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  • 10 21 13 72675 Voxox Proof of Fax of and Email 10 21 13 Supplemental Post-Trial Motions and 10 21 13 MTN Arrest Judgment 71437 PDF

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    NevadaGadfly
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    1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 1/18 - motion for new trial, notice of appeal of all orders to the 2jdc request for all audio transcripts, order for transcript of trial and all hearings, and request for docket and all nrs 189.030(1) papers at public expense. Zach Coughlin, Esq. NV Bar 9473 (temporarily suspended but authorized to practice on his own behalf in Reno Justice Court), license not suspended before the USPTO 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com Self Representing Attorney Defendant IN THE RENO JUSTICE COURT COUNTY OF WASHOE; STATE OF NEVADA STATE OF NEVADA, PLAINTIFF vs. ZACHARY BARKER COUGHLIN; DEFENDANT ) ) ) ) ) ) RCR2013-072675 D5, then reassigned SUPPLEMENTAL MOTION FOR NEW TRIAL, NOTICE OF APPEAL OF 10/11/13 ORDER REASSIGNING CASE AND 10/14/13 JUDGMENT OF CONVICTION AND COURT ORDER AND ALL OTHERS ORDERS (INCLUDING 9/24/13 ORDERS, 5/30/13 ORDERS, 6/18/13 ORDERS AND ANY OTHER ORDERS ) TO THE 2JDC) AND REQUEST FOR COPY OF DOCKET AND ALL AUDIO TRANSCRIPTS IN THIS CASES, AND REQUEST FOR PREPARATION OF TRANSCRIPT IMMEDIATELY NRS 189.030(1) AND COPY OF ENTIRE RECORD SO FAR AT PUBLIC EXPENSE AND MOTION TO PROCEED IFP AND FOR APPOINTMENT OF COUNSEL FOR POST-TRIAL AND SENTENCING CRITICAL PHASES AND SUPPORTING DECLARATION. Coughlin hereby files this Motion for New Trial (NRS 176.515) and Notice of Appeal of the 10/14/13 judgment of conviction and all other orders ever entered in this case (and especially the 10/14/12 Judgment of Conviction and Court Order, and all orders made in connection with the 5/30/13, 6/6/13, and 9/24/13 court dates (it is especially unjust fail to recognize Coughlin’s filing between 5/23/13 through the 6/18/13 removal of R. Bruce Lindsay as counsel when Coughlin had not agree to or even applied for any sole counsel appointed counsel) to the second judicial district court. POINTS AND AUTHORITIES Coughlin hereby moves for and files the following: Motion for New Trial pursuant to NRS 176.515, and a Motion to Arrest Judgment per NRS 176.525, and Motions for a Judgment of Acquittal per NRS 176.165.: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 2/18 - motion for new trial, notice of appeal of all orders to the 2jdc request for all audio transcripts, order for transcript of trial and all hearings, and request for docket and all nrs 189.030(1) papers at public expense. Motion for New Trial pursuant to NRS 176.515: Grounds for new trial in general. (1). In general. (2). Disqualification or prejudice of judge or officers at trial. (clear violation of ADKT 0411 by Judge Glasson, in addition to his persistently advocating on behalf of the State and making argumentation where DDA Stege failed to in support of the most key areas of dispute regarding the material elements of the crimes charged, in violation of Breliant) (3). Absence of witness. (Coughlin does not believe his proposed subpoena of Bailiff Reyes wife Cathy Ann Reyes was ever responded to by the RJC) (4). Imposition of improper sentence. (Coughlin reserves his right to address this post the 11/6/13 sentencing hearing); Errors and irregularities in preliminary proceedings. (the cumulative prejudicial effect of the RJC and its bailiffs and clerks refusing Coughlin access to and copies of materials necessary to his defense; the forcing of a conflict out conflict counsel in Lindsay that the direct appointment of by Judge Clifton was in violation of the dictates of ADKR 0411 that the judge presiding over trial refer to another judge all rulings on indigency, and the appointment of conflict counsel, both of which Clifton and Glasson violated); Defects in the Criminal Complaint (failure to specify what the order connected to complaint’s reference to “previously ordered by the court” actually was (ie, case number, date of order, n

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    10 21 13 72675 voxox proof of fax of and email 10 21 13 Supplemental Post-Trial Motions and 10 21 13 Mtn Arrest Judgment 71437.pdf

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    1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 1/18 - motion for new trial, notice of appeal of all orders to the 2jdc request for all audio transcripts, order for transcript of trial and all hearings, and request for docket and all nrs 189.030(1) papers at public expense. Zach Coughlin, Esq. NV Bar 9473 (temporarily suspended but authorized to practice on his own behalf in Reno Justice Court), license not suspended before the USPTO 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com Self Representing Attorney Defendant IN THE RENO JUSTICE COURT COUNTY OF WASHOE; STATE OF NEVADA STATE OF NEVADA, PLAINTIFF vs. ZACHARY BARKER COUGHLIN; DEFENDANT ) ) ) ) ) ) RCR2013-072675 D5, then reassigned SUPPLEMENTAL MOTION FOR NEW TRIAL, NOTICE OF APPEAL OF 10/11/13 ORDER REASSIGNING CASE AND 10/14/13 JUDGMENT OF CONVICTION AND COURT ORDER AND ALL OTHERS ORDERS (INCLUDING 9/24/13 ORDERS, 5/30/13 ORDERS, 6/18/13 ORDERS AND ANY OTHER ORDERS ) TO THE 2JDC) AND REQUEST FOR COPY OF DOCKET AND ALL AUDIO TRANSCRIPTS IN THIS CASES, AND REQUEST FOR PREPARATION OF TRANSCRIPT IMMEDIATELY NRS 189.030(1) AND COPY OF ENTIRE RECORD SO FAR AT PUBLIC EXPENSE AND MOTION TO PROCEED IFP AND FOR APPOINTMENT OF COUNSEL FOR POST-TRIAL AND SENTENCING CRITICAL PHASES AND SUPPORTING DECLARATION. Coughlin hereby files this Motion for New Trial (NRS 176.515) and Notice of Appeal of the 10/14/13 judgment of conviction and all other orders ever entered in this case (and especially the 10/14/12 Judgment of Conviction and Court Order, and all orders made in connection with the 5/30/13, 6/6/13, and 9/24/13 court dates (it is especially unjust fail to recognize Coughlin’s filing between 5/23/13 through the 6/18/13 removal of R. Bruce Lindsay as counsel when Coughlin had not agree to or even applied for any sole counsel appointed counsel) to the second judicial district court. POINTS AND AUTHORITIES Coughlin hereby moves for and files the following: Motion for New Trial pursuant to NRS 176.515, and a Motion to Arrest Judgment per NRS 176.525, and Motions for a Judgment of Acquittal per NRS 176.165.: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 2/18 - motion for new trial, notice of appeal of all orders to the 2jdc request for all audio transcripts, order for transcript of trial and all hearings, and request for docket and all nrs 189.030(1) papers at public expense. Motion for New Trial pursuant to NRS 176.515: Grounds for new trial in general. (1). In general. (2). Disqualification or prejudice of judge or officers at trial. (clear violation of ADKT 0411 by Judge Glasson, in addition to his persistently advocating on behalf of the State and making argumentation where DDA Stege failed to in support of the most key areas of dispute regarding the material elements of the crimes charged, in violation of Breliant) (3). Absence of witness. (Coughlin does not believe his proposed subpoena of Bailiff Reyes wife Cathy Ann Reyes was ever responded to by the RJC) (4). Imposition of improper sentence. (Coughlin reserves his right to address this post the 11/6/13 sentencing hearing); Errors and irregularities in preliminary proceedings. (the cumulative prejudicial effect of the RJC and its bailiffs and clerks refusing Coughlin access to and copies of materials necessary to his defense; the forcing of a conflict out conflict counsel in Lindsay that the direct appointment of by Judge Clifton was in violation of the dictates of ADKR 0411 that the judge presiding over trial refer to another judge all rulings on indigency, and the appointment of conflict counsel, both of which Clifton and Glasson violated); Defects in the Criminal Complaint (failure to specify what the order connected to complaint’s reference to “previously ordered by the court” actually was (ie, case number, date of order, n

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    10 21 13 72675 Voxox Proof of Fax of and Email 10 21 13 Supplemental Post-Trial Motions and 10 21 13 MTN Arrest Judgment 71437 PDF

    Uploaded by

    NevadaGadfly
    1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 1/18 - motion for new trial, notice of appeal of all orders to the 2jdc request for all audio transcripts, order for transcript of trial and all hearings, and request for docket and all nrs 189.030(1) papers at public expense. Zach Coughlin, Esq. NV Bar 9473 (temporarily suspended but authorized to practice on his own behalf in Reno Justice Court), license not suspended before the USPTO 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667 7402 ZachCoughlin@hotmail.com Self Representing Attorney Defendant IN THE RENO JUSTICE COURT COUNTY OF WASHOE; STATE OF NEVADA STATE OF NEVADA, PLAINTIFF vs. ZACHARY BARKER COUGHLIN; DEFENDANT ) ) ) ) ) ) RCR2013-072675 D5, then reassigned SUPPLEMENTAL MOTION FOR NEW TRIAL, NOTICE OF APPEAL OF 10/11/13 ORDER REASSIGNING CASE AND 10/14/13 JUDGMENT OF CONVICTION AND COURT ORDER AND ALL OTHERS ORDERS (INCLUDING 9/24/13 ORDERS, 5/30/13 ORDERS, 6/18/13 ORDERS AND ANY OTHER ORDERS ) TO THE 2JDC) AND REQUEST FOR COPY OF DOCKET AND ALL AUDIO TRANSCRIPTS IN THIS CASES, AND REQUEST FOR PREPARATION OF TRANSCRIPT IMMEDIATELY NRS 189.030(1) AND COPY OF ENTIRE RECORD SO FAR AT PUBLIC EXPENSE AND MOTION TO PROCEED IFP AND FOR APPOINTMENT OF COUNSEL FOR POST-TRIAL AND SENTENCING CRITICAL PHASES AND SUPPORTING DECLARATION. Coughlin hereby files this Motion for New Trial (NRS 176.515) and Notice of Appeal of the 10/14/13 judgment of conviction and all other orders ever entered in this case (and especially the 10/14/12 Judgment of Conviction and Court Order, and all orders made in connection with the 5/30/13, 6/6/13, and 9/24/13 court dates (it is especially unjust fail to recognize Coughlin’s filing between 5/23/13 through the 6/18/13 removal of R. Bruce Lindsay as counsel when Coughlin had not agree to or even applied for any sole counsel appointed counsel) to the second judicial district court. POINTS AND AUTHORITIES Coughlin hereby moves for and files the following: Motion for New Trial pursuant to NRS 176.515, and a Motion to Arrest Judgment per NRS 176.525, and Motions for a Judgment of Acquittal per NRS 176.165.: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 2/18 - motion for new trial, notice of appeal of all orders to the 2jdc request for all audio transcripts, order for transcript of trial and all hearings, and request for docket and all nrs 189.030(1) papers at public expense. Motion for New Trial pursuant to NRS 176.515: Grounds for new trial in general. (1). In general. (2). Disqualification or prejudice of judge or officers at trial. (clear violation of ADKT 0411 by Judge Glasson, in addition to his persistently advocating on behalf of the State and making argumentation where DDA Stege failed to in support of the most key areas of dispute regarding the material elements of the crimes charged, in violation of Breliant) (3). Absence of witness. (Coughlin does not believe his proposed subpoena of Bailiff Reyes wife Cathy Ann Reyes was ever responded to by the RJC) (4). Imposition of improper sentence. (Coughlin reserves his right to address this post the 11/6/13 sentencing hearing); Errors and irregularities in preliminary proceedings. (the cumulative prejudicial effect of the RJC and its bailiffs and clerks refusing Coughlin access to and copies of materials necessary to his defense; the forcing of a conflict out conflict counsel in Lindsay that the direct appointment of by Judge Clifton was in violation of the dictates of ADKR 0411 that the judge presiding over trial refer to another judge all rulings on indigency, and the appointment of conflict counsel, both of which Clifton and Glasson violated); Defects in the Criminal Complaint (failure to specify what the order connected to complaint’s reference to “previously ordered by the court” actually was (ie, case number, date of order, n

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    11/4/13 Outlook Print Message

    https://bay176.mail.live.com/mail/PrintMessages.aspx?cpids=d6830d46-3aac-11e3-b646-b4b52f561804,m&isSafe=false&FolderID=66666666-6666-6666-6666-6 1/4
    respectfully submitting filings of 10 21 13 due to time and indigency exigency
    From: Zach Coughlin (zachcoughlin@hotmail.com)
    Sent: Mon 10/21/13 4:59 PM
    To: msexton@washoecounty.us (msexton@washoecounty.us)
    2 attachments
    10 21 13 72675 Supplemental Post-trial motions and supporting Declaration.pdf (118.0
    KB) , 10 21 13 faxed Motion for New Trial, Motion for Arrest Judgment, Declaration in
    Support of Both 72675.pdf (423.5 KB)
    Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
    7402 ZachCoughlin@hotmail.com
    From: zachcoughlin@hotmail.com
    To: astege@da.washoecounty.us
    Subject: filings of 10 21 13
    Date: Mon, 21 Oct 2013 16:56:20 -0700
    Dear RJC for rcr2013-072675
    While there is authority for the position that "telecommunication lines" included email per NRS
    178.589 and the RJC's stated rule leverage by other litigants that "a facsimile is an original", with
    hesitance, this being faxed, respectfully due to exigent time and indigency concerns.
    Please realize there may have been/ was a problem in getting filed the previously faxed/served
    documents purporting to be post-trial motions and declaration in support thereof. Please call to
    clarify any confusion.
    ClosePrint
    Outbound fax report
    From: Voxox (noreply@voxox.com) This sender is in your safe list.
    Sent: Mon 10/21/13 4:46 PM
    To: zachcoughlin@hotmail.com
    Hi zachcoughlin,
    Your Fax was successfully sent to 11df3c14-7480-4a47-8c03-4eea464b570dgeneral693298 (
    17753256591).
    11/4/13 Outlook Print Message
    https://bay176.mail.live.com/mail/PrintMessages.aspx?cpids=d6830d46-3aac-11e3-b646-b4b52f561804,m&isSafe=false&FolderID=66666666-6666-6666-6666-6 2/4
    Your Fax was delivered @ 11:46:04 PM on 2013-10-21.
    xoxo,
    The Voxox Team
    This message was intended for zachcoughlin@hotmail.com. Want to control which emails you
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    Outbound fax report
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    Sent: Mon 10/21/13 4:39 PM
    To: zachcoughlin@hotmail.com
    Hi zachcoughlin,
    Your Fax was successfully sent to 18ff53cc-a121-4c3b-95aa-65913d1341c6general693298 (
    17753283844).
    Your Fax was delivered @ 11:39:44 PM on 2013-10-21.
    xoxo,
    The Voxox Team
    This message was intended for zachcoughlin@hotmail.com. Want to control which emails you
    receive from Voxox? Get Voxox: http://download.voxox.com and adjust your Notifications in the
    Settings/Preferences window. 2013 Voxox 9276 Scranton Road, Suite 300, San Diego, CA
    92121.
    Outbound fax report
    From: Voxox (noreply@voxox.com) This sender is in your safe list.
    Sent: Mon 10/21/13 4:34 PM
    To: zachcoughlin@hotmail.com
    Hi zachcoughlin,
    Your Fax was successfully sent to 18ff53cc-a121-4c3b-95aa-65913d1341c6general693298 (
    17753283844).
    Your Fax was delivered @ 11:34:24 PM on 2013-10-21.
    11/4/13 Outlook Print Message
    https://bay176.mail.live.com/mail/PrintMessages.aspx?cpids=d6830d46-3aac-11e3-b646-b4b52f561804,m&isSafe=false&FolderID=66666666-6666-6666-6666-6 3/4
    xoxo,
    The Voxox Team
    This message was intended for zachcoughlin@hotmail.com. Want to control which emails you
    receive from Voxox? Get Voxox: http://download.voxox.com and adjust your Notifications in the
    Settings/Preferences window. 2013 Voxox 9276 Scranton Road, Suite 300, San Diego, CA
    92121.
    Outbound fax report
    From: Voxox (noreply@voxox.com) This sender is in your safe list.
    Sent: Mon 10/21/13 4:33 PM
    To: zachcoughlin@hotmail.com
    Hi zachcoughlin,
    Your Fax was successfully sent to 18ff53cc-a121-4c3b-95aa-65913d1341c6general693298 (
    17753283844).
    Your Fax was delivered @ 11:33:40 PM on 2013-10-21.
    xoxo,
    The Voxox Team
    This message was intended for zachcoughlin@hotmail.com. Want to control which emails you
    receive from Voxox? Get Voxox: http://download.voxox.com and adjust your Notifications in the
    Settings/Preferences window. 2013 Voxox 9276 Scranton Road, Suite 300, San Diego, CA
    92121.
    Outbound fax report
    From: Voxox (noreply@voxox.com) This sender is in your safe list.
    Sent: Mon 10/21/13 4:54 PM
    To: zachcoughlin@hotmail.com
    Hi zachcoughlin,
    Your Fax was successfully sent to 11df3c14-7480-4a47-8c03-4eea464b570dgeneral693298 (
    17753256591).
    Your Fax was delivered @ 11:54:24 PM on 2013-10-21.
    xoxo,
    11/4/13 Outlook Print Message
    https://bay176.mail.live.com/mail/PrintMessages.aspx?cpids=d6830d46-3aac-11e3-b646-b4b52f561804,m&isSafe=false&FolderID=66666666-6666-6666-6666-6 4/4
    The Voxox Team
    This message was intended for zachcoughlin@hotmail.com. Want to control which emails you
    receive from Voxox? Get Voxox: http://download.voxox.com and adjust your Notifications in the
    Settings/Preferences window. 2013 Voxox 9276 Scranton Road, Suite 300, San Diego, CA
    92121.
    Respectfully.
    Zachary Barker Coughlin 1471 E. 9th St. Reno, NV 89512 Tel and Fax: 949 667
    7402 ZachCoughlin@hotmail.com

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