court
County
RENO JUSTICE COURT
WASHOE
Last
I ZACHARY I BARKER I COUGHLIN
SEX I RACE nOB IHT IWT
First Middle Last
Adverse Party's Home Address and Phone Number:
1471 E9TI-1 STRENONV 89505
M ICAUC
EYES HAIR
VEHICLE STATE
SEDAN
.CAUTION: 0 ACCESS TO WEAPONS 0 OTHER:
THE COURT HEREBY FINDS:
9/27/76 16
1
3
11
I
1
DISTINGUISHING
FEATURES
TAG #
COLOR
That is has jurisdiction over the parties and subject matter, and the Adverse Party received actual notice of hearing at
which such person had an opportunity to participate and be heard.
THE COURT HEREBY ORDERS:
That the Adverse Party be prohibited from committing further unlawful acts of harassment in the workplace. Additional
terms of this order are as set forth on the following pages.
181 The terms of this order shall expire at 11:59 p.m. on (date)
unless otherwise ordered by the Court. . Jrnonth) .
112014 (year)
This Order meets the Full Faith and Credit provisions of the Violence Against Women Act and is enforceable in alISO
states, the District of Columbia, U.S. Territories and Indian Nations. All other courts and law enforcement with
jurisdiction within the United States and all Indian Nations shall give full faith and credit to this Order pursuant to 18
U.S.C. Sec. 2265. Violation of the Order may subject you to federal charges and punishment pursuant to 18.U.S.C. Sec.
2261 (a)(1) and (2) and 2262(a)(l) and (2).
Form 8-24 Extended Order for Protection Against Harassment in the Workplace Cover Sheet m007 Nevada Supreme Court
June 30, 2007
Datemme
Local 10 1
Local 102
01-04-2013
7753256715

Broadcast Report
11 :03:06 a.m. Transmit Header Text
Local Name 1
Local Name2
This document: Confirmed
(reduced sample and details below)
Document size.: 8.5 a x11 a
I Extended Order for Protection Aga-inst---','
___ Stat:..tfNe't'oda NRS 33.270 I
2012-000607
Reno Justice Court - Civil
KMPLOVE.RJNAME OF BUSINESS
Dqrt.Nc).4
Cuurt
COIlllly
RENO JUSUG; COURT

v.
ADVEKSEPARTV
11ACHMY I BARiER I COOOH1.lN
DIm.'liGUl$IllNCi I
....... _ ......... _ .. _ .. . ___
VEl'lfCLE! nATE i +"CfI i ' \
SEDAN,--1--t--------l
CAUTION: 0 ACCESS TO WEAPONS 0 OTHER:
Till!: COURT HEREBV FINDS:
.11ntt It IlII:IJurbdlcllon I)VlOtihe paJ1iesand IIlIbjecl malW'.and tho AdveJWe P&n)' IY\.-eind aaualll.Olke "fhearingot
.micb SIICb paNUII hIId m ",pporlunily 10 plrticipctfc and heard.
TIlE C01.TRT HEREBY ORDERS:
fltar the Advenc Plut)' II.! \II'!hiblled fiom committins (1II'Iher uill:lwful 8CIIi of"hal'lliSlmnt in Ihct wurltpbce. Addlti"",,1
tern,) orela sri: 11'1 I'Ot furl/).xI tho follawllll\ JIIIBtS.
1m TbetenllSefthl!lorclct'slNIlIopll't.tlh59
P
olb.tIIIIJAN(lARV 114T1i (oW) J 11014i;1
uIJICI'fI by __ .....
Thi,; OI\1sr full t:1Iim 311d Crtdk "t Woroen il. in 111150
stWs.11v.> OkIric! \lfCowmbia, V.S. l'enilories IIIId Indian NaIlOlt$, All '1fMc crortund "Ii111
jnrmiclk>!; wilhill 1110 tj,:iled !.1a11:S AI1<I aJllndian I>SUollI 8iw full faith 4Jtd credir to) lh$ Otdt:r IU \ 8
I.:.$.l". l2ti5.
;(Ij{ nan:! {2J and 2l62(aX I} """ t2).
Total Pages Scanned: 5 Total Pages ConfIrmed: 30
No. Job Remote StatIon Start TIme DuratIon Pages Une Mode Job Type
001 967 775185S1ti3 10: 07: 56 a.m. 01-04-2013 00:02:17 515 1 EC HS
002 967 7757841695 10:07:56 a.m. 01-04-2013 00:01:23 515 1 EC HS
003 967 93342157 10:07:56 a.m. 01-04-2013 00:03:44 5/5 1 G3 HS
004 967 7753532436 10:07:56 a.m. 01-04-2013 00:02:12 5/5 1 EC HS
005 967 7753283055 10:07:56 a.m. 01 -04-2013 00:04:.04 515 1 EC HS
006 967 7756870478 10:07:56a.m. 01-04-2013 00:04:12 515 1 EC HS
Results
CP26400
CP28800
CP14400
CP14400
CPl4400
CPl4400
Oatemme
Local 10 1
Local 102
Abbreviations:
HS: Hostsend
HR: Host receive
WS: Waiting send
01-04-2013
nS32S671S

11:03:16a.m.
PL: Polled local
PR: Polled remote
MS: Mailbox save
Broadcast Report
Transmit Header Telet
Local Name 1
Local Name 2

RENO JUSTICE CIVIL DMSION
Reno Justice Court - Ovll
MP: Mailbox print
CP: Completed
FA: Fall
TU: Terminated by user
TS: Terminated by system G3: Group 3
RP: Report EC: Error Correct

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