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AO240(Rev.01/09)ApplicationtoProceedinDistrictCourtWithoutPrepayingFeesorCosts(ShortForm)
UNITED STATES DISTRICT COURT
Iorthe
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)
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Plaintiff
v. CivilActionNo.
Defendant
APPLICATIONTOPROCEEDINDISTRICTCOURTWITHOUTPREPAYINGFEESORCOSTS
(ShortForm)
IamaplaintiIIorpetitionerinthiscaseanddeclarethatIamunabletopaythecostsoItheseproceedingsand
thatIamentitledtotherelieIrequested.
InsupportoIthisapplication,IanswertheIollowingquestionsunderpenaltyoIperjury:
1. If incarcerated.Iambeingheldat: .
IIemployedthere,orhaveanaccountintheinstitution,IhaveattachedtothisdocumentastatementcertiIiedbythe
appropriateinstitutionaloIIicershowingallreceipts,expenditures,andbalancesduringthelastsixmonthsIorany
institutionalaccountinmyname.IamalsosubmittingasimilarstatementIromanyotherinstitutionwhereIwas
incarceratedduringthelastsixmonths.
2. If not incarcerated. IIIamemployed,myemployersnameandaddressare:
Mytake-homepayorwagesare:$ per(specify pay period) .
3. Other Income. Inthepast12months,IhavereceivedincomeIromtheIollowingsources(check all that apply):
(a)Business,proIession,orotherselI-employment u u Yes No
(b)Rentpayments,interest,ordividends u u Yes No
(c)Pension,annuity,orliIeinsurancepayments u u Yes No
(d)Disability,orworkerscompensationpayments u u Yes No
(e)GiIts,orinheritances u u Yes No
(I)Anyothersources u Yes u No
If you answered Yes to any question above, describe below or on separate pages each source of money and
state the amount that you received and what you expect to receive in the future.
District of Nevada
Zachary Barker Coughlin
Reno Police Department, Officer Nick Duralde, et al
I have been incarcer. twenty times since 8/20/11, but not currently
I am arguably self employed. Nearly every waking hour is spent in the defense of either my formal disciplinary
matter or the various criminal prosecutions against me. My license to practice law in Nevada is temporarily
suspended, license before the USPTO is not suspended, but I have never filed anything therein, focusing on 62337.
0.00 week.

My mother has been paying my rent since approximately November 2012..it was $75 a months for three months, then
increased to $150 a month. She has paid my car insurance as well. My father has filled up my gas tank on numerous
occasions. Both have given me nominal amounts of spending money once in awhile ($20-60 here and there,
approximately one a month or so, my mother since November 2012, my father since about April 2012), besides that I
have been eating food from local food pantries, and just generally hardly have more than $5.00 to my name, my bank
account is overdrawn. I have applied for foodstamps a couple times but missed both appointments, but am pursuing
reapplying.
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 1 of 11
AO240(Rev.01/09)ApplicationtoProceedinDistrictCourtWithoutPrepayingFeesorCosts(ShortForm)
4.AmountoImoneythatIhaveincashorinacheckingorsavingsaccount:$ .
5.Anyautomobile,realestate,stock,bond,security,trust,jewelry,artwork,orotherIinancialinstrumentor
thingoIvaluethatIown,includinganyitemoIvalueheldinsomeoneelsesname(describe the property and its approximate
value):
6.Anyhousing,transportation,utilities,orloanpayments,orotherregularmonthlyexpenses(describe and provide
the amount of the monthly expense):
7.Names(or,iIunder18,initialsonly)oIallpersonswhoaredependentonmeIorsupport,myrelationship
witheachperson,andhowmuchIcontributetotheirsupport:
8.AnydebtsorIinancialobligations(describe the amounts owed and to whom they are payable):
Declaration: IdeclareunderpenaltyoIperjurythattheaboveinIormationistrueandunderstandthataIalse
statementmayresultinadismissaloImyclaims.
Date:
Applicants signature
Printed name
0.00
1996 Honda Accord with 120,000 miles on it, in very poor condition, appears as though someone might have have
been living out of it at various points over the last ten or so years. Worth probably $500, if that. I do not own any real
estate, stocks, bond, security.
Car insurance through USAA, but my mother has been paying that.
none.
student loans of approximately $70K, just went to the ER for a kidney stone, probably have been sent to collections for
that...no longer have cell phone, T-Mobile probably feels I owe them some money, I owe at least one friend some
money for bailing me out of jail on one or more of the twenty occasions since the initial arrest of 8/20/11.
08/20/2013 /s/ Zach Coughlin
Zachary Barker Coughlin
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 2 of 11
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Zach Coughlin, Esq.
1471 E. 9th St.
Reno, NV 89512
NV Bar #9473 (temporarily suspended)
Iax and tele is same: 949 667 7402
ZachCoughlinhotmail.com
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
ZACHARY BARKER COUGHLIN
PlaintiII
v.
CITY OF RENO, ex rel., its )RENO
POLICE DEPARTMENT; )DOES 1-V;
ROE CORPORATIONS )1-V; inclusive;
Reno Police Department, City oI Reno,
RPD OIIicer Nicholas Duralde, Ron Rosa,
Thomas Alaksa,(all individually and in their
capacity as police oIIicer's), ECOMM,
Kelley Odom, Washoe County Public
DeIender's OIIice, WCPD Jim Leslie,
WCPD Joseph Goodnight, Biray Dogan,
WCPD's Evo Novak, Larry Carlson (all
individually and in their capacity as public
deIenders, or investigators, RJC Judge Peter
SIerrazza, Reno Justice Court, RJC Clerks
Robbin Baker and Cathy Wood, RJC Court
Administrator Steve Tuttle, Reno City
Attorney Creig Skau (individually and in
his capacity at deputy reno city attorney),
Cory Goble, Nathaniel K. Zarate, Austin
Lichty, Robert Dawson, Nicole Watson,
Washoe County Jail, Pre-Trial Services,
RJC BailiII John Holguin Reyes
CASE NO.:
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 3 of 11
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COMPLAINT FOR PERSONAL IN1URY
NATURE OF CASE
1. This is an action Ior relieI in damages, injunctive relieI, and Ior attorneys` Iees
and costs which is brought on behalI oI the PlaintiII identiIied hereinabove who
was assaulted, battered, and subjected to excessive Iorce under the color oI
governmental authority resulting in 42 U.S.C. 1983 Violation oI PlaintiII`s
constitutional rights guaranteed to him by the United States oI America and the
State oI Nevada to wit: violation oI Fourth Amendment rights and tortious act oI
battery on PlaintiII.
Coughlin realizes this Complaint needs a great deal oI work. The result oI
being wrongIully arrested nineteen more times since the 8/20/11 arrest at issue in
this Complaint has impeded Coughlin's ability to secure appropriate counsel and
pursue this matter:
1URISDICTION
2. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
1343 In that these claims arise under the Iederal civil rights statues, 28 U.S.C.
1331 In that a Iederal question exists and 28 U.S.C. 1367 Which conIers
supplemental jurisdiction over state law claims Ior relieI set Iorth in this Complaint.
This court also has jurisdiction over this matter pursuant to 42 U.S.C. 1983 In that
the action seeks to redress the deprivation under color oI state law, oI rights,
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 4 of 11
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privileges or immunities secured by the Constitution oI the United States or by an
act oI Congress providing Ior equal rights oI citizens and to recover damages or to
secure equitable or other relieI under an act oI Congress providing Ior the
protection oI civil rights.
3. Venue is proper in this, the northern District oI Nevada because the deIendant is
subject to personal jurisdiction here and the claims arose here COMES NOW,
PlaintiII above named, Ior the time being selI representing, ZACHARY BARKER
COUGHLIN, Esq., and Ior cause oI action against DeIendants, and each oI them,
alleges, avers, and complains as Iollows:
4. At all times material hereto, PlaintiII was, and is a resident oI Washoe County,
State oI Nevada.
5. At all times material hereto, DeIendant CITY OF RENO was, and is a political
subdivision oI the State oI Nevada and is brought Iorth in this action out oI its
relationship as the political entity Ior the DeIendant RENO POLICE
DEPARTMENT. All other deIendants are believed to be residents oI the City oI
Reno, and Washoe County.
6. At all times material hereto, upon inIormation and belieI, DeIendant Nicholas
Duralde was, and is, a resident oI Washoe County, State oI Nevada.
6.1 At all times pertinent hereto, upon inIormation and belieI, all other DeIendants
were and are, a resident oI Washoe County, State oI Nevada.
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 5 of 11
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7.At all times material hereto, upon inIormation and belieI, each oI the DeIendants
was the agent and employee oI each oI the remaining DeIendants, and was, at all
times acting within the purpose and scope oI said agency and employment and with
the knowledge and consent oI each other.
8. Video oI the 8/20/11 arrest: Http://www.Youtube.Com/watch?Vl6Fkvcy4ys
Transcripts oI every day oI the trial and some disturbing eIIorts by the Reno City
Attorney et al are available online, including, but not limited to:
Http://www.Scribd.Com/doc/155048527/9-5-12-CR12-2025-063341-Transcript-
by-Lynn-Stubbs-0204-Full Http://www.Scribd.Com/doc/155197698/8-29-12-
0204-063341-2025-201-Page-With-Index-Partial-Transcript-oI-Proceedings-1118-
a-M-180288bgb-Full Http://www.Scribd.Com/doc/155064328/11-19-12-0204-
063341-Transcript-by-RJC-B-Johnson-OCRd
Http://www.Scribd.Com/doc/155046947/11-20-12-0204-063341-CR12-2025-
Transcript-by-RJC-Cathy-W-Ie-Cathy-Woods-No-Numbers
Http://www.Scribd.Com/doc/161772031/11-8-12-0204-063341-2024-Transcript-
Motion-Hearing-November-13-2012-187549bgw-Condensed
Http://www.Scribd.Com/doc/161772070/11-13-12-0204-063341-2025-Transcript-
Motion-Hearing-November-13-2012-187549bgw-Full
Http://www.Scribd.Com/doc/161772089/10-22-12-0204-2025-063341-Hearing-
183074gw-Full-transcript
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 6 of 11
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9. Http://www.Youtube.Com/watch?VxUtUENlgngY Movie utilizing 911 calls,
video and audio recordings oI the arrest, audio transcripts oI trial, etc.
10. Http://www.Scribd.Com/doc/153541563/12-6-12-0204-063341-2025-
Coughlin-s-Version-oI-the-ROA Coughlin's cross-examination oI Duralde in a
subsequent prosecution Ior misuse oI 911 emergency services:
Http://www.Youtube.Com/watch?V2Vnph71YPBM
11.Reno Police OIIicers Nicholas Duralde, Ron Rosa, and Thomas Alaksa were
dispatched to the scene oI the arrest.
12. The WCPD
13. Creig Skau, Kelley Odom, WCPD Leslie....All Ior a reason. The ECOMM call
recordings between RPD and dispatch (Duraldes wiIe is EcOMM dispatcher Jessica
Duralde, 2/8/13 Iraudulent overcharging arrest by RPD Detective Tom Yturbide,
whose wiIe is Ecomm dispatcher Jodi Yturbide, etc.) And time stamping content oI
text logs versus recordings oI 'what dispatch told the oIIicers, and what the
oIIicers could have possibly heard or read Irom where they were at the times
involved proves the sort oI Iraudulent, willIul misconduct necessary to place
personal liability on these oIIicers, and same goes Ior the call records oI the iphone
in question, and Zarate et al's lying about where they were and what they could
have possibily saw or heard, DDA Young has some 'splainin to do about the
testimony and arguments he put on, SIerrazza and the RJC Clerk's, etc. willIul
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 7 of 11
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violations oI NRS 178.405 (Judicial immunity is not such a robust thing when it
comes to justices oI the peace), WCPD Jim Leslie obstructing Coughlin access to
the iphone and 911 calls records (redacting essential inIo Iorm police reports, nice
goin' Jim....The identiIy oI the calls and times oI the calls turned out to be pretty
essential, right ZARATE, and your whole 'yes, judge sIerrazza, I PERSONALLY
EYEWITNESSED THIS and that...Not according to Video0100 and video099
right DDA Young?.
14. Http://www.Scribd.Com/doc/161772089/10-22-12-0204-2025-063341-
Hearing-183074gw-Full-transcript
FIRST CLAIM FOR RELIEF (Fourth Amendment Right Violation) As Applied To
The States By The Fourteenth Amendment Excessive Force and or Damage to
Reputation, or False Arrest, or False Imprisonment
18. PlaintiII re alleges and incorporates all oI the allegations contained in
paragraphs 1-4
through 6 as iI set Iorth in Iull in this place.
19. At the time DeIendants CITY OF RENO and RENO POLICE DEPARTMENT
hired Duralde, Alaksa, and Rosa the police oIIicers involved, and subsequent
thereto, they knew, should have known, or could have easily ascertained that the
oIIicers had a reputation Ior Iailure to protect the civil rights oI persons in custody
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 8 of 11
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and use oI excessive Iorce on those persons based on their conduct while employed
by the Reno Police Department.
20. Having thus hired these oIIicers and having them conduct law enIorcement
duties as described herein, DeIendants CITY OF RENO and RENO POLICE
DEPARTMENT subjected themselves to liability to PlaintiII Ior subjecting him to
the risk oI, and as it turned out, the actual occurrence oI unlawIul, unjustiIied,
excessive, and damaging acts against PlaintiII.
21. As a direct and proximate result oI the use oI excessive Iorce by DeIendants,
and each oI them, PlaintiII has suIIered severe, painIul, permanent and disabling
injuries to his body and psyche which injuries have required extensive medical
care, all to PlaintiII`s general damages Ior physical and mental pain and suIIering,
emotional distress, and loss oI enjoyment oI liIe, past and Iuture, in a just and
reasonable amount in excess oI $10,000.
22.As a direct and proximate result oI the use oI excessive Iorce by DeIendants,
and each oI them, PlaintiII has incurred medical bills Ior necessary treatment in an
amount not presently known, and may, in the Iuture, incur additional medical bills
Ior necessary treatment, all to his Iuture damages Ior medical and incidental
expenses in an amount presently unknown, and subject to prooI at trial.
23. As a direct and proximate result oI the use oI excessive Iorce, by eIendants,
and each oI them, PlaintiII has incurred lost income, and may, in the Iuture, incur
additional lost income in amounts not presently known and subject to prooI at trial.
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Complaint
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24. As a Iurther direct and proximate result oI the use oI excessive Iorce by
DeIendants, and each oI them, PlaintiII has been required to retain the services oI
attorneys, investigators, and others in order to make his claim Ior damages and seek
recovery oI the same Irom the culpable parties, all to PlaintiII`s Iuture damages in
an undetermined amount subject to prooI at trial.
WHEREFORE, PlaintiII respectIully prays Ior judgment against DeIendants,
and each oI them as Iollows:
a.General damages in excess oI $10,000;
b. Special damages Ior medical and incidental expenses, past and Iuture,
according to prooI at trial;
c. Special damages Ior lost income, past and Iuture, according to prooI at
trial;
d. For an award oI attorney Iees, costs, expenses and interest as allowed by
law;
e. For an award oI injunctive relieI;
I. For such other and Iurther relieI as to the Court seems proper in the
premises.
DATED this 19th day oI August, 2013.
/s/ Zachary Barker Coughlin
ZACHARY BARKER COUGHLIN, Esq.
Pro Per Attorney Ior PlaintiII
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Complaint
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CERTIFICATE OF SERVICE
Pursuant to NRCP 5(b), I hereby certiIy that I am an employee oI the law oIIices oI
ZACHARY BARKER COUGHLIN, Esq., 1471 E. 9TH ST, Reno, Nevada 89512,
and that on this date, I served a true and correct copy oI the Ioregoing document by:
Depositing Ior mailing, in a sealed envelope, U.S. Postage prepaid, at Reno,
Nevada.
Reno/Carson Messenger Service.
Personal Delivery.
Facsimile.
E-Filing
addressed as Iollows: Don Christensen,Esq.
Reno City Attorney`s OIIice One South First Street Reno, NV 89501
DATED this 19 oI August, 2013
/s/Employee oI Zachary Barker Coughlin, Esq.,
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Complaint
Case 3:13-cv-00446 Document 1 Filed 08/20/13 Page 11 of 11

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